Personal Data Processing Policy

1. General provisions

1.1. This Personal Data Processing Policy (hereinafter the Policy) has been drawn up in accordance with the requirements of Federal Law No. 152-FZ of 27 July 2006 "On Personal Data" (hereinafter Law 152-FZ) and defines the procedure for processing personal data and the measures taken to ensure its security by CodeService LLP (hereinafter the Operator).

1.2. The Operator considers respect for human and civil rights and freedoms in the processing of personal data — including the protection of the right to privacy and to personal and family secrecy — its most important goal and a condition of its business.

1.3. The Policy applies to all information the Operator may obtain about visitors of the website webreaktor.com (hereinafter the Website).

1.4. By using the Website and submitting a request through the form, a visitor confirms that they have read the Policy and consent to the processing of personal data on the terms set out in it.

1.5. This is a translation for convenience; in case of discrepancies the Russian version prevails.

2. Operator

Company: CodeService LLP
E-mail: [email protected]
Phone: +7 (495) 960-90-71

3. Key terms

Personal data — any information relating directly or indirectly to an identified or identifiable natural person (the personal data subject).

Personal data processing — any operation or set of operations performed on personal data with or without the use of automated means: collection, recording, systematisation, accumulation, storage, updating, retrieval, use, transfer (provision, access), depersonalisation, blocking, deletion, destruction.

Operator — a person who independently organises and carries out the processing of personal data and determines its purposes, the scope of data and the operations performed.

User — any visitor of the Website.

Cookies — small pieces of data that the Website stores in the User's browser.

4. Categories of personal data processed

4.1. Through the request form on the Website the Operator processes:

name;
phone number and/or username in the Telegram or Max messengers;
the User's website address (if provided);
information the User provides on their own in the comment to the request.

4.2. Technical data is processed automatically when the Website is visited: IP address, browser and device information (user agent), date and time of the visit, addresses of the pages viewed. This data is used to keep the Website running, to protect it against abuse and to confirm the fact of consent.

4.3. The Operator does not process special categories of personal data (concerning race or ethnicity, political views, religious beliefs, health or intimate life) or biometric personal data.

5. Purposes of personal data processing

contacting the User about their request: clarifying the task, estimating the timeline and the price;
concluding and performing a website development contract;
answering the User's questions and enquiries;
ensuring the operability and security of the Website.

The Operator does not send marketing messages without the User's separate consent and does not make decisions that produce legal consequences solely on the basis of automated processing.

6. Legal grounds for processing

6.1. Processing is carried out on the basis of the User's consent (Articles 6 and 9 of Law 152-FZ), which is expressed by ticking the box "I agree to the personal data processing policy" and submitting the form, as well as for the purpose of concluding and performing a contract to which the User is a party.

6.2. The Operator processes personal data only if the User has filled it in and/or submitted it on their own through the forms on the Website.

7. Procedure and conditions of processing

7.1. Processing is carried out with and without the use of automated means: request data is stored in the Website database and may be sent to the Operator by e-mail and to messengers.

7.2. The Operator takes legal, organisational and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying and distribution: restricted access to the database, a secure connection (HTTPS), recording and storing the fact of consent.

7.3. Personal data is not transferred to third parties, except in cases provided for by the legislation of the Russian Federation and to persons engaged by the Operator to host the Website (the hosting provider), provided they ensure the confidentiality of the data.

7.4. No cross-border transfer of personal data is carried out. Databases containing the personal data of citizens of the Russian Federation are located in the Russian Federation.

7.5. Processing period: until the purposes of processing are achieved, consent is withdrawn or three years have passed since the User's last enquiry — whichever comes first. Once the period expires, the data is destroyed or depersonalised.

8. Rights of the personal data subject

The User has the right to:

obtain information concerning the processing of their personal data;
demand that incomplete, outdated, inaccurate or unlawfully obtained data be updated, blocked or destroyed;
withdraw consent to the processing of personal data;
appeal against the Operator's actions or inaction to the authorised body for the protection of the rights of personal data subjects (Roskomnadzor) or in court.

Requests are sent to the e-mail address [email protected] marked "Personal data". The Operator replies within the period established by Law 152-FZ. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

9. Cookies and analytics

9.1. The Website uses technical cookies necessary for its operation (for example, to protect forms against request forgery). Cookies can be disabled in the browser settings; in that case some functions of the Website may become unavailable.

9.2. If web analytics services are connected to the Website, they collect depersonalised data about visits. The Operator lists the services used in this section when they are connected.

10. Final provisions

10.1. The Operator may amend the Policy. A new revision takes effect from the moment it is published on the Website unless the revision itself provides otherwise. The current revision is always available at https://webreaktor.com/policy.

10.2. For any questions related to the processing of personal data, you can contact the Operator at the e-mail address [email protected].