Privacy Policy

1. General Provisions

This Privacy Policy is drawn up in accordance with the requirements of Federal Law No. 152‑FZ of July 27, 2006 "On Personal Data" (hereinafter – the Personal Data Law) and defines the procedure for processing personal data and measures to ensure the security of personal data undertaken by EXPERT NADZOR LIMITED LIABILITY COMPANY (INN 7725830121), located at 117105, Moscow, intra‑city territory Don municipal district, Varshavskoye shosse, 1A, office V312, room 43 (hereinafter – the Operator).

1.1. The Operator's top priority and condition for its activities is to respect the rights and freedoms of individuals and citizens when processing their personal data, including the protection of the rights to privacy, personal and family secrets.

1.2. This Privacy Policy of the Operator (hereinafter – the Policy) applies to all information that the Operator may obtain about visitors to the website https://exnd.ru/.

2. Key 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 personal data processing (except when processing is necessary to clarify personal data).

2.3. Website – a set of graphic and informational materials, as well as computer programs and databases, that ensure their availability on the Internet at the network address https://exnd.ru/.

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

2.5. Depersonalization of personal data – actions that make it impossible, without using additional information, to determine the ownership of personal data to a specific User or other personal data subject.

2.6. Processing of personal data – any action (operation) or set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.

2.7. Operator – a state body, municipal body, legal entity or individual who independently or jointly with other persons organizes and (or) processes personal data, and also determines the purposes of personal data processing, the composition of personal data to be processed, the actions (operations) performed with personal data.

2.8. Personal data – any information relating directly or indirectly to a specific or determinable User of the website https://exnd.ru/.

2.9. Personal data permitted by the data subject for dissemination – personal data to which an unlimited circle of persons has been granted access by the data subject by giving consent to the processing of personal data permitted for dissemination in the manner prescribed by the Personal Data Law (hereinafter – personal data permitted for dissemination).

2.10. User – any visitor to the website https://exnd.ru/.

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 public disclosure of personal data in the media, posting in information and telecommunications networks, or providing access to personal data in any other way.

2.13. Cross‑border transfer of personal data – 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 – any actions that result in the permanent destruction of personal data with no possibility of further restoration of the content of personal data in the personal data information system and/or destruction of the physical media containing personal data.

3. Key Rights and Obligations of the Operator

3.1. The Operator has the right:

  • to receive from the data subject accurate information and/or documents containing personal data;
  • in the event of withdrawal of consent by the data subject to the processing of personal data, the Operator has the right to continue processing personal data without the consent of the data subject if there are grounds specified in the Personal Data Law;
  • to independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations provided for by the Personal Data Law and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.

3.2. The Operator is obliged:

  • to provide the data subject, upon his/her request, with information concerning the processing of his/her personal data;
  • to organize the processing of personal data in the manner established by the current legislation of the Russian Federation;
  • to respond to inquiries and requests of data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
  • to inform the authorized body for the protection of the rights of personal data subjects, at its request, of the necessary information within 30 days from the date of receipt of such a request;
  • to publish or otherwise ensure unrestricted access to this Privacy Policy regarding the processing of personal data;
  • to adopt legal, organizational and technical measures to protect personal data from unlawful or accidental access, destruction, alteration, blocking, copying, provision, dissemination, as well as from other unlawful actions in relation to personal data;
  • to stop the transfer (distribution, provision, access) of personal data, to stop processing and destroy personal data in the manner and cases provided for by the Personal Data Law;
  • to fulfill other obligations provided for 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 regarding the processing of their personal data, except in cases provided for by federal laws. The information is provided to the data subject by the Operator in an accessible form and must not contain personal data relating to other personal data subjects, unless 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;
  • to demand that the Operator clarify their personal data, block or destroy them if the personal data are incomplete, outdated, inaccurate, illegally obtained or are not necessary for the stated purpose of processing, as well as to take measures provided by law to protect their rights;
  • to impose a condition of prior consent when processing personal data for the purposes of promoting goods, works and services on the market;
  • to withdraw consent to the processing of personal data;
  • to appeal to the authorized body for the protection of the rights of personal data subjects or in court against unlawful actions or inaction of the Operator in the processing of his/her personal data;
  • to exercise other rights provided for by the legislation of the Russian Federation.

4.2. Personal data subjects are obliged:

  • to provide the Operator with accurate data about themselves;
  • to inform the Operator about the clarification (updating, changing) of their personal data.

4.3. Persons who provide the Operator with false 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. The Operator May Process the Following Personal Data of the User

5.1. Last name, first name, patronymic.

5.2. Email address.

5.3. Phone numbers.

5.4. The website also collects and processes depersonalized data about visitors (including "cookies") using web analytics services (Yandex Metrica, Google Analytics, and others).

5.5. The above data are hereinafter referred to as Personal Data in the text of this Policy.

5.6. The Operator does not process special categories of personal data concerning race, nationality, political views, religious or philosophical beliefs, or intimate life.

5.7. Processing of personal data permitted for dissemination from among the special categories of personal data specified in Part 1 of Article 10 of the Personal Data Law is allowed subject to the prohibitions and conditions provided for in Article 10.1 of the Personal Data Law.

5.8. The User's consent to the processing of personal data permitted for dissemination is issued separately from other consents to the processing of his/her personal data. In doing so, the conditions stipulated, in particular, by Article 10.1 of the Personal Data Law are observed. The requirements for the content of such consent are established by the authorized body for the protection of the rights of personal data subjects.

5.8.1 The User provides consent to the processing of personal data permitted for dissemination directly to the Operator.

5.8.2 The Operator shall, no later than three business days from the date of receipt of the said consent from the User, publish information about the terms of processing, as well as about the existence of prohibitions and conditions for processing by an unlimited number of persons of personal data permitted for dissemination.

5.8.3 The transfer (distribution, provision, access) of personal data permitted by the data subject for dissemination must be terminated at any time at the request of the data subject. This request must include the last name, first name, patronymic (if any), contact information (phone number, email address or postal address) of the data subject, as well as a list of personal data whose processing is to be terminated. The personal data specified in this request may be processed only by the Operator to whom it was sent.

5.8.4 Consent to the processing of personal data permitted for dissemination shall terminate from the moment the Operator receives the request specified in clause 5.8.3 of this Policy regarding the processing of personal data.

6. Principles of Personal Data Processing

6.1. The processing of personal data is carried out on a lawful and fair basis.

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

6.3. Merging of databases containing personal data processed for incompatible purposes is not permitted.

6.4. Only personal data that correspond to the purposes of their processing are subject to processing.

6.5. The content and volume of processed personal data correspond to the stated purposes of processing. Redundancy of processed personal data in relation to the stated purposes of their processing is not allowed.

6.6. When processing personal data, the accuracy of personal data, their sufficiency and, where necessary, their relevance in relation to the purposes of processing personal data are ensured. The Operator takes the necessary measures and/or ensures their adoption to remove or clarify incomplete or inaccurate data.

6.7. Personal data is stored in a form that allows identifying the data subject for no longer than required by the purposes of processing personal data, unless the storage period is established by federal law or a contract to which the data subject is a party, beneficiary or guarantor. Processed personal data is destroyed or depersonalized upon achieving the purposes of processing or in the event of loss of the need to achieve these purposes, unless otherwise provided for by federal law.

7. Purposes of Personal Data Processing

7.1. The purpose of processing the User's personal data:

  • informing the User by sending emails;
  • conclusion, execution and termination of civil contracts.

7.2. The Operator also has the right to send the User notifications about new products and services, special offers and various events. The User can always refuse to receive informational messages by sending an email to with the subject "Refusal to receive notifications about new products and services and special offers".

7.3. Depersonalized User data collected using web analytics services serves to collect information about Users' actions on the site, improve the quality of the site and its content.

8. Legal Basis for Processing Personal Data

8.1. The legal grounds for the processing of personal data by the Operator are:

  • the Operator's statutory (foundation) documents;
  • contracts concluded between the Operator and the data subject;
  • federal laws, other regulatory legal acts in the field of personal data protection;
  • Users' consents to the processing of their personal data, as well as to the processing of personal data permitted for dissemination.

8.2. The Operator processes the User's personal data only if they are filled in and/or sent by the User independently through special forms located on the website https://exnd.ru/ or sent to the Operator by email. By filling out the relevant forms and/or sending their personal data to the Operator, the User expresses their consent to this Policy.

8.3. The Operator processes depersonalized data about the User if this is permitted in the User's browser settings (saving "cookies" and using JavaScript technology are enabled).

8.4. The data subject independently decides to provide his/her personal data and gives consent freely, by his/her own will and in his/her own interest.

9. Conditions for Processing Personal Data

9.1. The processing of personal data is carried out with the consent of the data subject to the processing of his/her personal data.

9.2. The processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or law, to perform the functions, powers and duties assigned to the Operator by the legislation of the Russian Federation.

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

9.4. The processing of personal data is necessary for the performance of a contract to which the data subject is a party, beneficiary or guarantor, as well as for the conclusion of a contract at the initiative of the data subject or a contract under which the data subject will be the beneficiary or guarantor.

9.5. The processing of personal data is necessary for the exercise of the rights and legitimate interests of the Operator or third parties, or for the achievement of socially significant goals, provided that this does not violate the rights and freedoms of the data subject.

9.6. The processing of personal data is carried out, access to which is granted to an unlimited circle of persons by the data subject or at his/her request (hereinafter – publicly available personal data).

9.7. The processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.

10. Procedure for Collecting, Storing, Transferring and Other Types of Processing Personal Data

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

10.1. The Operator ensures the safety of personal data and takes all possible measures to prevent unauthorized persons from accessing personal data.

10.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to the implementation of current legislation or if the data subject has given consent to the Operator to transfer data to a third party to fulfill obligations under a civil contract.

10.3. If inaccuracies in personal data are detected, the User can update them independently by sending a notification to the Operator's email address with the subject "Updating personal data".

10.4. The period for processing personal data is determined by achieving the purposes for which the personal data was collected, unless a different period is provided for by the contract or current legislation.

The User may at any time withdraw their consent to the processing of personal data by sending a notification to the Operator by email at with the subject "Withdrawal of consent to the processing of personal data".

10.5. All information collected by third‑party services, including payment systems, means of communication and other service providers, is stored and processed by such persons (Operators) in accordance with their User Agreement and Privacy Policy. The data subject and/or the User is obliged to independently and timely familiarize themselves with these documents. The Operator is not responsible for the actions of third parties, including the service providers listed in this clause.

10.6. Prohibitions established by the data subject on the transfer (except for providing access), as well as on the processing or conditions of processing (except for obtaining access) of personal data permitted for dissemination, do not apply in cases of processing personal data in state, public and other public interests defined by the legislation of the Russian Federation.

10.7. The Operator ensures the confidentiality of personal data when processing personal data.

10.8. The Operator stores personal data in a form that allows identifying the data subject for no longer than required by the purposes of processing personal data, unless the storage period is established by federal law or a contract to which the data subject is a party, beneficiary or guarantor.

10.9. The condition for termination of personal data processing may be the achievement of the purposes of processing personal data, the expiration of the consent of the data subject, or the withdrawal of consent by the data subject, as well as the detection of unlawful processing of personal data.

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

11.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), extracts, uses, transfers (distributes, provides, accesses), depersonalizes, blocks, deletes and destroys personal data.

11.2. The Operator carries out automated processing of personal data with or without receiving and/or transmitting the received information via information and telecommunications networks.

12. Cross‑Border Transfer of Personal Data

12.1. Before starting cross‑border transfer of personal data, the Operator must ensure that the foreign state to whose territory the transfer of personal data is intended ensures reliable protection of the rights of personal data subjects.

12.2. Cross‑border transfer of personal data to the territory of foreign states that do not meet the above requirements may be carried out only with the written consent of the data subject to the cross‑border transfer of his/her personal data and/or in execution of a contract to which the data subject is a party.

13. Confidentiality of Personal Data

The Operator and other persons who have gained access to personal data are obliged not to disclose to third parties and not to disseminate personal data without the consent of the data subject, unless otherwise provided for by federal law.

14. Final Provisions

14.1. The User can obtain any clarifications on issues of interest concerning the processing of their personal data by contacting the Operator via email at .

14.2. Any changes to the processing of personal data by the Operator will be reflected in this Policy. The Policy is valid indefinitely until it is replaced by a new version.

14.3. The current version of the Policy is freely available on the Internet at https://exnd.ru/privacy/.

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