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Personal Data Processing Policy
1. General Provisions
This personal data processing policy has been prepared in accordance with the requirements of Federal Law No. 152-FZ of July 27, 2006, On Personal Data (hereinafter, the Personal Data Law), and defines the procedure for processing personal data and the measures taken by Exima PRO LLC (hereinafter, the Operator) to ensure personal data security.
1.1. The Operator considers respect for human and civil rights and freedoms in the processing of personal data, including the protection of the rights to privacy and personal and family confidentiality, to be a primary objective and an essential condition of its activities.
1.2. This Operator’s personal data processing policy (hereinafter, the Policy) applies to all information that the Operator may obtain about visitors to https://exima.pro.
2. Key Terms Used in the Policy
2.1. Automated processing of personal data means processing personal data using computer technology.
2.2. Blocking of personal data means temporarily suspending the processing of personal data, except where processing is required to clarify personal data.
2.3. Website means a collection of graphic and informational materials, computer programs, and databases that make them available online at https://exima.pro.
2.4. Personal data information system means a collection of personal data contained in databases and the information technologies and technical means used to process such data.
2.5. Anonymization of personal data means actions that make it impossible, without additional information, to determine whether personal data belongs to a particular User or another personal data subject.
2.6. Processing of personal data means any action or set of actions performed with or without automation tools in relation to personal data, including collection, recording, organization, accumulation, storage, clarification (updating or modification), retrieval, use, transfer (distribution, provision, or access), anonymization, blocking, deletion, and destruction of personal data.
2.7. Operator means a state or municipal authority, legal entity, or individual that independently or jointly with others organizes and/or carries out the processing of personal data and determines the purposes of processing, the personal data to be processed, and the actions performed with personal data.
2.8. Personal data means any information relating directly or indirectly to an identified or identifiable User of https://exima.pro.
2.9. Personal data permitted by the personal data subject for distribution means personal data to which the subject has granted access to an unlimited number of persons by consenting to its processing for distribution in the manner established by the Personal Data Law (hereinafter, personal data permitted for distribution).
2.10. User means any visitor to https://exima.pro.
2.11. Provision of personal data means actions intended to disclose personal data to a specific person or a specific group of persons.
2.12. Distribution of personal data means any actions intended to disclose personal data to an indefinite group of persons or to make personal data available to an unlimited group of persons, including publication in mass media, placement in information and telecommunications networks, or providing access by any other means.
2.13. Cross-border transfer of personal data means the transfer of personal data to the territory of a foreign state, to a foreign state authority, foreign individual, or foreign legal entity.
2.14. Destruction of personal data means actions resulting in the irreversible destruction of personal data so that its content cannot be restored in a personal data information system and/or the destruction of physical media containing personal data.
3. Key Rights and Obligations of the Operator
3.1. The Operator has the right to:
— obtain accurate information and/or documents containing personal data from the personal data subject;
— if the personal data subject withdraws consent to processing or submits a request to stop processing, continue processing without the subject’s consent where grounds specified by the Personal Data Law apply;
— independently determine the composition and list of measures necessary and sufficient to fulfill the obligations established by the Personal Data Law and regulations adopted pursuant to it, unless otherwise provided by the Personal Data Law or other federal laws.
3.2. The Operator must:
— provide the personal data subject, upon request, with information concerning the processing of their personal data;
— organize personal data processing in accordance with the applicable laws of the Russian Federation;
— respond to requests and inquiries from personal data subjects and their legal representatives in accordance with the Personal Data Law;
— provide the competent authority for the protection of personal data subjects’ rights with requested information within 10 days of receiving such a request;
— publish or otherwise provide unrestricted access to this Policy;
— take legal, organizational, and technical measures to protect personal data against unlawful or accidental access, destruction, alteration, blocking, copying, provision, distribution, and other unlawful actions;
— stop the transfer, distribution, provision, or access to personal data, stop processing, and destroy personal data in the manner and cases prescribed by the Personal Data Law;
— fulfill other obligations established by the Personal Data Law.
4. Key Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects have the right to:
— receive information concerning the processing of their personal data, except in cases provided for by federal law. The Operator must provide the information in an accessible form, and it must not contain personal data relating to other subjects unless there are lawful grounds for disclosure. 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 it is incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the stated processing purpose, and take measures provided by law to protect their rights;
— require prior consent for the processing of personal data for the purpose of promoting goods, works, and services;
— withdraw consent to personal data processing and request that processing be stopped;
— appeal unlawful actions or omissions by the Operator in processing personal data to the competent authority for protecting personal data subjects’ rights or to a court;
— exercise other rights provided by the laws of the Russian Federation.
4.2. Personal data subjects must:
— provide the Operator with accurate information about themselves;
— inform the Operator when their personal data is clarified, updated, or changed.
4.3. Persons who provide the Operator with false information about themselves or information about another personal data subject without that subject’s consent are liable under the laws of the Russian Federation.
5. Principles of Personal Data Processing
5.1. Personal data is processed lawfully and fairly.
5.2. Personal data processing is limited to specific, predetermined, and lawful purposes. Processing incompatible with the purposes for which personal data was collected is not permitted.
5.3. Databases containing personal data processed for incompatible purposes may not be combined.
5.4. Only personal data that meets the purposes of processing may be processed.
5.5. The content and volume of processed personal data must correspond to the stated purposes. Excessive processing in relation to those purposes is not permitted.
5.6. The accuracy, sufficiency, and, where necessary, relevance of personal data to the processing purposes must be ensured. The Operator takes or ensures the necessary measures to delete or clarify incomplete or inaccurate data.
5.7. Personal data is stored in a form that permits identification of the personal data subject for no longer than required by the processing purposes, unless a retention period is established by federal law or an agreement to which the subject is a party, beneficiary, or guarantor. Processed personal data is destroyed or anonymized once the processing purposes have been achieved or the need to achieve them no longer exists, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing
Purpose of processing
informing the User by sending emails
Personal data
philosophical beliefs
Legal grounds
Federal Law No. 149-FZ of July 27, 2006, On Information, Information Technologies and Information Protection
Types of personal data processing
transfer of personal data
7. Conditions for Personal Data Processing
7.1. Personal data is processed with the consent of the personal data subject.
7.2. Processing is necessary to achieve purposes provided for by an international treaty of the Russian Federation or by law, or to exercise functions, powers, and duties assigned to the Operator by Russian law.
7.3. Processing is necessary for the administration of justice or enforcement of a judicial act or an act of another authority or official subject to enforcement under Russian enforcement proceedings law.
7.4. Processing is necessary to perform an agreement to which the personal data subject is a party, beneficiary, or guarantor, or to enter into an agreement at the subject’s initiative or an agreement under which the subject will be a beneficiary or guarantor.
7.5. Processing is necessary to exercise the rights and legitimate interests of the Operator or third parties, or to achieve socially significant goals, provided that the rights and freedoms of the personal data subject are not violated.
7.6. Personal data made available to an unlimited number of persons by the subject or at the subject’s request is processed (publicly available personal data).
7.7. Personal data subject to publication or mandatory disclosure under federal law is processed.
8. Collection, Storage, Transfer, and Other Processing of Personal Data
The security of personal data processed by the Operator is ensured through legal, organizational, and technical measures necessary to fully comply with applicable personal data protection laws.
8.1. The Operator ensures the security of personal data and takes all possible measures to prevent unauthorized access.
8.2. The User’s personal data will not be transferred to third parties under any circumstances, except where required by applicable law or where the personal data subject has consented to a transfer to a third party for the performance of obligations under a civil-law agreement.
8.3. If inaccuracies are identified, the User may update their personal data by emailing the Operator at privacy@thismywebsite.com with the subject line “Personal Data Update.”
8.4. The processing period is determined by the achievement of the purposes for which the personal data was collected, unless another period is established by an agreement or applicable law.
The User may withdraw consent at any time by emailing the Operator at privacy@thismywebsite.com with the subject line “Withdrawal of Consent to Personal Data Processing.”
8.5. Information collected by third-party services, including payment systems, communication providers, and other service providers, is stored and processed by those parties under their user agreements and privacy policies. The personal data subject must review the relevant documents. The Operator is not responsible for the actions of third parties, including the service providers referred to in this clause.
8.6. Restrictions established by the personal data subject on transfer, other than providing access, or on the processing or processing conditions, other than obtaining access, of personal data permitted for distribution do not apply where personal data is processed in state, public, or other public interests defined by Russian law.
8.7. The Operator maintains the confidentiality of personal data during processing.
8.8. The Operator stores personal data in a form that permits identification of the subject for no longer than required by the processing purposes, unless a retention period is established by federal law or an agreement to which the subject is a party, beneficiary, or guarantor.
8.9. Processing may end when its purposes are achieved, the subject’s consent expires, the subject withdraws consent or requests that processing stop, or unlawful processing is identified.
9. Actions Performed by the Operator with Personal Data
9.1. The Operator collects, records, organizes, accumulates, stores, clarifies (updates or modifies), retrieves, uses, transfers (distributes, provides, or grants access to), anonymizes, blocks, deletes, and destroys personal data.
9.2. The Operator carries out automated processing of personal data with or without receiving and/or transmitting the resulting information through information and telecommunications networks.
10. Cross-Border Transfer of Personal Data
10.1. Before beginning cross-border transfers, the Operator must notify the competent authority for the protection of personal data subjects’ rights of its intention to carry out such transfers. This notification is submitted separately from the notification of intent to process personal data.
10.2. Before submitting the above notification, the Operator must obtain the relevant information from the foreign state authorities, foreign individuals, or foreign legal entities to which personal data is to be transferred.
11. Confidentiality of Personal Data
The Operator and other persons with access to personal data must not disclose it to third parties or distribute it without the subject’s consent unless otherwise provided by federal law.
12. Final Provisions
12.1. The User may obtain clarification on any questions concerning the processing of their personal data by contacting the Operator at privacy@thismywebsite.com.
12.2. Any changes to the Operator’s personal data processing policy will be reflected in this document. The Policy remains in effect indefinitely until replaced by a new version.
12.3. The current version of the Policy is publicly available online at https://exima.pro/pilicy.
1. General Provisions
This personal data processing policy has been prepared in accordance with the requirements of Federal Law No. 152-FZ of July 27, 2006, On Personal Data (hereinafter, the Personal Data Law), and defines the procedure for processing personal data and the measures taken by Exima PRO LLC (hereinafter, the Operator) to ensure personal data security.
1.1. The Operator considers respect for human and civil rights and freedoms in the processing of personal data, including the protection of the rights to privacy and personal and family confidentiality, to be a primary objective and an essential condition of its activities.
1.2. This Operator’s personal data processing policy (hereinafter, the Policy) applies to all information that the Operator may obtain about visitors to https://exima.pro.
2. Key Terms Used in the Policy
2.1. Automated processing of personal data means processing personal data using computer technology.
2.2. Blocking of personal data means temporarily suspending the processing of personal data, except where processing is required to clarify personal data.
2.3. Website means a collection of graphic and informational materials, computer programs, and databases that make them available online at https://exima.pro.
2.4. Personal data information system means a collection of personal data contained in databases and the information technologies and technical means used to process such data.
2.5. Anonymization of personal data means actions that make it impossible, without additional information, to determine whether personal data belongs to a particular User or another personal data subject.
2.6. Processing of personal data means any action or set of actions performed with or without automation tools in relation to personal data, including collection, recording, organization, accumulation, storage, clarification (updating or modification), retrieval, use, transfer (distribution, provision, or access), anonymization, blocking, deletion, and destruction of personal data.
2.7. Operator means a state or municipal authority, legal entity, or individual that independently or jointly with others organizes and/or carries out the processing of personal data and determines the purposes of processing, the personal data to be processed, and the actions performed with personal data.
2.8. Personal data means any information relating directly or indirectly to an identified or identifiable User of https://exima.pro.
2.9. Personal data permitted by the personal data subject for distribution means personal data to which the subject has granted access to an unlimited number of persons by consenting to its processing for distribution in the manner established by the Personal Data Law (hereinafter, personal data permitted for distribution).
2.10. User means any visitor to https://exima.pro.
2.11. Provision of personal data means actions intended to disclose personal data to a specific person or a specific group of persons.
2.12. Distribution of personal data means any actions intended to disclose personal data to an indefinite group of persons or to make personal data available to an unlimited group of persons, including publication in mass media, placement in information and telecommunications networks, or providing access by any other means.
2.13. Cross-border transfer of personal data means the transfer of personal data to the territory of a foreign state, to a foreign state authority, foreign individual, or foreign legal entity.
2.14. Destruction of personal data means actions resulting in the irreversible destruction of personal data so that its content cannot be restored in a personal data information system and/or the destruction of physical media containing personal data.
3. Key Rights and Obligations of the Operator
3.1. The Operator has the right to:
— obtain accurate information and/or documents containing personal data from the personal data subject;
— if the personal data subject withdraws consent to processing or submits a request to stop processing, continue processing without the subject’s consent where grounds specified by the Personal Data Law apply;
— independently determine the composition and list of measures necessary and sufficient to fulfill the obligations established by the Personal Data Law and regulations adopted pursuant to it, unless otherwise provided by the Personal Data Law or other federal laws.
3.2. The Operator must:
— provide the personal data subject, upon request, with information concerning the processing of their personal data;
— organize personal data processing in accordance with the applicable laws of the Russian Federation;
— respond to requests and inquiries from personal data subjects and their legal representatives in accordance with the Personal Data Law;
— provide the competent authority for the protection of personal data subjects’ rights with requested information within 10 days of receiving such a request;
— publish or otherwise provide unrestricted access to this Policy;
— take legal, organizational, and technical measures to protect personal data against unlawful or accidental access, destruction, alteration, blocking, copying, provision, distribution, and other unlawful actions;
— stop the transfer, distribution, provision, or access to personal data, stop processing, and destroy personal data in the manner and cases prescribed by the Personal Data Law;
— fulfill other obligations established by the Personal Data Law.
4. Key Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects have the right to:
— receive information concerning the processing of their personal data, except in cases provided for by federal law. The Operator must provide the information in an accessible form, and it must not contain personal data relating to other subjects unless there are lawful grounds for disclosure. 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 it is incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the stated processing purpose, and take measures provided by law to protect their rights;
— require prior consent for the processing of personal data for the purpose of promoting goods, works, and services;
— withdraw consent to personal data processing and request that processing be stopped;
— appeal unlawful actions or omissions by the Operator in processing personal data to the competent authority for protecting personal data subjects’ rights or to a court;
— exercise other rights provided by the laws of the Russian Federation.
4.2. Personal data subjects must:
— provide the Operator with accurate information about themselves;
— inform the Operator when their personal data is clarified, updated, or changed.
4.3. Persons who provide the Operator with false information about themselves or information about another personal data subject without that subject’s consent are liable under the laws of the Russian Federation.
5. Principles of Personal Data Processing
5.1. Personal data is processed lawfully and fairly.
5.2. Personal data processing is limited to specific, predetermined, and lawful purposes. Processing incompatible with the purposes for which personal data was collected is not permitted.
5.3. Databases containing personal data processed for incompatible purposes may not be combined.
5.4. Only personal data that meets the purposes of processing may be processed.
5.5. The content and volume of processed personal data must correspond to the stated purposes. Excessive processing in relation to those purposes is not permitted.
5.6. The accuracy, sufficiency, and, where necessary, relevance of personal data to the processing purposes must be ensured. The Operator takes or ensures the necessary measures to delete or clarify incomplete or inaccurate data.
5.7. Personal data is stored in a form that permits identification of the personal data subject for no longer than required by the processing purposes, unless a retention period is established by federal law or an agreement to which the subject is a party, beneficiary, or guarantor. Processed personal data is destroyed or anonymized once the processing purposes have been achieved or the need to achieve them no longer exists, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing
Purpose of processing
informing the User by sending emails
Personal data
philosophical beliefs
Legal grounds
Federal Law No. 149-FZ of July 27, 2006, On Information, Information Technologies and Information Protection
Types of personal data processing
transfer of personal data
7. Conditions for Personal Data Processing
7.1. Personal data is processed with the consent of the personal data subject.
7.2. Processing is necessary to achieve purposes provided for by an international treaty of the Russian Federation or by law, or to exercise functions, powers, and duties assigned to the Operator by Russian law.
7.3. Processing is necessary for the administration of justice or enforcement of a judicial act or an act of another authority or official subject to enforcement under Russian enforcement proceedings law.
7.4. Processing is necessary to perform an agreement to which the personal data subject is a party, beneficiary, or guarantor, or to enter into an agreement at the subject’s initiative or an agreement under which the subject will be a beneficiary or guarantor.
7.5. Processing is necessary to exercise the rights and legitimate interests of the Operator or third parties, or to achieve socially significant goals, provided that the rights and freedoms of the personal data subject are not violated.
7.6. Personal data made available to an unlimited number of persons by the subject or at the subject’s request is processed (publicly available personal data).
7.7. Personal data subject to publication or mandatory disclosure under federal law is processed.
8. Collection, Storage, Transfer, and Other Processing of Personal Data
The security of personal data processed by the Operator is ensured through legal, organizational, and technical measures necessary to fully comply with applicable personal data protection laws.
8.1. The Operator ensures the security of personal data and takes all possible measures to prevent unauthorized access.
8.2. The User’s personal data will not be transferred to third parties under any circumstances, except where required by applicable law or where the personal data subject has consented to a transfer to a third party for the performance of obligations under a civil-law agreement.
8.3. If inaccuracies are identified, the User may update their personal data by emailing the Operator at privacy@thismywebsite.com with the subject line “Personal Data Update.”
8.4. The processing period is determined by the achievement of the purposes for which the personal data was collected, unless another period is established by an agreement or applicable law.
The User may withdraw consent at any time by emailing the Operator at privacy@thismywebsite.com with the subject line “Withdrawal of Consent to Personal Data Processing.”
8.5. Information collected by third-party services, including payment systems, communication providers, and other service providers, is stored and processed by those parties under their user agreements and privacy policies. The personal data subject must review the relevant documents. The Operator is not responsible for the actions of third parties, including the service providers referred to in this clause.
8.6. Restrictions established by the personal data subject on transfer, other than providing access, or on the processing or processing conditions, other than obtaining access, of personal data permitted for distribution do not apply where personal data is processed in state, public, or other public interests defined by Russian law.
8.7. The Operator maintains the confidentiality of personal data during processing.
8.8. The Operator stores personal data in a form that permits identification of the subject for no longer than required by the processing purposes, unless a retention period is established by federal law or an agreement to which the subject is a party, beneficiary, or guarantor.
8.9. Processing may end when its purposes are achieved, the subject’s consent expires, the subject withdraws consent or requests that processing stop, or unlawful processing is identified.
9. Actions Performed by the Operator with Personal Data
9.1. The Operator collects, records, organizes, accumulates, stores, clarifies (updates or modifies), retrieves, uses, transfers (distributes, provides, or grants access to), anonymizes, blocks, deletes, and destroys personal data.
9.2. The Operator carries out automated processing of personal data with or without receiving and/or transmitting the resulting information through information and telecommunications networks.
10. Cross-Border Transfer of Personal Data
10.1. Before beginning cross-border transfers, the Operator must notify the competent authority for the protection of personal data subjects’ rights of its intention to carry out such transfers. This notification is submitted separately from the notification of intent to process personal data.
10.2. Before submitting the above notification, the Operator must obtain the relevant information from the foreign state authorities, foreign individuals, or foreign legal entities to which personal data is to be transferred.
11. Confidentiality of Personal Data
The Operator and other persons with access to personal data must not disclose it to third parties or distribute it without the subject’s consent unless otherwise provided by federal law.
12. Final Provisions
12.1. The User may obtain clarification on any questions concerning the processing of their personal data by contacting the Operator at privacy@thismywebsite.com.
12.2. Any changes to the Operator’s personal data processing policy will be reflected in this document. The Policy remains in effect indefinitely until replaced by a new version.
12.3. The current version of the Policy is publicly available online at https://exima.pro/pilicy.