General Provisions This personal data processing policy is drawn up in accordance with the requirements of the Federal Law No. 152-FZ of 27.07.2006 "On Personal Data" (hereinafter - the Personal Data Law) and defines the procedure for processing personal data and measures to ensure the security of personal data taken by Silent Partner (hereinafter - the Operator).
1.1. The Operator's primary goal and condition for its activities is the observance of human and civil rights and freedoms when processing personal data, including the protection of the rights to privacy, personal and family secrets.
1.2. This Policy of the Operator regarding the processing of personal data (hereinafter - the Policy) applies to all information that the Operator may receive about visitors to the website https://silentpartner.ru/.
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 the processing of personal data (except when processing is necessary to clarify personal data).
2.3. Website - a set of graphic and informational materials, as well as programs for computers and databases, ensuring their availability on the internet at the network address https://silentpartner.ru/.
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 of determining the belonging of personal data to a specific User or another subject of personal data without the use of additional information.
2.6. Processing of personal data - any action (operation) or a set of actions (operations) performed with or without the use of automation tools with personal data, including the collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
2.7. Operator - a state body, municipal body, legal or natural 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 relating directly or indirectly to a specific or identifiable User of the website https://silentpartner.ru.
2.9. Personal data allowed by the subject of personal data for dissemination – personal data access to an unlimited number of persons which is provided by the subject of personal data by giving consent to the processing of personal data allowed by the subject of personal data for dissemination in accordance with the procedure provided by the Personal Data Law (hereinafter - personal data allowed for dissemination).
2.10. User – any visitor to the website https://silentpartner.ru.
2.11. Provision of personal data – actions aimed at disclosing personal data to a specific person or a specific circle of persons.
2.12. Dissemination of personal data – any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or at familiarizing an unlimited number of persons with personal data, including the publication of personal data in the media, posting on information and telecommunication 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 state authority, a foreign individual, or a foreign legal entity.
2.14. Destruction of personal data – any actions resulting in the irreversible destruction of personal data with the impossibility of further restoration of personal data content in the personal data information system and (or) the destruction of personal data material carriers.

1. Main Rights and Responsibilities of the Operator 3.1. The Operator has the right to:

• Receive from the subject of personal data accurate information and/or documents containing personal data;
• In the event of the subject of personal data withdrawing consent to the processing of personal data, the Operator is entitled to continue processing personal data without the consent of the subject of personal data if there are grounds specified in the Personal Data Law;
• Independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations provided by the Personal Data Law and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.

3.2. The Operator is obliged to:

• Provide the subject of personal data, upon 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 inquiries and requests from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
• Report necessary information to the authorized body for the protection of the rights of personal data subjects upon request of this body within 30 days from the date of receipt of such a request;
• Publish or otherwise ensure 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, dissemination, as well as from other unlawful actions regarding personal data;
• Cease the transfer (dissemination, 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 duties as provided by the Personal Data Law.

1. Main Rights and Responsibilities of Personal Data Subjects 4.1. Personal data subjects have the right to:

• Receive information regarding the processing of their personal data, except in cases provided for by federal laws. The information is provided to the personal data subject by the Operator in an accessible form and should not contain personal data relating to other personal data subjects, except in cases where there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
• Require the Operator to clarify, block, or destroy their personal data if the personal data is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, as well as take measures provided by law 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;
• Appeal to the authorized body for the protection of the rights of personal data subjects or in court against unlawful actions or inaction of the Operator when processing their personal data;
• Exercise other rights provided by the legislation of the Russian Federation.

4.2. Personal data subjects are obliged to:

• Provide the Operator with accurate data about themselves;
• Notify the Operator of any clarification (updating, change) of their personal data.

4.3. Persons who have provided the Operator with inaccurate information about themselves, or information about another personal data subject without the consent of the latter, bear responsibility in accordance with the legislation of the Russian Federation.
5. The Operator may process the following User Personal Data:
5.1. Last name, first name, middle name.
5.2. Email address.
5.3. Phone numbers.
5.4. The website also collects and processes anonymized visitor data (including cookies) using internet statistics services (Yandex Metrica, Google Analytics, and others).
5.5. The aforementioned data are collectively referred to as Personal Data in this Policy.
5.6. The Operator does not process special categories of personal data related to race, nationality, political views, religious or philosophical beliefs, or intimate life.
5.7. The processing of personal data allowed for dissemination, from among the special categories of personal data specified in part 1 of Article 10 of the Personal Data Law, is permitted if the prohibitions and conditions stipulated in Article 10.1 of the Personal Data Law are observed.
5.8. The User's consent to the processing of personal data allowed for dissemination is obtained separately from other consents for the processing of their personal data. The conditions stipulated, in particular, by Article 10.1 of the Personal Data Law are observed. The requirements for the content of such consent are established by the authorized body for the protection of the rights of personal data subjects.
5.8.1. The User provides the Operator with consent to the processing of personal data allowed for dissemination directly.
5.8.2. The Operator is obliged to publish information on the conditions of processing, the presence of prohibitions and conditions on the processing by an unlimited number of persons of personal data allowed for dissemination, within three business days from the moment of receiving the User's consent.
5.8.3. The transfer (dissemination, provision, access) of personal data allowed by the subject of personal data for dissemination must be terminated at any time upon the request of the personal data subject. This request must include the last name, first name, middle name (if any), contact information (phone number, email address, or postal address) of the personal data subject, as well as a list of personal data whose processing is to be terminated. The personal data specified in this request may only be processed by the Operator to whom it was sent.
5.8.4. The consent to the processing of personal data allowed for dissemination ceases to be effective from the moment the Operator receives the request specified in paragraph 5.8.3 of this Policy regarding the processing of personal data.
6. Principles of Personal Data Processing
6.1. The processing of personal data is carried out on a lawful and fair basis.
6.2. The processing of personal data is limited to achieving specific, predetermined, and lawful purposes. Processing of personal data incompatible with the purposes of collecting personal data is not allowed.
6.3. Combining databases containing personal data, the processing of which is carried out for purposes incompatible with each other, is not allowed.
6.4. Only personal data that meet the purposes of their processing are subject to processing.
6.5. 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.
6.6. The accuracy, sufficiency, and, where necessary, relevance of personal data in relation to the purposes of personal data processing are ensured during the processing of personal data. The Operator takes the necessary measures and/or ensures that incomplete or inaccurate data are removed or clarified.
6.7. Personal data is stored in a form that allows the identification of the personal data subject, no longer than required by the purposes of personal data processing 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. The processed personal data is destroyed or anonymized upon achieving the purposes of processing or if there is no longer a need to achieve these purposes unless otherwise provided by federal law.
7. Purposes of Personal Data Processing
7.1. The purpose of processing the User's personal data:

• Informing the User by sending emails;
• Conclusion, execution, and termination of civil law contracts;
• Providing the User with access to services, information, and/or materials contained on the website https://silentpartner.ru/.

7.2. The Operator also has the right to send notifications to the User about new products and services, special offers, and various events. The User can always refuse to receive informational messages by sending a letter to the Operator's email address privacy@thismywebsite.com with the note "Refusal of notifications about new products, services, and special offers."
7.3. Anonymized User data collected using internet statistics services is used to collect information about User actions on the site, improve the quality of the site, and its content.
8. Legal Bases for Personal Data Processing
8.1. The legal bases for processing personal data by the Operator are:

• List the regulatory legal acts governing relations related to your activities. For example, if your activities are related to information technology, particularly the creation of websites, you can mention the Federal Law "On Information, Information Technologies and Information Protection" dated 27.07.2006 N 149-FZ;
• The Operator's charter documents;
• Contracts concluded between the operator and the subject of personal data;
• Federal laws and other regulatory legal acts in the field of personal data protection;
• User consents to the processing of their personal data, including the processing of personal data allowed for dissemination.

8.2. The Operator processes the User's personal data only if it is submitted and/or sent by the User independently through special forms located on the website https://silentpartner.ru/ or sent to the Operator via email. By filling out the respective forms and/or sending their personal data to the Operator, the User expresses their consent to this Policy.
8.3. The Operator processes anonymized User data if it is allowed in the User's browser settings (enabled storage of cookies and use of JavaScript technology).
8.4. The subject of personal data independently decides to provide their personal data and gives consent freely, by their own will, and in their own interest.

1. Conditions for Processing Personal Data 9.1. Processing of personal data is carried out with the consent of the subject of personal data to the processing of their personal data.

9.2. Processing of personal data is necessary to achieve the purposes provided by an international treaty of the Russian Federation or law, for the performance of functions, powers, and duties imposed on the operator by the legislation of the Russian Federation.
9.3. Processing of personal data is necessary for the administration of justice, the execution of a judicial act, an act of another body or official to be executed in accordance with the legislation of the Russian Federation on enforcement proceedings.
9.4. 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.
9.5. Processing of personal data is necessary for the exercise of the rights and legitimate interests of the operator or third parties or for the achievement of socially significant goals, provided that this does not violate the rights and freedoms of the subject of personal data.
9.6. Processing of personal data is carried out, access to which is provided by an unlimited number of persons by the subject of personal data or at their request (hereinafter – publicly available personal data).
9.7. Processing of personal data is carried out, which is subject to publication or mandatory disclosure in accordance with federal law.

1. Procedure for Collecting, Storing, Transferring, and Other Types of Processing Personal Data The security of personal data processed by the Operator is ensured through the implementation of legal, organizational, and technical measures necessary to fully comply with the requirements of current legislation in the field of personal data protection.

10.1. The Operator ensures the safety of personal data and takes all possible measures to prevent access to personal data by unauthorized persons.
10.2. The User's personal data will never, under any circumstances, be transferred to third parties, except for cases related to the execution of current legislation or if the subject of personal data has given consent to the Operator to transfer data to a third party for the fulfillment of obligations under a civil law contract.
10.3. If inaccuracies are identified in personal data, the User can update them independently by sending a notification to the Operator's email address privacy@thismywebsite.com marked "Updating Personal Data".
10.4. The processing period for personal data is determined by achieving the purposes for which the personal data was collected unless another period is provided by contract or current legislation. The User may at any time withdraw their consent to the processing of personal data by sending a notification to the Operator via email to the Operator's email address privacy@thismywebsite.com marked "Withdrawal of Consent to the Processing of Personal Data".
10.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by these parties (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data and/or User must independently and timely familiarize themselves with these documents. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this clause.
10.6. Restrictions imposed by the subject of personal data on the transfer (except for providing access) as well as the processing or conditions for processing (except for obtaining access) personal data allowed for dissemination do not apply in cases of processing personal data in the state, public, and other public interests as defined by the legislation of the Russian Federation.
10.7. The Operator ensures the confidentiality of personal data during its processing.

• 10.8. The Operator stores personal data in a form that allows the identification of the subject of personal data, no longer than required by the purposes of personal data processing, 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.

10.8. The Operator stores personal data in a form that allows the identification of the personal data subject, no longer than required by the purposes of personal data processing, 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.
10.9. The condition for terminating the processing of personal data may be the achievement of the purposes of processing personal data, the expiration of the consent of the personal data subject, or the withdrawal of consent by the personal data subject, as well as the identification of unlawful processing of personal data.

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

11.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), extracts, uses, transfers (disseminates, provides, accesses), anonymizes, blocks, deletes, and destroys personal data.
11.2. The Operator performs automated processing of personal data with the receipt and/or transmission of the received information via information and telecommunication networks or without such.

1. Cross-Border Transfer of Personal Data

• 12.1. Before starting the cross-border transfer of personal data, the Operator must ensure that the foreign country to which the transfer of personal data is intended provides reliable protection of the rights of personal data subjects.