POLICY ON THE PROCESSING OF PERSONAL DATA

Approved on April 01, 2025

 

1. General Provisions

 

This policy on the processing of personal data has been drafted in accordance with the requirements of Federal Law No. 152-FZ of July 27, 2006, “On Personal Data” (hereinafter – the “Personal Data Law”) and defines the procedure for processing personal data and the measures taken by UFO.Hosting LLC (hereinafter – the “Operator”) to ensure the security of personal data.

1.1. The Operator considers its most important goal and a condition for its activities to be the respect for the rights and freedoms of individuals and citizens in the processing of their personal data, including the protection of the rights to privacy, personal and family life.
1.2. This Operator’s policy on the processing of personal data (hereinafter – the “Policy”) applies to all information that the Operator may obtain about visitors to the website https://ufo.hosting/ (hereinafter – the “Website”).

 

2. Key Concepts 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 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 computer programs and databases, ensuring their availability on the internet at the Website’s address.
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. Anonymization of personal data – actions as a result of which it becomes impossible to determine, without the use of additional information, the affiliation of personal data to a specific User or other data subject.
2.6. Processing of personal data – any action (operation) or set of actions (operations) performed with or without the use of automation tools on personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (dissemination, provision, access), anonymization, blocking, deletion, and destruction of personal data.
2.7. Operator – a state body, municipal body, legal or natural person, independently or jointly with others, organizing and/or carrying out the processing of personal data, as well as determining the purposes of processing personal data, the composition of personal data to be processed, and the actions (operations) performed with personal data.
2.8. Personal data – any information relating directly or indirectly to an identified or identifiable User of the Website.
2.9. Personal data permitted by the data subject for dissemination – personal data to which an unlimited number of persons have been granted access by the data subject by giving consent to the processing of personal data permitted for dissemination in the manner prescribed by the Personal Data Law (hereinafter – personal data permitted for dissemination).
2.10. User – any visitor to the Website.
2.11. Provision of personal data – actions aimed at disclosing personal data to a specific person or a specific circle of persons.
2.12. Dissemination of personal data – any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or at making personal data available to an unlimited number of persons, including public disclosure of personal data in the media, placement in information and telecommunication networks, or providing access to personal data in any other way.
2.13. Cross-border transfer of personal data – transfer of personal data to the territory of a foreign state to a foreign state authority, a foreign individual, or a foreign legal entity.
2.14. Destruction of personal data – any actions as a result of which personal data are irretrievably destroyed with the impossibility of further restoring the content of personal data in the personal data information system and/or the material carriers of personal data are destroyed.

 

3. Main Rights and Obligations of the Operator

 

3.1. The Operator has the right to:

  • Receive from the data subject reliable information and/or documents containing personal data;
  • In the event of the data subject’s withdrawal of consent to the processing of personal data, the Operator has the right to continue processing personal data without the data subject’s consent 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 obligations provided for 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 data subject, upon their request, with information regarding the processing of their personal data;
  • Organize the processing of personal data in the manner established by the current legislation of the Russian Federation;
  • Respond to requests and inquiries from data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
  • Provide the competent supervisory authority for the protection of data subjects’ rights, upon its request, with the necessary information within 30 days from the date of receipt of 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, destruction, modification, blocking, copying, provision, dissemination, as well as from other unlawful actions in relation to personal data;
  • Cease the transfer (dissemination, provision, access) of personal data, stop processing, and destroy personal data in the manner and cases provided for by the Personal Data Law;
  • Fulfill other obligations provided for by the Personal Data Law.

 

4. Main Rights and Obligations of Data Subjects

 

4.1. Data subjects have the right to:

  • Receive information regarding the processing of their personal data, except in cases provided for by federal laws. The information is provided to the data subject by the Operator in an accessible form and must not contain personal data relating to other data subjects, except where 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;
  • Demand from the operator the clarification of their personal data, its blocking, or destruction if the personal data is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, as well as to take measures provided by law to protect their rights;
  • Set a condition of prior consent when processing personal data for the purpose of promoting goods, works, and services on the market;
  • Withdraw consent to the processing of personal data;
  • Appeal to the competent supervisory authority for the protection of data subjects’ rights or in court against unlawful actions or inaction of the Operator in the processing of their personal data;
  • Exercise other rights provided for by the legislation of the Russian Federation.

 

4.2. Data subjects are obliged to:

  • Provide the Operator with reliable data about themselves;
  • Inform the Operator about the clarification (updating, changing) of their personal data.

 

4.3. Persons who have provided the Operator with false information about themselves, or information about another data subject without the latter’s consent, are liable in accordance with the legislation of the Russian Federation.

 

5. The Operator may process the following personal data of the User

 

5.1. Last name, first name, patronymic.
5.2. Email address.
5.3. Phone numbers.
5.4. The website also collects and processes anonymized data about visitors (including cookies) using internet statistics services (Yandex Metrica, Google Analytics, and others).
5.5. The above-mentioned data are hereinafter collectively referred to as Personal Data in this Policy.
5.6. The Operator does not process special categories of personal data concerning race, nationality, political views, religious or philosophical beliefs, or intimate life.
5.7. The processing of personal data permitted for dissemination from among the special categories of personal data specified in Part 1 of Art. 10 of the Personal Data Law is allowed if the prohibitions and conditions provided for in Art. 10.1 of the Personal Data Law are observed.
5.8. The User’s consent to the processing of personal data permitted for dissemination is formalized separately from other consents to the processing of their personal data. The conditions provided for, in particular, by Art. 10.1 of the Personal Data Law are observed. The requirements for the content of such consent are established by the competent supervisory authority for the protection of data subjects’ rights.
5.8.1 The User provides consent to the processing of personal data permitted for dissemination directly to the Operator.
5.8.2 The Operator is obliged, no later than three working days from the moment of receiving the said consent from the User, to publish information about the conditions of processing, the existence of prohibitions and conditions on the processing by an unlimited number of persons of personal data permitted for dissemination.
5.8.3 The transfer (dissemination, provision, access) of personal data permitted by the data subject for dissemination must be terminated at any time upon the request of the data subject. This request must include the last name, first name, patronymic (if any), contact information (phone number, email address, or postal address) of the data subject, as well as a list of personal data whose processing is to be terminated. The personal data specified in this request may only be processed by the Operator to whom it is sent.
5.8.4 Consent to the processing of personal data permitted for dissemination ceases to be effective from the moment the Operator receives the request specified in clause 5.8.3 of this Policy on the processing of personal data.

 

6. Principles of Personal Data Processing

 

6.1. The processing of personal data is carried out on a lawful and fair basis.
6.2. The processing of personal data is limited to the achievement of specific, predetermined, and legitimate purposes. Processing of personal data that is incompatible with the purposes of collecting personal data is not permitted.
6.3. The merging of databases containing personal data, the processing of which is carried out for purposes incompatible with each other, is not permitted.
6.4. Only personal data that meets the purposes of their processing are subject to processing.
6.5. The content and volume of the processed personal data correspond to the stated purposes of processing. The redundancy of processed personal data in relation to the stated purposes of their processing is not permitted.
6.6. When processing personal data, the accuracy of the personal data, its sufficiency, and, where necessary, its relevance to the purposes of processing personal data are ensured. The Operator takes the necessary measures and/or ensures their adoption to delete or clarify incomplete or inaccurate data.
6.7. The storage of personal data is carried out in a form that allows the identification of the data subject for no longer than is required by the purposes of processing personal data, unless the storage period for personal data is established by federal law, a contract to which the data subject is a party, beneficiary, or guarantor. The processed personal data are destroyed or anonymized upon reaching the purposes of processing or in case of loss of the need to achieve these purposes, unless otherwise provided by federal law.

 

7. Purposes of Personal Data Processing

 

7.1. The purpose of processing the User’s personal data is:

  • Informing the User by sending emails;
  • Entering into, executing, and terminating civil law contracts;
  • Providing the User with access to the services, information, and/or materials contained on the Website.

 

7.2. The Operator also has the right to send the User notifications about new products and services, special offers, and various events. The User can always refuse to receive informational messages by sending the Operator an email to support@ufo.hosting with the subject “Refusal of notifications about new products and services and special offers.”

7.3. Anonymized data of Users, collected using internet statistics services, are used to gather information about Users’ actions on the site, to improve the quality of the site and its content.

 

8. Legal Basis for Personal Data Processing

 

8.1. The legal bases for the processing of personal data by the Operator are:

  • The statutory (founding) documents of the Operator;
  • Contracts concluded between the operator and the data subject;
  • Federal laws and other regulatory legal acts in the field of personal data protection;
  • Consents of Users to the processing of their personal data, and to the processing of personal data permitted for dissemination.

 

8.2. The Operator processes the User’s personal data only if they are filled in and/or sent by the User independently through special forms located on the Website or sent to the Operator via email. By filling out the corresponding forms and/or sending their personal data to the Operator, the User expresses their consent to this Policy.
8.3. The Operator processes anonymized data about the User if this is permitted in the User’s browser settings (saving of cookies and use of JavaScript technology are enabled).
8.4. The data subject independently decides on the provision of their personal data and gives consent freely, of their own will, and in their own interest.

 

9. Conditions for Personal Data Processing

 

9.1. The processing of personal data is carried out with the consent of the data subject to the processing of their personal data.
9.2. The processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, for the exercise of the functions, powers, and duties imposed on the operator by the legislation of the Russian Federation.
9.3. The processing of personal data is necessary for the administration of justice, the execution of a judicial act, an act of another body or official, subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
9.4. The processing of personal data 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.
9.5. 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 data subject.
9.6. The processing of personal data is carried out for data to which an unlimited number of persons have been granted access by the data subject or at their request (hereinafter – publicly available personal data).
9.7. The processing of personal data is carried out for data subject to publication or mandatory disclosure in accordance with federal law.
9.8. The Operator does not notify the Federal Service for Supervision of Communications, Information Technology and Mass Media of the commencement of personal data collection in accordance with clause 2 of Part 2 of Art. 22 of the Federal Law of July 27, 2006, No. 152-FZ.

 

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

 
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 current legislation in the field of personal data protection.
10.1. The Operator ensures the safety of personal data and takes all possible measures to exclude access to personal data by unauthorized persons.
10.2. The User’s personal data will never, under any circumstances, be transferred to third parties, except in cases related to the execution of current legislation or if the data subject has given consent to the Operator to transfer the data to a third party for the performance of obligations under a civil law contract.
10.3. In case of inaccuracies in personal data, the User can update them independently by sending the Operator a notification to the Operator’s email address support@ufo.hosting with the subject “Updating personal data.”
10.4. The processing period for personal data is determined by the achievement of the purposes for which the personal data were collected, unless a different period is provided for by a contract or current legislation.
The User may at any time withdraw their consent to the processing of personal data by sending the Operator a notification via email to the Operator’s email address support@ufo.hosting with the subject “Withdrawal of consent to the processing of personal data.”
10.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by these persons (Operators) in accordance with their User Agreement and Privacy Policy. The data subject and/or the User is obliged to independently and in a timely manner familiarize themselves with these documents. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this clause.
10.6. The prohibitions established by the data subject on the transfer (except for providing access), as well as on the processing or conditions of processing (except for obtaining access) of personal data permitted for dissemination, do not apply in cases of processing personal data in state, public, and other public interests defined by the legislation of the Russian Federation.
10.7. The Operator ensures the confidentiality of personal data when processing it.
10.8. The Operator stores personal data in a form that allows the identification of the data subject for no longer than is required by the purposes of processing personal data, unless the storage period for personal data is established by federal law, a contract to which the data subject is a party, beneficiary, or guarantor.
10.9. The condition for terminating the processing of personal data may be the achievement of the purposes of processing personal data, the expiration of the data subject’s consent, or the withdrawal of consent by the data subject, as well as the detection of unlawful processing of personal data.

 

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

 

11.1. The Operator carries out the collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (dissemination, provision, access), anonymization, blocking, deletion, and destruction of personal data.
11.2. The Operator carries out automated processing of personal data with or without the receipt and/or transfer of the received information via information and telecommunication networks.

 

12. Cross-Border Transfer of Personal Data

 

12.1. Before commencing the cross-border transfer of personal data, the Operator is obliged to ensure that the foreign state to whose territory the transfer of personal data is intended provides adequate protection of the rights of data subjects.
12.2. The cross-border transfer of personal data to the territories of foreign states that do not meet the above requirements may only be carried out if there is written consent from the data subject for the cross-border transfer of their personal data and/or for the performance of a contract to which the data subject is a party.

 

13. Confidentiality of Personal Data

 

The Operator and other persons who have gained access to personal data are obliged not to disclose it to third parties and not to disseminate personal data without the consent of the data subject, unless otherwise provided by federal law.

 

14. Final Provisions

 

14.1. The User can obtain any clarifications on questions of interest regarding the processing of their personal data by contacting the Operator via email at support@ufo.hosting.
14.2. Any changes to the Operator’s policy on the processing of personal data will be reflected in this document. The Policy is effective indefinitely until replaced by a new version.
14.3. The current version of the Policy is freely available on the internet and is located on the Website at https://ufo.hosting/.