Privacy Policy

1. General Provisions

This Personal Data Processing Policy is compiled in accordance with the requirements of Federal Law No. 152-FZ dated 27.07.2006 “On Personal Data” and defines the procedure for processing personal data and measures to ensure the security of personal data undertaken by Safeharbor (hereinafter referred to as the Operator).

1.1. The Operator’s main goal and condition for carrying out its activities is to respect the rights and freedoms of individuals and citizens when processing their personal data, including the protection of the rights to privacy, personal and family secrets.

1.2. This Operator’s policy regarding personal data processing (hereinafter — the Policy) applies to all information that the Operator may receive about visitors to the website https://safe-harbor.ru.

2. Basic Terms Used in the Policy

2.1. Automated processing of personal data — processing of personal data using computer technology.

2.2. Blocking of personal data — temporary suspension of personal data processing (except in cases where processing is necessary to clarify personal data).

2.3. Website — a set of graphic and informational materials, as well as computer programs and databases, ensuring their availability on the Internet at the network address https://safe-harbor.ru.

2.4. Personal data information system — a set of personal data contained in databases, as well as information technologies and technical means ensuring their processing.

2.5. Depersonalization of personal data — actions that make it impossible to determine, without using additional information, whether personal data belongs to a specific User or another subject of personal data.

2.6. Processing of personal data — any action (operation) or set of actions (operations) performed with or without automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.

2.7. Operator — a state body, municipal body, legal or individual person that independently or jointly with others organizes and/or carries out the processing of personal data, as well as determines the purposes of processing personal data, the composition of personal data to be processed, and actions (operations) performed with personal data.

2.8. Personal data — any information relating directly or indirectly to an identified or identifiable User of the website https://safe-harbor.ru.

2.9. Personal data allowed by the subject of personal data for dissemination — personal data to which an unlimited number of persons have access, provided by the subject of personal data by giving consent to the processing of personal data allowed by the subject for dissemination in accordance with the Law on Personal Data (hereinafter — personal data allowed for dissemination).

2.10. User — any visitor of the website https://safe-harbor.ru.

2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific group of persons.

2.12. Distribution of personal data — any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or at making personal data accessible to an unlimited number of persons, including publication of personal data in mass media, placement in information and telecommunication networks, or providing access to personal data in any other way.

2.13. Cross-border transfer of personal data — transfer of personal data to the territory of a foreign state, to an authority of a foreign state, to a foreign individual or foreign legal entity.

2.14. Destruction of personal data — any actions that result in the irreversible destruction of personal data with the impossibility of further restoration of the content of personal data in the personal data information system and/or destruction of physical carriers of personal data.

3. Main Rights and Obligations of the Operator

3.1. The Operator has the right to:

receive from the subject of personal data reliable information and/or documents;

in case the subject of personal data withdraws consent to the processing of personal data or sends a request to stop processing, the Operator has the right to continue processing personal data without the consent of the subject if there are grounds specified in the Law on Personal Data;

independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations provided by the Law on Personal Data and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Law on Personal Data or other federal laws.

3.2. The Operator is obliged to:

provide the subject of personal data, upon request, with information concerning the processing of their personal data; organize the processing of personal data in accordance with the current legislation of the Russian Federation; respond to requests and inquiries of subjects of personal data and their legal representatives in accordance with the requirements of the Law on Personal Data;

report to the authorized body for the protection of the rights of personal data subjects, upon request, the required information within 10 days from the date of receipt of such a request;

publish or otherwise ensure unrestricted access to this Policy regarding the processing of personal data;

take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision, distribution, as well as from other illegal actions in relation to personal data;

cease transfer (distribution, provision, access) of personal data, stop processing, and destroy personal data in the manner and in cases provided for by the Law on Personal Data;

fulfill other obligations provided for by the Law on Personal Data.

4. Main Rights and Obligations of Personal Data Subjects

4.1. Personal data subjects have the right to:

receive information concerning the processing of their personal data, except in cases provided for by federal laws. The information is provided to the personal data subject by the Operator in an accessible form and must not contain personal data relating to other subjects, except when there are legal grounds for such disclosure. The list of information and the procedure for obtaining it are established by the Law on Personal Data;

demand that the Operator clarify, block, or destroy their personal data if the data is incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the stated purpose of processing, as well as take legal measures to protect their rights; set a condition for prior consent to processing of personal data for marketing purposes of goods, works, and services;

withdraw consent to the processing of personal data or send a request to stop processing of personal data;

appeal to the authorized body for the protection of the rights of personal data subjects or to a court against unlawful actions or inaction of the Operator in processing their personal data;

exercise other rights provided by the legislation of the Russian Federation.

4.2. Personal data subjects are obliged to:

provide the Operator with accurate data about themselves;

inform the Operator about clarification (updating, changing) of their personal data.

4.3. Persons who provided the Operator with inaccurate information about themselves or information about another personal data subject without their consent are liable in accordance with the legislation of the Russian Federation.

5. Principles of Personal Data Processing

5.1. Processing of personal data is carried out on a lawful and fair basis.

5.2. Processing of personal data is limited to achieving specific, predetermined, and lawful purposes. Processing of personal data incompatible with the purposes of personal data collection is not allowed.

5.3. It is not allowed to combine databases containing personal data processed for purposes incompatible with each other.

5.4. Only personal data that meets the purposes of its processing is subject to processing.

5.5. The content and volume of processed personal data must correspond to the declared purposes of processing. Excessive processing of personal data in relation to the declared purposes is not allowed.

5.6. When processing personal data, the accuracy, sufficiency, and, where necessary, relevance of personal data in relation to the purposes of processing are ensured. The Operator takes necessary measures to delete or clarify incomplete or inaccurate data.

5.7. Personal data is stored in a form that allows identifying the personal data subject no longer than required by the purposes of personal data processing, unless a longer storage period is established by federal law or a contract to which the personal data subject is a party, beneficiary, or guarantor. Processed personal data is destroyed or depersonalized upon achievement of the purposes of processing or when the need for achieving these purposes is lost, unless otherwise provided by federal law.

6. Purposes of Personal Data Processing

Purpose of processing	Conclusion, execution, and termination of civil law contracts
Personal data	last name, first name, patronymic email address phone numbers year, month, date, and place of birth
Legal grounds	Contracts concluded between the Operator and the personal data subject
Types of processing	Collection, recording, systematization, accumulation, storage, destruction, and depersonalization of personal data

7. Conditions for Personal Data Processing

7.1. Processing of personal data is carried out with the consent of the subject of personal data to the processing of their personal data.

7.2. Processing of personal data is necessary to achieve goals provided for by international treaties of the Russian Federation or by law, for the exercise of the powers and duties imposed on the Operator by the legislation of the Russian Federation.

7.3. Processing of personal data is necessary for the administration of justice, execution of a judicial act, or an act of another body or official to be executed in accordance with the legislation of the Russian Federation on enforcement proceedings.

7.4. Processing of personal data is necessary for the performance of a contract to which the personal data subject is a party, beneficiary, or guarantor, as well as for the conclusion of a contract at the initiative of the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor.

7.5. Processing of personal data is necessary for the exercise of the rights and legitimate interests of the Operator or third parties, or for the achievement of socially significant goals, provided that the rights and freedoms of the personal data subject are not violated.

7.6. Processing of personal data is carried out when access to an unlimited number of persons to the personal data is provided by the subject of personal data or at their request (hereinafter — publicly available personal data).

7.7. Processing of personal data is carried out when such processing is subject to publication or mandatory disclosure under federal law.

8. Procedure for Collection, Storage, Transfer, and Other Types of Personal Data Processing

The security of personal data processed by the Operator is ensured through the implementation of legal, organizational, and technical measures necessary to fully comply with applicable personal data protection legislation.

8.1. The Operator ensures the safety of personal data and takes all possible measures to exclude access by unauthorized persons.

8.2. The User’s personal data will never, under any circumstances, be transferred to third parties, except in cases related to compliance with current legislation or if the personal data subject has given consent to transfer data to a third party to fulfill obligations under a civil law contract.

8.3. In case of inaccuracies in personal data, the User may update them independently by sending a notification to the Operator via email at info@safe-harbor.ru with the note “Updating personal data”.

8.4. The period of personal data processing is determined by the achievement of the purposes for which personal data were collected unless otherwise provided by a contract or applicable law. The User may withdraw their consent to the processing of personal data at any time by sending a notification to the Operator via email at info@safe-harbor.ru with the note “Withdrawal of consent to personal data processing”.

8.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by these persons (Operators) in accordance with their User Agreements and Privacy Policies. The subject of personal data should familiarize themselves with these documents. The Operator is not responsible for the actions of third parties, including those listed in this paragraph.

8.6. Restrictions established by the subject of personal data on transfer (except granting access), as well as on processing or conditions of processing (except for access) of personal data allowed for dissemination, do not apply in cases of processing personal data in state, public, and other public interests determined by the legislation of the Russian Federation.

8.7. The Operator ensures the confidentiality of personal data during processing.

8.8. The Operator stores personal data in a form that allows identifying the personal data subject no longer than required by the purposes of personal data processing, unless a longer period is established by federal law or a contract to which the personal data subject is a party, beneficiary, or guarantor.

8.9. Grounds for termination of personal data processing may include achieving the purposes of processing, expiration of consent, withdrawal of consent by the subject, a request to stop processing, or detection of unlawful processing of personal data.

9. List of Actions Performed by the Operator with Personal Data

9.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, modifies), retrieves, uses, transfers (distributes, provides, grants access), depersonalizes, blocks, deletes, and destroys personal data.

9.2. The Operator carries out automated processing of personal data with or without receiving/transmitting information via information and telecommunication networks.

10. Cross-Border Transfer of Personal Data

10.1. Before starting cross-border transfer of personal data, the Operator must notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out such a transfer (this notification is sent separately from the notification of intent to process personal data).

10.2. Before submitting the above notification, the Operator must obtain from the authorities of the foreign state, foreign individuals, or foreign legal entities to which the cross-border transfer is planned, the relevant information.

11. Confidentiality of Personal Data

The Operator and other persons who have gained access to personal data must not disclose or distribute personal data to third parties without the consent of the personal data subject unless otherwise provided by federal law.

12. Final Provisions

12.1. The User may receive any clarifications on matters concerning the processing of their personal data by contacting the Operator via email at info@safe-harbor.ru.

12.2. Any changes to this Policy will be reflected in this document. The Policy remains in effect indefinitely until it is replaced by a new version.

12.3. The current version of the Policy is freely available online at https://safe-harbor.ru.