Policy on the processing of personal data
This document is issued under part 2 of article 18.1 of Russian Federal Law No. 152-FZ of 27 July 2006 “On Personal Data” and sets out how personal data is processed and protected on socode.ru.
This English text is provided for convenience. The legally binding version is the Russian one: socode.ru/privacy.
1. GENERAL PROVISIONS
THE OPERATOR AND THE SCOPE1.1. The data operator is Individual Entrepreneur Anton Igorevich Bogatushin (OGRNIP 321784700217652, INN 780507554542), hereinafter the “Operator”, “we”. The Operator trades under the commercial name Social Code agency.
1.2. This Policy applies to all information the Operator may obtain about visitors to socode.ru (the “Site”), including people who submit a request through the forms on the Site or who contact us using the details published on it.
1.3. A User is an individual who visits the Site and/or sends their personal data to the Operator. By sending data, the User confirms that they have read this Policy and the Consent to personal data processing.
1.4. The Operator does not verify the accuracy of the personal data provided and assumes that the User supplies accurate data and keeps it current. The User must not send the Operator personal data of third parties without their consent.
1.5. The Site is not intended for persons under 18. The Operator does not deliberately collect personal data of minors.
2. THE DATA WE PROCESS
CATEGORIES AND SOURCE2.1. The Operator processes the following personal data, provided by the User themselves:
- surname and first name (or the name the User goes by);
- email address;
- telephone number;
- messenger handle (Telegram and similar);
- company name and website address — where the User provides them voluntarily;
- the content of the enquiry — any details of the task described in free form.
2.2. In addition, visiting the Site may automatically generate anonymised data: IP address, browser and operating system details, language settings, referring page, date and time of the request, and actions taken on the Site. Such data does not identify a specific individual.
2.3. The Operator does not process special categories of personal data (racial or ethnic origin, political views, religious beliefs, health, sex life), nor biometric data.
2.4. The Operator does not carry out automated decision-making that produces legal effects for the User.
3. PURPOSES AND LEGAL BASES
WHY, AND UNDER WHAT RIGHT| Purpose | Data involved | Legal basis |
|---|---|---|
| Handling the request, contacting the User, preparing and delivering the express audit | name, contact details, content of the enquiry | the User’s consent (art. 6(1)(1) of No. 152-FZ) |
| Entering into and performing a services contract | name, contact and company details, content of the enquiry | performance of a contract (art. 6(1)(5)) |
| Sending informational and promotional messages | name, email address, telephone number | separate consent (art. 18(1) of No. 38-FZ “On Advertising”) |
| Improving the Site and compiling visit statistics | anonymised data under clause 2.2 | the Operator’s legitimate interest |
| Complying with the law (accounting and tax records) | data required by law | statutory requirement (art. 6(1)(2)) |
3.1. The Operator processes personal data only for the purposes listed above. Processing incompatible with those purposes does not take place.
4. COOKIES AND ANALYTICS
WHAT IS COLLECTED AUTOMATICALLY4.1. A cookie is a small piece of data the Site stores in the User’s browser. The Site uses cookies and similar technologies (browser local storage) for the following purposes:
- strictly necessary — making the pages work correctly, remembering the chosen language version, protecting against automated requests. Without these the Site does not work properly;
- analytics — collecting anonymised statistics on traffic and behaviour so we can tell which pages are useful and improve them;
- advertising — measuring campaign performance and showing the Operator’s advertising on third-party platforms, where such systems are connected.
4.2. For analytics and advertising the Operator may use third-party services, including Yandex Metrica (Yandex LLC) and Google Analytics (Google LLC). These services set their own cookies and process anonymised data on terms set by their respective owners.
4.3. By continuing to use the Site, the User agrees to the use of cookies for these purposes. The User may disable or delete cookies in their browser settings at any time; disabling strictly necessary cookies may make parts of the Site unavailable.
4.4. The Operator does not use cookies to identify the User and does not combine cookie data with the data submitted through forms without the User’s consent.
5. HOW PROCESSING IS CARRIED OUT
RETENTION, SHARING, SECURITY5.1. Personal data is processed both with and without the use of automation and includes collection, recording, systematisation, accumulation, storage, updating, use, transfer, blocking, deletion and destruction.
5.2. Localisation. Recording, systematisation, accumulation, storage, updating and retrieval of the personal data of citizens of the Russian Federation are carried out using databases located in the territory of the Russian Federation (art. 18(5) of No. 152-FZ).
5.3. Retention. Personal data is kept no longer than the purposes require: until the User withdraws consent, and in any event no longer than 3 years from the last interaction, unless a longer period is required by law (for example, for accounting records). Once the purposes are met or consent is withdrawn, data is destroyed within 30 days.
5.4. Sharing with third parties. The Operator may instruct processors engaged to deliver the services: hosting and email providers, analytics and accounting systems, payment services. Such instruction is governed by a contract requiring confidentiality and compliance with No. 152-FZ. The Operator does not sell personal data.
5.5. Personal data may be disclosed to state authorities on the grounds and in the manner established by the legislation of the Russian Federation.
5.6. Security measures. The Operator applies the legal, organisational and technical measures required by article 19 of No. 152-FZ: limiting who has access to the data; transferring data over HTTPS; storing it on access-controlled servers; keeping software up to date; maintaining records of storage media.
5.7. In the event of a personal data breach the Operator notifies the competent supervisory authority in the manner and within the deadlines set by article 21(3.1) of No. 152-FZ.
6. YOUR RIGHTS
WHAT YOU CAN REQUIRE6.1. The User has the right to:
- obtain information about the processing of their personal data to the extent set out in article 14(7) of No. 152-FZ;
- require correction, blocking or destruction of data that is incomplete, out of date, inaccurate, unlawfully obtained or unnecessary for the stated purpose;
- withdraw consent to the processing of personal data;
- opt out of informational and promotional messages;
- complain to the supervisory authority or bring court proceedings.
6.2. To exercise any of these rights, write to upsalesvideo@gmail.com with the subject line “Personal data”. The Operator replies within 10 working days of receiving the request. A withdrawal of consent is actioned within 30 days.
6.3. Withdrawing consent stops the processing, except where the law permits processing without the data subject’s consent.
7. FINAL PROVISIONS
CHANGES AND DETAILS7.1. The Operator may amend this Policy. A new version takes effect once published on this page unless the new version states otherwise. The current version is always available at https://socode.ru/privacy.
7.2. The law of the Russian Federation applies to all matters relating to the processing of personal data.
Related documents: Consent to personal data processing · Public offer