1. General Provisions

This Personal Data Processing Policy has been drawn up in accordance with the requirements of Federal Law No. 152-FZ (152-ФЗ) dated 27 July 2006 “On Personal Data” (hereinafter referred to as the Law on Personal Data) and determines the procedure for processing personal data and measures to ensure the security of personal data taken by Intana CRS Tax Consulting Limited Liability Company (hereinafter referred to as the Operator).

1.1. The Operator sets as its most important goal and condition for the implementation of its activities the observance of the rights and freedoms of a person and a citizen in the processing of his/her personal data, including the protection of the rights to privacy, personal and family secrets.

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 can receive about visitors to the website https://intana.legal.

2. Main Terms and Definitions Used in the Policy

2.1. Automated personal data processing — personal data processing using means of computer technology.

2.2. Personal data blocking — suspension of personal data processing (except when such processing is required for the personal data rectification).

2.3. Website — a set of graphic and informational materials, as well as computer programs and databases that ensure their availability on the Internet at the network address https://intana.legal.

2.4. Personal data information system — an aggregate of personal data contained in databases and information technologies and hardware which allow for such personal data processing.

2.5. Depersonalization of personal data — actions resulting in impossibility to attribute personal data to a specific User or other data subject without using additional information.

2.6. Personal data processing — any action (operation) or series of actions (operations) with the personal data performed with or without automation means including collection, recording, classification, accumulation, storage, rectification (updating, modification), extraction, using, transfer (distribution, provision, granting access), depersonalization, blocking, deletion, destruction of the personal data.

2.7. Operator — a government agency, municipal authority, legal entity or individual that independently or jointly with other persons organizes and/or performs processing of personal data, as well as defines the purposes of personal data processing, composition of personal data to be processed, actions (operations) to be performed with personal data.

2.8. Personal data — any information related directly or indirectly to an identified or identifiable User of the website https://intana.legal.

2.9. Personal data permitted by the data subject for distribution — personal data to which access to an unlimited number of persons is provided by the data subject by giving consent to the processing of personal data permitted by the data subject for distribution in the manner prescribed by the Law on Personal Data (hereinafter referred to as the personal data permitted for distribution).

2.10. User — any visitor to the website https://intana.legal.

2.11. Provision of personal data — actions aimed at disclosing personal data to a certain person or a certain scope of persons.

2.12. Distribution of personal data — any actions aimed at disclosing personal data to general public (transfer of personal data) or at communicating personal data to general public, including publication of personal data in mass media, posting on information and telecommunication networks or providing access to personal data otherwise.

2.13. Cross-border transfer of personal data — transfer of personal data to the territory of a foreign state to the government agency of a foreign state, a foreign individual or a foreign legal entity.

2.14. Destruction of personal data — any actions as a result of which personal data is permanently destroyed with the impossibility of further restoration of the content of personal data in the personal data information system and/or the physical personal data storage media are destroyed.

3. Basic Rights and Obligations of the Operator

3.1. The Operator shall have the right:
— to receive reliable information and/or documents containing personal data from the data subject;
— in the event that the data subject withdraws consent to the processing of personal data, as well as sends an appeal with a request to stop processing personal data, the Operator shall have the right to continue processing personal data without the consent of the data subject if there are grounds specified in the Law on Personal Data;
— to independently determine the composition and list of measures necessary and sufficient to ensure the performance of obligations provided for by the Law on Personal Data and regulatory legal acts adopted in accordance with it, unless otherwise provided for by the Law on Personal Data or other federal laws.

3.2. The Operator shall:
— provide the data subject, at his/her request, with information regarding the processing of his/her personal data;
— organize the processing of personal data in the manner prescribed by the current legislation of the Russian Federation;
— respond to the requests of data subjects and their legal representatives in accordance with the requirements of the Law on Personal Data;
— provide the authorized body for the protection of the rights of data subjects, at the request of this body, with the necessary information within 30 days from the date of receipt of such a request;
— publish or otherwise ensure unlimited access to this Policy regarding the processing of personal data;
— make legal arrangements, take organizational measures and engineering controls to protect personal data against unauthorized or accidental access thereto, destruction, modification, blocking, copying, provision, distribution of personal data, as well as other illegal actions with respect to personal data;
— stop the transfer (distribution, provision, granting access) of personal data, stop processing and destroy personal data in the manner and cases provided for by the Law on Personal Data;
— perform other duties stipulated by the Law on Personal Data.

4. Basic Rights and Obligations of Data Subjects

4.1. Data Subjects shall have the right:
— to receive information regarding the processing of their personal data, except as otherwise provided for by federal laws. The information is provided to the data subject by the Operator in an accessible form, and it should not contain personal data related to other data subjects, unless there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it is established by the Law on Personal Data;
— to require from the Operator to clarify their personal data, block or destroy them if they are incomplete, outdated, inaccurate, illegally obtained or are not necessary for the stated processing purpose, and also take measures prescribed by law to protect their rights;
— to set the condition of prior consent when processing personal data in order to promote goods, works and services on the market;
— to withdraw consent to the processing of personal data, as well as to send a request to stop processing personal data;
— to appeal to the authorized body for the protection of the rights of data subjects or in court against illegal actions or inaction of the Operator when processing their personal data;
— to exercise other rights provided for in the laws of the Russian Federation.

4.2. Data Subjects shall:
— provide the Operator with reliable data about themselves;
— if necessary or upon receipt of a corresponding request, inform the Operator of the clarification (updating, modification) 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 consent of the latter, shall be liable in accordance with the legislation of the Russian Federation.

5. Personal Data Processing Principles

5.1. The processing of personal data shall be carried out on the basis of the legislation of the Russian Federation, taking into account the current (ratified) international treaties of the Russian Federation.

5.2. The personal data processing shall be limited to certain predefined legal purposes. It is not
allowed to process personal data that is incompatible with the purposes of collecting personal data.

5.3. Databases containing personal data processed for incompatible purposes may not be integrated.

5.4. Only personal data which serve the purposes of their processing can be processed.

5.5. The content and scope of the processed personal data correspond to the stated purposes of processing. The redundancy of the processed personal data in relation to the stated purposes of their processing is not allowed.

5.6. Personal data processed shall be accurate, sufficient and, in specific cases, up-to-date as regards the processing purposes. The operator shall take the necessary measures and/or ensure their adoption to remove or clarify incomplete or inaccurate data.

5.7. Personal data shall be stored so that a data subject is identified for the period necessary to achieve a personal data processing purpose, unless the period of their storage is stipulated by federal law or agreement a party to which or beneficiary or guarantor under which is the data subject. Processed personal data shall be destructed or depersonalized once a processing purpose has been achieved or if the processing is no longer required, unless otherwise stipulated by federal law.

6. Purposes of Personal Data Processing
Purpose of processing: informing the User by sending e-mails or in the callback mode, including using the Telegram and WhatsApp messengers

Personal Data:

• surname, name, patronymic
• e-mail address
• telephone numbers
• place of work
• position

Legal grounds:

• statutory (constituent) documents and relevant local regulations of the Operator
• contracts (agreements) concluded between the Operator and the data subject, as well as the informed consent of the data subject, provided through the functionality of the Operator’s website

Types of Personal Data Processing:

• Collection, recording, systematization, accumulation, storage, destruction and depersonalization of personal data
• Sending informational letters to an e-mail address, making a callback, including using Telegram and WhatsApp messengers

7. Personal Data Processing Conditions

7.1. The processing of personal data is carried out with the consent of the data subject to processing of his/her personal data.

7.2. The processing of personal data is required for achievement of purposes provided for by an international treaty of the Russian Federation or by law, for execution and performance of functions, powers and obligations imposed on the Operator by the legislation of the Russian Federation.

7.3. The processing of personal data is required for administration of justice, enforcement of a judicial act or act of another agency or official enforceable in accordance with the legislation of the Russian Federation on enforcement proceedings.

7.4. The processing of personal data is required for performance of an agreement, under which the data subject is either a party, or a beneficiary or a guarantor, as well as for entry into an agreement at the initiative of the data subject or an agreement, under which the data subject will be a beneficiary or a guarantor.

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

7.6. Personal data made available to public by the data subject or upon his/her request can be processed (hereinafter referred to as publicly available personal data).

7.7. The processing is performed in relation to data subject to publication or mandatory disclosure in accordance with federal law.

8. Procedure for Collecting, Storing, Transferring and other Types of Personal Data Processing
Security of personal data processed by the Operator is ensured by implementation of legal, organizational and technical measures necessary to fully comply with the requirements of the current legislation on personal data protection.

8.1. The Operator shall ensure the safety of personal data and take all possible measures to exclude access to personal data of unauthorized persons.

8.2. The User’s personal data will never, under any circumstances, be transferred to third parties, except in cases related to the implementation of applicable law or if the data subject has given consent to the Operator to transfer data to a third party to perform obligations under a civil law contract.

8.3. In case of detection of inaccuracies in personal data, the User may update it independently by sending a notification to the Operator to the Operator’s e-mail address ask@intana.legal marked “Updating personal data”.

8.4. The term of processing of personal data is determined by the achievement of the purposes for which personal data was collected, unless another term is provided for by the contract or current legislation.
The User may at any time withdraw his/her consent to the processing of personal data by sending a notification to the Operator by e-mail to the Operator’s e-mail address ask@intana.legal marked “Withdrawal of consent to the processing of personal data”.

8.5. All information that is collected by third-party services, including payment systems, means of communication and other service providers, is stored and processed by such persons (Operators) in accordance with their User Agreement and Privacy Policy. The data subject and/or with the specified documents. The Operator shall not be responsible for the actions of third parties, including the service providers specified in this clause.

8.6. The prohibitions established by the data subject on the transfer (except for granting access), as well as on the processing or processing conditions (except for obtaining access) of personal data permitted for distribution, shall not apply in cases of processing personal data in the state, public and other public interests defined by the legislation of the Russian Federation.

8.7. The Operator shall ensure the confidentiality of personal data when processing personal data.

8.8. The Operator shall store personal data so that a data subject is identified for the period necessary to achieve a personal data processing purpose, unless the period of their storage is stipulated by federal law or agreement a party to which or beneficiary or guarantor under which is the data subject.

8.9. The condition for terminating the processing of personal data may be the achievement of the purposes of processing personal data, the expiration of the consent of the data subject, the withdrawal of consent by the data subject or the requirement to stop processing personal data, as well as the identification of unlawful processing of personal data.

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

9.1. The Operator collects, records, classifies, accumulates, stores, rectifies (updates, modifies), extracts, uses, transfers (distributes, provides, grants access), depersonalizes, blocks, deletes and destroys personal data, and, by placing this Policy freely available, provides an unlimited number of persons with the information provided for in Part 7 of Article 14 of Federal Law No. 152-FZ dated 27 July 2006 “On Personal Data”.

9.2. The Operator carries out automated personal data processing with or without receipt and/or transfer of the obtained information via information and telecommunications networks.

10. Cross-Border Transfer of Personal Data

10.1. The Operator, prior to the commencement of activities for the cross-border transfer of personal data, shall notify the authorized body for the protection of the rights of data subjects of its intention to carry out a cross-border transfer of personal data (such a notification shall be sent separately from the notification of the intention to process personal data).

10.2. Before submitting the above notification, the Operator shall obtain relevant information from the authorities of a foreign state, foreign individuals, foreign legal entities to whom the cross-border transfer of personal data is planned.

11. Confidentiality of Personal Data
The Operator and other persons that gained access to personal data shall not disclose to the third parties or distribute personal data without the consent of the data subject, unless otherwise provided for by the federal law.

12. Final Provisions

12.1. The User can receive any clarifications on issues of interest regarding the processing of his/her personal data by contacting the Operator via e-mail ask@intana.legal.

12.2. This document will reflect any changes in the Policy of processing personal data by the Operator. The Policy is valid indefinitely until it is replaced by a new version.

12.3. The current version of the Policy is freely available on the Internet at https://intana.legal/privacy-policy.