Personal Data Processing Policy

This document is an informational translation. The legally binding original is in Russian: Политика обработки персональных данных (RU). In the event of any discrepancy, the Russian version takes precedence.

1. General Provisions

1.1. This Personal Data Processing Policy (hereinafter — "Policy") has been developed in accordance with Federal Law No. 152-FZ of 27.07.2006 "On Personal Data" and other regulatory legal acts of the Russian Federation in the field of personal data protection.

1.2. The personal data operator is Individual Entrepreneur Isa Aluevich Khakimov (hereinafter — "Operator"), TIN 201502363823, PSRNIE 315203600026869, operating under the commercial designation "VP Studio" (vpstudio.pro).

1.3. The Policy applies to all personal data that the Operator may receive about users of the website vpstudio.pro, clients, customers and other persons who contact the Operator.

1.4. Using the website vpstudio.pro, submitting forms or otherwise interacting with the Operator constitutes the user's acceptance of the terms of this Policy. If the user does not agree, they must refrain from providing their personal data to the Operator.

2. Key Definitions

• Personal data — any information relating to a directly or indirectly identified natural person.
• Operator — the person who organises and/or carries out the processing of personal data.
• Data subject — the natural person whose personal data is being processed.
• Processing of personal data — any action performed with personal data: collection, recording, systematisation, accumulation, storage, clarification, use, transfer, anonymisation, blocking, deletion and destruction.
• Website — the internet resource vpstudio.pro and all its sections.

3. Personal Data Processed

3.1. The Operator processes the following categories of personal data:

When filling out forms on the website and contacting via email:

• Name or full name (if provided);
• Email address;
• Phone number (if voluntarily provided);
• Telegram identifier (if voluntarily provided);
• Other information voluntarily shared in a free-text enquiry field.

When purchasing a licence and activating software products:

• Name or organisation name;
• Email address;
• A unique technical device identifier ("computer code"), used exclusively for binding the licence;
• Payment information (transmitted directly to the payment operator and not received by the Operator in full).

When entering into custom development contracts:

• Full name; contact details;
• Contract and payment details (for legal entities and individual entrepreneurs — name, TIN, PSRN/PSRNIE, address, banking details).

3.2. The Operator does not request special categories of personal data (racial origin, political views, health status, etc.) or biometric data.

3.3. The Operator does not request data of children (persons under 14 years of age) and does not direct its services at minors.

4. Purposes of Personal Data Processing

4.1. Personal data is processed exclusively for the following purposes:

• responding to user enquiries received via website forms, email and messaging services;
• selling and activating licences for VP Studio software products;
• entering into and performing custom software development contracts;
• complying with Russian Federation legislative requirements;
• informing about order status, licence activation and product updates;
• receiving feedback on the performance of software products;
• protecting the rights and legitimate interests of the Operator.

4.2. The Operator does not use personal data for marketing profiling, behavioural targeting or automated decision-making that produces legal consequences for the data subject.

5. Legal Grounds for Processing

The Operator processes personal data on the following grounds:

• consent of the data subject (Art. 6, Part 1, Clause 1 of Law No. 152-FZ);
• necessity for the performance of a contract to which the data subject is a party (Art. 6, Part 1, Clause 5 of Law No. 152-FZ);
• necessity for exercising the rights and legitimate interests of the Operator (Art. 6, Part 1, Clause 7 of Law No. 152-FZ);
• fulfilment of obligations established by Russian Federation legislation (tax and accounting law).

6. Processing Procedure and Conditions

6.1. Personal data is processed both using automated means and without such means.

6.2. Actions performed with personal data: collection, recording, systematisation, accumulation, storage, clarification, use, transfer, blocking, deletion and destruction.

6.3. Personal data is stored on servers and devices physically located in the Russian Federation, in compliance with the localisation requirement (Part 5, Art. 18 of Law No. 152-FZ).

7. Transfer of Personal Data to Third Parties

7.1. The Operator does not transfer personal data to third parties, except in cases expressly provided for by law or this Policy.

7.2. Personal data may be transferred to: payment operators and banks — to the extent necessary to accept payment; Russian Federation state authorities — in cases provided for by law; other parties — exclusively with the prior consent of the data subject.

7.3. Cross-border transfer of personal data is not carried out by the Operator.

8. Retention and Storage Periods

8.1. Personal data is processed for the period necessary to achieve the purposes of processing, or until the data subject withdraws their consent.

8.2. Documents subject to mandatory retention periods under law (accounting and tax documents) are retained for the periods established by law.

8.3. Upon expiry of the processing period, personal data is subject to destruction or anonymisation.

9. Security Measures

9.1. The Operator applies legal, organisational and technical measures to ensure the security of personal data in accordance with Articles 18.1 and 19 of Law No. 152-FZ:

• restricting the number of persons who have access to data;
• using information security and encryption tools;
• regular creation of backups;
• keeping records of personal data storage media;
• monitoring the effectiveness of security measures taken.

10. Rights of Data Subjects

10.1. The data subject has the right to:

• receive information about the fact of processing their personal data, the purposes, methods and retention periods;
• request correction, blocking or destruction of their personal data;
• withdraw consent to personal data processing at any time;
• appeal to Roskomnadzor or to a court to protect their rights.

10.2. To exercise their rights, the data subject may contact info@vpstudio.pro with the subject line "Personal Data". A response will be sent within 30 days.

11. Use of Cookies

The website vpstudio.pro uses cookies to ensure correct operation and to collect anonymised visit statistics (Yandex.Metrica). The user may configure their browser to block cookies, but this may limit the functionality of the website.

12. Policy Updates

12.1. The Operator may make changes to this Policy. The current version is always available at vpstudio.pro. Material changes take effect from the moment the new version is published.

13. Contact Information

For all questions related to personal data processing:

Individual Entrepreneur Isa Aluevich Khakimov
TIN 201502363823 · PSRNIE 315203600026869 · Chechen Republic
Email: info@vpstudio.pro · Telegram: @VP_studio
Person responsible for organising personal data processing — IE Khakimov I.A.