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Policy on the Processing of Personal Data

1. General Provisions

This Personal Data Processing Policy is drafted in accordance with the requirements of Federal Law No. 152-FZ dated July 27, 2006, “On Personal Data” (hereinafter referred to as the Personal Data Law) and defines the procedure for processing personal data and the measures taken to ensure the security of personal data by LLC “AISIU+” (hereinafter referred to as the Operator).

1.1. The Operator considers the observance of human and civil rights and freedoms during the processing of personal data, including the protection of the right to privacy, personal and family confidentiality, to be its primary objective and essential condition for carrying out its activities.

1.2. This Policy of the Operator regarding the processing of personal data (hereinafter – the Policy) applies to all information that the Operator may receive about visitors to the website .

2.9. Personal data made publicly available by the subject of personal data – personal data to which the subject has granted access to an unlimited number of persons by giving consent to the processing of personal data made publicly available, in accordance with the procedure established by the Personal Data Law (hereinafter – personal data made publicly available).

2.10. User – any visitor of the website.

7.2. The Operator is also entitled to send the User notifications about new products and services, special offers, and various events. The User may at any time opt out of receiving such informational messages by sending an email to the Operator at hello@icu.agency with the subject “Unsubscribe from notifications about new products, services, and special offers.”

7.3. Anonymized data of Users collected through web analytics services is used to gather information about User behavior on the website, improve the quality of the website, and enhance its content.

8. Legal Grounds for Personal Data Processing

8.1. The legal grounds for the processing of personal data by the Operator are:
– Federal Law “On Information, Information Technologies and Information Protection” No. 149-FZ dated July 27, 2006;
– federal laws and other regulatory legal acts in the field of personal data protection;
– the Users’ consent to the processing of their personal data, including the processing of personal data permitted for distribution.

8.2. The Operator processes the User’s personal data only if it is provided and/or submitted by the User voluntarily through special forms available on the website . By filling out the relevant forms and/or sending their personal data to the Operator, the User consents to this Policy.

8.3. The Operator processes anonymized data about the User if this is permitted in the User’s browser settings (such as enabling the storage of cookies and the use of JavaScript technology).

8.4. The personal data subject independently decides to provide their personal data and gives consent freely, by their own will, and in their own interest.

9. Conditions for Personal Data Processing

9.1. Personal data is processed with the consent of the personal data subject to the processing of their personal data.

9.2. The processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, as well as to fulfill the functions, powers, and duties imposed on the Operator by the legislation of the Russian Federation.

9.3. The processing of personal data is necessary for the administration of justice, the execution of a court decision, or the decision of another authority or official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.

9.4. The processing of personal data is necessary for the performance of a contract to which the personal data subject is a party, a beneficiary, or a guarantor, or 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 a guarantor.

9.5. The 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 this does not violate the rights and freedoms of the personal data subject.

9.6. Personal data is processed that has been made publicly available by the personal data subject or at their request (hereinafter – publicly available personal data).

9.7. Personal data is processed that is subject to publication or mandatory disclosure in accordance with federal law.
10. Procedure for the 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 the requirements of current legislation in the field of personal data protection.

10.1. The Operator ensures the safekeeping of personal data and takes all possible measures to prevent unauthorized access to personal data.

10.2. The User’s personal data will never, under any circumstances, be transferred to third parties, except in cases related to the fulfillment of applicable legislation or if the personal data subject has given the Operator consent to transfer the data to a third party for the purpose of fulfilling obligations under a civil law contract.

10.3. If any inaccuracies in the personal data are identified, the User may update them independently by sending a notification to the Operator at the email address hello@icu.agency with the subject line “Personal Data Update.”

10.4. The period of personal data processing is determined by the achievement of the purposes for which the personal data was collected, unless a different period is specified by 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 hello@icu.agency with the subject line “Withdrawal of Consent to Personal Data Processing.”

10.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by those parties (Operators) in accordance with their own User Agreements and Privacy Policies. The personal data subject and/or User is solely responsible for reviewing such documents in a timely manner. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this clause.

10.6. Any restrictions established by the personal data subject on the transfer (except access), processing, or conditions of processing (except access) of personal data permitted for distribution do not apply in cases where personal data is processed for state, public, or other socially significant interests as defined by the legislation of the Russian Federation.
10.7. The Operator ensures the confidentiality of personal data during processing.

10.8. The Operator stores personal data in a form that allows identification of the personal data subject for no longer than is necessary to achieve 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.

10.9. The grounds for termination of personal data processing may include the achievement of the processing purposes, the expiration of the data subject’s consent, the withdrawal of consent by the personal data subject, or the identification of unlawful processing of personal data.

11. List of Actions Performed by the Operator with Collected Personal Data

11.1. The Operator carries out the collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.

11.2. The Operator performs automated processing of personal data with the receipt and/or transfer of the obtained information via information and telecommunication networks or without such transfer.

12. Cross-Border Transfer of Personal Data

12.1. Before initiating the cross-border transfer of personal data, the Operator must ensure that the foreign country to which the data is to be transferred provides reliable protection of the rights of personal data subjects.

12.2. Cross-border transfer of personal data to foreign countries that do not meet the above requirements may only occur if there is written consent from the personal data subject for the cross-border transfer of their personal data and/or for the execution of a contract to which the personal data subject is a party.

13. Confidentiality of Personal Data

The Operator and other individuals who have access to personal data are obligated not to disclose or distribute personal data to third parties without the consent of the personal data subject, unless otherwise required by federal law.

14. Final Provisions

14.1. The User can obtain any clarifications regarding the processing of their personal data by contacting the Operator via email at hello@icu.agency.

14.2. 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.