Personal Data Processing Policy

Revision from [date of publication]

---

1. General provisions

1.1. This Policy defines the procedure and conditions of processing personal data and measures to ensure their security, which applies [full name of the legal entity] (hereinafter — Operator).

1.2. The Policy applies to all personal data that The operator receives from site visitors https://systemslab.su and its language versions (hereinafter — Website).

1.3. The Policy is freely available on the Website. Current The editorial office is always located at the address indicated above.

1.4. The operator is included in the register of processing operators personal data, [registration number in the Roskomnadzor registry].

2. Information about the operator

Name	[OOO "..."]
INN / OGRN	[…] / […]
Address	[legal address]
E-mail for personal data requests	[privacy@systemslab.su]
Phone number	[…]
Responsible for the organization of PD processing	[position, full name]

3. Basic concepts

Personal data — any information related to directly or indirectly to a specific or identifiable natural person (to the subject of personal data). Personal data processing data — any action or set of actions with personal data performed using the means automation or without them: collection, recording, systematization, accumulation, storage, refinement, extraction, use, transfer (provision, access), depersonalization, blocking, deletion, destruction. A cookie is a small piece of data, which the Site saves in the user's browser. Other concepts are used in the meaning established by 152-FZ.

4. Legal grounds processing

• Federal Law No. 152-FZ of 27.07.2006 " On Personal Data data";
• The Civil Code of the Russian Federation;
• consent of the personal data subject to processing (paragraph 1 of part 1 Article 6 152-FZ);
• contracts to which the entity is a party or under which it is the beneficiary, as well as the actions preceding conclusion of the contract on the initiative of the subject (paragraph 5 of part 1 of Article 6 152-FZ).

5. Goals, categories of data, methods and terms of processing

Goal	Subjects	Personal data	Foundation	Method	Term
1. Response to a request from the Site (form, chat, go to messenger) and preparation of the proposal	Site visitors, representatives of organizations	Name; phone number and/or user name in the messenger; e-mail; name of the organization; content of the request and attached files	Consent; actions before the conclusion of the contract on the initiative of The subject	Automated	Before reaching the goal, but no more than 3 years from the last request, or before revocation of consent
2. Request documents for purchase	Representatives of organizations	Full name, position, e-mail, phone, organization	Consent	Automated	1 year from the date of the request or until the withdrawal of consent
3. Offers of cooperation	Representatives of suppliers, contractors, agents	Full name, organization, region, phone, e-mail, content offers	Consent	Automated	1 year or until the withdrawal of consent
4. Analysis of the effectiveness of the Site and advertising	Site Visitors	User ID (cookie), session information: date and time, pages, traffic source and advertising tags (UTM), device type, and browser, IP address, approximate IP location, ID Yandex.Metrica	Consent (cookie banner)	Automated	12 months from the last visit or until the withdrawal of consent
5. Ensuring the operation and security of the Site	Site Visitors	IP address, technical cookies, browser information	The legitimate interest of the Operator in ensuring the operability of the Site; consent	Automated	30 days for technical journals

The Operator does not process special categories of personal data and biometric personal data through the Website. The operator does not makes decisions that generate legal consequences for the subject, on the basis of based solely on automated processing.

6. Terms and Conditions processing

6.1. Processing is carried out with the consent of the subject, unless otherwise specified provided by law. Consent to the processing of personal data it is issued separately from other documents, including from this Policy, by marking in the form on the Website. Text The consent is posted at https://systemslab.su/soglasie-na-obrabotku-pd/.

6.2. Personal data of citizens of the Russian Federation are recorded, are systematized, accumulated, stored, refined and extracted from using databases located on the territory of the Russian Federation Federation.

6.3. The Operator uses the following services that process data on his behalf or provide infrastructure:

Service	For what	Where the data is processed
[server hosting provider]	Site and database placement	Russian Federation
Yandex. Metrica ("Yandex" LLC)	Traffic analysis, with consent to analytical cookies	Russian Federation
Yandex SmartCaptcha ("Yandex Cloud" LLC)	Protecting forms from spam	Russian Federation
Yandex Cloud Translate ("Yandex Cloud" LLC)	Translation of Site texts. Personal data is not transmitted	Russian Federation
Telegram	Official notifications to the Operator's employees about new requests	See section 6.4

6.4. Notifications to employees in Telegram. By by default, the notification contains only the request number, channel, and source transfer and link to the Operator's internal system, without personal data data. [If the Operator includes the transfer of name and contact in the notifications, this is a cross-border transfer of personal data. Before switching on, the Operator sends a notification to Roskomnadzor in accordance with Article 12 152-FZ, and this item is supplemented with information about the country, the recipient and the composition of the data.]

6.5. If the visitor himself goes from the Site to the messenger (Telegram, MAX or other) and writes to the Operator, the processing of correspondence is regulated also the rules of the corresponding messenger.

6.6. The Operator does not sell personal data and does not transfer it to third parties persons, except for the cases specified in clauses 6.3 and 6.4, as well as the cases, provided for by the legislation of the Russian Federation.

6.7. Termination of processing and destruction of personal data are made when the processing goals are achieved, the deadlines specified in section 5, withdrawal of consent (unless there are other legal grounds) or detection of illegal processing, within the time limits established by Article 21 152-FZ.

7. Cookies and Analytics

7.1. The Website uses:

• necessary cookies — for the operation of the Site, forms, chat, spam protection and memorization of language selection and consent. Without them, the Site does not It works;
• analytical cookies — Yandex.Metrica and own statistics of sessions and ad tags. Are installed only after the user's consent in the cookie banner.

7.2. Details and a list of cookies are provided on the page https://systemslab.su/cookie/. You can change the selection by link "Cookie Settings" in the basement of the Site or by deleting cookies in the settings browser.

8. Rights of the subject personal data

The subject has the right:

• to obtain information about the processing of your personal data (article 14 152-FZ);
• request clarification, blocking or destruction of data if they incomplete, outdated, inaccurate, illegally obtained or not needed for the stated goal;
• revoke consent to processing;
• to appeal against the actions or omissions of the Operator in Roskomnadzor or in the court.

How to send a request. By email to [privacy@systemslab.su ] or by mail to the Operator's address. The request must contain information that allows you to identify the subject and its address (for example, the address number SL-XXXX and the contact specified when applying). The operator responds within no more than 10 business days from the date receiving the request. The term can be extended for no more than 5 working days days with the notification of the subject of the reasons.

Revocation of consent. It is sent in the same way. The operator stops processing and destroys the data within 30 days, if there are no other legal grounds for processing.

9. Measures to ensure security

The operator takes legal, organizational and technical measures, provided for in Articles 18.1 and 19 152-FZ, including:

• a person responsible for organizing the processing of personal data has been appointed data;
• local acts on the processing and protection of personal data have been approved, employees are familiar with them;
• access to personal data is available only to employees to whom it is needed for work, with a distinction by roles;
• data transfer between the browser and the Site is encrypted (HTTPS);
• employee passwords are stored in the form of strong hashes, secret keys services — in encrypted form;
• a log of employees' actions with personal data is kept;
• the database is not directly accessible from the Internet;
• an assessment of the harm that may be caused to the subjects is carried out, and Security threats are identified;
• when identifying an incident that resulted in an illegal transfer personal data, the Operator notifies Roskomnadzor in time, established by part 3.1 of Article 21 152-FZ (within 24 hours — initial notification, within 72 hours — results investigations).

10. Final provisions

10.1. The Operator has the right to change the Policy. The new edition comes into force effective from the date of publication on the Site, unless otherwise specified in it.

10.2. Issues not regulated by the Policy are resolved in accordance with with the legislation of the Russian Federation.

10.3. The Policy is valid in Russian. Translations into English and Chinese languages, if posted, are of a reference nature.