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 of Dial Group LLC (hereinafter referred to as the Operator) located on the Internet at www.dial-group.ru (hereinafter referred to as the Website).
1.2. This Policy has been developed in accordance with paragraph 2 of part 1 of Article 18.1 of the Federal Law of July 27, 2006 No. 152-FZ “On Personal Data”, as well as the Recommendations on preparing a document defining the operator’s policy regarding personal data processing in accordance with the Federal Law of July 27, 2006 No. 152-FZ “On Personal Data”.
1.3. In compliance with the requirements of part 2 of Article 18.1 of Federal Law No. 152-FZ “On Personal Data”, this Policy is published in open access on the Internet on the Operator’s Website at: www.dial-group.ru.
1.4. This Policy applies exclusively to users of the Dial Group LLC website and does not cover the processing of personal data of employees, clients, or offline interactions. The Operator does not control and is not responsible for third-party websites that the User may access via links available on the Website.
1.5. The use of the Dial Group LLC website by the User constitutes acceptance of this Privacy Policy and the terms for processing the User’s personal data.
1.6. If the User disagrees with the terms of this Privacy Policy, the User must stop using the Dial Group LLC website.
1.7. The Operator does not verify the accuracy of the personal data provided by the User.
1.8. The terms defined in Article 3 of Federal Law No. 152-FZ “On Personal Data” are used in this Policy with the same meaning.
1.9. The following terms are also used in this Policy:

• “Website Administration” (hereinafter referred to as the Administration) – authorized employees responsible for managing the Dial Group LLC website, acting on behalf of Dial Group LLC, who organize and/or carry out the processing of personal data and determine the purposes of processing personal data, the composition of personal data subject to processing, and the actions (operations) performed with personal data.
• “Personal Data” – any information relating to an identified or identifiable individual (data subject), directly or indirectly.
• “Processing of Personal Data” – any action (operation) or set of actions (operations) performed with personal data using automation tools or without such tools, including collection, recording, systematization, accumulation, storage, clarification (updating or modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
• “Confidentiality of Personal Data” – a mandatory requirement for the Operator or any other person who has gained access to personal data to prevent their disclosure without the consent of the personal data subject or other legal grounds.
• “Dial Group LLC Website” – a set of interconnected web pages located on the Internet under the unique address (URL): dial-group.ru.
• “Website Services” – all interactive features available on the Website pages, including but not limited to feedback forms and analytics tools used to analyze website traffic and improve the Website’s performance.
• “User” – any individual visiting the Website and using the information, materials, and services available on the Website. A Website User is a personal data subject within the meaning of the Federal Law of July 27, 2006 No. 152-FZ “On Personal Data”.
• “Cookies” – a small piece of data sent by a web server and stored on the User’s computer, which the web client or web browser sends back to the web server in an HTTP request each time the User attempts to open a page of the relevant website.
• “IP address” – a unique network address of a device in a computer network through which the User accesses the Website.
• The Website has been created using the Tilda Publishing platform, which ensures the functioning of the Website and the technical processing of submitted requests.

1.10. Rights and Obligations of the Administration
1.10.1. The Administration is obliged to:

• process personal data solely for the purposes specified in this Policy and in accordance with the procedures established by the current legislation of the Russian Federation, and to take necessary and sufficient measures to ensure compliance with the obligations provided for by Federal Law No. 152-FZ “On Personal Data” and other regulatory legal acts adopted in accordance with it;
• not disclose personal data without the User’s consent unless otherwise provided by the legislation of the Russian Federation;
• process personal data in compliance with the principles and rules established by Federal Law No. 152-FZ “On Personal Data”;
• organize the protection of personal data in accordance with the requirements of the legislation of the Russian Federation;
• consider requests from the User (or the User’s legal representative) regarding the processing of personal data and provide reasoned responses;
• provide the User (or the User’s legal representative) with free access to their personal data;
• take measures to clarify, block, or destroy the User’s personal data in cases provided for by Federal Law No. 152-FZ “On Personal Data”.

1.10.2. The Administration has the right to:

• independently determine the composition and list of measures necessary and sufficient to ensure compliance with the obligations provided for by Federal Law No. 152-FZ “On Personal Data” and other regulatory legal acts adopted in accordance with it, unless otherwise provided by Federal Law No. 152-FZ “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, on the basis of a contract concluded with such person, including a state or municipal contract, or by adopting an appropriate act by a state or municipal authority;
• in the event that the User withdraws 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 “On Personal Data”;
• obtain from the User reliable information and/or documents containing the User’s personal data for the purposes specified in clause 2.2 of this Policy;
• require the User to promptly update the personal data previously provided.

1.11. Rights and Obligations of the User
1.11.1. The User is obliged to:

• ensure the accuracy of the personal data provided to the Administration that are necessary for the processing purposes specified in clause 2.2 of this Policy;
• provide the Administration, where necessary, with information required to clarify (update or modify) the personal data previously provided.

1.11.2. The User has the right to:

• receive full information regarding the processing of their personal data by the Administration, except in cases provided for by the legislation of the Russian Federation;
• request clarification, blocking, or destruction of their personal data in cases where the personal data are incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing;
• withdraw consent to the processing of personal data;
• take measures provided by law to protect their rights;
• appeal to the authorized body for the protection of the rights of personal data subjects or to a court against unlawful actions or inaction of the Administration when processing their personal data;
• provide prior consent to the processing of personal data for the purpose of receiving advertising.

The Administration and the Users also have other rights and bear other obligations provided for by the legislation of the Russian Federation.
1.12. Principles of Personal Data Processing
The Operator’s activities are based on the following principles:

• Legality
• Fairness
• Data minimization
• Purpose limitation
• Limited data retention
• Data confidentiality
• Localization of data processing

At the time of approval of this Policy, the Operator does not carry out cross-border transfer of personal data.


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 that is incompatible with the purposes for which the data were collected is not permitted. Personal data being processed must not be excessive in relation to the stated purposes of processing. Only personal data that are necessary to achieve the purposes of processing are subject to processing.
2.2. The Operator processes the User’s personal data for the following purposes:
2.2.1. Ensuring the correct operation and security of the Website.
2.2.2. Establishing feedback with the User, including sending notifications and requests regarding the use of the Website, provision of services, performance of work, and processing requests and applications submitted by the User.
2.2.3. Providing the User with effective customer and technical support in case of problems related to the use of the Website.
2.2.4. Processing inquiries submitted via the Website forms.


3. LEGAL BASIS FOR PERSONAL DATA PROCESSING

3.1. The legal grounds for the Operator’s processing of personal data include:

• 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 Protection of Information”;
• Federal Law No. 294-FZ of December 26, 2008 “On the Protection of the 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 the Requirements for the Protection of Personal Data during their Processing in Personal Data Information Systems”;
• Order of the Federal Service for Technical and Export Control of Russia (FSTEC) 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”;
• User consent to the processing of personal data provided on the Website.

4. SCOPE AND CATEGORIES OF PERSONAL DATA PROCESSED; CATEGORIES OF PERSONAL DATA SUBJECTS

4.1. The Operator may process the personal data of the following Users: visitors of the Operator’s Website.
4.2. Personal data permitted for processing under this Privacy Policy are provided by the User by completing forms on the Dial Group LLC website and include the following information:

• User’s last name, first name, and patronymic;
• Mobile phone number;
• Email address;
• Content of messages submitted via feedback forms;
• IP address;
• Cookies data;
• Information about the source from which the User accessed the Website;
• Information about the User’s interactions with Website forms;
• Technical specifications of the User’s device, browser, and access time.

4.3. The Operator ensures that the content and volume of processed personal data correspond to the purposes of processing specified in Section 2 of this Policy.
4.4. The Operator does not process biometric personal data or special categories of personal data relating to racial or ethnic origin, political opinions, religious or philosophical beliefs, or sexual life.


5. PROCEDURE AND CONDITIONS FOR PERSONAL DATA PROCESSING

5.1. The User’s personal data may be processed without time limitation, by any lawful means, including in personal data information systems using automation tools or without such tools.
5.2. The User agrees that personal data may be accessible to organizations whose platforms host the Website and which process information, including the User’s personal data.
5.3. The User’s personal data may be transferred to authorized state authorities of the Russian Federation only on grounds and in the manner established by the legislation of the Russian Federation.
5.4. Transfer of personal data to third parties is carried out only on legal grounds or with the User’s consent.
5.5. The Administration takes the necessary organizational and technical measures to protect the User’s personal information from unauthorized or accidental access, destruction, modification, blocking, copying, distribution, as well as from other unlawful actions by third parties.
5.6. The Administration, together with the User, takes all necessary measures to prevent losses or other negative consequences caused by the loss or disclosure of the User’s personal data.
5.7. The list of actions performed by the Administration with the User’s personal data for the purposes specified in clause 2.2 of this Policy includes: collection, recording, systematization, accumulation, storage, clarification (updating or modification), extraction, use, anonymization, blocking, deletion, destruction.
5.8. Personal data are processed by the Operator upon obtaining the User’s consent (hereinafter – Consent), expressed by filling out the form and confirming the Consent in accordance with the requirements of Federal Law No. 152-FZ “On Personal Data”, except in cases established by the legislation of the Russian Federation where processing may be carried out without such Consent.
5.9. The User provides their personal data and gives Consent voluntarily, of their own free will, and in their own interest.
5.10. The period of personal data processing is determined by the achievement of the purposes for which the personal data were collected, unless a different period is provided by the agreement with the User or by applicable law.
5.11. When processing personal data, the Administration complies with the requirements of Article 18 of Federal Law No. 152-FZ “On Personal Data”.
5.12. The Administration undertakes to maintain the confidentiality of personal data when processing them.
5.13. The Administration does not carry out cross-border transfers of personal data.
5.14. In the event that a cross-border transfer becomes necessary, the Operator ensures compliance with the legislation of the Russian Federation.


6. BLOCKING, CLARIFICATION, AND DESTRUCTION OF PERSONAL DATA; RESPONSES TO USER REQUESTS FOR ACCESS TO PERSONAL DATA

6.1. In the event of identifying unlawful processing of personal data, upon a request from the User (or their representative) or from an authorized personal data protection authority, the Administration shall block the unlawfully processed personal data relating to the relevant User or ensure such blocking from the moment of the request, for the duration of the verification.
In case of inaccurate personal data, upon a request from the User (or their representative) or from an authorized body, the Administration shall block the relevant personal data from the moment of the request for the duration of the verification, provided that such blocking does not violate the rights and lawful interests of the User or third parties.
6.2. If the inaccuracy of personal data is confirmed, the Administration shall, based on information provided by the User (or their representative), the authorized personal data protection authority, or other necessary documents, clarify the personal data or ensure their clarification within seven business days from the date of submission of such information.
6.3. If unlawful processing of personal data is identified, the Administration shall cease the unlawful processing or ensure its cessation within three business days from the date of identification. If it is impossible to ensure the lawfulness of processing, the Administration shall destroy or ensure the destruction of such personal data within ten business days from the date of identification.
6.4. Within seven business days from the date the User (or their representative) provides information confirming that such personal data were unlawfully obtained or are not necessary for the stated purpose of processing, the Operator shall destroy such personal data.
6.5. Personal data being processed shall be destroyed if they are no longer necessary for achieving the purposes of processing, unless otherwise provided by federal law.


7. RESPONSIBILITY OF THE PARTIES

7.1. The Administration that fails to fulfill its obligations shall be liable for losses incurred by the User due to unlawful use of personal data in accordance with the legislation of the Russian Federation, except in cases provided for in clauses 5.2, 5.3, and 7.2 of this Privacy Policy.
7.2. In the event of loss or disclosure of Confidential Information, the Administration shall not be liable if such confidential information:
7.2.1. Became publicly available before its loss or disclosure;
7.2.2. Was received from a third party before being obtained by the Administration;
7.2.3. Was disclosed with the User’s consent.
7.3. The User is fully responsible for compliance with the legislation of the Russian Federation, including laws on advertising, copyright and related rights, and the protection of trademarks and service marks, including, but not limited to, full responsibility for the content and form of materials.
7.4. The User acknowledges that responsibility for any information (including, but not limited to, data files, texts, etc.) to which they may have access as part of the Dial Group LLC website lies with the person who provided such information.
7.5. The User agrees that information provided to them as part of the Dial Group LLC website may constitute intellectual property, the rights to which are protected and belong to other Users, partners, or advertisers who place such information on the website. The User is not allowed to modify, lease, lend, sell, distribute, or create derivative works based on such content (in whole or in part), except where such actions are explicitly authorized in writing by the owners of the content under a separate agreement.
7.6. Distribution of textual materials (articles, publications freely available on the Dial Group LLC website) is permitted, provided that a reference to the Website is given.
7.7. The Administration shall not be liable to the User for any loss or damage resulting from the deletion, malfunction, or inability to save any content or communication data contained on or transmitted via the Dial Group LLC website.
7.8. The Administration shall not be liable for any direct or indirect losses arising from the use or inability to use the Website or its individual services; unauthorized access to the User’s communications; statements or conduct of any third party on the Website.
7.9. The Administration shall not be liable for any information posted by the User on the Dial Group LLC website, including, but not limited to, information protected by copyright without the direct consent of the copyright owner.


8. DISPUTE RESOLUTION

8.1. In the event of disputes and/or disagreements arising from the relationship between the User and the Operator, such matters shall be resolved in accordance with the current legislation of the Russian Federation.
8.2. This Policy and the relationship between the User and the Operator are governed by the current legislation of the Russian Federation.
8.3. Before filing a lawsuit regarding disputes arising from the relationship between the User and the Administration, it is mandatory to submit a claim (a written or electronic proposal for voluntary settlement of the dispute).
8.4. The recipient of the claim shall notify the claimant in writing or electronically of the results of the claim’s consideration within 30 calendar days from the date of receipt.
8.5. If no agreement is reached, the dispute shall be submitted to the Arbitration Court of Moscow.


9. FINAL PROVISIONS

9.1. The Operator has the right to make changes to this Policy without the User’s consent.
9.2. The new version of the Policy comes into effect from the moment it is posted on the Website, unless otherwise provided by the new version of the Policy. The new version of the Policy applies to relationships arising after its entry into force.
9.3. Any proposals or questions regarding the Policy should be sent by email to di@dial-group.ru.
9.4. The current Privacy Policy is posted on the page at the following address: en.dial-group.ru/policy