Privacy Policy

Policy of Limited Liability Company "Goriahiy Sever" Regarding Personal Data Processing

1. General Provisions

This Policy of Limited Liability Company “Goriahiy Sever” regarding personal data processing (hereinafter referred to as the “Policy”) has been developed in accordance with paragraph 2, part 1, Article 18.1 of Federal Law No. 152-FZ of July 27, 2006, “On Personal Data” (hereinafter referred to as the Personal Data Law) to ensure the protection of the rights and freedoms of individuals during the processing of their personal data, including the protection of rights to privacy, personal, and family confidentiality when visiting the website with the domain name https://dedborey.ru (hereinafter referred to as the “Website”). The Operator is not responsible for information posted on third-party websites that the User may access via links available on the Website.

This Policy applies to all personal data processed by the Limited Liability Company “Goriahiy Sever” (hereinafter referred to as the “Operator” or LLC "Goriahiy Sever") during the User's visit to and use of the Website. The Operator does not verify the accuracy of Personal Data provided.

Using the Website's content and any of its functionalities, including providing your full name and phone number in the “Callback” form, constitutes the User’s unconditional acceptance of this Policy, including its terms, purposes, and rules for collecting and processing Personal Data. If the User disagrees, they must immediately cease using the Website.

This Policy applies to relationships in the field of personal data processing that arose both before and after its approval by the Operator.

In accordance with part 2, Article 18.1 of the Personal Data Law, this Policy is published for free access in the information and telecommunications network, the Internet, on the Operator's Website.

Key Terms Used in the Policy

Automated processing of personal data: Processing of personal data using computer technology.
Blocking of personal data: Temporary suspension of personal data processing (except in cases where processing is necessary to clarify personal data).
Personal data information system: A set of personal data contained in databases and the information technologies and technical means ensuring its processing.
Website Content (hereinafter referred to as “Content”): Any information published on the Website, in any format (graphic, text, photo, audio, video), including information about the educational process, training programs, and other details.
Anonymization of personal data: Actions that make it impossible to determine the subject of personal data without additional information.
Personal data processing: Any operation or set of operations performed with personal data, with or without automation tools, including:

Collection;
Recording;
Systematization;
Accumulation;
Storage;
Clarification (updating, modification);
Retrieval;
Use;
Transfer (distribution, provision, access);
Anonymization;
Blocking;
Deletion;
Destruction.

Personal data operator (Operator): Limited Liability Company “Goriahiy Sever,” Taxpayer Identification Number (INN): 5118 0060 84, Tax Registration Reason Code (KPP): 511 801 001, Primary State Registration Number (OGRN): 12351 00000 277, Registered Address: 184250, Russia, Murmansk Region, Kirovsk, Kommunalnaya Street, 9.
Personal data: Any information related directly or indirectly to an identified or identifiable individual (personal data subject/User).
Provision of personal data: Actions aimed at disclosing personal data to a specific person or a defined group of persons.
Website User (hereinafter referred to as the “User”): Any individual using the Website as intended.
Distribution of personal data: Actions aimed at disclosing personal data to an indefinite number of persons.
Website: A set of computer programs, mobile device tools, and other information contained in the information system, accessible via the Internet at https://dedborey.ru.
Parties: The Operator and the User collectively.
Destruction of personal data: Actions that make it impossible to restore the content of personal data in the personal data information system and/or result in the destruction of physical carriers of personal data.
Cookies: Small text files stored on the User’s computer or mobile device to save browsing preferences. These files are downloaded during the first visit to the Website via the browser. On subsequent visits from the same device, the browser can check for a relevant cookie file (associated with the Website) and use its data to send them back to the Website. This allows the Operator to determine whether the Website has been accessed before from that browser and, in some cases, modify the displayed Content accordingly. Cookies facilitate Website usage and provide Users with appropriate Content. They are used for research and statistical purposes to improve the services provided by the Website.
IP Address: A unique identifier (address) of a device (computer or mobile device) connected to a local or Internet network.

Key Rights and Responsibilities of the Operator

The Operator has the right to:

Independently determine the scope and list of measures necessary and sufficient to fulfill obligations under the Personal Data Law and related regulations, unless otherwise provided by the Personal Data Law or other federal laws.
Delegate the processing of personal data to another party with the User's consent, unless otherwise provided by federal law, under a contract concluded with this party. The party processing personal data on behalf of the Operator must adhere to the principles and rules of personal data processing stipulated in the Personal Data Law, maintain confidentiality, and take necessary measures to ensure compliance with the obligations outlined in the Personal Data Law.
Continue processing personal data without the User's consent in case of consent withdrawal, provided that there are grounds specified in the Personal Data Law.
Receive information and/or documents containing personal data from the User.

The Operator is obligated to:

Organize the processing of personal data in compliance with the requirements of the Personal Data Law.
Respond to inquiries and requests from personal data subjects or their legal representatives in accordance with the requirements of the Personal Data Law.
Provide necessary information to the authorized body for protecting personal data rights (Federal Service for Supervision in the Sphere of Telecom, Information Technologies, and Mass Communications, hereinafter "Roskomnadzor") upon its request within 10 business days from receiving the request. This term may be extended by no more than five business days, provided the Operator sends Roskomnadzor a justified notification stating the reasons for the extension.
Cooperate with the state system for detecting, preventing, and mitigating the consequences of computer attacks on Russian Federation information resources, including reporting computer incidents that resulted in the unauthorized transmission (provision, dissemination, access) of personal data, in accordance with procedures defined by the authorized federal executive body.
Provide the User with information regarding the processing of their personal data upon request.
Publish or otherwise ensure unrestricted access to this Policy on personal data processing.
Take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, alteration, blocking, copying, provision, dissemination, and other unlawful actions.
Cease the transfer (dissemination, provision, access) of personal data, terminate processing, and destroy personal data in the manner and in cases stipulated by the Personal Data Law.
Fulfill other obligations stipulated by the Personal Data Law.

Key Rights of the Personal Data Subject (User)

The User has the right to:

Obtain information about the processing of their personal data, except in cases stipulated by federal laws. This information is provided by the Operator in an accessible format and should not include personal data of other subjects, except when lawful grounds exist for such disclosure. The scope of information and procedure for obtaining it are defined by the Personal Data Law.
Demand that the Operator clarify, block, or destroy their personal data if the data is incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the stated purpose of processing, as well as take legal measures to protect their rights.
Provide prior consent for the processing of personal data for marketing purposes related to goods, works, or services.
File a complaint with Roskomnadzor or pursue legal action against unlawful acts or omissions by the Operator during personal data processing.
Withdraw their consent to the processing of personal data.
Exercise other rights stipulated by the Personal Data Law.

User Obligations

The User is obligated to:

Provide the Operator with accurate personal data about themselves.
Inform the Operator about updates (corrections, changes) to their personal data.

Supervision and Responsibility

Compliance with the requirements of this Policy is overseen by an authorized individual responsible for organizing personal data processing at the Operator. Responsibility for violations of the legislation of the Russian Federation and local regulations of LLC "Goriahiy Sever" concerning personal data processing and protection is determined in accordance with Russian Federation legislation. Individuals who provide the Operator with false information about themselves or other personal data subjects without their consent bear responsibility in accordance with Russian Federation legislation.

2. Principles of Personal Data Processing

Legality and Fairness:
Personal data is processed on a lawful and fair basis. Combining databases containing personal data processed for incompatible purposes is prohibited.
Purpose Compliance:
The content and scope of the processed personal data correspond to the declared purposes of processing. Excessive processing of personal data in relation to the stated purposes is not permitted.
Accuracy and Relevance:
When processing personal data, accuracy, sufficiency, and relevance to the purposes of processing are ensured. The operator takes necessary measures or ensures such measures are taken to delete or update incomplete or inaccurate data.
Data Retention:
Personal data is stored in a form that allows identification of the user no longer than required by the purposes of data processing unless a federal law, contract, or another legal agreement specifies otherwise. Processed personal data is destroyed or anonymized upon achieving the processing purposes or when the necessity of achieving these purposes is lost, unless otherwise provided by federal law.

3. Purposes of Personal Data Collection

Personal data processing is limited to achieving specific, predetermined, and lawful purposes. Processing incompatible with the purposes of collection is not allowed.
Only personal data relevant to the stated purposes is subject to processing.

The operator processes personal data to carry out activities in accordance with the charter of LLC "Goriahiy Sever", including:

User identification registered on the website.
Submission of applications for training under the operator's educational programs.
Execution, performance, and termination of civil law contracts.
Providing users with access to personalized resources on the website.
Establishing feedback with users, including notifications or requests related to site use, query handling, and registrations.
Fraud prevention.
Verification of the accuracy and completeness of personal data.
User registration status notifications.
Processing, receiving, and disputing payments from users.
Providing customer and technical support for website-related issues.
Sending information about new educational programs offered by the operator.
Conducting advertising campaigns.

The operator may send notifications to users about new products and services, special offers, and various events. Users can opt out of receiving informational messages by sending an email to hot.sever@mail.ru with the subject line "Unsubscribe."

Anonymized user data collected via internet analytics services is used to gather information about user activities on the website, improving the site's quality and content.

4. Legal Grounds for Personal Data Processing

The legal grounds for processing personal data include a set of regulatory legal acts under which and in accordance with which the operator processes personal data, including:

The Constitution of the Russian Federation.
The Civil Code of the Russian Federation.
The Tax Code of the Russian Federation.
Federal Law No. 14-FZ dated February 8, 1998, "On Limited Liability Companies."
Federal Law No. 402-FZ dated December 6, 2011, "On Accounting."
Other regulatory legal acts governing relationships related to the operator's activities.

Additional legal grounds for processing personal data include:

The charter of LLC "Goriahiy Sever."
Agreements between the operator and personal data subjects (users).
User consent for processing their personal data.

The operator processes user personal data only when submitted by the user via special forms on the website or through email, including as part of submitted documents. By filling out the respective forms or sending their personal data to the operator, the user consents to this policy.

The user voluntarily decides to provide their personal data and gives consent freely, by their own will, and in their interest.

5. Scope and Categories of Processed Personal Data

Categories of Data Subjects

The Operator may process the following personal data of Users:

Last name, first name, and patronymic.
Email address.
Phone numbers.
Year, month, date, and place of birth.
Photographs.
Citizenship details.
Identification document details.
Pension insurance certificate number, and registration date in the mandatory pension system.
Education document details.
Information about education, profession, specialty, and qualifications, including education document details.
Income information.
Information on previously held positions, work experience, military service, and registration for military duty.

Additionally, anonymized data about website visitors is collected and processed (including "cookie" files) using internet analytics services (e.g., Yandex.Metrica, Google Analytics, and others).

The Operator does not process special categories of personal data related to race, ethnicity, political views, religious or philosophical beliefs, or intimate life.

The Operator processes biometric personal data (characteristics defining physiological and biological traits of individuals, enabling their identification) in compliance with Russian Federation legislation.

The processing of personal data permitted for dissemination, from special categories defined in Part 1 of Article 10 of the Personal Data Law, is allowed if restrictions and conditions outlined in Article 10.1 of the Personal Data Law are observed.

User consent for processing personal data permitted for dissemination must be provided separately from other consents for personal data processing, in compliance with Article 10.1 of the Personal Data Law. The requirements for such consent are established by the authority responsible for personal data protection.

Consent for processing such data must be provided directly by the User to the Operator. Within three working days of receiving this consent, the Operator must publish information regarding the conditions, restrictions, and provisions for processing personal data accessible to an indefinite number of persons.

The transfer (distribution, provision, or access) of personal data permitted by the data subject for dissemination must cease immediately upon the User’s request. This request should include the User's full name, contact details (phone number, email address, or postal address), and a list of personal data for which processing must be terminated.

Such consent ceases to be valid upon receipt of the User's request as described in Section 9 of the Personal Data Processing Policy.

The Operator does not process special categories of personal data related to race, ethnicity, political views, religious or philosophical beliefs, health conditions, or intimate life, except as required by Russian law.

6. Procedure and Conditions for Personal Data Processing

The Operator processes personal data in compliance with the laws of the Russian Federation. Processing occurs with the User's consent, unless otherwise required by Russian law.

Methods of Processing:

Non-automated personal data processing.
Automated personal data processing with or without information transfer over telecommunication networks.
Mixed personal data processing.

Employees responsible for processing personal data within the Operator’s organization are granted access based on their job duties.

Processing Activities Include:

Obtaining data directly from data subjects orally or in writing.
Recording data into logs, registries, and information systems.
Using other methods of personal data processing.

Personal data will not be transferred to third parties under any circumstances, except as required by law or with the User's explicit consent to fulfill contractual obligations.

Measures for Data Protection:

Identifying risks to personal data security.
Implementing local regulations governing personal data processing and protection.
Appointing personnel responsible for ensuring data security in structural units and information systems.
Ensuring secure conditions for working with personal data.
Organizing record-keeping of documents containing personal data.
Managing information systems that process personal data.
Storing personal data securely, preventing unauthorized access.
Conducting training for employees involved in personal data processing.

Storage and Retention:

Personal data is stored in a form allowing User identification, only as long as necessary for the purposes of processing unless otherwise required by law or contract.
Physical records are retained following Russian Federation archival laws.
Data processed in information systems follows the same retention periods as physical records.

Termination of Processing:

Processing ends in the following cases:

Identified unlawful processing (within three working days).
Achievement of processing purposes.
Expiry of consent or its withdrawal by the User when processing requires consent.

The Operator ensures the confidentiality of processed data and ceases processing if no legal grounds exist. User requests to stop processing must be executed within 10 working days unless otherwise stipulated by law.

Users may withdraw their consent at any time by sending an email to hot.sever@mail.ru with the subject "Withdrawal of Consent for Personal Data Processing."

Third-Party Services:

Information collected by third-party services (e.g., payment systems, communication tools) is stored and processed by those parties in accordance with their user agreements and privacy policies. Users should review these documents independently. The Operator is not responsible for actions by these third parties.

7. Processing of Personal Data Using Cookies

Cookies are classified into the following types:

Necessary cookies required for the use of the Website and its features.
Operational cookies, which collect information about the use of the Website, such as frequently visited pages. This data can be used to optimize the Website and simplify navigation. These cookies are not used to collect personal information. All information collected is solely for statistical purposes and remains anonymous.
Functional cookies, which remember choices made on the Website, such as text size, font settings, and other preferences. These cookies allow the Website to recall the User's choices and settings. The information provided by these cookies does not enable the identification of Users.

The Operator uses cookies to collect and store fragments of data in small files on the User’s computer or mobile device, ensuring maximum convenience in navigation based on the User's preferences. These files do not save any personal data and are used solely to identify the User's device and collect navigation data (e.g., pages viewed on the Website, the User’s IP address).

Cookies enable the Operator to:

Analyze traffic patterns on the Website.
Enhance navigation convenience.
Determine the User’s geographic location.
Retain browser settings to simplify the login process.
Offer helpful links based on recently viewed pages.
Collect statistics on navigation and facilitate social media sharing.

Cookies transferred by the Website to the User's computer or mobile device are used to provide personalized Website features, tailored advertising, statistical and research purposes, and Website improvement.

Users are aware that their equipment and software may have functionalities to block or delete cookies. The Operator may specify that certain Website features are only accessible if cookies are enabled.

The structure, content, and technical parameters of cookies are determined by the Operator and may change without prior notice. The Operator processes anonymized User data if allowed by the browser settings (enabled cookies and JavaScript).

User-imposed restrictions on processing or conditions for processing personal data permitted for dissemination do not apply to cases involving the processing of personal data in public or state interests as defined by Russian Federation law.

Updating, Correction, Deletion, and Responses to User Requests on Access to Personal Data

Confirmation of personal data processing by the Operator, legal grounds, processing purposes, and other information (as specified in Article 14, Part 7 of the Personal Data Law) is provided to the User or their representative within 10 business days of a request. This term may be extended by no more than five business days, with the User notified and reasons for the extension explained.

Requests must include:

Details of the primary document identifying the User or their representative (number, date of issue, issuing authority).
Information confirming the User’s relationship with the Operator (e.g., contract number, date).
Signature of the User or their representative.

Requests can be submitted electronically and signed using electronic signatures in accordance with Russian Federation legislation.

The Operator provides information in the format specified in the User’s request unless otherwise stated. If the request lacks required details or the User lacks access rights, a justified refusal is sent.

If inaccuracies in personal data are identified, the Operator blocks the data during verification and rectifies inaccuracies within seven business days upon confirmation.

In cases of unauthorized personal data processing, the Operator blocks such data upon User or regulatory request and notifies relevant parties within 24 hours. Internal investigation results must be submitted to authorities within 72 hours.

Conditions and Terms for Personal Data Destruction by the Operator:

Achieving the purpose of processing or loss of necessity: within 30 days.
Expiry of document retention periods containing personal data: within 30 days.
User-provided confirmation of unlawful data acquisition: within seven business days.
Withdrawal of User consent if data retention is no longer necessary: within 30 days.

Destruction is carried out by a commission formed by the Operator’s general director. Methods are defined in internal regulatory documents.

Final Provisions
Users can request clarifications on personal data processing by contacting the Operator at hot.sever@mail.ru.

This policy is effective indefinitely until replaced by a new version.