Personal Data Processing Policy

1. General Provisions

This Personal Data Processing Policy has been prepared in accordance with the requirements of Federal Law No. 152-FZ dated July 27, 2006 “On Personal Data” (hereinafter referred to as the Personal Data Law) and defines the procedure for processing personal data and the measures taken by Paranoid Security LLC (hereinafter referred to as the Operator) to ensure the security of personal data.

1.1. The Operator considers observance of the rights and freedoms of individuals and citizens in the processing of their personal data, including protection of the rights to privacy and personal and family confidentiality, to be its most important objective and a prerequisite for carrying out its activities.

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 obtain about visitors to the website https://pert.paranoid.security.

2. Key Terms Used in the Policy

2.1. Automated processing of personal data means the processing of personal data using computer technology.

2.2. Blocking of personal data means the temporary suspension of personal data processing (except where processing is required to clarify personal data).

2.3. Website means a collection of graphic and informational materials, as well as computer programs and databases, ensuring their availability on the Internet at the network address https://pert.paranoid.security.

2.4. Personal data information system means a set of personal data contained in databases and the information technologies and technical means that enable their processing.

2.5. Depersonalization of personal data means 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 means any action (operation) or 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), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.

2.7. Operator means a state authority, municipal authority, legal entity or individual that, independently or jointly with other persons, organizes and/or carries out the processing of personal data and also 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 means any information relating directly or indirectly to an identified or identifiable User of the website https://pert.paranoid.security.

2.9. Personal data authorized by the personal data subject for distribution means personal data to which access by an unlimited number of persons has been granted by the personal data subject by giving consent to the processing of personal data authorized by the personal data subject for distribution in accordance with the procedure established by the Personal Data Law (hereinafter referred to as personal data authorized for distribution).

2.10. User means any visitor to the website https://pert.paranoid.security.

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

2.12. Distribution of personal data means any actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or making personal data available to an unlimited number of persons, including publication of personal data in mass media, posting in information and telecommunications networks, or providing access to personal data by any other means.

2.13. Cross-border transfer of personal data means the transfer of personal data to the territory of a foreign state, to a foreign state authority, a foreign individual, or a foreign legal entity.

2.14. Destruction of personal data means any actions as a result of which personal data is irreversibly destroyed, making it impossible to further restore the content of personal data in the personal data information system, and/or physical media containing personal data are destroyed.

3. Key Rights and Obligations of the Operator

3.1. The Operator has the right to:

— receive from the personal data subject accurate information and/or documents containing personal data;

— if the personal data subject withdraws consent to the processing of personal data or submits a request to terminate the processing of personal data, continue processing personal data without the consent of the personal data subject where grounds specified in the Personal Data Law exist;

— independently determine the composition and list of measures necessary and sufficient to ensure fulfillment of the obligations stipulated by the Personal Data Law and regulatory legal acts adopted pursuant thereto, unless otherwise provided by the Personal Data Law or other federal laws.

3.2. The Operator is obliged to:

— provide the personal data subject, upon request, with information concerning the processing of their personal data;

— organize the processing of personal data in accordance with the procedure established by the applicable legislation of the Russian Federation;

— respond to applications and requests from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;

— provide the competent authority for the protection of the rights of personal data subjects, at the request of that authority, with the necessary information within 10 days from the date of receipt of such request;

— publish or otherwise provide unrestricted access to this Personal Data Processing Policy;

— take legal, organizational, and technical measures to protect personal data against unlawful or accidental access, destruction, modification, blocking, copying, provision, or distribution, as well as against other unlawful actions involving personal data;

— terminate the transfer (distribution, provision, access) of personal data, terminate processing, and destroy personal data in the manner and cases provided for by the Personal Data Law;

— perform other obligations stipulated by the Personal Data Law.

4. Key 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. Such information shall be provided by the Operator to the personal data subject in an accessible form and shall not contain personal data relating to other personal data subjects, except where there are lawful 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, block, or destroy their personal data if the personal data is incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the stated purpose of processing, and to take measures provided by law to protect their rights;

— require prior consent as a condition for processing personal data for the purpose of promoting goods, works, and services in the market;

— withdraw consent to the processing of personal data and submit a request to terminate the processing of personal data;

— appeal to the competent authority for the protection of the rights of personal data subjects or to a court against unlawful actions or omissions of the Operator in processing their personal data;

— exercise other rights stipulated by the legislation of the Russian Federation.

4.2. Personal data subjects are obliged to:

— provide the Operator with accurate information about themselves;

— notify the Operator of any clarification (update or modification) of their personal data.

4.3. Persons who have provided the Operator with inaccurate information about themselves or information about another personal data subject without the latter’s consent shall be liable in accordance with the legislation of the Russian Federation.

5. Principles of Personal Data Processing

5.1. Personal data shall be processed on a lawful and fair basis.

5.2. Personal data processing shall be limited to achieving specific, predetermined, and lawful purposes. Processing of personal data incompatible with the purposes for which the personal data was collected is not permitted.

5.3. Databases containing personal data processed for mutually incompatible purposes may not be combined.

5.4. Only personal data that meets the purposes of its processing shall be processed.

5.5. The content and scope of personal data processed shall correspond to the stated purposes of processing. Excessive processing of personal data in relation to 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 personal data processing shall be ensured. The Operator shall take or ensure that necessary measures are taken to delete or clarify incomplete or inaccurate data.

5.7. Personal data shall be stored in a form that permits identification of the personal data subject for no longer than required by the purposes of personal data processing, unless the personal data retention period is established by federal law or by an agreement to which the personal data subject is a party, beneficiary, or guarantor. Personal data processed shall be destroyed or depersonalized upon achievement of the processing purposes or if the need to achieve those purposes is lost, unless otherwise provided by federal law.

6. Purposes of Personal Data Processing

7. Conditions for Personal Data Processing

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

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

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

7.4. Personal data processing is necessary for the performance of an agreement to which the personal data subject is a party, beneficiary, or guarantor, as well as for entering into an agreement at the initiative of the personal data subject or an agreement under which the personal data subject will be a beneficiary or guarantor.

7.5. Personal data processing is necessary to exercise the rights and legitimate interests of the Operator or third parties or to achieve socially significant purposes, provided that this does not violate the rights and freedoms of the personal data subject.

7.6. Personal data to which access by an unlimited number of persons has been granted by the personal data subject or at their request shall be processed (hereinafter referred to as publicly available personal data).

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

8. Procedure for the Collection, Storage, Transfer, and Other Types of Personal Data Processing

The security of personal data processed by the Operator shall be ensured through the implementation of legal, organizational, and technical measures necessary to fully comply with the requirements of applicable legislation in the field of personal data protection.

8.1. The Operator shall ensure the safekeeping of personal data and take all possible measures to prevent unauthorized persons from accessing personal data.

8.2. Under no circumstances shall the User’s personal data be transferred to third parties, except in cases related to compliance with applicable legislation or where the personal data subject has consented to the Operator transferring the data to a third party for the performance of obligations under a civil-law agreement.

8.3. If inaccuracies in personal data are identified, the User may update such data independently by sending the Operator a notice to the Operator’s email address pert@paranoid.security marked “Personal Data Update.”

8.4. The period of personal data processing shall be determined by achievement of the purposes for which the personal data was collected, unless another period is provided for by an agreement or applicable legislation.

The User may withdraw consent to the processing of personal data at any time by sending the Operator a notice by email to the Operator’s email address pert@paranoid.security marked “Withdrawal of Consent to Personal Data Processing.”

8.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, shall be stored and processed by such persons (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject and/or with the said documents. The Operator shall not be liable for the actions of third parties, including the service providers specified in this clause.

8.6. Prohibitions established by the personal data subject on transfer (except for providing access), as well as on processing or the conditions of processing (except for obtaining access) of personal data authorized for distribution, shall not apply where personal data is processed in state, public, and other public interests defined by the legislation of the Russian Federation.

8.7. When processing personal data, the Operator shall ensure the confidentiality of personal data.

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

8.9. Grounds for terminating personal data processing may include achievement of the purposes of personal data processing, expiration of the personal data subject’s consent, withdrawal of consent by the personal data subject or a request to terminate personal data processing, as well as identification of unlawful personal data processing.

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

9.1. The Operator shall collect, record, systematize, accumulate, store, clarify (update, modify), retrieve, use, transfer (distribute, provide, grant access), depersonalize, block, delete, and destroy personal data.

9.2. The Operator shall carry out automated processing of personal data with or without receipt and/or transfer of the information obtained through information and telecommunications networks.

10. Cross-Border Transfer of Personal Data

10.1. Before commencing activities involving the cross-border transfer of personal data, the Operator shall notify the competent authority for the protection of the rights of personal data subjects of its intention to carry out cross-border transfer of personal data (such notification shall be submitted separately from the notification of the intention to process personal data).

10.2. Before submitting the above notification, the Operator shall obtain relevant information from the authorities of the foreign state, foreign individuals, and foreign legal entities to which the cross-border transfer of personal data is planned.

11. Confidentiality of Personal Data

The Operator and other persons who have obtained access to personal data shall not disclose personal data to third parties or distribute personal data without the consent of the personal data subject, unless otherwise provided by federal law.

12. Final Provisions

12.1. The User may obtain any clarification on matters concerning the processing of their personal data by contacting the Operator by email at pert@paranoid.security.

12.2. Any changes to the Operator’s personal data processing policy shall be reflected in this document. The Policy shall remain in effect indefinitely until replaced by a new version.

12.3. The current version of the Policy is freely available on the Internet at https://pert.paranoid.security/privacy.