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Policy on Personal Data Processing
1. General Provisions

This personal data processing policy is compiled in accordance with the requirements of Federal Law No. 152-FZ "On Personal Data" dated July 27, 2006, and defines the procedure for processing personal data and measures to ensure the security of personal data undertaken by "FINDER GROUP" LLC (hereinafter referred to as the Operator; LLC "FINDER GROUP").

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

1.2. This Operator's policy on personal data processing (hereinafter referred to as the Policy) applies to all information that the Operator may receive about visitors to the website https://fds.agency.


2. Key Terms Used in the Policy

2.1. Automated processing of personal data – processing of personal data using computing technology;

2.2. Blocking of personal data – temporary cessation of personal data processing (except when processing is necessary for personal data clarification);

2.3. Website – a collection of graphical and informational materials, as well as programs for computers and databases, ensuring their availability on the Internet at https://fds.agency;

2.4. Personal data information system – a collection of personal data contained in databases and ensuring their processing through information technology and technical means;

2.5. Depersonalization of personal data – actions that result in the impossibility of determining the ownership of personal data by a specific User or another subject without additional information;

2.6. Processing of personal data – any action (operation) or set of actions (operations) performed using automation tools or without them on personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data;

2.7. Operator – a state authority, municipal authority, legal or physical entity that independently or jointly with others organizes and (or) carries out the processing of personal data and determines the purposes, composition, and 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://fds.agency;

2.9. User – any visitor to the website https://fds.agency;

2.10. Provision of personal data – actions aimed at disclosing personal data to a specific individual or a specific group of individuals;
2.11. Distribution of personal data – any actions aimed at disclosing personal data to an undefined group of individuals (transfer of personal data) or making personal data available to an unlimited group of individuals, including publication of personal data in the media, placement on information and telecommunications networks, or providing access to personal data in any other way;
2.12. Cross-border transfer of personal data – transfer of personal data to the territory of a foreign state, to a foreign state authority, foreign individual, or foreign legal entity;
2.13. Destruction of personal data – any actions that result in the irreversible destruction of personal data, making it impossible to restore the content of personal data in an information system of personal data and/or the destruction of physical media containing personal data.


3. The Operator may process the following personal data of the User

3.1. Surname, first name, patronymic;
3.2. Phone number;
3.3. Email address;
3.4. Social networks.
3.4. The website also collects and processes anonymized data about visitors (including “cookie” files) using internet analytics services (Yandex Metrica, Google Analytics, and others).
3.5. The aforementioned data is collectively referred to as Personal Data throughout the Policy.


4. Purpose of processing personal data

4.1. The purpose of processing the User’s personal data is to conclude, execute, and terminate civil law contracts; to provide the User with access to services, information, and/or materials on the website https://fds.agency; to clarify order details.
4.2. The Operator also has the right to send notifications to the User about new products and services, special offers, and events. The User can always opt out of receiving informational messages by sending a letter to the Operator’s email address info@fds.agency with the subject “Opt-out of notifications about new products, services, and special offers.”
4.3. Anonymized data about Users collected using internet analytics services is used to gather information about the User’s actions on the website, to improve the quality of the website and its content.


5. Legal grounds for processing personal data

5.1. The Operator processes the User’s personal data only if it is filled out and/or submitted by the User independently through special forms located on the website https://fds.agency. By filling out the appropriate forms and/or submitting their personal data to the Operator, the User expresses their consent to this Policy.
5.2. The Operator processes anonymized data about the User if permitted by the User’s browser settings (cookies storage is enabled, and JavaScript technology is used).


6. Procedure for collection, storage, transfer, and other types of processing of personal data

The security of personal data processed by the Operator is ensured by implementing legal, organizational, and technical measures necessary to fully comply with the requirements of applicable legislation in the field of personal data protection.
6.1. The Operator ensures the security of personal data and takes all possible measures to prevent unauthorized access to personal data by unauthorized persons.
6.2. The User’s personal data will never, under any circumstances, be transferred to third parties, except in cases related to compliance with applicable law.
6.3. In case inaccuracies are found in the personal data, the User may update them independently by sending a notification to the Operator’s email address info@fds.agency with the subject “Personal Data Update.”
6.4. The processing period of personal data is unlimited. The User can withdraw their consent to the processing of personal data at any time by sending a notification via email to the Operator’s email address info@fds.agency with the subject “Withdrawal of consent for processing personal data.”


7. Cross-border transfer of personal data

7.1. Before initiating a cross-border transfer of personal data, the Operator must ensure that the foreign country to which the personal data is to be transferred provides reliable protection of the rights of personal data subjects.
7.2. Cross-border transfer of personal data to foreign countries that do not meet the above requirements may only take place with the written consent of the personal data subject for the cross-border transfer of their personal data and/or the performance of a contract in which the personal data subject is a party.


8. Final provisions

8.1. The User can obtain any clarifications on issues concerning the processing of their personal data by contacting the Operator via email at info@fds.agency.
8.2. This document will reflect any changes in the Operator’s personal data processing policy. The Policy is valid indefinitely until replaced by a new version.
It is effective from September 1, 2023.

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