Personal Data Processing Policy

Purpose of processing
providing the User with access to services, information and/or materials contained on the website
Personal data
surname, first name, patronymic
email address
phone numbers
year, month, date and place of birth

Legal grounds
the Operator’s charter/incorporation documents
agreements concluded between the Operator and the personal data subject

Types of personal data processing
collection, recording, systematization, accumulation, storage, destruction and anonymization of personal data
sending informational emails to an email address
7. Conditions for personal data processing
7.1. Personal data is processed with the consent of the personal data subject to the processing of his or her personal data.
7.2. Personal data processing is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, and to perform the functions, powers and duties assigned to the Operator by the legislation of the Russian Federation.
7.3. Personal data processing is necessary for the administration of justice, enforcement of a judicial act, or an act of another body or official that must be enforced in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. Personal data processing is necessary for the performance of an agreement to which the personal data subject is a party, beneficiary or guarantor, as well as for concluding an agreement at the initiative of the personal data subject or an agreement under which the personal data subject will be a beneficiary or guarantor.
7.5. Personal data processing is necessary for the exercise of the rights and legitimate interests of the Operator or third parties, or for achieving socially significant purposes, provided that the rights and freedoms of the personal data subject are not violated.
7.6. Personal data is processed where access by an unlimited number of persons has been provided by the personal data subject or at his or her request (hereinafter referred to as publicly available personal data).
7.7. Personal data is processed where such data is subject to publication or mandatory disclosure in accordance with federal law.
8. Procedure for collecting, storing, transferring and otherwise processing personal data
The security of personal data processed by the Operator is ensured by implementing the legal, organizational and technical measures necessary to fully comply with the requirements of current legislation in the field of personal data protection.
8.1. The Operator ensures the security of personal data and takes all possible measures to prevent unauthorized persons from accessing personal data.
8.2. The User’s personal data will never, under any circumstances, be transferred to third parties, except in cases related to compliance with current legislation or where the personal data subject has consented to the Operator transferring the data to a third party for the performance of obligations under a civil-law agreement.
8.3. If inaccuracies in personal data are identified, the User may update them independently by sending a notification to the Operator’s email address at info@koya.company with the subject line “Personal data update.”
8.4. The period of personal data processing is determined by the achievement of the purposes for which the personal data was collected, unless another period is provided for by an agreement or current legislation.
The User may withdraw his or her consent to the processing of personal data at any time by sending the Operator a notification by email to the Operator’s email address at info@koya.company with the subject line “Withdrawal of consent to personal data processing.”
8.5. All information collected by third-party services, including payment systems, communication tools and other service providers, is stored and processed by those persons (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject and/or with the specified documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.
8.6. Restrictions established by the personal data subject on transfer (except for granting access), as well as on processing or processing conditions (except for obtaining access) of personal data permitted for distribution, do not apply in cases of personal data processing in state, public and other public interests defined by the legislation of the Russian Federation.
8.7. When processing personal data, the Operator ensures the confidentiality of personal data.
8.8. The Operator stores personal data in a form that allows the personal data subject to be identified for no longer than required by the purposes of personal data processing, unless the personal data storage period is established by federal law or by an agreement to which the personal data subject is a party, beneficiary or guarantor.
8.9. The condition for terminating personal data processing may be the achievement of the purposes of personal data processing, expiration of the personal data subject’s consent period, withdrawal of consent by the personal data subject, a request to terminate personal data processing, or identification of unlawful personal data processing.
9. List of actions performed by the Operator with the personal data received
9.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, modifies), retrieves, uses, transfers (distributes, provides, grants access to), anonymizes, blocks, deletes and destroys personal data.
9.2. The Operator carries out automated personal data processing with or without receiving and/or transferring the information received via information and telecommunications networks.
10. Cross-border transfer of personal data
10.1. Before commencing cross-border transfer of personal data, the Operator must notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out cross-border transfer of personal data (such notification is sent separately from the notification of intent to process personal data).
10.2. Before submitting the above notification, the Operator must obtain the relevant information from the authorities of the foreign state, foreign individuals and foreign legal entities to which the cross-border transfer of personal data is planned.
11. Confidentiality of personal data
The Operator and other persons who have gained access to personal data must not disclose personal data to third parties or distribute personal data without the consent of the personal data subject, unless otherwise provided for by federal law.
12. Final provisions
12.1. The User may receive any clarifications on matters of interest regarding the processing of his or her personal data by contacting the Operator by email at info@koya.company.
12.2. This document will reflect any changes to the Operator’s personal data processing policy. The Policy remains in effect indefinitely until replaced by a new version.
12.3. The current version of the Policy is freely available on the Int