1. General Provisions
This Personal Data Processing Policy (hereinafter — the "Policy") defines the procedures for processing and protecting the personal data of users of the website en.korovski.ru (hereinafter — the "Website"). The Policy has been developed in accordance with Federal Law No. 152-FZ of 27 July 2006 "On Personal Data".
The personal data controller (hereinafter — the "Controller") is Spectral-Dynamic Systems LLC, TIN 7715733707, OGRN 1097760001570, registered address: 109235, г. Москва, ул. 1-я Курьяновская, д. 34, стр. 11, этаж 3, пом. 1, ком. 2. Contact for personal data processing matters: admin@kmsd.su, +7 (926) 145-82-37.
By using the Website and submitting data through Website forms, the user confirms their agreement with the terms of this Policy.
2. Categories of Personal Data Processed
2.1. Data provided by the user through Website forms
When completing a contact form (demo request, inquiry, application), the Controller processes the data that the user voluntarily provides:
- last name, first name (or any other name provided);
- phone number;
- e-mail address;
- message text and any other information voluntarily provided by the user.
Contact forms on the Website are implemented using the Bitrix24 service (CRM forms). Data submitted through these forms is received by the Bitrix24 system, the operator of which is 1C-Bitrix LLC.
2.2. Data collected automatically via web analytics
The Website uses the Yandex.Metrica web analytics service. The following data is collected automatically:
- IP address and approximate geolocation data;
- browser and operating system information (User-Agent);
- referral source (referrer);
- information about pages viewed, time spent, and actions taken on the Website;
- Yandex.Metrica service cookies;
- a recording of the user's on-page activity (when the Webvisor feature is enabled).
3. Purposes of Processing
- reviewing and handling user inquiries, requests, and applications, and providing feedback;
- preparing and concluding agreements at the user's initiative, and fulfilling obligations to the user;
- analysing Website traffic and improving the Website's performance and content;
- fulfilling the obligations imposed on the Controller by the legislation of the Russian Federation.
4. Legal Basis for Processing
Personal data is processed on the following legal grounds (Article 6 of Federal Law No. 152-FZ):
- consent of the data subject — expressed by voluntarily completing and submitting a form on the Website, as well as by continuing to use the Website after being notified of the use of cookies (clause 1, part 1, Article 6);
- performance of a contract to which the user is a party, or the conclusion of a contract at the user's initiative (clause 5, part 1, Article 6) — when processing applications and requests intended to give rise to contractual relations.
5. Disclosure to Third Parties
The Controller does not sell or transfer personal data to third parties, with the exception of the following parties engaged to support the operation of the Website:
- 1C-Bitrix LLC — processing of data submitted through the Website's CRM forms within the Bitrix24 system (under a data processing agreement; data is stored in the Russian Federation);
- Yandex LLC — processing of anonymised metric data through the Yandex.Metrica service (within the Russian Federation).
Data is transferred to these parties only to the extent necessary for the relevant purpose. No cross-border transfer of personal data is carried out.
6. Retention Periods
- data from inquiries and applications is retained until the purposes of processing are achieved, but no longer than the period necessary for possible follow-up on the inquiry and within the periods established by applicable law;
- web analytics data is retained by the Yandex.Metrica service for the period set by the service (generally up to 540 days from the last visit), after which it is anonymised.
Upon achievement of the processing purposes or upon withdrawal of consent, personal data shall be deleted or anonymised.
7. Security Measures
The Controller implements the necessary legal, organisational, and technical measures to protect personal data against unauthorised access, destruction, modification, blocking, copying, and distribution, including:
- data is transmitted over the secure HTTPS protocol;
- access to data is restricted to authorised personnel of the Controller;
- data is stored in infrastructure located within the Russian Federation;
- measures are applied in accordance with Articles 18.1 and 19 of Federal Law No. 152-FZ.
8. Rights of the Data Subject
The user has the right to:
- obtain information about the processing of their personal data;
- request the correction, blocking, or deletion of their data if it is incomplete, outdated, inaccurate, or processed in violation of the law;
- withdraw consent to the processing of personal data;
- lodge a complaint with Roskomnadzor (rkn.gov.ru) or seek judicial redress.
To exercise these rights, please send a request to admin@kmsd.su. The response time is no more than 30 calendar days from the date the request is received.
Consent to the processing of web analytics data may be withdrawn by disabling cookies in your browser or by using the official Yandex.Metrica opt-out mechanism.
9. Changes to the Policy
The Controller reserves the right to amend this Policy. The current version is always available at /privacy/. The date of the last update is indicated at the top of this document.