Personal Data Processing Policy on the website
St. Petersburg
October 17, 2025
1. GENERAL PROVISIONS
1.1. This document (hereinafter referred to as the Policy) defines the policy regarding the processing of personal data of users of the website operated by Individual Entrepreneur Penkovsky Konstantin Evgenievich (OGRNIP 325784700021128) (hereinafter referred to as the Operator) on the website in the information and telecommunications network Internet at: https://kpenkovskiy.com/ (hereinafter referred to as the Website).1.2. This Policy has been developed on the basis of paragraph 2, part 1, Article 18.1 of Federal Law No. 152-FZ of July 27, 2006 "On Personal Data," as well as the Recommendations for composing a document defining the operator's policy regarding the processing of personal data, in the manner established by Federal Law No. 152-FZ of July 27, 2006 "On Personal Data."
1.3. In accordance with the requirements of part 2, Article 18.1 of Federal Law No. 152-FZ of July 27, 2006 "On Personal Data," the Policy is published in free access on the information and telecommunications network Internet on the Operator's Website at: https://kpenkovskiy.com/
1.4. This Privacy Policy applies only to the Website. The Operator does not control and is not responsible for third-party websites to which the User may navigate through links available on the Website.
1.5. The concepts contained in Article 3 of Federal Law No. 152-FZ of July 27, 2006 "On Personal Data" are used in this Policy with the same meaning.
1.7. Rights and obligations of the Operator.
1.7.1. The Operator is obliged to:
- process personal data exclusively for the purposes specified in the Policy, in the manner established by the current legislation of the Russian Federation, and take measures necessary and sufficient to ensure the fulfillment of obligations provided for by Federal Law No. 152-FZ of July 27, 2006 "On Personal Data" and regulatory legal acts adopted in accordance with it;
- not distribute personal data without the User's consent, unless otherwise provided by the current legislation of the Russian Federation;
- process personal data in compliance with the principles and rules provided for by Federal Law No. 152-FZ of July 27, 2006 "On Personal Data";
- organize the protection of personal data in accordance with the requirements of the legislation of the Russian Federation;
- review the User's (their legal representative's) requests regarding the processing of personal data and provide reasoned responses;
- provide the User (their legal representative) with the opportunity for free access to their personal data;
- take measures to clarify, block, and destroy the User's personal data in cases established by Federal Law No. 152-FZ of July 27, 2006 "On Personal Data."
- independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations provided for by Federal Law No. 152-FZ of July 27, 2006 "On Personal Data" and regulatory legal acts adopted in accordance with it, unless otherwise provided by Federal Law No. 152-FZ of July 27, 2006 "On Personal Data" or other federal laws;
- entrust the processing of personal data to another person with the User's consent, unless otherwise provided by federal law, based on an agreement concluded with that person, including a state or municipal contract, or by adopting a corresponding act by a state body or municipal body;
- in case of withdrawal of the User's consent to the processing of personal data, continue processing personal data without the User's consent if there are grounds specified in Federal Law No. 152-FZ of July 27, 2006 "On Personal Data";
- receive reliable information and/or documents containing the User's personal data from the User for the processing purposes specified in paragraph 2.2 of the Policy;
- require the User to promptly update the provided personal data.
1.8.1. The User is obliged to:
- ensure the accuracy of personal data provided to the Operator necessary for the processing purposes provided for in paragraph 2.2 of the Policy;
- provide the Operator with information to clarify (update, change) the provided personal data when necessary.
- complete information regarding the processing of their personal data by the Operator, except in cases provided for by the legislation of the Russian Federation;
- clarification of their personal data, blocking or destruction if the personal data is incomplete, outdated, inaccurate, illegally obtained, or is not necessary for the stated purpose of processing;
- withdrawal of consent to the processing of personal data;
- adoption of legally prescribed measures to protect their rights;
- appeal to the authorized body for the protection of the rights of personal data subjects or in court against unlawful actions or inaction of the Operator in processing their personal data;
- giving prior consent to the processing of personal data for the purpose of receiving advertising.
2. PURPOSES OF PERSONAL DATA PROCESSING
2.1. 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. The processed personal data should not be excessive in relation to the stated purposes of their processing. Only personal data that meet the purposes of their processing are subject to processing.2.2. The Operator processes the User's personal data for the following purposes:
2.2.1. Informing about the operation of the Website (Services), monitoring and improving the quality of Services.
2.2.2. Providing the User with access to personalized resources of the Website.
2.2.3. Establishing feedback with the User, including sending notifications, requests regarding the use of the Website, provision of services, performance of work, processing requests and applications from the User.
2.2.4. Conclusion, execution, and termination of civil law contracts.
2.2.5. Providing the User with effective customer and technical support when problems arise related to the use of the Website.
2.2.6. Sending advertising to the User with their prior consent.
3. LEGAL BASIS FOR PERSONAL DATA PROCESSING
3.1. The legal bases for the Operator's processing of personal data are:- The Constitution of the Russian Federation;
- The Civil Code of the Russian Federation;
- Federal Law No. 149-FZ of July 27, 2006 "On Information, Information Technologies and Information Protection";
- Federal Law No. 294-FZ of December 26, 2008 "On Protection of Rights of Legal Entities and Individual Entrepreneurs in the Exercise of State Control (Supervision) and Municipal Control";
- Decree of the President of the Russian Federation No. 188 of March 6, 1997 "On Approval of the List of Confidential Information";
- Resolution of the Government of the Russian Federation No. 1119 of November 1, 2012 "On Approval of Requirements for the Protection of Personal Data During Their Processing in Personal Data Information Systems";
- Order of FSTEC of Russia No. 21 of February 18, 2013 "On Approval of the Composition and Content of Organizational and Technical Measures to Ensure the Security of Personal Data During Their Processing in Personal Data Information Systems";
4. SCOPE AND CATEGORIES OF PROCESSED PERSONAL DATA, CATEGORIES OF PERSONAL DATA SUBJECTS
4.1. The Operator may process personal data of the following Users: visitors to the Operator's website.4.2. Personal data processed by the Operator may include:
- surname, name, patronymic of the User;
- place of residence (region/city);
- mobile phone number;
- email address (e-mail);
- landline phone number;
- links to accounts in social networks and messengers;
- data that is automatically transmitted to the Website Services during their use using software installed on the User's device, namely: IP address, cookie file data, information about the User's browser (or other program used to access the Services), technical characteristics of the equipment and software used by the User, date and time of access to the Services, addresses of requested pages, history of requests and views on the Website and its Services.
- other information (the above list may be reduced or expanded depending on the specific case and processing purposes).
4.4. The Operator does not process biometric personal data, special categories of personal data concerning racial, national origin, political views, religious or philosophical beliefs, intimate life.
5. PROCEDURE AND CONDITIONS FOR PROCESSING PERSONAL DATA
5.1. The Operator processes personal data in accordance with the requirements of the legislation of the Russian Federation in the following ways:- non-automated processing of personal data;
- automated processing of personal data with or without transmission of the obtained information via information and telecommunication networks;
- mixed processing of personal data.
5.3. The processing of personal data is carried out by the Operator subject to obtaining the User's consent (hereinafter referred to as Consent), obtained in accordance with the requirements of Federal Law No. 152-FZ of July 27, 2006 "On Personal Data," except for cases established by the legislation of the Russian Federation when the processing of personal data may be carried out without such Consent.
5.4. The User makes a decision to provide their personal data and gives Consent freely, by their own will and in their own interest.
5.5. The period of personal data processing is determined by the achievement of the purposes for which the personal data was collected, unless another period is provided for by an agreement with the User or current legislation. The condition for terminating the processing of personal data may be the achievement of the purposes of processing personal data or the loss of the need to achieve these purposes, the expiration of the Consent or withdrawal of Consent by the User, as well as the identification of unlawful processing of personal data.
5.6. Consent can be withdrawn in the following way: by sending an email to the following address: k.penkovskiy@pkfuture.io with the note "Withdrawal of consent to the processing of personal data."
5.7. The Operator carries out the distribution of personal data authorized by the User for distribution, that is, performs actions aimed at disclosing them to an indefinite circle of persons, in compliance with the requirements, prohibitions, and conditions established by part 9, Article 9, Article 10.1 of Federal Law No. 152-FZ of July 27, 2006 "On Personal Data." Disclosure to third parties and distribution of personal data without the User's consent is not allowed, unless otherwise provided by federal law. Consent to the processing of personal data authorized by the User for distribution is formalized separately from other consents of the User to the processing of their personal data, taking into account the Requirements for the content of consent to the processing of personal data authorized by the personal data subject for distribution, approved by Order of Roskomnadzor No. 18 of February 24, 2021.
5.8. When processing personal data, the Operator takes or ensures the adoption of necessary legal, organizational, and technical measures to protect personal data from unlawful or accidental access to them, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other unlawful actions regarding personal data.
5.9. Personal data is stored in a form that allows the User to be identified for no longer than the purposes of processing personal data require, except in cases where the period of storage of personal data is established by federal law, an agreement to which the User is a party, beneficiary, or guarantor.
5.10. When processing personal data, the Operator complies with the requirements of Article 18 of Federal Law No. 152-FZ of July 27, 2006 "On Personal Data."
5.11. The Operator undertakes to maintain confidentiality of personal data when processing personal data.
5.12. Cross-border transfer of personal data is not carried out by the Operator.
5.13. In case of unlawful or accidental transfer (provision, distribution, access) of personal data, the Operator informs the User about this within 5 (Five) business days.
5.14. The Operator, together with the User, takes all necessary measures to prevent losses or other negative consequences caused by unlawful or accidental transfer (provision, distribution, access) of the User's personal data.
6. BLOCKING, CLARIFICATION AND DESTRUCTION OF PERSONAL DATA. RESPONSES TO USER REQUESTS FOR ACCESS TO PERSONAL DATA
6.1. In case of identification of unlawful processing of personal data upon the User's (their representative's) request or at the request of the User (their representative) or the authorized body for the protection of the rights of personal data subjects, the Operator blocks unlawfully processed personal data relating to the relevant User, or ensures their blocking from the moment of such request or receipt of the specified request from the User for the period of verification.In case of identification of inaccurate personal data upon the User's or their representative's request or at their request or at the request of the authorized body for the protection of the rights of personal data subjects, the Operator blocks personal data relating to this User, or ensures their blocking from the moment of such request or receipt of the specified request for the period of verification, if blocking personal data does not violate the rights and legitimate interests of the User or third parties.
6.2. In case of confirmation of the fact of inaccuracy of personal data, the Operator, based on information provided by the User (their representative) or the authorized body for the protection of the rights of personal data subjects, or other necessary documents, clarifies personal data or ensures their clarification within seven business days from the date of submission of such information.
6.3. In case of identification of unlawful processing of personal data, the Operator, within a period not exceeding three business days from the date of this identification, terminates unlawful processing of personal data or ensures termination of unlawful processing of personal data, and in case it is impossible to ensure the lawfulness of personal data processing, within a period not exceeding ten business days from the date of identification of unlawful processing of personal data, destroys such personal data or ensures their destruction.
6.4. In case of achieving the purpose of processing personal data, the Operator destroys personal data or ensures their destruction within a period not exceeding thirty days from the date of achieving the purpose of processing personal data, unless otherwise provided by an agreement to which the User is a party, beneficiary or guarantor, another agreement between the Operator and the User, or if the Operator is not entitled to process personal data without the User's consent on the grounds provided for by Federal Law No. 152-FZ of July 27, 2006 "On Personal Data" or other federal laws.
6.5. In case of withdrawal of the User's consent to the processing of their personal data and in case the storage of personal data is no longer required for the purposes of processing personal data, the Operator destroys personal data or ensures their destruction within a period not exceeding thirty days from the date of receipt of the specified withdrawal, unless otherwise provided by an agreement to which the User is a party, beneficiary or guarantor, another agreement between the Operator and the User, or if the Operator is not entitled to process personal data without the User's consent on the grounds provided for by Federal Law No. 152-FZ of July 27, 2006 "On Personal Data" or other federal laws.
6.6. Within a period not exceeding seven business days from the date of submission by the User (their representative) of information confirming that such personal data is illegally obtained or is not necessary for the stated purpose of processing, the Operator destroys such personal data.
6.7. Processed personal data is subject to destruction in case of loss of the need to achieve the purposes of processing, unless otherwise provided by federal law.
6.8. The Operator responds to requests and appeals of the User (their representative) regarding their processing of personal data by sending a corresponding request by email to k.penkovskiy@pkfuture.io.
7. LIABILITY OF THE PARTIES
7.1. The Operator is liable for violation of the requirements of Federal Law No. 152-FZ of July 27, 2006 "On Personal Data" in accordance with the legislation of the Russian Federation.7.2. The User has the right to demand compensation for losses and/or compensation for moral damage in court. Moral damage caused to the User as a result of violation of their rights, violation of the rules for processing personal data, as well as requirements for the protection of personal data established in accordance with Federal Law No. 152-FZ of July 27, 2006 "On Personal Data," as well as the provisions of the Policy, is subject to compensation in accordance with the legislation of the Russian Federation. Compensation for moral damage is carried out regardless of compensation for property damage and losses incurred by the User.
8. DISPUTE RESOLUTION
8.1. In case of disputes and/or disagreements arising from relations between the User and the Operator, such issues are resolved in accordance with the current legislation of the Russian Federation.8.2. The current legislation of the Russian Federation applies to the Policy and relations between the User and the Operator.
9. FINAL PROVISIONS
9.1. The Operator has the right to make changes to the Policy without the User's consent.9.2. The new version of the Policy comes into force from the moment of its posting on the Website, unless otherwise provided by the new version of the Policy. The new version of the Policy applies to relations arising after its entry into force.
9.3. All suggestions or questions regarding the Policy should be reported by email to k.penkovskiy@pkfuture.io