Privacy and Personal Data Processing Policy

1.1. This Personal Data Processing Policy (hereinafter – the “Policy”) is drawn up in accordance with Federal Law No. 152-FZ of 27.07.2006 “On Personal Data” and other regulatory legal acts of the Russian Federation. The Policy defines the procedure and conditions for processing personal data (PD), measures for their protection, as well as information on the implemented requirements for PD protection. The Operator ensures unrestricted access to this Policy on the Internet.

1.2. The personal data operator is: ITSports LLC, TIN 9731077855, PSRN 1217700165990, Moscow, Pokhodny Proezd 4, Building 1, Floor 4, Room IX, Office 410.

1.3. The Policy applies to all information that the Operator receives about users of the itsports.ru website.

The terms are used in the meanings established by Articles 3 and 9 of Federal Law 152-FZ.

3.1. Personal data not relating to special or biometric data:

– Full name, contact telephone numbers, email addresses;

– Place of work, position (if specified in the form);

– User data collected automatically when using the site: IP address, cookies data, browser information, device and screen resolution, referral source, actions on pages (clicks, pages visited), location data, information from the Yandex.Metrica counter. Such data may be considered personal and require a legal basis and/or consent.

– Handling incoming user requests and inquiries for consultation and feedback;

– Conclusion and performance of contracts;

– Analytics of user actions to improve the site and its functionality (including using Yandex.Metrica);

– Distribution of advertising and news information upon obtaining the user’s prior consent.

– Articles 6 and 9 of Federal Law 152-FZ (consent of the subject, performance of a contract, other grounds provided by law);

– Article 18 of the Federal Law “On Advertising” No. 38-FZ for mailings – prior consent of the addressee is required;

– For cross-border transfer of personal data – notification to Roskomnadzor before the start of transfer (Article 12 of Federal Law 152-FZ).

6.1. Processing is carried out lawfully and fairly, using minimally necessary methods.

6.2. Processing is limited to achieving the declared purposes; processing incompatible with these purposes is not permitted.

6.3. Storage of PD – in a form that allows identification of the subject, no longer than required by the processing purposes.

6.4. Transfer of PD to third parties is possible upon the existence of a legal basis and a commission agreement (the person acting on commission is not obliged to obtain separate consent from the subject).

Collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), blocking, deletion, destruction.

8.1. The site uses cookies and Yandex.Metrica for analytics. The setting of cookies (except strictly technical ones) and the activation of counters are carried out after obtaining the user’s consent via a banner/control panel for cookies, with the option to refuse or change the choice.

8.2. The user can change cookie settings in their browser.

Before the start of cross-border transfer, the Operator notifies Roskomnadzor separately from the notification of PD processing. Roskomnadzor has the right to restrict such transfer.

The Operator, before the start of processing, sends a notification to Roskomnadzor (except in cases provided for by Part 2 of Article 22). In case of changes to information – not later than the 15th day of the month following the month of changes.

The PD subject has the right to:

– Obtain information about the processing of their PD (Articles 14, 18 of Federal Law 152-FZ);

– Withdraw consent (at any time), request clarification, blocking, or destruction of PD;

– Appeal the Operator’s actions to Roskomnadzor or to court.

The Operator takes necessary legal, organizational, and technical measures to protect PD from unauthorized access, destruction, modification, and other unlawful actions (Article 19 of Federal Law 152-FZ).

A responsible person for organizing PD processing is appointed (Article 22.1 of Federal Law 152-FZ).

PD are processed until the purposes are achieved or until consent is withdrawn. After achieving the purpose, data are subject to destruction/anonymization, unless otherwise provided by law (for example, archival storage).

The user can withdraw consent by sending a written statement to the Operator’s address or via an electronic form/personal account (if available). After receiving the withdrawal, the Operator ceases processing unless there are other legal grounds (subparagraphs 2–11 of Part 1 of Article 6, Part 2 of Article 10, Part 2 of Article 11 of Federal Law 152-FZ).

The Policy may be amended. The new edition comes into force from the moment of its placement on the site.