Personal data processing policy

1. General provisions

This document sets out how personal data of users and clients of the OtdelP Service are processed in accordance with Federal Law No. 152-FZ “On Personal Data”. Processing is performed by the Operator whose details appear above. Together with this Policy, the following also apply: Privacy policy; public offer (when paid services are provided); Integration agreement (when the API or widget is connected).

2. Categories of personal data

Depending on how the Service is used, the following may be processed:

• identification data: full name (if provided), email address, phone number;
• account and Service settings data;
• content of messages in chats, integrations and channels connected by the user;
• deal, lead, order and payment data (to the extent needed to perform the contract);
• technical data: IP address, cookies, device and browser information;
• other data voluntarily provided by the user when filling in forms.

3. Purposes of processing

• registration and authentication, granting access to Service features;
• performance of the services agreement (including accepting payment via сервис эквайринга Selfwork (pro.selfwork.ru) — only from individuals when paying through Site forms);
• communicating with the user about use of the Service;
• ensuring the security and operability of the Service;
• keeping accounting and tax records where required by law;
• complying with the laws of the Russian Federation.

4. Legal grounds for processing

Personal data are processed on the basis of the data subject’s consent (including consent expressed by ticking boxes on the payment page and at registration), performance of a contract with the user, and other grounds provided by Articles 6 and 10 of Federal Law No. 152-FZ.

5. Processing operations and retention periods

With respect to personal data, the following may be performed: collection, recording, systematisation, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (provision, access), depersonalisation, blocking, deletion and destruction. Retention periods are determined by the purposes of processing, the need to perform the contract, and legal requirements (including those on accounting documents).

6. Transfer to third parties

The Operator may transfer personal data to contractors acting on instruction or under processing / engagement agreements: hosting provider, email delivery services, payment intermediaries, including сервис эквайринга Selfwork (pro.selfwork.ru), — strictly to the extent necessary to deliver the services. Cross-border transfer may occur when foreign cloud or other services are used; in such cases the Operator follows the requirements of Federal Law No. 152-FZ on cross-border transfer. The current list of foreign recipients should be checked in the latest edition of the documents or with support.

7. Cookies

Cookie use and the consent process are described in the “Cookies” section of the Privacy policy.

8. Rights of the personal data subject

The data subject may obtain information about processing, demand clarification, blocking or destruction of personal data, withdraw consent (where processing is based on consent), and appeal the Operator’s actions to the authorised body for the protection of personal data subjects’ rights or in court.

9. Contacts for personal data matters

Please send requests to the Operator’s email: boris.slesareff@yandex.ru