Policy on the Processing of Personal Data

General provisions

This policy on the processing of personal data establishes the procedure for processing personal data and measures to ensure the security of personal data taken by MF Consult Co., Ltd (hereinafter referred to as the Operator).
1.1. The Operator sets compliance with the rights and freedoms of individuals as its most important goal and condition for carrying out its activities when processing their personal data, including the protection of the rights to privacy, personal and family secrets.
1.2. This Policy applies to all information that the Operator may obtain about visitors to the website https://www.mfconsult.co.


Key terms used in the Policy

2.1. Automated processing of personal data - processing of personal data using computer technology.
2.2. Blocking of personal data - temporary suspension of the processing of personal data (except in cases where processing is necessary to clarify personal data).
2.3. Website - a set of graphic and informational materials, as well as computer programs and databases that provide their accessibility on the Internet at the network address https://www.mfconsult.co.
2.4. Personal data information system - a set of personal data contained in databases and ensuring their processing through information technologies and technical means.
2.5. Depersonalization of personal data - actions that make it impossible to determine, without using additional information, the belonging of personal data to a specific User or other subject of personal data.
2.6. Processing of personal data - any action (operation) or a combination of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
2.7. Operator - a state authority, municipal authority, legal entity, or individual who independently or jointly with others organizes and/or carries out the processing of personal data, as well as determines the purposes of processing personal data, the composition of personal data subject to processing, actions (operations) performed with personal data.
2.8. Personal data - any information directly or indirectly related to a specific or identifiable User of the website https://www.mfconsult.co.
2.9. Personal data permitted for distribution by the subject of personal data - personal data that the subject of personal data has consented to for processing and distribution in the manner provided by the Personal Data Law (hereinafter referred to as personal data permitted for distribution).
2.10. User - any visitor to the website https://www.mfconsult.co.
2.11. Provision of personal data - actions aimed at disclosing personal data to a specific person or a specific circle of persons.
2.12. Distribution of personal data - any actions aimed at disclosing personal data to an indefinite circle of persons (transferring personal data) or providing access to personal data to an unlimited number of persons, including making personal data publicly available in mass media, placing in information and telecommunications networks, or providing access to personal data in any other way.
2.13. Cross-border transfer of personal data - the transfer of personal data to the territory of a foreign state to the authority of a foreign state, foreign individual, or foreign legal entity.
2.14. Destruction of personal data - any actions as a result of which personal data is destroyed irreversibly with the impossibility of further restoring the content of personal data in the information system of personal data and


Main Rights and Obligations of the Operator

3.1. The Operator has the right to:
  • receive reliable information and/or documents containing personal data from the subject of personal data;
  • in the event of withdrawal by the subject of personal data of consent to the processing of personal data, as well as the submission of a request to cease the processing of personal data, the Operator has the right to continue processing personal data without the consent of the subject of personal data if there are grounds specified in the Personal Data Law;
  • independently determine the scope and list of measures necessary and sufficient to ensure the fulfillment of obligations provided by the Personal Data Law and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.
  • 3.2. The Operator is obliged to:
  • provide the subject of personal data, upon their request, with information regarding the processing of their personal data;
  • organize the processing of personal data in accordance with the current legislation of the Russian Federation;
  • respond to inquiries and requests from the subjects of personal data and their legal representatives in accordance with the requirements of the Personal Data Law;
  • provide the necessary information to the authorized body for the protection of the rights of the subjects of personal data within 10 days from the date of receiving such a request;
  • publish or otherwise ensure unrestricted access to this Policy on the processing of personal data;
  • take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access to them, destruction, alteration, blocking, copying, provision, distribution of personal data, as well as other unauthorized actions with respect to personal data;
  • cease the transfer (distribution, provision, access) of personal data, cease processing, and destroy personal data in accordance with the procedures and cases provided by the Personal Data Law;
  • fulfill other obligations provided by the Personal Data Law.


Main Rights and Obligations of the Data Subjects

4.1. Data subjects have the right to:
  • receive information regarding the processing of their personal data, except in cases provided by federal laws. The information is provided to the data subject by the Operator in an accessible form and should not contain personal data related to other data subjects unless there are legal grounds for the disclosure of such personal data. The list of information and the procedure for its receipt are determined by the Personal Data Law;
  • request the Operator to clarify their personal data, block or destroy it if the personal data is incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the stated purpose of processing, as well as take measures provided by law to protect their rights;
  • impose a condition of preliminary consent for the processing of personal data for marketing purposes;
  • withdraw consent to the processing of personal data, as well as submit a request to cease the processing of personal data;
  • appeal to the authorized body for the protection of the rights of data subjects or file a lawsuit against the Operator in case of unlawful actions or inaction regarding the processing of their personal data;
  • exercise other rights provided by the legislation of the Russian Federation.
  • 4.2. Data subjects are obliged to:
  • provide the Operator with accurate information about themselves;
  • inform the Operator about any updates or changes to their personal data.
  • 4.3. Individuals who provide the Operator with false information about themselves or information about another data subject without their consent bear responsibility in accordance with the legislation of the Russian Federation.

Principles of Personal Data Processing

5.1. Personal data processing is carried out on a legal and fair basis.
5.2. The processing of personal data is limited to achieving specific, predetermined, and lawful purposes. Processing of personal data incompatible with the purposes of collecting personal data is not allowed.
5.3. The merging of databases containing personal data processed for incompatible purposes is not permitted.
5.4. Only personal data that corresponds to the purposes of its processing shall be subject to processing.
5.5. The content and volume of processed personal data shall correspond to the stated purposes of processing. Redundancy of processed personal data in relation to the stated purposes of processing is not allowed.
5.6. When processing personal data, accuracy, sufficiency, and, if necessary, relevance of the personal data to the purposes of processing are ensured. The Operator takes necessary measures and/or ensures their adoption to delete or clarify incomplete or inaccurate data.
5.7. Personal data shall be stored in a form that allows the identification of the data subject for a period not exceeding the purposes of personal data processing, unless the storage period for personal data is established by federal law, a contract in which the data subject is a party, beneficiary, or guarantor. Processed personal data shall be destroyed or depersonalized upon achieving the purposes of processing or in case there is no longer a need to achieve these purposes, unless otherwise provided by federal law.


Purposes of Personal Data Processing
Processing Purpose: Consultation and notification of the User about the company's products and services
Personal Data: Email address, phone numbers, name
Legal Basis: Charter (constituent) documents of the Operator
Types of Personal Data Processing: Sending informational emails to the email address
Legal Basis: Federal Law "On Information, Information Technologies, and Information Protection" dated July 27, 2006, No. 149-FZ
Types of Personal Data Processing: Collection, recording, systematization, accumulation, storage, destruction, and depersonalization of personal data
Sending informational emails to the email address


Conditions of Personal Data Processing

7.1. Personal data processing is carried out with the consent of the data subject for the processing of their personal data.
7.2. Personal data processing is necessary to achieve the goals stipulated by an international treaty of the Russian Federation or by law, for the performance of functions, powers, and duties imposed by the legislation of the Russian Federation on the Operator.
7.3. Personal data processing is necessary for the administration of justice, enforcement of a court decision, an act of another authority or official, subject to enforcement in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. Personal data processing is necessary for the performance of a contract to which the data subject is a party, beneficiary, or guarantor, as well as for the conclusion of a contract at the initiative of the data subject or a contract under which the data subject will be a beneficiary or guarantor.
7.5. Personal data processing is necessary to exercise the rights and legitimate interests of the Operator or third parties, or to achieve socially significant goals, provided that the rights and freedoms of the data subject are not violated.
7.6. Personal data processing is carried out with personal data that has been made publicly available by the data subject or at their request (hereinafter referred to as publicly available personal data).
7.7. Personal data processing is carried out with personal data that is subject to publication or mandatory disclosure in accordance with federal law.


Procedure for Collection, Storage, Transmission, and Other Types of Personal Data Processing

The security of personal data processed by the Operator is ensured through the implementation of legal, organizational, and technical measures necessary to fully comply with the requirements of the current legislation on personal data protection.

8.1. The Operator ensures the security of personal data and takes all possible measures to prevent unauthorized access to personal data.
8.2. The User's personal data will never be transferred to third parties under any circumstances, except in cases related to the execution of current legislation or when the data subject has given consent to the Operator for the transfer of data to a third party to fulfill obligations under a civil contract.
8.3. In case of inaccuracies in personal data, the User can update them independently by sending a notification to the Operator's email address contact@mfconsult.co with the subject line "Updating Personal Data."
8.4. The processing period of personal data is determined by the achievement of the purposes for which the personal data were collected, unless otherwise specified in the contract or current legislation. The User may revoke their consent to the processing of personal data at any time by sending a notification to the Operator via email to the Operator's email address contact@mfconsult.co with the subject line "Revocation of Consent to Personal Data Processing."
8.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by those entities (Operators) in accordance with their User Agreement and Privacy Policy. The data subject should refer to the respective documents. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this section.
8.6. Prohibitions on the transfer (except for providing access) and processing (except for obtaining access) of personal data, as well as conditions for processing personal data permitted for dissemination, do not apply in cases of personal data processing in the public interest, as defined by Russian legislation.
8.7. The Operator ensures the confidentiality of personal data during their processing.
8.8. The Operator stores personal data in a form that allows identifying the data subject for a period no longer than necessary for the purposes of personal data processing, unless the storage period of personal data is established by federal law, a contract to which the data subject is a party, beneficiary, or guarantor.
8.9. The termination of personal data processing may occur upon achieving the purposes of personal data processing, expiration of the consent period given by the data subject, revocation of the data subject's consent, or upon request to cease processing personal data, as well as in case of unlawful processing of personal data being identified.


List of Actions Performed by the Operator with Acquired Personal Data

9.1. The Operator carries out the collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transmission (distribution, provision, access), de-identification, blocking, deletion, and destruction of personal data.
9.2. The Operator carries out automated processing of personal data, including obtaining and/or transmitting the received information through information and telecommunication networks or without them.


Cross-Border Transfer of Personal Data

10.1. Before commencing activities related to the cross-border transfer of personal data, the Operator must notify the authorized body for the protection of the rights of personal data subjects about their intention to carry out such cross-border transfer of personal data (this notification is sent separately from the notification regarding the intention to process personal data).
10.2. Before submitting the aforementioned notification, the Operator must obtain relevant information from the authorities of a foreign state, foreign individuals, or foreign legal entities to whom the cross-border transfer of personal data is planned.


Confidentiality of Personal Data
11.1. The Operator and other individuals who have access to personal data are obligated not to disclose personal data to third parties and not to disseminate personal data without the consent of the data subject, unless otherwise provided by federal law.

Final Provisions

12.1. The User can obtain any clarifications regarding the processing of their personal data by contacting the Operator via email at contact@mfconsult.co.
12.2. Any changes to the policy for processing personal data by the Operator will be reflected in this document. The policy is valid indefinitely until it is replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet at https://www.mfconsult.co/privacy.