1. General Provisions

This personal data processing policy is drawn up in accordance with the requirements of the Federal Law No. 152-FZ "On Personal Data" dated July 27, 2006 (hereinafter referred to as the Personal Data Law) and defines the procedure for processing personal data and measures to ensure the security of personal data of clients and other individuals undertaken by Call Solutions Limited Liability Company (hereinafter referred to as the Operator).

1.1. The Operator considers the observance of human and civil rights and freedoms during the processing of personal data, including the protection of the rights to privacy, personal and family secrets, as one of its most important conditions for carrying out its activities.

1.2. This Policy of the Operator regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator may receive about visitors to the website https://callsolutions.info/ .

2. Key Terms Used in the Policy

2.1. Automated Processing of Personal Data - the processing of personal data using computer technology.

2.2. Blocking of Personal Data - temporary cessation of the processing of personal data (except in cases where processing is necessary to clarify personal data).

2.3. Website - a collection of graphic and informational materials, as well as software and databases, that ensure their availability on the internet at the web address https://callsolutions.info/ .

2.4. Personal Data Information System - a set of personal data contained in databases, and the information technologies and technical means that ensure their processing.

2.5. Processing of Personal Data - any action (operation) or a set of actions (operations) performed with or without the use of automation tools with personal data, including the collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.

2.6 Operator - Call Solutions Limited Liability Company (OGRN 1197847104927, TIN 7810757289, address: 196247, Russia, St. Petersburg, Constitution Square, 3, Bldg. 2)

2.7. Personal Data - any information directly or indirectly related to a specific or identifiable User of the website https://callsolutions.info/ .

2.8. Personal Data Allowed for Distribution by the Personal Data Subject - personal data to which an unlimited number of people have access, granted by the personal data subject through consent for the processing of personal data allowed for distribution in the manner prescribed by the Personal Data Law (hereinafter referred to as personal data allowed for distribution).

2.9. User - any visitor to the website https://callsolutions.info/ .

2.10. Provision of Personal Data - actions aimed at disclosing personal data to a specific person or a specific group of persons.

2.11. Distribution of personal data - any actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or at making personal data available to an unlimited number of persons, including making personal data public in the media, posting in information and telecommunication networks, or providing access to personal data in any other way.

2.12. Destruction of Personal Data - any actions that result in the irreversible destruction of personal data, making it impossible to further restore the content of personal data in the personal data information system and/or resulting in the destruction of tangible media containing personal data.

2.13. Depersonalization of Personal Data - actions that make it impossible to determine, without the use of additional information, the ownership of personal data by a specific User or another personal data subject.

3. Main Rights and Responsibilities of the Operator

3.1. The Operator has the right to:

• Obtain accurate information and/or documents containing personal data from the personal data subject;
• In the event that the personal data subject withdraws their consent for the processing of personal data, or submits a request demanding the cessation of personal data processing, the Operator has the right to continue processing the personal data without the consent of the personal data subject if there are grounds specified in the Personal Data Law;
• Independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of the obligations stipulated by the Personal Data Law and the 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 obligated to:

• provide the personal data subject, upon their request, with information related to the processing of their personal data;
• organize the processing of personal data in accordance with the procedures established by the current legislation of the Russian Federation;
• respond to inquiries and requests from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
• provide the authorized agency for the protection of the rights of personal data subjects with the necessary information within 10 calendar days from the date of receiving such a request from the agency;
• publish or otherwise ensure unrestricted access to this Policy regarding the processing of personal data;
• take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, alteration, blocking, copying, provision, dissemination of personal data, as well as from other unlawful actions concerning personal data;
• cease processing and destruct personal data in the manner and cases provided for by the Personal Data Law;
• fulfill other obligations of the Operator as stipulated by the Personal Data Law.

4. Main Rights and Responsibilities of Personal Data Subjects

4.1. Personal Data Subjects have the right to:

• obtain information related to the processing of their personal data, except in cases provided by federal laws. The information is provided to the personal data subject by the Operator in an accessible form and should not contain personal data related to other personal data subjects, except when there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
• request the Operator to clarify their personal data, or to delete it if the personal data is incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the stated purpose of processing, and to take legal measures to protect their rights;
• set a condition of prior consent for the processing of personal data for the purpose of promoting goods, works, and services on the market;
• withdraw consent for the processing of personal data, as well as submit a demand to cease the processing of personal data;
• appeal to the authorized agency for the protection of the rights of personal data subjects or to a court regarding unlawful actions or inaction of the Operator in the processing of their personal data;
• exercise other rights provided by the legislation of the Russian Federation.

4.2. Personal Data Subjects are obligated to:

• provide the Operator with accurate data about themselves;
• inform the Operator about the clarification (updating, modification) of their personal data.

5. Principles of Personal Data Processing

5.1. The processing of personal data is carried out on a lawful and fair basis.

5.2. The processing of personal data is limited to the achievement of specific, predetermined, and lawful purposes. Processing of personal data that is incompatible with the purposes of data collection is not allowed.

5.3. The merging of databases containing personal data, the processing of which is carried out for purposes incompatible with each other, is not allowed.

5.4. Only personal data that meets the purposes of their processing is subject to processing.

5.5. The content and scope of the processed personal data must correspond to the stated purposes of processing. The processed personal data must not be excessive in relation to the stated purposes of processing.

5.6. During the processing of personal data, the accuracy, sufficiency, and, where necessary, relevance of personal data in relation to the purposes of processing must be ensured. The Operator takes the necessary measures and/or ensures that incomplete or inaccurate data is deleted or clarified.

5.7. The storage of personal data is carried out in a form that allows identifying the personal data subject no longer than required by the purposes of personal data processing unless a longer storage period is established by federal law, a contract to which the personal data subject is a party, beneficiary, or guarantor. The processed personal data is destructed or depersonalized upon achieving the purposes of processing or when it is no longer necessary to achieve those purposes unless otherwise provided by federal law.

6. Purpose of Personal Data Processing

6.1. The anonymized data of Users collected through internet statistics services is used to gather information about Users' actions on the website, improve the quality of the website, and enhance its content.

7. Conditions for Personal Data Processing

7.1. The processing of personal data is carried out with the consent of the personal data subject for the processing of their personal data.

7.2. The processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, and to perform the functions, powers, and duties imposed on the operator by the legislation of the Russian Federation.

7.3. The processing of personal data is necessary for the administration of justice, the execution of a judicial act, or an act of another body or official to be executed in accordance with the legislation of the Russian Federation on enforcement proceedings.

7.4. The processing of personal data is necessary for the performance of a contract to which the personal data subject is a party, beneficiary, or guarantor, as well as for the conclusion of a contract at the initiative of the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor.

7.5. The processing of personal data is necessary for the exercise of the rights and legitimate interests of the operator or third parties, or for the achievement of socially significant goals, provided that this does not violate the rights and freedoms of the personal data subject.

7.6. The processing of personal data is carried out in relation to personal data that has been made publicly available by the personal data subject or at their request (hereinafter referred to as publicly accessible personal data).

7.7. The processing of personal data is carried out when such data is subject to publication or mandatory disclosure in accordance with federal law.

8. Procedure for the Collection, Storage, Transfer, and Other Types of Processing of Personal Data

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

8.2. The Operator ensures the safekeeping of personal data and takes all possible measures to prevent unauthorized access to personal data.

8.3. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to compliance with current legislation or if the personal data subject has given consent to the Operator to transfer the data to a third party for the fulfillment of obligations under a civil law contract.

8.4. If any inaccuracies are found in the personal data, the User can update them independently by sending a notification to the Operator's email address at hr@callsolutions.info with the subject line "Personal Data Update."

8.5. The duration of personal data processing is determined by the achievement of the purposes for which the personal data was collected unless otherwise specified by the contract or applicable law.

The User may withdraw their consent to the processing of personal data at any time by sending a notification to the Operator via hr@callsolutions.info with the subject line "Withdrawal of Consent for Personal Data Processing."

8.6. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by these entities (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject is responsible for familiarizing themselves with these documents. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this clause.

8.7. Restrictions imposed by the personal data subject on the transfer (except for granting access), as well as on the processing or conditions of processing (except for gaining access) of personal data allowed for dissemination, do not apply in cases where personal data is processed for state, public, and other public interests as defined by the legislation of the Russian Federation.

8.8. The Operator ensures the confidentiality of personal data during its processing.

8.9. The Operator stores personal data in a form that allows the identification of the personal data subject for no longer than is required to achieve the purposes of personal data processing unless a longer storage period is established by federal law or a contract to which the personal data subject is a party, beneficiary, or guarantor.

8.10. The conditions for terminating the processing of personal data may include the achievement of the purposes for which the personal data was processed, the expiration of the personal data subject's consent, the withdrawal of consent by the personal data subject, or a request to stop processing the personal data, as well as the detection of unlawful processing of personal data.

9. List of Actions Performed by the Operator with the Received Personal Data

9.1. The Operator carries out the collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.

9.2. The Operator performs automated processing of personal data with the receipt and/or transfer of the obtained information via information and telecommunication networks or without such networks.

10. Confidentiality of Personal Data

10.1. The Operator and other persons who have access to personal data are obligated not to disclose or distribute personal data to third parties without the consent of the personal data subject, unless otherwise provided by federal law.

11. Final Provisions

11.1. The User can obtain any clarifications on questions of interest regarding the processing of their personal data by contacting the Operator via email address hr@callsolutions.info.

11.2. Any changes to the Operator's personal data processing policy will be reflected in this document. The Policy is valid indefinitely until it is replaced by a new version.

11.3. The current version of the Policy is publicly available on the internet at https://callsolutions.info/ .