Personal Data Processing Policy

1. General provisions
This Personal data processing policy is compiled in accordance with the requirements of Federal Law No. 152-FZ of 27.07.2006 "On Personal Data" and defines the procedure for processing personal data and measures to ensure the security of personal data of Zvezda Digital Innovations LLC (hereinafter referred to as the Operator).

1. The operator sets as its most important goal and condition for the implementation of its activities the observance of the rights and freedoms of man and citizen in the processing of his personal data, including the protection of the rights to privacy, personal and family secrets.

2. This Operator's policy regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator can receive about website visitors
2. Basic concepts used in the policy
1. Automated processing of personal data – processing of personal data using computer technology;

2. Blocking of personal data – temporary termination of processing of personal data (except in cases where processing is necessary to clarify personal data);

3. Website – a set of graphic and informational materials, as well as computer programs and databases data ensuring their availability on the Internet at the network address;

4. Personal data information system — a set of personal data contained in databases, and information technologies and technical means that ensure their processing;

5. Depersonalisation of personal data — actions as a result of which it is impossible to determine, without the use of additional information, the identity of personal data to a specific User or another subject of personal data;

6. Personal data processing – any action (operation) or a set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalisation, blocking, deletion, destruction of personal data;

7. Operator – a state body, municipal body, legal entity, or individual, independently or jointly with other persons organising and (or) processing personal data, as well as determining the purposes of processing personal data, the composition of personal data to be processed, actions (operations) performed with personal data;

8. Personal data – any information relating directly or indirectly to a specific or identifiable User of the website;

9. User – any visitor to the website;

10. Provision of personal data – actions aimed at disclosure of personal data to a specific person or a particular circle of persons;

11. Dissemination of personal data – any actions aimed at disclosure of personal data to an indefinite circle of persons (transfer of personal data) or familiarisation with personal data of an unlimited process of persons, including the publication of personal data in the media, placement in information and telecommunication networks or provision of access to personal data in any other way;

12. Cross–border transfer of personal data – transfer of personal data to the territory of a foreign state to foreign state authority, a foreign individual, or a foreign legal entity;

13. Destruction of personal data - any actions resulting from which personal data is permanently destroyed with the impossibility of further restoration of the content of personal data in the private data information system and (or) as a result of which material individual data carriers.
3. The operator can process the following user data
1. Surname, first name, patronymic;

2. Email address;

3. Phone numbers;

4. Also on site is collecting and processing anonymous data about visitors (including cookies) using Internet statistics (Yandex Metric and Google Analytics, and others).

5. From now referred to in the text of the Police, the above data are combined with the general concept of Personal Data.
4. Purposes of personal data processing
1. The purpose of processing the User's persona data is to inform the User by sending emails; to provide the User with access to the services, information, and/or materials on the website.

2. The Operator also has the right to send notifications to the User about new products and services, special offers, and various events. The User can always refuse to receive informational messages by emailing the Operator marked "Refusal of notifications about new products and services and special offers."

3. Depersonalised User data collected using Internet statistics services are used to collect information about User actions on the site and improve the site's quality and content.
5. Legal grounds for processing personal data
1. The Operator processes the User's data only if they are filled in and/or sent by the User independently through particular forms located on the website By filling out the appropriate forms and/or sending their persona data to the Operator, the User agrees with this Policy.

2. The Operator processes depersonalized data about the User if this is allowed in the User's browser settings (the saving of cookies and the use of JavaScript technology are enabled).

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

1. The operator ensures the safety of personal data and takes all possible measures to exclude access to the personal data of unauthorized persons.

2. The User's data will never, under any circumstances, be transferred to third parties, except in cases related to the implementation of current legislation.

3. In case of identification of inaccuracies in personal data, the User can update them independently by sending a notification to the Operator to the Operator's email address marked "Updating of personal data."
4. The period of processing o personal data is unlimited. The User can withdraw his consent to the processing of personal data by sending a notification to the Operator via e-mail to the Operator's e-mail address marked "Withdrawal of consent to the processing of personal data."
6. Cross-border transfer of personal data
1. Before starting the cross-border transfer of personal data, the operator is obliged to make sure that the foreign state to whose territory the transfer of personal data is supposed to be carried out provides reliable protection of the rights of individual data subjects.

2. The cross-border transfer of personal data on the territory of foreign states that do not meet the above requirements can be carried out only if the personal data subject has written consent to the cross-border transfer of his data and/or the execution of the contract to which the personal data subject is a party.
7. Final provisions
1. The User can receive any clarifications on issues of interest concerning the processing of his personal data by contacting the Operator via e-mail

2 . This document will reflect any changes to the Operator's personal data processing policy. The policy is valid indefinitely until a new version is replaced.

3. The current version of the Policy is freely available on the Internet at