Personal Data Processing Policy
Date of placement:
May 01, 2025

The Personal Data Processing Policy (hereinafter referred to as the "Policy") defines the general principles and procedures for processing personal data, as well as other data of the Personal Data Subject and measures to ensure their security, implemented by Darya Kuzmenko, an Individual entrepreneur (TIN 260710892006).
The Policy is a publicly available document, the text of which is permanently posted on the Internet at: https://daliagency.ru/privacy where it is available to an unlimited number of people.

TERMS
1.1. The Operator
The individual entrepreneur Kuzmenko Darya Olegovna
1.2. The subject of Personal Data (Subject)
is an individual who is directly or indirectly identified or determined using Personal Data. Within the meaning of the Policy, a Subject is defined as a User or other person visiting the Platform.
1.3. The User
is an individual who uses the Platform on behalf of the legal entity of which he is an employee, in accordance with the User Agreement concluded with the Operator.
1.4. Personal Data
is any information related directly or indirectly to a specific or identifiable natural person (Personal Data Subject).
1.5. The Platform/Website
https://daliagency.ru
1.6. Personal Data processing (Processing)
any action (operation) or set of actions (operations) with Personal Data performed using automation tools or without the use of such tools, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (provision, access), depersonalization, blocking, deletion and destruction of Personal Data.
1.7. Dissemination of Personal Data
actions aimed at disclosing Personal Data to an unspecified group of people.
1.8. Provision of Personal Data
actions aimed at disclosure of Personal Data to a certain person or a certain circle of persons.
1.9. Blocking of Personal data
temporary termination of the processing of Personal Data (except in cases where the processing is necessary to clarify Personal Data).
1.10. Destruction of Personal Data
actions as a result of which it becomes impossible to restore the content of Personal Data in the Personal data information system and (or) as a result of which the material carriers of personal data are destroyed.
1.11. Depersonalization of Personal Data
is an action that makes it impossible to determine the identity of Personal Data to a specific Personal Data Subject without using additional information).
1.12. Personal Data Information System
the totality of Personal Data contained in databases and information technologies and technical means that ensure their processing.
1.13. Cookies
are information that may contain the following information about the Subject: the IP address of the device, geolocation data, information about the program that accesses the Platform, technical characteristics of the equipment and software that the Subject uses, the date and time of access to the Platform, as well as other similar information.

Other terms are interpreted in accordance with the User Agreement, as well as in accordance with the provisions of Federal Law No. 152-FZ of July 27, 2006 "On Personal Data".

2. GENERAL PROVISIONS
2.1. The Personal Data Processing Policy has been developed in accordance with the provisions of Federal Law No. 152-FZ of July 27, 2006 "On Personal Data" (with amendments and additions), other legislative and regulatory legal acts in the field of personal data collection and processing (hereinafter referred to as the "Legislation") and defines the working procedure with the Personal Data of the Subject that the Operator collects through the Platform, as well as the requirements for ensuring their security.
2.2. The subject has the right to:
2.2.1. Make a decision to provide your Personal Data to the Operator and consent to their Processing freely, voluntarily and in your own interest.
2.2.2. To receive information regarding the Processing of his Personal Data.
2.2.3. Require the Operator to clarify 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.
2.2.4. To appeal actions (inaction) An Operator who processes Personal Data in violation of legal requirements or otherwise violates his rights and freedoms, to the authorized body for the protection of the rights of Subjects or in court.
2.2.5. Take measures provided for by law to protect their rights and legitimate interests, including through compensation for damages and (or) compensation for moral damage in court.

2.3. The Operator is obliged to:
2.3.1.Take measures necessary and sufficient to comply with the rights of the Subject and fulfill the obligations provided for by Law.
2.3.2. Provide the Subject with information regarding the Processing of the Subject's Personal Data upon receipt of a request from such Subject.
2.3.3. Terminate Processing in case of detection of facts of unlawful Processing of Personal Data.
2.3.4. Destroy Personal Data in accordance with the procedure established by Law if it is impossible to ensure the legality of Personal Data Processing.
2.3.5. To block Personal Data and clarify them in accordance with the procedure established by Law in case of detection of inaccuracy of Personal Data.

3. LEGAL GROUNDS FOR PERSONAL DATA PROCESSING
3.1. The Operator processes Personal Data on the basis of the following acts:
✔ Legislation governing the Operator's activities; including the Civil Code of the Russian Federation;
✔ Consent to the Processing of Personal Data.
✔ Contracts concluded between the Operator and the Subject, including the User Agreement concluded by the Operator with the User's employer;

4. THE COMPOSITION OF THE PERSONAL DATA BEING PROCESSED AND THE PURPOSES OF PROCESSING
4.1. Personal data is processed by the Operator for the following purposes:


Collection of applications, provision of information on services




Collection of applications, provision of information on services




Improving the operation of the platform:




Improving the operation of the platform:




Preparation, conclusion and execution of a civil law contract:




Preparation, conclusion and execution of a civil law contract:


4.2. In all cases of Personal Data processing:
5. PROCEDURE AND CONDITIONS OF PERSONAL DATA PROCESSING
5.1. The processing of Personal Data by the Operator is allowed in the following cases::
✔ Subject to the User's consent to the processing of his Personal Data;
✔ If there are grounds provided for by Law that allow the processing of Personal Data in the absence of the User's consent.
5.2. The Operator processes the Personal Data of the Subject:
✔ using automation tools
✔ without using automation tools
5.3. The Operator does not process Personal Data belonging to special categories and relating to race and nationality, political views, religious or philosophical beliefs, health status, intimate life, membership in public associations, as well as related to biometric Personal Data, except in cases expressly provided for by Law.
5.4. The Operator transfers the Personal Data of the Subject, in particular entrusts the Processing of Personal Data to the following third party:
5.5. The Operator has the right to transfer the Subject's Personal Data without his consent to the following persons:
✔ State bodies, including bodies of inquiry and investigation, and local self-government bodies upon their reasoned request
✔ In other cases directly provided for by the Legislation
5.6. The Operator ensures the Confidentiality of Personal Data, including that the Operator does not disclose or distribute Personal Data to third parties without the consent of the Subject, unless otherwise provided by Law.
5.7. The Operator ensures the security of Personal Data in accordance with the procedure provided for by Law, including by:
5.8. Access to Information Systems containing Personal Data is provided by a password system. Passwords are set by authorized employees of the Operator and are individually communicated to employees of the Operator who have access to Personal Data. The Operator restricts access to the Subject's Personal Data only to those employees who require it in accordance with their official duties.
5.9. The Operator stops Processing Personal Data:
✔ upon achievement of the Processing objectives
✔ in case of detection of unlawful Processing of Personal Data
✔ in case of expiration or withdrawal of the Subject's consent to Processing
The Operator has the right to continue Processing Personal Data in cases stipulated by Law.
5.10. Personal data is stored and processed for the period necessary to achieve the stated purposes of Processing.
5.11. Personal data is collected, stored and processed on the territory of the Russian Federation.

6. MODIFICATION, DELETION AND DESTRUCTION OF PERSONAL DATA
6.1. The Subject has the right to change (update, supplement) Personal Data at any time by contacting by sending a written application to the Operator by e-mail: dari.797@yandex.ru
6.2. The Subject has the right to require the Operator to clarify his Personal Data, block or destroy them if the Personal Data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated purpose of Processing, as well as to take measures provided for by Law to protect their rights. To exercise this right, the Subject has the right to personally submit an appropriate request by sending it to the Operator by e-mail: dari.797@yandex.ru
6.3. Upon receipt of the Subject's request for information regarding the Processing of Personal Data, the Operator undertakes to provide the Subject with such information free of charge in an accessible form within the time limits established by Law.
6.4. In case of detection of cases of unlawful Processing of Personal Data, the Operator undertakes to terminate such Processing. If it is impossible to ensure the legality of the Processing of Personal Data, the Operator undertakes to destroy such Personal Data in accordance with the procedure established by Law.
6.5. If the inaccuracy of Personal Data is revealed, the Operator undertakes to block such Personal Data and clarify them in accordance with the procedure established by Law.
6.6. If the Subject believes that the Operator is processing Personal Data in violation of legal requirements or otherwise violates his rights and freedoms, the Subject has the right to file a complaint with the Operator, as well as to appeal the actions or omissions of the Operator to the authorized body for the protection of the rights of Subjects or in court.
6.7. The Subject may revoke his consent to the Processing of Personal Data at any time by sending a written application to the Operator by e-mail to the Operator dari.797@yandex.ru
6.8. Upon receipt by the Operator of a request containing the withdrawal of the Subject's consent to the Processing of Personal Data, within 30 calendar days from the date of its receipt, the Operator is obliged to delete the Personal Data and stop Processing them, except for with the exception of cases directly provided for by Law, which allow the Processing of Personal Data in the absence of the User's consent.

7. OTHER PROVISIONS
7.1. The law of the Russian Federation is applicable to this Policy and the relations between the Entity and the Operator arising in connection with the application of the Policy.
7.2. If, for one reason or another, one or more provisions of the Policy are declared invalid or unenforceable, this does not affect the validity or applicability of the remaining provisions of the Policy.
7.3. The Operator has the right to make changes to the Policy unilaterally by posting a new version of the Policy at: https://daliagency.ru/privacy . The changes will take effect the day after they are posted at the specified address.

8. OPERATOR'S DETAILS
The individual entrepreneur Kuzmenko Darya Olegovna
TAX ID: 260710892006
E-mail: dari.797@yandex.ru