1. General Provisions

This personal data processing policy has been developed in accordance with the requirements of Federal Law No. 152-FZ of 27.07.2006 "On Personal Data" (hereinafter referred to as the "Personal Data Law") and defines the procedure for processing personal data and the measures to ensure the security of personal data taken by LLC "OCTO UNIT" (hereinafter referred to as the "Operator").

1.1. The Operator's primary goal and condition for carrying out its activities is the observance of the rights and freedoms of individuals and citizens in the processing of their personal data, including the protection of the right to privacy, personal, and family secrets.

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 may receive about visitors to the website https://octounit.ru.

2. Key Terms 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 personal data processing (except in cases where processing is necessary for clarification of personal data).

2.3. Website – a collection of graphical and informational materials, as well as computer programs and databases ensuring their availability on the Internet at the network address https://octounit.ru.

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

2.5. Anonymization of personal data – actions that result in the inability to determine the affiliation of personal data to a specific User or other subject of personal data without using additional information.

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

2.7. Operator – a state body, municipal body, legal entity, or individual that independently or jointly with others organizes and/or carries out the processing of personal data, as well as determines the purposes of personal data processing, the composition of personal data to be processed, and the actions (operations) performed with personal data.

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

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

2.10. User – any visitor to the website https://octounit.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. Distribution of personal data – any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or at making personal data available to an unlimited number of persons, including publication in the media, placement 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 an authority of a foreign state, 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 inability to further restore the content of personal data in the personal data information system and/or resulting in the destruction of tangible personal data carriers.

3. Main 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 case of withdrawal of consent, as well as upon submission of a request to cease processing personal data, provided 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 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;
— Notify the authorized body for the protection of the rights of subjects of personal data upon request within 10 days from the date of receipt of such a request;
— Publish or otherwise ensure unrestricted access to this Policy regarding personal data processing;
— Take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision, distribution, as well as from other illegal actions concerning personal data;
— 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 prescribed by the Personal Data Law.

4. Main Rights and Obligations of Personal Data Subjects

4.1. Personal data subjects have the right to:
— Obtain information regarding the processing of their personal data, except in cases provided by federal laws. The information is provided to the personal data subject by the Operator in an accessible form and must not contain personal data relating to other subjects of personal data, except when 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 their personal data, block, or destroy it if the personal data is incomplete, outdated, inaccurate, illegally obtained, or not necessary for the declared processing purpose, as well as take measures provided by law to protect their rights;
— Set conditions for prior consent in processing personal data for market promotion of goods, works, and services;
— Withdraw consent to personal data processing, as well as submit a request to cease processing personal data;
— File complaints with the authorized body for the protection of personal data subjects or in court regarding unlawful actions or inactions of the Operator in 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 reliable data about themselves;
— Inform the Operator about the clarification (updating, changing) of their personal data.

4.3. Persons who provided the Operator with false information about themselves, or information about another personal data subject without the latter's consent, 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, predefined, and lawful purposes. The processing of personal data that is incompatible with the purposes of data collection is not allowed.

5.3. It is not allowed to combine databases containing personal data if the processing purposes of such data are incompatible with each other.

5.4. Only personal data that meets the processing objectives is subject to processing.

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

5.6. When processing personal data, accuracy, sufficiency, and, where necessary, relevance of the data concerning the purposes of processing are ensured. The Operator takes necessary measures and/or ensures their implementation for deleting or updating incomplete or inaccurate data.

5.7. The storage of personal data is carried out in a form that allows the identification of the subject of personal data for no longer than required for the purposes of processing, unless a different retention period is established by federal law, a contract, or an agreement to which the personal data subject is a party, beneficiary, or guarantor. Processed personal data is destroyed or anonymized upon achieving the processing objectives or when the need to achieve these objectives is lost, unless otherwise provided by federal law.

6. Purposes of Personal Data Processing
Purpose of Processing: Informing the User by sending emails.
Personal Data: Surname, first name, patronymic, email address, phone numbers.
Legal Basis: Federal Law "On Information, Information Technologies, and Information Protection" No. 149-FZ of 27.07.2006.
Types of Personal Data Processing: 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 personal data subject.

7.2. Personal data processing is necessary to achieve the purposes stipulated by an international treaty of the Russian Federation or by law, for the performance of functions, powers, and duties assigned to the Operator under Russian legislation.

7.3. Personal data processing is necessary for the administration of justice, the execution of a judicial act, or an act of another authority or official subject to execution under Russian legislation on enforcement proceedings.

7.4. Personal data processing is necessary for the execution of a contract in which the personal data subject is a party, beneficiary, or guarantor, as well as for concluding a contract at the initiative of the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor.

7.5. Personal data processing is necessary for the realization of the Operator's or third parties' rights and legitimate interests or for achieving socially significant objectives, provided that this does not infringe upon the rights and freedoms of the personal data subject.

7.6. Processing of personal data that is publicly available or has been made publicly available by the personal data subject at their request (hereinafter referred to as "publicly available personal data") is carried out.

7.7. Processing of personal data subject to publication or mandatory disclosure under federal law is carried out.

8. Procedure for the Collection, Storage, Transfer, and Other Types of Personal Data Processing
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 current legislation in the field of personal data protection.

8.1. The Operator ensures the security of personal data and takes all possible measures to prevent unauthorized access to personal data.

8.2. The User’s personal data will never, under any circumstances, be transferred to third parties, except in cases related to compliance with current legislation or if the personal data subject has given consent to the Operator for transferring data to a third party to fulfill obligations under a civil law contract.

8.3. If inaccuracies in personal data are identified, the User can update them independently by sending a notification to the Operator’s email address info@octounit.ru with the subject line “Personal Data Update.”

8.4. The period of personal data processing is determined by the achievement of the purposes for which the personal data was collected unless otherwise provided by contract or current legislation. The User may revoke their consent to the processing of personal data at any time by sending a notification to the Operator via email at info@octounit.ru with the subject line “Revocation of Consent to Personal Data Processing.”

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

8.6. Restrictions imposed by the personal data subject on the transfer (except for granting access) and processing or conditions of processing (except for access) of personal data authorized for distribution do not apply in cases where the processing of personal data is carried out in state, public, or other public interests as defined by Russian legislation.

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

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

8.9. The processing of personal data may be terminated upon achieving the purposes of processing, expiration of the personal data subject’s consent, revocation of consent by the personal data subject, a request to cease processing, or the identification of unlawful processing of personal data.

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

9.1. The Operator performs the collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, usage, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.

9.2. The Operator carries out automated processing of personal data with the receipt and/or transfer of the obtained information via information and telecommunication networks or without such transmission.

10. Cross-Border Transfer of Personal Data

10.1. Before engaging in cross-border transfer of personal data, the Operator must notify the authorized body for the protection of personal data subjects' rights about its intention to carry out such a transfer (this notification is submitted separately from the notification of intent to process personal data).

10.2. Prior to submitting the aforementioned notification, the Operator must obtain the necessary information from foreign government authorities, foreign individuals, or 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 are obligated not to disclose or distribute personal data to third parties without the consent of the personal data subject, unless otherwise required by federal law.

12. Final Provisions
12.1. The User may request any clarification on matters related to the processing of their personal data by contacting the Operator via email at info@octounit.ru.

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 it is replaced by a new version.

12.3. The current version of the Policy is freely available on the Internet at https://octounit.ru/#popup:privacyen