Personal Data Processing Policy

Personal Data Processing Policy

Version of 2 September 2026, effective upon publication.

This is a translation for convenience. The Russian version is the authoritative text; in case of discrepancy the Russian version prevails.

1. General provisions

This Policy sets out how personal data is processed and protected in the «Service in Online» service and is drawn up pursuant to part 2 of article 18.1 of Federal Law No. 152-FZ of 27 July 2006 «On Personal Data».

Operator: individual entrepreneur Artem Valerievich Marinets, TIN 236101894293, PSRNIE 324619600264387, Rostov-on-Don, Russia. The full postal address is provided on request to ServiceInOnline@yandex.ru.

The person responsible for organising the processing of personal data is individual entrepreneur Artem Valerievich Marinets.

2. Categories of data subjects

3. Allocation of roles

The Operator acts as the operator of personal data in respect of account data: surname, first name, patronymic, phone number, email address, public name, messenger address, balance and booking history.

In respect of an organisation's client base — client cards, notes and visit history maintained by the owner — the organisation itself is the operator. The Operator processes such data on the organisation's instructions under part 3 of article 6 of Law 152-FZ, on the terms set out in the public offer.

The organisation owner is solely responsible for the lawfulness of entering their specialists' data into the Service and for obtaining their consent.

4. Purposes, legal grounds and retention periods

5. Methods of processing and location of databases

Processing is carried out by mixed means — both with and without automation tools.

Recording, systematisation, accumulation, storage, updating and retrieval of personal data of citizens of the Russian Federation are carried out using databases located within the territory of the Russian Federation (part 5 of article 18 of Law 152-FZ). Servers are hosted with a Russian cloud provider.

6. Transfer to third parties and message delivery

The list of recipients and the scope of data transferred are set out in the Consent to the processing of personal data.

The delivery channel is determined by the recipient of a message: every user of the Service chooses the channel in which they receive messages. A user's personal data may therefore pass through the infrastructure of a messenger owner even when that user uses the Service through the website only — if their message is addressed to a messenger user. Such infrastructure may be located outside the Russian Federation.

For a messenger user the messenger is the interface of the Service: everything that user sees on screen and enters themselves passes through it.

The messenger owner acts under its own rules and does not process personal data on the Operator's instructions. In all cases the Service databases are located within the territory of the Russian Federation (part 5 of article 18 of Law 152-FZ).

7. Rights of the data subject and how to exercise them

You have the right to obtain information about the processing of your personal data, to request its correction, blocking or destruction, to withdraw consent, and to appeal the Operator's actions to Roskomnadzor or to a court.

Requests are sent to ServiceInOnline@yandex.ru and must contain details allowing your identity and connection with the Service to be established: surname, first name, patronymic, the phone number or email address given at registration, and the substance of the request.

The response time is 10 working days from receipt of the request; it may be extended by no more than 5 working days with notice to the applicant. If the request is refused, the Operator provides a reasoned reply.

8. Account deletion and archive retention

When an account is deleted, profile data and bookings are erased.

Some information is retained in the Operator's archive: surname, first name, patronymic, phone number, email address and the account balance at the time of deletion. This is necessary to complete settlements and to handle possible claims. The retention period depends on the balance at the time of deletion: if the balance is zero — 30 days; if it is not zero — 3 years from the date of account deletion, after which the information is destroyed.

9. Destruction of personal data

Personal data is destroyed once the purposes of processing have been achieved, upon withdrawal of consent (where no other legal ground applies), and where unlawful processing is identified — within the periods set by article 21 of Law 152-FZ. Destruction is confirmed by a formal act.

10. Security measures

The Operator applies the legal, organisational and technical measures required by article 19 of Law 152-FZ, including:

11. Minors

The Service is not intended for persons under 14. Data of a person aged 14 to 18 is processed with the consent of their legal representative, except where the law provides otherwise.

12. Cookies

The website uses cookies necessary for the Service to work (authentication, storing settings). Other cookies are set only with your consent, which is requested on your first visit and can be withdrawn in your browser settings.

13. Changes to the Policy

The Operator may amend this Policy. A new version is published in the Service with its effective date. When the version changes, consent is requested anew.

14. Contact

For questions regarding the processing of personal data: ServiceInOnline@yandex.ru.