Privacy Policy regarding Personal Data Processing

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

2.2. Blocking of personal data — temporary cessation of personal data processing (except when processing is necessary to clarify personal data).

2.3. Website — a collection of graphic and informational materials, as well as computer programs and databases, ensuring their availability on the Internet at network addresses https://clientpulse.ru and https://onecdp.ru.

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

2.5. Anonymization of personal data — actions that make it impossible to determine the ownership of personal data to a specific User or other personal data subject without using additional information.

2.6. Personal data processing — any action (operation) or set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (dissemination, provision, access), anonymization, blocking, deletion, destruction of personal data.

2.7. Operator — a state body, municipal body, legal entity or individual, independently or jointly with other persons organizing and/or carrying out personal data processing, as well as determining the purposes of personal data processing, the composition of personal data to be processed, actions (operations) performed with personal data.

2.8. Personal data — any information directly or indirectly related to an identified or identifiable User of the websites https://clientpulse.ru and https://onecdp.ru.

2.9. Personal data permitted by the personal data subject for dissemination — personal data to which an unlimited circle of persons has been granted access by the personal data subject by giving consent to the processing of personal data permitted by the personal data subject for dissemination in the manner prescribed by the Personal Data Law (hereinafter — personal data permitted for dissemination).

2.10. User — any visitor to the websites https://clientpulse.ru and https://onecdp.ru.

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

2.12. Dissemination of personal data — any actions aimed at disclosing personal data to an unlimited circle of persons (transfer of personal data) or familiarizing an unlimited circle of persons with personal data, including the 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 a foreign state authority, foreign individual, or foreign legal entity.

2.14. Destruction of personal data — any actions resulting in the irreversible destruction of personal data with the impossibility of further restoring the content of personal data in the personal data information system and/or the destruction of material carriers of personal data.

5.1. Personal data processing is carried out on a legal and fair basis.

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

5.3. It is not allowed to combine databases containing personal data, the processing of which is carried out for incompatible purposes.

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

5.5. The content and volume of processed personal data correspond to the stated purposes of processing. Excessiveness of processed personal data in relation to the stated purposes of its processing is not allowed.

5.6. When processing personal data, the accuracy of personal data, its sufficiency, and, if necessary, relevance to the purposes of personal data processing are ensured. The Operator takes necessary measures and/or ensures their adoption 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 the personal data storage period is established by federal law, a contract, a party to which, a beneficiary or a guarantor of which is the personal data subject. Processed personal data is destroyed or anonymized upon achieving the processing purposes or in case of loss of necessity to achieve these purposes, unless otherwise provided by federal law.

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

7.2. Personal data processing is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, for the exercise of functions, powers, and duties assigned by the legislation of the Russian Federation to the operator.

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

7.4. Personal data processing is necessary for the execution of a contract to which the personal data subject is a party, beneficiary, or guarantor, as well as for concluding a contract on the initiative of the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor.

7.5. Personal data processing is necessary for the exercise of the operator's or third parties' rights and legitimate interests or for achieving socially significant goals, provided that the rights and freedoms of the personal data subject are not violated.

7.6. Personal data to which an unlimited circle of persons has been granted access by the personal data subject or at their request (hereinafter — publicly available personal data) is processed.

7.7. Personal data subject to publication or mandatory disclosure in accordance with federal law is processed.

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

8.2. User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to the execution of current legislation or if the personal data subject has given consent to the Operator to transfer data to a third party for the fulfillment of obligations under a civil law contract.

8.3. In case of inaccuracies in personal data, the User can update them independently by sending a notification to the Operator's email address welcome@wifly.ru with the subject "Personal Data Update".

8.4. The term of personal data processing is determined by the achievement of the purposes for which the personal data was collected, unless a different term is provided by a contract or current legislation. The User can withdraw their consent to personal data processing at any time by sending a notification to the Operator via email to welcome@wifly.ru with the subject "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 Agreement and Privacy Policy. The personal data subject and/or with these documents. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this paragraph.

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

8.7. The Operator ensures the confidentiality of personal data when processing it.

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 the personal data storage period is established by federal law, a contract, a party to which, a beneficiary or a guarantor of which is the personal data subject.

8.9. The condition for ceasing personal data processing may be the achievement of personal data processing purposes, the expiration of the personal data subject's consent, the withdrawal of consent by the personal data subject, or a request to cease personal data processing, as well as the detection of unlawful personal data processing.

9.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), extracts, uses, transfers (disseminates, provides, accesses), anonymizes, blocks, deletes, and destroys personal data.

9.2. The Operator performs automated personal data processing with the receipt and/or transfer of received information via information and telecommunication networks or without them.

10.1. Before commencing activities involving cross-border transfer of personal data, the Operator is obliged to notify the authorized body for the protection of personal data subjects' rights of its intention to carry out cross-border personal data transfer (such notification is sent separately from the notification of intention to process personal data).

10.2. Before submitting the aforementioned notification, the Operator is obliged to obtain relevant information from the authorities of the foreign state, foreign individuals, foreign legal entities to whom personal data is planned to be transferred cross-border.

13.1. The User can receive any clarifications on questions of interest concerning the processing of their personal data by contacting the Operator via email welcome@wifly.ru.

13.2. Any changes to the Operator's personal data processing policy will be reflected in this document. The Policy is valid indefinitely until replaced by a new version.

13.3. The current version of the Policy is freely available on the Internet at https://clientpulse.ru/privacy and https://onecdp.ru/privacy.