Privacy policy

1. General Provisions

This personal data processing policy is prepared in accordance with the requirements of the Federal Law of 27.07.2006 No. 152-FZ "On Personal Data" (hereinafter referred to as the Personal Data Law) and defines the procedure for processing personal data and measures to ensure the security of personal data taken by OOO "Liapunov i partnery" (hereinafter referred to as the Operator).

1.1. The Operator considers the observance of human and civil rights and freedoms in the processing of personal data, including the protection of rights to privacy, personal and family secrets, as the most important goal and condition for the implementation of its activities.

1.2. This policy of the Operator regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator can receive about visitors to the website https://liapunov.com/.

2. Basic Concepts Used in the Policy

2.1. Automated processing of personal data – processing of personal data using computer technology.

2.2. Blocking of personal data – temporary cessation of processing of personal data (except in cases where processing is necessary to clarify personal data).

2.3. Website – a set of graphic and information materials, as well as software and databases, ensuring their availability on the internet at the network address https://liapunov.com/.

2.4. Information system of personal data – a set of personal data contained in databases, and information technologies and technical means ensuring their processing.

2.5. Depersonalization of personal data – actions that result in the impossibility to determine without the use of additional information the belonging of personal data to a specific User or another subject of personal data.

2.6. Processing of personal data – any action (operation) or set of actions (operations) performed using automation tools or without using such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.

2.7. Operator – a legal person independently or jointly with other persons organizing and (or) carrying out the processing of personal data, as well as determining the purposes of processing personal data, the composition of personal data to be processed, actions (operations) performed with personal data.

2.8. Personal data – any information related directly or indirectly to a specific or identifiable User of the website https://liapunov.com/.

2.9. Personal data allowed by the subject of personal data for distribution – personal data to which an unlimited number of persons have access by the subject of personal data by giving consent to the processing of personal data allowed by the subject of personal data for distribution in the manner prescribed by the Personal Data Law (hereinafter referred to as personal data allowed for distribution).

2.10. User – any visitor to the website https://liapunov.com/.

2.11. Provision of personal data – actions aimed at disclosing personal data to a specific person or a specific set of persons.

2.12. Distribution of personal data – any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or at familiarizing with personal data an unlimited set of persons, including publishing personal data in the media, placing it in information and telecommunications networks, or providing access to personal data in any other way.

2.13. Cross-border transfer of personal data – transfer of personal data to the territory of a foreign state to a foreign authority, a foreign individual or a foreign legal entity.

2.14. Destruction of personal data – any actions resulting in the irrevocable destruction of personal data with the impossibility of further restoration of the content of personal data in the information system of personal data and (or) the destruction of material carriers of personal data.

3. Basic Rights and Obligations of the Operator

3.1. The Operator has the right to:

  • receive reliable information and/or documents containing personal data from the subject of personal data;
  • continue processing personal data without the consent of the subject of personal data in cases specified by the Personal Data Law if the subject withdraws consent to the processing of personal data and sends a demand to cease processing;
  • independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations under the Personal Data Law and adopted in accordance with it regulatory legal acts, unless otherwise provided by the Personal Data Law or other federal laws.

3.2. The Operator must:

  • provide the subject of personal data, at their request, with information regarding the processing of their personal data;
  • organize the processing of personal data in accordance with the current legislation of the Russian Federation;
  • respond to requests and inquiries from subjects of personal data and their legal representatives in accordance with the requirements of the Personal Data Law;
  • inform the authorized body for the protection of the rights of subjects of personal data, upon request from this body, within 10 days from the date of receipt of such a request;
  • publish or otherwise provide unrestricted access to this Policy regarding the processing of personal data;
  • take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, alteration, blocking, copying, provision, distribution of personal data, and other unlawful actions;
  • li>cease the transfer (distribution, provision, access) of personal data, cease processing and destroy personal data in the manner and cases provided for by the Personal Data Law;

  • fulfill other obligations stipulated by the Personal Data Law.

4. Basic Rights and Obligations of Personal Data Subjects

4.1. Subjects of personal data have the right to:

  • receive information regarding the processing of their personal data, except in cases provided for by federal laws. Information is provided to the subject of personal data by the Operator in an accessible form, and it should not contain personal data related to other subjects of personal data unless there are legal grounds for disclosing such personal data. The list of information and the procedure for its receipt are established by the Personal Data Law;
  • demand from the operator clarification of their personal data, their blocking or destruction in case the personal data are incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, as well as to take legal measures to protect their rights;
  • set a condition of prior consent when processing personal data for the purpose of promoting goods, works, and services on the market;
  • withdraw consent to the processing of personal data, as well as send a demand to cease processing personal data;
  • appeal to the authorized body for the protection of the rights of subjects of personal data or to the court for unlawful actions or inaction of the Operator when processing their personal data;
  • exercise other rights provided for by the legislation of the Russian Federation.

4.2. Subjects of personal data must:

  • provide the Operator with reliable data about themselves;
  • notify the Operator of the clarification (update, change) of their personal data.

4.3. Persons who provided the Operator with unreliable information about themselves or information about another subject of personal data without the consent of the latter bear responsibility in accordance with the legislation of the Russian Federation.

5. Principles of Personal Data Processing

5.1. The processing of personal data is carried out on a lawful and fair basis.

5.2. The processing of personal data is limited to achieving specific, predetermined, and lawful goals. The processing of personal data incompatible with the purposes of collecting personal data is not allowed.

5.3. The combination of databases containing personal data, the processing of which is carried out for purposes incompatible with each other, is not allowed.

5.4. Only personal data that meet the purposes of their processing are subject to processing.

5.5. The content and volume of processed personal data correspond to the stated purposes of processing. Excessive processing of personal data in relation to the stated purposes of their processing is not allowed.

5.6. When processing personal data, the accuracy of personal data, their sufficiency, and, if necessary, relevance to the purposes of processing personal data are ensured. The Operator takes the necessary measures and/or ensures their adoption to remove or clarify incomplete or inaccurate data.

5.7. The storage of personal data is carried out in a form that allows determining the subject of personal data, no longer than required by the purposes of processing personal data, unless the period for storing personal data is established by federal law, a contract to which the subject of personal data is a party, beneficiary, or guarantor. Processed personal data are destroyed or depersonalized upon reaching the purposes of processing or in case of loss of necessity in achieving these purposes unless otherwise provided by federal law.

6. Purposes of Personal Data Processing

Purpose of Processing.

Informing the User by sending emails.

Personal Data

  • Surname
  • name
  • patronymic
  • email address
  • phone numbers

Legal Basis

Federal Law “On Information, Information Technologies and Information Protection” of 27.07.2006 No. 149-FZ

Types of Personal Data Processing

  • Collection, recording, systematization, accumulation, storage, destruction, and depersonalization of personal data.
  • Sending informational emails to the email address.

7. Conditions for Personal Data Processing

7.1. Personal data processing is carried out with the consent of the subject of personal data to the processing of their personal data.

7.2. The processing of personal data is necessary to achieve the goals stipulated by the international treaty of the Russian Federation or the law, for the fulfillment of the functions, powers, and duties imposed by the legislation of the Russian Federation on the operator.

7.3. The processing of personal data is necessary for the administration of justice, the execution of a judicial act, an act of another body, or an official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.

7.4. The processing of personal data is necessary for the performance of a contract to which the subject of personal data is a party, beneficiary, or guarantor, as well as for the conclusion of a contract initiated by the subject of personal data or a contract under which the subject of personal data will be a beneficiary or guarantor.

7.5. The processing of personal data is necessary for the exercise of the rights and legitimate interests of the operator or third parties, or for achieving socially significant goals provided that the rights and freedoms of the subject of personal data are not violated.

7.6. The processing of personal data to which an unlimited number of persons have access or at the request of the subject of personal data is carried out (hereinafter – publicly available personal data).

7.7. The processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.

8. Procedure for Collecting, Storing, Transferring, and Other Types of Personal Data Processing

The security of personal data processed by the Operator is ensured by the implementation of legal, organizational, and technical measures necessary to fully comply with the requirements of the current legislation in the field of personal data protection.

8.1. The Operator ensures the safety of personal data and takes all possible measures to exclude access to personal data by unauthorized persons.

8.2. Personal data of the User will never, under any circumstances, be transferred to third parties, except for cases related to the implementation of current legislation or if the subject of personal data has given consent to the Operator to transfer data to a third party to fulfill obligations under a civil law contract.

8.3. In case of detection of inaccuracies in personal data, the User can update them independently by sending a notification to the Operator’s email address mail@liapunov.com with the note “Updating personal data.”

8.4. The period for processing personal data is determined by achieving the purposes for which the personal data were collected unless another period is established by the contract or current legislation. The User can revoke their consent to the processing of personal data at any time by sending a notification to the Operator via email to the Operator's email address mail@liapunov.com with the note “Revocation of consent to the processing of personal data.”

8.5. All information that is collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by these persons (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data and/or familiarized with these documents. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this paragraph.

8.6. The restrictions established by the subject of personal data on the transfer (except for providing access) and on the processing or conditions of processing (except for access) of personal data allowed for distribution do not apply in cases of processing personal data in state, public, and other public interests determined by the legislation of the Russian Federation.

8.7. The Operator ensures the confidentiality of personal data when processing personal data.

8.8. The Operator stores personal data in a form that allows determining the subject of personal data no longer than required by the purposes of processing personal data unless the period for storing personal data is established by federal law, a contract to which the subject of personal data is a party, beneficiary, or guarantor.

8.9. The condition for the termination of personal data processing can be the achievement of the purposes of personal data processing, the expiration of the consent of the subject of personal data, the withdrawal of consent by the subject of personal data, or the requirement to cease the processing of personal data, as well as the detection of unlawful processing of personal data.

9. List of Actions Performed by the Operator with Received Personal Data

9.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), extracts, uses, transfers (distributes, provides, accesses), depersonalizes, blocks, deletes, and destroys personal data.

9.2. The Operator carries out automated processing of personal data with the receipt and/or transmission of received information via information and telecommunications networks or without them.

10. Cross-border Transfer of Personal Data

10.1. Before starting the cross-border transfer of personal data, the Operator must notify the authorized body for the protection of the rights of subjects of personal data of its intention to carry out the 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 necessary information from the authorities of the foreign state, foreign individuals, foreign legal entities to whom 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 to third parties or distribute personal data without the consent of the subject of personal data unless otherwise provided by federal law.

12. Final Provisions

12.1. The User can receive any clarifications on issues of interest regarding the processing of their personal data by contacting the Operator via email mail@liapunov.com.

12.2. Any changes to the personal data processing policy will be reflected in this document. The policy is valid indefinitely until it is replaced with a new version.

12.3. The current version of the Policy is freely available on the Internet at https://liapunov.com/privacy-policy/.