Personal Data Processing Policy1. General Provisions
1.1. This Personal Data Processing Policy (hereinafter referred to as the *Policy*) has been prepared in accordance with Clause 2, Part 1, Article 18.1 of Federal Law of the Russian Federation No. 152-FZ "On Personal Data" dated July 27, 2006 (hereinafter referred to as the *Law*) and defines the position of Sole Proprietor Ekaterina Markovna Rozhdestvenskaya and/or her affiliated persons (hereinafter referred to as the *Company*) regarding the processing and protection of personal data (hereinafter referred to as the *Data*), as well as ensuring the observance of human rights and freedoms, particularly the right to privacy and personal and family confidentiality.
2. Scope of Application
2.1. This Policy applies to Data received both before and after the entry into force of this Policy.
2.2. Understanding the importance and value of Data, and ensuring compliance with the constitutional rights of citizens of the Russian Federation and other countries, the Company guarantees reliable protection of Data.
3. Definitions
3.1. *Data* means any information relating to a directly or indirectly identified or identifiable individual, including but not limited to: full name, email address, phone number, and passport details.
3.2. *Data processing* means any action or set of actions performed with or without automation tools, including collection, recording, systematization, accumulation, storage, updating, extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of Data.
3.3. *Data security* means the protection of Data from unlawful or unauthorized access, destruction, modification, blocking, copying, distribution, or other unlawful actions.
4. Legal Grounds and Purposes of Data Processing
4.1. The processing and protection of Data are carried out in accordance with applicable legislation.
4.2. Data subjects include clients and website visitors of
www.logos-psy.com, including those submitting service requests via the website.
4.3. The Company processes Data for the following purposes:
* providing information about products/services, promotions, and special offers;
* analyzing service quality and improving customer support.
5. Principles and Conditions of Data Processing
5.1. Data processing is carried out lawfully and fairly. Data are not disclosed to third parties without the subject’s consent, except where disclosure is required by law or by competent authorities.
5.2. The Company may include Data in publicly available sources only with the subject’s written consent or consent provided via website forms (checkbox confirmation).
5.3. The Company does not process Data related to race, nationality, political views, religious or philosophical beliefs, intimate life, or membership in public associations.
5.4. Biometric Data are not processed by the Company.
5.5. The Company does not carry out cross-border transfer of Data.
5.6. Data may be transferred to government authorities in cases established by law.
5.7. The Company may entrust Data processing to third parties with the subject’s consent based on a contractual agreement.
6. Rights and Obligations of Data Subjects and the Company
6.1. Data subjects have the right to:
* receive confirmation of Data processing and information regarding such processing;
* request correction, blocking, or deletion of inaccurate or unlawfully obtained Data;
* withdraw consent to Data processing at any time;
* protect their rights and legitimate interests, including through legal remedies.
6.2. The Company shall:
* provide information on Data processing upon request within statutory timeframes;
* implement legal, organizational, and technical measures to protect Data;
* publish this Policy and ensure public access to it online.
7. Data Protection Measures
7.1. The Company takes necessary legal, organizational, and technical measures to protect Data from unauthorized access, destruction, alteration, or distribution.
7.2. Such measures include appointing responsible personnel, implementing internal regulations, assessing risks, using certified protection tools, and monitoring system security.
8. Data Retention Periods
8.1. Data retention periods are determined based on processing purposes, contractual obligations, and legal requirements.
8.2. Upon expiration of retention periods, Data shall be destroyed or anonymized unless otherwise required by law.
9. Clarifications on Data Processing
9.1. Individuals may request clarification regarding Data processing by contacting the Company at its registered address in Moscow, Russian Federation.
10. Specific Features of Internet-Based Data Processing
10.1. The Company processes Data received via the website, email, and telephone communications.
10.2. Data may be provided voluntarily by users when completing online forms or sending emails.
10.3. The Company may automatically collect non-personal information such as website usage statistics and cookies to improve user experience.
10.4. Data may be transferred to third parties only with consent or in cases required by law.
10.5. Users may withdraw consent to Data processing at any time by contacting the Company.