Personal Data Processing Policy

1. General Provisions

This Personal Data Processing Policy is prepared in accordance with the requirements of Federal Law No. 152-FZ of July 27, 2006 “On Personal Data” (hereinafter — the Personal Data Law) and defines the procedure for processing personal data and the measures implemented by SoftMaster LLC (hereinafter — the Operator) to ensure the security of personal data.

1.1. The Operator considers the observance of human and civil rights and freedoms when processing personal data, including the protection of the rights to privacy, personal and family confidentiality, as one of its most important goals and essential conditions when carrying out its activities.

1.2. This Policy applies to all information that the Operator may obtain about visitors of the website https://softmaster.tech.

2. Basic Terms Used in the Policy

• 2.1. Automated processing of personal data — processing of personal data with the use of computer technology.
• 2.2. Blocking of personal data — temporary suspension of personal data processing (except when processing is necessary to clarify personal data).
• 2.3. Website — a set of graphic and information materials, as well as software and databases, accessible on the Internet at https://softmaster.tech.
• 2.4. Personal data information system — a set of personal data contained in databases and the information technologies and technical tools that ensure 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 data subject.
• 2.6. Processing of personal data — any action (operation) or combination of actions performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, updating, retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction.
• 2.7. Operator — a state body, municipal authority, legal entity or individual that organizes and/or processes personal data and determines the purposes of personal data processing, the composition of the personal data to be processed, and the actions performed with the personal data.
• 2.8. Personal data — any information relating directly or indirectly to an identified or identifiable User of the website https://softmaster.tech.
• 2.9. Personal data permitted by the data subject for dissemination — personal data made available to an unlimited number of persons by the data subject by granting consent in accordance with the Personal Data Law.
• 2.10. User — any visitor of the website https://softmaster.tech.
• 2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or group of persons.
• 2.12. Distribution of personal data — any actions aimed at disclosing personal data to an unlimited number of persons or making personal data publicly available.
• 2.13. Cross-border transfer of personal data — transfer of personal data to the territory of a foreign state, foreign authority, foreign individual or foreign legal entity.
• 2.14. Destruction of personal data — any actions that result in irreversible destruction of personal data, making further recovery impossible.

3. Rights and Obligations of the Operator

3.1. The Operator has the right to:

• request accurate personal data and/or documents containing personal data from the data subject;
• continue processing personal data without consent if grounds specified in the Personal Data Law are present, even after consent is revoked;
• independently determine measures required to fulfill obligations under the Personal Data Law.

3.2. The Operator must:

• provide the data subject with information regarding the processing of their personal data upon request;
• organize personal data processing in accordance with Russian legislation;
• respond to requests from data subjects and their legal representatives;
• provide the authorized data protection body with requested information within 10 days;
• publish or otherwise provide unrestricted access to this Policy;
• take legal, organizational, and technical measures to protect personal data from unlawful access and other unlawful actions;
• cease transfer and processing of personal data in cases outlined by the Personal Data Law;
• fulfill other obligations as required by the Personal Data Law.

4. Rights and Obligations of Personal Data Subjects

4.1. Data subjects have the right to:

• receive information regarding the processing of their personal data, except in cases defined by law;
• request clarification, blocking, or destruction of personal data that is incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the declared purpose;
• define requirements for prior consent to personal data processing for marketing purposes;
• revoke consent to personal data processing;
• appeal unlawful actions or inaction of the Operator;
• exercise other rights provided by Russian law.

4.2. Data subjects must:

• provide accurate data about themselves;
• notify the Operator about updates to their personal data.

4.3. Persons who submit inaccurate information or provide data about another person without their consent bear responsibility under Russian law.

5. Principles of Personal Data Processing

1. Processing is carried out lawfully and fairly.
2. Processing is limited to specific, lawful purposes.
3. Combining databases with incompatible purposes is prohibited.
4. Only data relevant to the processing purposes may be processed.
5. Processing excessive personal data is not allowed.
6. Personal data must be accurate and up to date; necessary measures must be taken to correct inaccuracies.
7. Personal data must not be stored longer than required for processing purposes.

6. Purposes of Personal Data Processing

Purpose: Informing the User via emails and phone calls.

Personal data processed:

• last name, first name, patronymic
• email address
• phone numbers

Legal basis: incorporating documents of the Operator.

Types of processing:

• collection, recording, systematization, accumulation, storage, destruction, depersonalization;
• sending informational emails.

7. Conditions for Personal Data Processing

• Processing is carried out with the consent of the data subject.
• Processing is necessary to fulfill obligations under Russian law.
• Processing is necessary for justice and execution of judicial acts.
• Processing is necessary to fulfill or conclude a contract with the data subject.
• Processing is necessary to exercise the rights and legitimate interests of the Operator or third parties.
• Processing of publicly available personal data.
• Processing required to comply with federal law.

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

The Operator ensures the security of personal data through legal, organizational, and technical measures.

• The Operator ensures the confidentiality of personal data and prevents unauthorized access.
• Personal data will never be shared with third parties except where required by law or with consent of the data subject.
• Users may update their personal data by sending an email marked “Personal Data Update” to info@softmaster.tech.
• The processing period is determined by the achievement of processing purposes unless otherwise required by law. Users may withdraw consent at any time by emailing a notice marked “Consent Withdrawal” to info@softmaster.tech.
• Data collected by third-party services is stored and processed by those parties under their agreements; the Operator is not responsible for their actions.
• Restrictions imposed by the data subject do not apply when processing is carried out for public interest.
• The Operator ensures the confidentiality of personal data.
• Personal data is stored no longer than necessary for its processing purposes.
• Processing may be terminated upon achieving processing goals, expiration or withdrawal of consent, or unlawful processing detection.

9. Actions Performed by the Operator

• The Operator performs collection, recording, systematization, accumulation, storage, updating, retrieval, use, transfer, depersonalization, blocking, deletion, and destruction of personal data.
• Automated processing with or without information transmission via telecommunications networks is performed.

10. Cross-Border Transfer of Personal Data

• The Operator must notify the authorized data protection authority before starting cross-border transfer of personal data.
• The Operator must obtain necessary information from foreign recipients of personal data.

11. Confidentiality of Personal Data

The Operator and other persons who have access to personal data are obliged not to disclose or distribute it without the consent of the data subject unless required by law.

12. Final Provisions

• Users may request clarification regarding the processing of their personal data by emailing info@softmaster.tech.
• Any changes to this Policy will be reflected in this document. The Policy is valid indefinitely until replaced by a new version.
• The current version of the Policy is publicly available at https://softmaster.tech.