Personal data processing policy

1. General provisions

1.1. This policy sets out how the sole proprietor Konstantin Igorevich Luchnikov (INN 500603330605, OGRNIP 319505300004064; hereinafter, the operator, we) processes personal data. The document is published in fulfilment of Part 2 of Article 18.1 of Federal Law No. 152-FZ of 27.07.2006 “On Personal Data” (hereinafter, the Personal Data Law).

1.2. The policy applies to data that we receive through the website tacticgu.ru (hereinafter, the website), and when you write to us using the contacts given on the website: on Telegram (@tacticgu_ru), WhatsApp or MAX (links are on the “Contacts” page) or by e-mail at info@tacticgu.ru, or call by phone at +7 999 990-10-09.

1.3. Terms are used in the meaning given in the Personal Data Law.

1.4. The consent to personal data processing and the cookie policy are published separately from this policy.

2. How the website works

2.1. The website has no request forms, registration or personal account. The website does not ask you to enter your name, phone, e-mail or other data by which you could be identified.

2.2. The savings calculator runs in your browser. The numbers you enter are not sent to the server and are not saved. If, after the calculation, you click the review button, Telegram opens with a ready-made message text. Whether to send it is up to you.

2.3. The website does not use traffic counters, advertising pixels or third-party scripts and does not set cookies for visitors. Fonts and images are loaded from the website itself.

2.4. If a request form or a traffic counter appears on the website, we will update this policy before they are launched.

3. Whose and what data we process

3.1. Website visitors. The website’s web server, like any web server, keeps a technical request log: IP address, date and time of the request, address of the requested page, address of the referring page, browser and device information (User-Agent), server response code.

3.2. Those who write to us or call us. If you contact us on Telegram, WhatsApp, MAX or by e-mail, we receive what you send yourself or what is visible in your profile: name or username, e-mail address, phone number (if you provided it), the text of messages and attached files, including the result of the calculator if you sent it. If you call, we receive the phone number the call came from and the information you give in the conversation.

3.3. Clients and their representatives. If a contract is concluded as a result of an inquiry, we process the data needed to conclude and perform it: full name, job title, contacts of the client’s representatives, details.

3.4. We do not process special categories of personal data (about health, political views, religious beliefs, etc.) or biometric data. Please do not send them in your inquiries.

4. Purposes and legal bases

We do not use your data for advertising mailings, and we do not make decisions that give rise to legal consequences for you solely on the basis of automated processing.

5. What we do with the data

5.1. The actions performed with personal data are those needed for the purposes in section 4: collection, recording, systematization, accumulation, storage, clarification (updating, changing), retrieval, use, transfer (provision, access), blocking, deletion and destruction.

5.2. Processing is mixed: with and without the use of automation tools.

5.3. Access to the data is given only to those team members who need it to handle your inquiry or contract. They are bound to keep it confidential.

6. Where data is stored and to whom it is transferred

6.1. The website is hosted on a server in the Russian Federation. The info@tacticgu.ru mailbox runs on the Yandex 360 service. Phone calls go through a mobile carrier; we do not record conversations. Inquiries are processed in the Russian Federation.

6.2. You choose the messenger (Telegram, WhatsApp or MAX) for contacting us yourself. The correspondence there is stored and processed by the owner of that messenger under its own rules; where its servers are located is determined by it, not by us. We ourselves do not carry out cross-border transfer of personal data: we do not transfer it outside the Russian Federation, including to employees or servers in the UAE; information needed to handle your inquiry is moved to our own systems hosted in Russia. If you do not want to use messengers, write to us by e-mail or call.

6.3. We do not sell personal data and do not transfer it to third parties, except where this is necessary to perform a contract with you, where you have consented to it, or where the law requires it (for example, at the request of an authorized government body).

7. Retention periods and destruction

7.1. We keep personal data no longer than the purposes of processing require, unless a longer period is established by law or by contract.

7.2. The web server’s technical log is used only for the operation and protection of the website, is not used to identify a visitor, and is kept no longer than needed for these purposes.

7.3. Correspondence on an inquiry that did not lead to a contract is kept while we are discussing the task. Once the purpose of processing is achieved, the data is destroyed within 30 days (Part 4 of Art. 21 of the Personal Data Law).

7.4. Data from contracts and primary accounting documents is kept for the periods established by accounting and tax legislation.

7.5. If you withdraw your consent, we stop processing and destroy the data within 30 days, unless we have another lawful basis to continue processing (Part 2 of Art. 9, Part 5 of Art. 21 of the Personal Data Law).

8. Your rights

8.1. You have the right to:

• obtain information on whether we process your data, exactly which data, why, on what basis and for how long;
• require us to clarify, block or destroy the data if it is incomplete, outdated, inaccurate, unlawfully obtained or not needed for the stated purpose;
• withdraw your consent to processing;
• appeal our actions or inaction to Roskomnadzor (Russia’s data protection regulator) or in court.

8.2. A request can be sent to info@tacticgu.ru or on Telegram at @tacticgu_ru. Indicate how to contact you and which inquiry or contract it concerns. We may ask you to confirm that the request was sent by you.

8.3. We respond to requests within the periods established by the Personal Data Law: as a rule, within 10 business days of receiving the request. This period may be extended by no more than 5 business days, and we will notify you of this, stating the reason.

9. How we protect the data

9.1. We take the legal, organizational and technical measures provided for by Articles 18.1 and 19 of the Personal Data Law, including:

• the person responsible for organizing personal data processing is the operator himself;
• access to the data is given only to those who need it for work, and only under personal accounts;
• the website works only over the secure HTTPS protocol;
• servers and accounts are protected by passwords and keys, and software is kept updated;
• team members are familiarized with this policy and are bound to maintain confidentiality.

9.2. If we learn of an incident involving personal data, we act in the manner established by the Personal Data Law, including notifying Roskomnadzor within the established periods.

10. Changes to the policy

10.1. We update the policy when the way the website works or the way we process data changes. The new edition is published on this page and takes effect from the date of publication, unless it states otherwise.

10.2. Send questions about the policy and personal data processing to info@tacticgu.ru.