Personal Data Processing Policy

1. The Operator

The operator of the personal data processed through the request form on the astrolabs.ru website is ALFADISK LLC (hereinafter, the “Operator”). Under Russian law the operator is the party that determines the purposes and means of processing — the role corresponding to a data controller in other jurisdictions.

• OGRN (primary state registration number): 1217700601722
• INN (taxpayer identification number): 7727479639
• Registered address: (details available on request)
• Email for enquiries: info@astrolabs.ru

2. Definitions

This policy has been drawn up in accordance with the requirements of Federal Law No. 152-FZ of 27 July 2006 “On Personal Data” and sets out the principles and procedures governing the processing of the personal data of users of the astrolabs.ru website (the “Website”), together with the measures taken to keep that data secure.

Personal data means any information relating, directly or indirectly, to an identified or identifiable natural person (the data subject).

Processing of personal data means any operation or set of operations performed on personal data, whether or not by automated means, including collection, recording, systematisation, accumulation, storage, rectification, retrieval, use, transfer, anonymisation, blocking, erasure and destruction.

3. What data we collect

When the request form on the Website is completed, the Operator collects and processes the following personal data, which the user provides voluntarily:

• Name — so that we know how to address the user;
• Company name — an optional field, to give us the context of the enquiry;
• Contact details (phone, email or messenger handle, in free form) — so that we can reply;
• Message (a description of the task) — the substance of the user's enquiry.

In addition, technical details of the request (IP address, date and time of the enquiry, browser User-Agent) are recorded automatically. They are used to protect the form against automated abuse (spam, brute-force attempts) and are not combined with information about the user's identity beyond that purpose.

4. Purpose of processing

Personal data is processed solely in order to handle the user's enquiry submitted through the request form on the Website: to contact the user, to answer their question and to prepare a commercial proposal for the task described. The data is not used for purposes incompatible with that purpose without the user's separate consent.

5. Legal basis

Personal data is processed on the basis of the consent of the data subject (article 6(1)(1) of 152-FZ), which the user gives by ticking the corresponding consent box when submitting the request form. The form cannot be submitted unless that box is ticked.

6. Retention period

Personal data obtained through the request form is retained for as long as is necessary to handle the enquiry and any subsequent dealings arising from it, and in any event for no longer than 3 (three) years from the date of last contact with the user, unless a different period is required by applicable law or agreed separately with the user. Once the retention period expires, the data is anonymised or destroyed.

7. Rights of the data subject

Under 152-FZ the user, as a data subject, has the right to:

• obtain information concerning the processing of their personal data;
• require that their personal data be rectified, blocked or destroyed where it is incomplete, out of date, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing;
• withdraw their consent to the processing of personal data at any time;
• appeal against the acts or omissions of the Operator to the authority responsible for the protection of data subjects' rights (Roskomnadzor) or before the courts;
• protect their rights and legitimate interests, including by seeking damages and/or compensation for moral harm through the courts.

8. How to withdraw consent

To withdraw consent to the processing of personal data, the user should send a written request to the email address given in the “Contact for enquiries” section, with the subject line “Withdrawal of consent to the processing of personal data” and details sufficient to identify the original enquiry (the name and contact details given in the form). The Operator will then cease processing and destroy the user's personal data within the period prescribed by law, except where processing remains necessary on grounds provided for by law.

9. Security measures

The Operator takes the organisational and technical measures necessary to protect personal data against unlawful or accidental access, destruction, alteration, blocking, copying, dissemination and other unlawful acts by third parties: data is transmitted over a secure connection (HTTPS), access to the server and to the enquiry logs is restricted, and the infrastructure is audited regularly.

10. Contact for enquiries

For any matter relating to the processing of personal data, including the withdrawal of consent, the user may contact the Operator at: info@astrolabs.ru or at the postal address given in section 1 of this policy.

11. Language and governing version

This English text is provided for convenience only. The Russian version of this policy is the original and the sole legally binding text. In the event of any discrepancy, ambiguity or difference of interpretation between the two, the Russian version prevails. The policy is governed by the law of the Russian Federation.