1. General Provisions

1.1. This Privacy Policy of LLC “Marketing Agency ES” (hereinafter – the “Policy”) regarding the processing of personal data has been developed in accordance with Clause 2, Part 1, Article 18.1 of Federal Law No. 152-FZ dated July 27, 2006 “On Personal Data” (hereinafter – the “Personal Data Law”) in order to ensure the protection of human and civil rights and freedoms in the processing of personal data, including the right to privacy, personal and family secrets.

1.2. This Policy applies to all personal data processed by LLC “Marketing Agency ES” (hereinafter – the “Operator” or “Marketing Agency ES”).

1.3. The Policy applies to all relations concerning the processing of personal data, regardless of whether they arose before or after the approval of this Policy.

1.4. In accordance with Part 2, Article 18.1 of the Personal Data Law, this Policy is published in open access on the Internet on the Operator’s website at www.es812.ru.

1.5. Key definitions used in the Policy:
·Personal data: any information relating directly or indirectly to an identified or identifiable individual (personal data subject);
Personal data operator (Operator): a state or municipal authority, legal entity, or individual who organizes and/or carries out the processing of personal data, and determines the purposes, scope, and means of processing;
Processing of personal data: any action (operation) or set of actions with personal data, with or without automation tools. This includes:

• collection;
• recording;
• systematization;
• accumulation;
• storage;
• clarification (updating, modification);
• usage;
• transfer (distribution, provision, access);
• anonymization;
• deletion;
• destruction;

Automated processing: processing using computing technology;
Distribution: actions aimed at disclosure to an indefinite number of persons;
Provision: actions aimed at disclosure to a specific person or group;
Destruction: actions making recovery impossible;
Anonymization: actions making identification impossible without additional information;
Information system: a set of databases and IT tools for processing personal data.

1.6. Main rights and obligations of the Operator:

The Operator has the right to:

1. Define the necessary measures to ensure compliance with legal obligations;
2. Delegate data processing to third parties by contract, with the subject’s consent, unless otherwise stipulated by law;
3. Continue processing without consent if there are lawful grounds (as per the Personal Data Law).

The Operator is obliged to:

1. Organize processing in accordance with the law;
2. Respond to data subjects’ inquiries;
3. Provide requested information to the supervisory authority (Roskomnadzor) within 30 days.

1.7. Main rights of personal data subjects:
Receive information on the processing of their data;
Demand correction, blocking, or destruction of their data if it is inaccurate or illegally obtained;
Require prior consent for data use in marketing;
File complaints with Roskomnadzor or in court.

1.8. Compliance with this Policy is monitored by an authorized individual responsible for data processing.

1.9. Liability for violations is determined in accordance with Russian law.

2. Purposes of Collecting Personal Data

2.1–2.4. Processing must be limited to lawful and specific goals, including:
Compliance with Russian laws;
Employment relations;
Contractual obligations;
Respondent recruitment for surveys;
Market and opinion research;
Quality control;
Other lawful purposes.

Employee data is processed solely to comply with legal obligations.

3. Legal Grounds for Processing

3.1–3.2. The legal basis includes:
The Constitution of the Russian Federation;
The Civil Code, Labor Code, Tax Code;
Federal Laws (on LLCs, accounting, pensions);
The Operator’s charter;
Contracts and consent of data subjects.

4. Scope and Categories of Personal Data

4.1–4.5. Data must match processing goals and may include:
Full name, birth details, passport info;
Gender, citizenship, registration address;
Phone number, email;
Education, job history, position;
Taxpayer ID, pension account number;
Bank details;
Other information provided by the data subject.

Special categories (e.g. health, political views) may only be processed with written consent.

5. Procedure and Conditions for Processing

5.1–5.10. The Operator ensures:
Both automated and manual processing;
Access limited to authorized employees;
Third-party processing only with contractual safeguards;
Data obtained from subjects and public sources;
Data entry into registries and systems.

Data may be disclosed to:
Survey clients;
Contractors (e.g. recruiters, interviewers);
Authorities (e.g. tax office, pension fund) as required by law.

The Operator undertakes legal, organizational, and technical measures to protect data from unauthorized access, destruction, or alteration, including:
Threat analysis;
Internal regulations;
Appointed data security officers;
Secure data storage;
Staff training.

Data is stored no longer than necessary. Russian citizens’ data must be stored in databases located in the Russian Federation unless exceptions apply.

6. Updating, Correction, Deletion, and Destruction of Personal Data

6.1–6.4. Upon request, the Operator confirms the processing and purpose, excluding data about third parties unless legally justified.

Requests must include:
ID document details;
Proof of data involvement (contract, etc.);
Signature (or digital signature for electronic requests).

Requests lacking sufficient information are rejected with explanation.

If data is found to be inaccurate or illegally processed, the Operator blocks it and updates or deletes it as appropriate within seven business days.

Data is destroyed upon fulfillment of processing purposes or consent withdrawal, unless otherwise required by law or contract.

Consent to Personal Data Processing

By clicking the “Send Message” button, you consent to the processing of your personal data.