Home | Personal data processing policy

Personal data processing policy

1. General provisions

This personal data processing policy has been drawn up in accordance with the requirements of the Federal Law of 27.07.2006. No. 152-FZ “On personal data” (hereinafter referred to as the Personal Data Law) and defines the procedure for processing personal data and measures to ensure the security of personal data taken by IP Lazarev Artem Sergeevich INN: 272389994971 OGRNIP: 314272334300038, address: Khabarovsk, Kholmogorsky pereulok 16 (hereinafter referred to as the Company).

1.1. The Company sets as its most important goal and condition for the implementation of its activities the observance of the rights and freedoms of man and citizen when processing his personal data, including the protection of the rights to privacy, personal and family secrets.

1.2. This Company policy on the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Company may receive about visitors to the website https://forma.agency (hereinafter referred to as the Site)

1.3. This Policy applies only to the site. The Site does not control and is not responsible for third-party sites that the user may follow via links available on the Site, including as search results. On such sites, the user may collect or request other personal information, and may also perform other actions.

1.4. The site generally does not verify the accuracy of personal information provided by users and does not exercise control over their activity. However, the Site assumes that the user provides reliable and sufficient personal information on the questions asked in the registration form and maintains this information up to date

1.5. By providing the Company with personal data, you agree to their processing in accordance with this Policy.

2. Basic concepts used in the Policy

Personal data – any information related to a directly or indirectly determined or determinable individual (subject of personal data). Also includes information that the user provides about himself/herself when filling out forms on the Site.

Personal data processing – the implementation of actions or a set of actions in relation to personal data, including collection, recording, systematization, accumulation, storage, clarification, updating and modification, retrieval, use, provision, access, blocking, deletion and destruction – both with and without the use of automated data processing tools. The Company may process your data in the listed ways for the purposes set out in Section 4 of this Policy.

Personal data operator – a person who, independently or jointly with other persons, 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 subject to processing, actions (operations) performed with personal data. For the purposes of this Policy, IP Lazarev Artem Sergeevich INN: 272389994971 OGRNIP: 314272334300038, address: Khabarovsk, lane. Kholmogorsky 16, processing personal data, is the operator, unless otherwise expressly stated in the Policy

Website – a collection of graphic and information materials, as well as computer programs and databases that ensure their availability on the Internet at the network address https://forma.agency

Subject of personal data processing (also – Subject) – an individual to whom the personal data relate

User – a visitor to the website https://forma.agency

Company – IP Lazarev Artem Sergeevich INN: 272389994971 OGRNIP: 314272334300038, address: Khabarovsk, lane Kholmogorsky 16

Any terms used in the Policy should be interpreted in accordance with the Law on Personal Data.

3. Types of processed data

3.1. The user’s device automatically transmits technical data: information stored in cookies, information about the browser and its settings, date and time of access to the site, addresses of requested pages, actions on the site or in the application, technical characteristics of the device, IP address, etc.

3.2. Processed personal data necessary to ensure the purposes of processing the personal data of the subject, depending on the purposes of processing personal data:

Last name, first name, patronymic;
Email address;
Phone numbers;
The site also collects and processes anonymized data about visitors (including cookies) using Internet statistics services (Yandex Metrica).
Purposes of personal data processing

Purpose of processingType of processed data4.1. Communication with the user, including communication via phone, processing and clarification of requests and applications from the user, providing responses to requests for the Company’s servicesLast name, first name, telephone number, email address, other information that the subject of the first

personal data indicated when filling out the form on the Site4.2. Ensuring stable operation and security of the site, improving user experience, quality of services, services and marketing activities, developing new services and developing functionality on the site, conducting statistical and other research based on anonymized data, targeting advertising materials Personal data that is not biometric: IP address, type of browser and device from which the Site is accessed, operating system and Internet provider data, information about the country from which the access is made, date and time of visiting the Site, as well as the possible number of clicks made by the User

4. Purposes of personal data processing

Purpose of processing	Type of data processed
4.1. Communication with the user, including communication via phone call, processing and clarification of requests and applications from the user, providing responses to requests for the Company’s services	Last name, first name, telephone number, email address, and other information that the personal data subject indicated when filling out the form on the Site
4.2. Ensuring stable operation and security of the site, improving user experience, quality of services, services and marketing activities, developing new services and developing functionality on the site, conducting statistical and other research based on anonymized data, targeting advertising materials	Personal data that is not biometric: IP address, browser type and device from which the Site is accessed, operating system and Internet provider information, information about the country from which the access is made, date and time of the Site visit, as well as the possible number of clicks made by the User

5. RIGHTS AND RESPONSIBILITIES OF THE OPERATOR AND THE USER

5.1 Basic rights and responsibilities of the Company as the Operator

5.1.1 The Company has the right to:

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

— if the personal data subject revokes their consent to the processing of their personal data, or if they submit an application requesting that the processing of their personal data be terminated, the Company has the right to continue processing the personal data without the consent of the personal data subject if there are grounds specified in the Personal Data Law;

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

5.2.1 The Company is obliged to:

— provide the personal data subject, at their request, with information regarding the processing of their personal data;

— organize the processing of personal data in the manner established by the current legislation of the Russian Federation;

— respond to requests and inquiries from personal data subjects and their legal representatives in accordance with the requirements of the Law on Personal Data;

— notify the authorized body for the protection of the rights of personal data subjects, at the request of this body, of the necessary information within 10 days from the date of receipt of such a request;

— publish or otherwise provide unlimited access to this Policy regarding the processing of personal data;

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

— stop transferring (distributing, providing, accessing) personal data, stop processing and destroy personal data in the manner and cases stipulated by the Law on Personal Data;

— fulfill other obligations stipulated by the Law on Personal Data.

5.3 Basic rights and obligations of personal data subjects

5.3.1 Personal data subjects have the right to:

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

— require the Company to clarify his/her personal data, block it or destroy it if the personal data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated purpose of processing, and also take measures provided by law to protect his/her rights;

— put forward the condition of prior consent when processing personal data for the purpose of promoting goods, works and services on the market;

— to revoke consent to the processing of personal data, as well as to send a request to stop the processing of personal data;

— appeal to the authorized body for the protection of the rights of personal data subjects or in court against the illegal actions or inaction of the Company when processing his/her personal data;

— to exercise other rights provided for by the legislation of the Russian Federation.

5.4. Personal data subjects are obliged to:

— provide the Company with reliable information about themselves;

— notify the Company about clarification (update, change) of their personal data.

5.5. Persons who have transferred to the Company false information about themselves, or information about another subject of personal data without the consent of the latter, are liable in accordance with the legislation of the Russian Federation.

6. PROCEDURE FOR PROCESSING PERSONAL DATA

6.1. Receipt of personal data and legal grounds for processing

6.1.1. The Company receives the personal data of the subject when the latter, as a user, leaves a request on the Site.

6.1.2. The Company processes the user’s personal data with his/her consent.

6.1.3. The User gives consent:

for 1 year from the date of achieving the purpose of personal data processing. Another term may be provided in individual cases;

for concluding, executing, amending or terminating an agreement with the Company;

for exercising the rights and legitimate interests of the company or third parties, if this does not violate your rights and freedoms;

for fulfilling the obligations imposed on the Company by law.

6.2. Storage of personal data

6.2.1. When storing personal data, the Company must comply with the conditions that ensure the safety of personal data and prevent unauthorized access to them.

6.2.2. Storage of personal data of subjects means the presence of records in the Company’s information systems and on paper media.

6.2.3. Documents containing personal data contained on paper media are located in specially designated places with limited access under conditions that ensure their protection from unauthorized access.

6.2.4. Personal data stored in electronic form are protected from unauthorized access using special technical and software protection tools, as well as by delimiting access rights using an account.

6.2.5. Personal data is stored until the purpose of processing personal data is achieved, but not more than 1 year from the date of achieving this purpose.

6.3. Use of personal data

6.3.1. Access to personal data is granted only to those employees of the Company whose job responsibilities involve working with personal data, and only for the period necessary to work with the relevant data. The list of such persons is determined by the Company. Other persons, if necessary, may be granted temporary access to a limited range of personal data in exceptional cases by order of the General Director of the Company, the head or other person authorized to do so by the General Director of the Company.

6.4. Transfer and assignment of processing of personal data

6.4.1. The transfer of personal data of subjects to third parties is permitted in the minimum necessary volumes and only for the purpose of performing tasks corresponding to the objective reason for collecting this data.

6.4.2. The transfer of personal data of subjects to third parties, including for commercial purposes, is permitted only subject to notification and obtaining the consent of the subject, except for cases specified by law, in particular, if:

Personal data are made publicly available by the subject or received from a publicly available source;

Personal data are processed for statistical or other research purposes, for the implementation of professional activities of a journalist or scientific, literary or other creative activities, if this does not violate the rights and legitimate interests of the subject.

6.4.3. Upon a reasoned request, solely for the purpose of fulfilling the functions and powers imposed on the Company by the legislation of the Russian Federation, the personal data of the subject may be transferred to judicial and state bodies without his consent in cases established by regulatory legal acts binding on the Company.

6.4.4. The transfer of information containing the personal data of the subject is carried out in a manner that ensures the protection of information from unauthorized use.

The Site has the right to transfer the user’s personal information to third parties in the following cases:

The user has expressed his consent to such actions;

The transfer is necessary within the framework of the user’s use of a certain service or for the provision of a service to the user;

The transfer is provided for by Russian or other applicable legislation within the framework of the procedure established by law;

Such transfer occurs as part of a sale or other transfer of business (in whole or in part), whereby the acquirer assumes all obligations to comply with the terms of this Policy as applied to the personal information received by it;

In order to ensure the possibility of protecting the rights and legitimate interests of the Company or third parties

6.5. Procedure and conditions for processing personal data

6.5.1. The Company carries out:

non-automated processing of personal data;

automated processing of personal data with or without the transfer of the received information via information and telecommunications networks;

mixed processing of personal data.

6.5.2. The processing of personal data may include, among other things: collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (provision, access, distribution), blocking, deletion, destruction.

6.5.3. The Company does not disclose personal data to third parties without the consent of the subject of personal data, unless otherwise provided by law and/or agreement.

6.5.4. To government agencies, including

inquiry and investigation bodies, the Federal Tax Service, the Pension Fund of the Russian Federation, the Social Insurance Fund and other authorized executive bodies, personal data are provided (transferred) in accordance with the requirements of the legislation of the Russian Federation.

6.5.5. When collecting personal data, including through the information and telecommunications network “Internet”, the Company ensures the recording, systematization, accumulation, storage, clarification (updating, modification), extraction of personal data using databases located on the territory of the Company (in the Russian Federation) and in data centers on the territory of the Russian Federation.

6.5.6. The Company has the right to carry out cross-border transfer of personal data in accordance with the procedure established by the current legislation, subject to the requirements of Article 12 of Federal Law 152-FZ.

6.5.7. Destruction of personal data must exclude the possibility of their recovery by software or physical methods.

7. Change, clarification, blocking, destruction of personal data

7.1. The personal data subject has the right to demand that the Company clarify his personal data, block or destroy it if the personal data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated purpose of processing, and also to take measures to protect his rights provided for by the Law on Personal Data. The loss of a phone number, as well as its transfer to another person, is the responsibility of the User. In this case, the User must contact the Company via email info@forma.agency

7.2. The personal data subject has the right to contact the Company with a request to stop the transfer (distribution, provision, access) of his personal data, previously authorized by the personal data subject, in terms of the specified actions for distribution, in case of non-compliance with the provisions of Article 10.1 of the Law on Personal Data or to apply to the court with such a request. The Company is obliged to stop transferring (distributing, providing, accessing) personal data within three business days from the moment of receipt of the request of the personal data subject or within the period specified in the court decision that has entered into legal force, and if such period is not specified in the court decision, then within three business days from the moment the court decision enters into legal force.

7.3. The personal data subject has the right to appeal the actions or inactions of the Company to the Federal Service for Supervision of Communications, Information Technology and Mass Media (Roskomnadzor) or in court if the personal data subject believes that the Company is processing his personal data in violation of the requirements of the Law on Personal Data or otherwise violates his rights and freedoms.

7.4. In order to exercise his rights and protect his legitimate interests, the personal data subject has the right to contact the Company. To send official requests to the Company, it is necessary to use the contact information specified in paragraphs. 7.13., 7.14 and 7.15. of this Policy.

7.5. In the event that unlawful processing of personal data is detected upon an application by a personal data subject or his/her representative or at the request of a personal data subject or his/her representative or an authorized body for the protection of the rights of personal data subjects, the Company is obliged to block the unlawfully processed personal data related to this personal data subject or ensure their blocking (if the personal data is processed by another person acting on behalf of the operator) from the moment of such application or receipt of the said request for the verification period.

7.6. In the event that inaccurate personal data is detected upon an application by a personal data subject or his/her representative or at their request or at the request of an authorized body for the protection of the rights of personal data subjects, the Company is obliged to block the personal data related to this personal data subject or ensure their blocking (if the personal data is processed by another person acting on behalf of the operator) from the moment of such application or receipt of the said request for the verification period, unless blocking the personal data violates the rights and legitimate interests of the personal data subject or third parties. In the event of confirmation of the fact of inaccuracy of personal data, the Company, on the basis of information provided by the subject of personal data or his representative or the authorized body for the protection of the rights of subjects of personal data, or other necessary documents, is obliged to clarify the personal data or ensure their clarification (if the processing of personal data is carried out by another person acting on behalf of the operator) within seven working days from the date of submission of such information and remove the blocking of personal data.

7.7. In the event of achievement of the purpose of processing personal data, the Company is obliged to stop processing personal data or ensure its termination (if the processing of personal data is carried out by another person acting on behalf of the operator) and destroy personal data or ensure their destruction (if the processing of personal data is carried out by another person acting on behalf of the Company) within a period not exceeding thirty days from the date of achieving the purpose of processing personal data, unless otherwise provided by an agreement to which the subject of personal data is a party, beneficiary or guarantor, another agreement between the Company and the subject of personal data, or if the Company does not have the right to process personal data without the consent of the subject of personal data on the grounds provided for by the Law on Personal Data or other federal laws.

7.8. In the event that the personal data subject revokes their consent to the processing of their personal data, the Company is obliged to stop their processing or ensure that such processing is terminated (if the personal data is processed by another person acting on behalf of the Company) and, if the storage of personal data is no longer required for the purposes of processing personal data, to destroy the personal data or ensure that it is destroyed (if the personal data is processed by another person acting on behalf of the Company) within a period not exceeding thirty days from the date of receipt of such revocation, unless otherwise provided by an agreement to which the personal data subject is a party, beneficiary or guarantor, or by another agreement between the Company and the personal data subject, or if the Company is not entitled to process personal data without the consent of the personal data subject on the grounds provided for by the Personal Data Law or other federal laws.

7.9. If a personal data subject requests the Company to stop processing personal data, the Company shall, within a period not exceeding ten business days from the date of receipt by the Company of the relevant request, stop processing them or ensure that such processing is stopped (if such processing is carried out by the person processing the personal data), except for the cases provided for in paragraphs 2 – 11 of Part 1 of Article 6, Part 2 of Article 10 and Part 2 of Article 11 of the Law on Personal Data. The specified period may be extended, but not more than by five business days if the Company, as the operator, sends to the personal data subject a reasoned notice indicating the reasons for extending the period for providing the requested information.

7.10. If it is impossible to destroy personal data within the period established by the Law on Personal Data, the Company shall block such personal data or ensure that they are blocked (if the personal data is processed by another person acting on the instructions of the operator) and ensure that the personal data are destroyed within a period not exceeding six months, unless another period is established by federal laws.

7.11. When collecting personal data, the Company ensures the recording, systematization, accumulation, storage, clarification (updating, modification), extraction of personal data of users using databases located on the territory of the Russian Federation, except for cases stipulated by the Law on Personal Data.

7.12. The Company considers any requests and complaints from personal data subjects, investigates violations and takes all necessary measures for their immediate elimination and settlement of disputes out of court. The processing of personal data permitted by the personal data subject for distribution is carried out in compliance with the prohibitions and conditions stipulated by Article 10.1 of the Law on Personal Data.

7.13. A written request from a personal data subject for information regarding the processing of his personal data must contain the mandatory information established by Part 3 of Article 14 of the Law, including the telephone number used when filling out forms/questionnaires on the Site. A written request (inquiry) can be sent to the following address: Russia, 680043, Khabarovsk, Kholmogorsky pereulok 16.

7.14. To obtain information about your personal data, to familiarize yourself with it, to clarify it, block or stop its processing, or to revoke consent to its processing, requests can be sent to the following email address: info@forma.agency. The request can be sent by the subject of personal data in the form of an electronic document and signed with an electronic signature in accordance with the legislation of the Russian Federation.

7.15. Interaction on other issues related to the processing of personal data by the Company is also carried out using the following contact information: postal address: Russia, 680043, Khabarovsk, Kholmogorsky pereulok 16 and / or email address info@forma.agency

8. Terms of personal information processing

The Company stops processing personal data within the timeframes established by law:

8.1. upon achieving the processing goals specified in Section 4 of this Policy, or when there is no longer a need to achieve them (unless there are other grounds for processing provided by law). Such goals as providing the opportunity to use the site’s services, ensuring the stable operation and security of services, improving user experience, quality of services, services and marketing activities, sending marketing messages will be achieved upon termination of obligations arising from contracts with us.

8.2. upon expiration of the consent period or upon withdrawal of consent (unless there are other grounds for processing provided by law). For example, in the case of processing for the purpose of organizing participation in events, research and surveys.

8.3. upon detection of unlawful processing, if it is impossible to ensure lawfulness;

8.4. upon liquidation of the Company.

9. Cross-border transfer

9.1. Before commencing activities on the cross-border transfer of personal data, the Operator shall notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out the cross-border transfer of personal data (such notification shall be sent separately from the notification of the intention to process personal data).

9.2. Before submitting the above notification, the Operator shall obtain relevant information from the authorities of a foreign state, foreign individuals, foreign legal entities to whom the cross-border transfer of personal data is planned.

10. Changes to the Privacy Policy. Applicable Law

10.1. The Company has the right to make changes to this Personal Data Processing Policy. When making changes, the current version shall indicate the date of the last update. The new version of the Policy shall enter into force from the moment of its posting, unless otherwise provided by the new version of the Policy.

10.2. This Policy and the relationship between the user and the Site, arising in connection with the application of the Privacy Policy, are subject to the application of the law of the Russian Federation.

11. Cookies

The Site and / or the Service may use cookies. The Site uses cookies for technical and marketing purposes – mainly small pieces of data that are stored on the User’s device and allow recording certain information during any visit to the Site in order to identify the User, regardless of the device used.

11.1. Purposes of use

storing information about the User for the duration of his use of the Site;

User identification (recognizing the browser and/or device each time the Site is accessed, saving the screen and browser settings and/or saving the User’s login and password to access the Site);

to analyze the Site’s traffic by Users, identify the effectiveness of advertising content and its popularity among Users;

for the operation of individual sections/pages of the Site;

to improve navigation on the Site;

to improve the interaction between the Site and Users;

to improve the quality of service and ensure maximum convenience and comfort for Users when using the Site.

11.2. Types of information collected

Using cookies, the Company may collect the following information about Users:

IP address, browser type and device from which the Site is accessed;

operating system and Internet provider data;

information about the country from which the login is performed;

date and time of the Site visit, as well as the possible number of clicks made by the User.

11.3. List of cookies used

Technical cookies that are necessary for the smooth and reliable functioning of the Site. Disabling this type may limit the User’s access to certain functionalities of the Site.

Session cookies, which are temporary and store information about the User’s activity in the browser during one session (i.e. until the User closes such browser).

Permanent cookies, which are stored in the memory of the User’s device for a certain period of time and are responsible for the User’s personal preferences set in the browser (for example, the browser’s language settings and/or the Site’s font).

Statistical cookies, which are necessary to track the pages/sections of the Site visited by the User, as well as to identify possible errors in the Site. The information collected about Users by this type of cookie is anonymous and is necessary for the effective maintenance and updating of the Site, as well as for providing the User with targeted content.

Behavioral cookies, which are necessary for collecting information about the User’s search queries and preferences for conducting marketing and/or other market research for the purpose of subsequently providing personalized marketing and advertising content to the User.

Analytical cookies that allow us to identify and count the number of visitors and track their movements around the Site. Using this information, the Company optimizes the operation of the Site, for example, by helping Users find the information they need faster and identify the most popular sections.

Advertising cookies that the Company’s advertising partners may install on the Site. Such companies may use them to create a profile of the User’s interests and display relevant advertisements on other websites.

Third parties and their cookies. They are needed for the following purposes: (a) collection of information by analytical platforms about the Users’ visits to the Site, the formation of a portrait of the User, as well as analysis of the effectiveness of the Site and marketing strategy; and (b) providing, with the help of third parties (marketing platforms or agencies), personalized advertising and/or marketing content to the User on the Site and/or on third-party websites. The Company uses the Yandex.Metrica service, which allows analyzing the activity of Site visitors and improving its operation. This service receives data on an anonymous basis and does not collect information about the identity of the site visitor, does not identify him/her as an individual (does not establish identity). The received information can be used to improve the operation of the site and its sections.

11.4. The storage period of cookies on the User’s device depends on whether they are “persistent” or “session”. Persistent cookies are stored in the browser and remain valid until their set expiration date (unless deleted by the User before that time). 11.5. Session cookies expire at the end of the User’s communication session after closing the web browser.

11.6. The User can control and manage the use of cookies in various ways. At the same time, the User must take into account that blocking or deleting cookies may affect browsing the Site and may result in some of its functions not working.

In cases where cookies are not strictly necessary for the Site to function, the Company asks the User to consent to the use of cookies upon the first visit to the Site.

If the User of the Site does not agree to cookies being saved on his device, he can independently disable this option in the browser settings. Saved cookies can also be deleted at any time in the system settings of the browser. The User of the Site can change the browser settings to accept or reject all cookies by default or cookies from certain websites, including the Site. Disabling some cookies may make it impossible to use certain sections or functions of the Site.

Detailed instructions on disabling cookies are available at external links:

If the User of the Site does not agree with the use of methods, means and tools of Internet statistics and settings, he must stop using the Site, in which case the Company will not be able to provide the User with the use of the Site.

If the User does not want to disable the operation of cookies and / or delete previously downloaded cookies, no additional actions are required from the User to continue working in this case.

Any consent to accept or reject cookies is limited only to the Site to which this Policy applies, and does not apply to pages of other information resources that may also contain hyperlinks to this Site. For more detailed information about the cookies used by these websites, the User should read the privacy or cookie notices posted on the relevant websites.