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Personal Data Processing Policy

This is a translation of the Russian version; in case of discrepancy, the Russian version prevails.

The procedure for processing personal data and the measures to ensure its security taken by Sole Proprietor V. S. Vasilev in accordance with Federal Law No. 152-FZ.

Operator: Sole Proprietor Vladimir Stanislavovich Vasilev

Taxpayer ID (INN): 710707425317 · Registration number (OGRNIP): 319715400074092

Address: 300002, Tula Region, Tula, Galkina Street, building 10, apartment 206

Email: manager@byeroutine.com

1. General provisions

This personal data processing policy has been drawn up in accordance with the requirements of Federal Law No. 152-FZ of 27 July 2006 “On Personal Data” (hereinafter - the Personal Data Law) and sets out the procedure for processing personal data and the measures to ensure the security of personal data taken by Sole Proprietor Vladimir Stanislavovich Vasilev (hereinafter - the Operator).

1.1. The Operator's most important goal and condition for carrying out its activities is respect for the rights and freedoms of a person and citizen when processing their personal data, including protection of the rights to privacy and to personal and family secrets.

1.2. This Operator's policy on the processing of personal data (hereinafter - the Policy) applies to all information that the Operator may obtain about visitors to the website https://byeroutine.com.

1.3. The operator of personal data is:

Sole Proprietor Vladimir Stanislavovich Vasilev

Taxpayer ID (INN): 710707425317

Registration number (OGRNIP): 319715400074092

Registered address: 300002, Tula Region, the city of Tula, Galkina Street, building 10, apartment 206

Email address: manager@byeroutine.com

2. Basic 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 suspension of the processing of personal data (except where processing is necessary to clarify the personal data).

2.3. Website - a set of graphic and information materials, as well as computer programs and databases that make them available on the Internet at the network address https://byeroutine.com.

2.4. Personal data information system - a set of personal data contained in databases, together with the information technologies and technical means that ensure their processing.

2.5. Depersonalisation of personal data - actions as a result of which it is impossible, without the use of additional information, to determine whether personal data belongs to a specific User or another personal data subject.

2.6. Processing of personal data - any action (operation) or set of actions (operations) performed with personal data, with or without the use of automation tools, including collection, recording, systematisation, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (dissemination, provision, access), depersonalisation, blocking, deletion and destruction of personal data.

2.7. Operator - a state body, municipal body, legal entity or individual that, independently or jointly with other persons, organises and/or carries out the processing of personal data, and also determines the purposes of processing personal data, the personal data to be processed and the actions (operations) performed with personal data.

2.8. Personal data - any information relating directly or indirectly to an identified or identifiable User of the website https://byeroutine.com.

2.9. Personal data permitted by the personal data subject for dissemination - personal data to which the personal data subject has given access to an unlimited number of persons by giving consent to the processing of personal data permitted by the personal data subject for dissemination in the manner provided for by the Personal Data Law (hereinafter - personal data permitted for dissemination).

2.10. User - any visitor to the website https://byeroutine.com.

2.11. Provision of personal data - actions aimed at disclosing personal data to a specific person or a specific group of persons.

2.12. Dissemination of personal data - any actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or at making personal data available to an unlimited number of persons, including publishing personal data in the mass media, posting it on information and telecommunication 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, to a foreign individual or to a foreign legal entity.

2.14. Destruction of personal data - any actions as a result of which personal data is irretrievably destroyed, with no possibility of further restoring the content of the personal data in the personal data information system, and/or the physical media of personal data are destroyed.

3. Basic 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 personal data subject;
  • if the personal data subject withdraws consent to the processing of personal data, or sends a request to stop processing personal data, the Operator may continue processing personal data without the consent of the personal data subject where there are grounds specified in the Personal Data Law;
  • independently determine the composition and list of measures necessary and sufficient to fulfil the obligations provided for by the Personal Data Law and the regulations adopted in accordance with it, unless otherwise provided for by the Personal Data Law or other federal laws.

3.2. The Operator is obliged to:

  • provide the personal data subject, at their request, with information concerning the processing of their personal data;
  • organise the processing of personal data in the manner established by the current legislation of the Russian Federation;
  • respond to requests and enquiries from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
  • provide the authorised body for the protection of the rights of personal data subjects, at the request of that body, with the necessary information within 10 days of receiving such a request;
  • publish or otherwise ensure unrestricted access to this Policy on the processing of personal data;
  • take legal, organisational and technical measures to protect personal data from unlawful or accidental access to it, destruction, modification, blocking, copying, provision or dissemination of personal data, as well as from other unlawful actions in relation to personal data;
  • stop the transfer (dissemination, provision, access) of personal data, stop processing and destroy personal data in the manner and in the cases provided for by the Personal Data Law;
  • fulfil other obligations provided for by the Personal Data Law.

4. Basic 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 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 personal data subjects, except where 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, unlawfully obtained or not necessary for the stated purpose of processing, and to take measures provided for by law to protect their rights;
  • set a condition of prior consent when personal data is processed for the purpose of promoting goods, works and services on the market;
  • withdraw consent to the processing of personal data and send a request to stop processing personal data;
  • appeal against unlawful actions or inaction of the Operator in processing their personal data to the authorised body for the protection of the rights of personal data subjects or in court;
  • exercise other rights provided for by the legislation of the Russian Federation.

4.2. Personal data subjects are obliged to:

  • provide the Operator with reliable information about themselves;
  • inform the Operator of any clarification (updating, modification) of their personal data.

4.3. Persons who have provided the Operator with false information about themselves, or information about another personal data subject without the latter's consent, are liable in accordance with the legislation of the Russian Federation.

5. Principles of personal data processing

5.1. Personal data is processed on a lawful and fair basis.

5.2. The processing of personal data is limited to achieving specific, predetermined and lawful purposes. Processing of personal data that is incompatible with the purposes of collecting personal data is not permitted.

5.3. Combining databases containing personal data that are processed for purposes incompatible with each other is not permitted.

5.4. Only personal data that meets the purposes of its processing is subject to processing.

5.5. The content and volume of the personal data processed correspond to the stated purposes of processing. Processing personal data in excess of the stated purposes of its processing is not permitted.

5.6. When personal data is processed, its accuracy, sufficiency and, where necessary, relevance to the purposes of processing are ensured. The Operator takes the necessary measures and/or ensures that they are taken to delete or clarify incomplete or inaccurate data.

5.7. Personal data is stored in a form that makes it possible to identify the personal data subject for no longer than the purposes of processing require, unless the storage period is established by federal law or by a contract to which the personal data subject is a party, beneficiary or guarantor. Personal data being processed is destroyed or depersonalised once the purposes of processing have been achieved or if there is no longer a need to achieve these purposes, unless otherwise provided for by federal law.

6. Purposes of personal data processing

Purpose of processing

  • handling Users' enquiries;
  • concluding, performing and terminating civil law contracts;
  • providing consultations and services;
  • sending notifications, information messages and replies to enquiries;
  • ensuring the operation of the website and improving its quality;
  • keeping internal records and reporting.

Personal data

  • surname, first name, patronymic;
  • phone number;
  • email address;
  • other information provided by the User voluntarily through the website's forms.

Technical data processed

  • IP address;
  • browser information;
  • cookies;
  • information about the User's actions on the website;
  • data from analytics services.

Legal grounds for processing

  • Federal Law No. 152-FZ “On Personal Data”;
  • other regulations of the Russian Federation;
  • the consent of the personal data subject;
  • contracts concluded between the Operator and the personal data subject.

Types of personal data processing

  • collection;
  • recording;
  • systematisation;
  • accumulation;
  • storage;
  • clarification (updating, modification);
  • use;
  • depersonalisation;
  • blocking;
  • deletion;
  • destruction of personal data.

7. Conditions for processing personal data

7.1. Personal data is processed with the consent of the personal data subject to the processing of their personal data.

7.2. The processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, and to carry out the functions, powers and duties imposed on the operator by the legislation of the Russian Federation.

7.3. The processing of personal data is necessary for the administration of justice and for the enforcement of a judicial act or an act of another body or official that is subject to enforcement in accordance with the legislation of the Russian Federation on enforcement proceedings.

7.4. The processing of personal data is necessary for the performance of a contract to 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. The processing of personal data is necessary to exercise the rights and legitimate interests of the operator or third parties, or to achieve socially significant purposes, provided that the rights and freedoms of the personal data subject are not violated.

7.6. Personal data is processed to which an unlimited number of persons has been given access by the personal data subject or at their request (hereinafter - publicly available personal data).

7.7. Personal data is processed that is subject to publication or mandatory disclosure in accordance with federal law.

8. Procedure for collecting, storing, transferring and otherwise processing personal data

The security of personal data processed by the Operator is ensured by implementing the legal, organisational and technical measures necessary to comply in full with the requirements of the current legislation on personal data protection.

8.1. The Operator ensures the safety of personal data and takes all possible measures to prevent access to personal data by unauthorised persons.

8.2. Recording, systematisation, accumulation, storage, clarification (updating, modification) and retrieval of personal data of citizens of the Russian Federation are carried out using databases located on the territory of the Russian Federation.

8.3. The Operator may transfer personal data to third parties:

  • in cases provided for by the legislation of the Russian Federation;
  • with the consent of the personal data subject;
  • if such transfer is necessary for the performance of a contract;
  • to ensure the operation of the website and the services used.

8.4. If inaccuracies are found in personal data, the User can update them themselves by sending a notice to the Operator's email address manager@byeroutine.com marked “Updating personal data”.

8.5. Personal data is processed and stored for no longer than the purposes of processing require, unless a different storage period is established by the legislation of the Russian Federation. The User may withdraw their consent to the processing of personal data at any time by sending the Operator a notice by email to the Operator's address manager@byeroutine.com marked “Withdrawal of consent to the processing of personal data”.

8.6. Third-party services used by the Operator, including web analytics, communication, hosting and payment processing services, independently determine the procedure for processing personal data in accordance with their user agreements and privacy policies. The Operator is not responsible for the actions of third parties. The personal data subject must read the relevant documents of these services on their own.

8.7. The website may use cookies and other technologies for collecting technical data about Users. By continuing to use the website, the User agrees to the processing of cookies and other technical data in accordance with this Policy.

8.8. The website may use the Yandex.Metrica web analytics service provided by Yandex LLC, which uses cookies and collects depersonalised data about Users.

8.9. Prohibitions set by the personal data subject on the transfer (except for granting access) and on the processing or conditions of processing (except for obtaining access) of personal data permitted for dissemination do not apply where personal data is processed in the state, public and other public interests defined by the legislation of the Russian Federation.

8.10. When processing personal data, the Operator ensures the confidentiality of personal data.

8.11. The Operator stores personal data in a form that makes it possible to identify the personal data subject for no longer than the purposes of processing require, unless the storage period is established by federal law or by a contract to which the personal data subject is a party, beneficiary or guarantor.

8.12. The grounds for terminating the processing of personal data may be the achievement of the purposes of processing, the expiry of the consent of the personal data subject, the withdrawal of consent by the personal data subject or a request to stop processing personal data, as well as the identification of unlawful processing of personal data.

9. List of actions performed by the Operator with the personal data received

9.1. The Operator collects, records, systematises, accumulates, stores, clarifies (updates, modifies), retrieves, uses, transfers (disseminates, provides, grants access to), depersonalises, 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 information obtained via information and telecommunication networks.

10. Cross-border transfer of personal data

10.1. Before starting cross-border transfer of personal data, the Operator must notify the authorised body for the protection of the rights of personal data subjects of its intention to carry out cross-border transfer of personal data (such notification is sent separately from the notification of the intention to process personal data).

10.2. Before submitting the above notification, the Operator must obtain the relevant information from the authorities of the foreign state, foreign individuals and foreign legal entities to which 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 must not disclose personal data to third parties or disseminate it without the consent of the personal data subject, unless otherwise provided for by federal law.

12. Final provisions

12.1. The User can obtain any clarification on matters of interest concerning the processing of their personal data by contacting the Operator by email at manager@byeroutine.com

12.2. Any changes to the Operator's personal data processing policy will be reflected in this document. The Policy is valid 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://byeroutine.com/ru/politika/.

Version of 13 October 2026. For questions about the processing of personal data: email manager@byeroutine.com, Telegram @ByeRoutine.