1. General Provisions

This personal data processing policy is compiled in accordance with the requirements of Federal Law No. 152-FZ of July 27, 2006, “On Personal Data,” and defines the procedure for processing personal data and measures to ensure the security of personal data undertaken by LLC "Oblako" (hereinafter referred to as the Operator).

1.1. The Operator considers its most important goal and condition for its activities to be the observance of human and civil rights and freedoms when processing personal data, including the protection of rights to privacy, personal and family secrets.

1.2. This Operator's policy regarding personal data processing (hereinafter referred to as the Policy) applies to all information that the Operator may obtain about visitors to the wifly.tech website.

2. Key Terms Used in the Policy

2.1. Automated personal data processing – processing of personal data using computer technology;

2.2. Blocking of personal data – temporary cessation of personal data processing (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 network address wifly.tech.

2.4. Personal data information system — a set of personal data contained in databases, and information technologies and technical means ensuring their processing;

2.5. Anonymization of personal data — actions that make it impossible to determine, without the use of additional information, the belonging of personal data to a specific User or other personal data subject;

2.6. Personal data processing – any action (operation) or set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (dissemination, provision, access), anonymization, blocking, deletion, destruction of personal data;

2.7. Operator – a state body, municipal body, legal entity or individual, independently or jointly with other persons organizing and (or) carrying out the processing of personal data, as well as determining the purposes of personal data processing, the composition of personal data to be processed, actions (operations) performed with personal data;

2.8. Personal data – any information relating directly or indirectly to a specific or identifiable User of the wifly.tech website.

2.9. User – any visitor to the wifly.tech website.

2.10. Provision of personal data – actions aimed at disclosing personal data to a specific person or a specific group of persons;

2.11. Dissemination of personal data – any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or making personal data available to an unlimited circle of persons, including the publication of personal data in mass media, placement in information and telecommunication networks, or providing access to personal data in any other way;

2.12. Cross-border transfer of personal data – transfer of personal data to the territory of a foreign state to a foreign state authority, foreign individual, or foreign legal entity;

2.13. Destruction of personal data – any actions that result in the irreversible destruction of personal data with no possibility of further restoring the content of personal data in the personal data information system and (or) the destruction of tangible personal data carriers.

3. The Operator May Process the Following Personal Data of the User

3.1. Last name, first name, patronymic. Email address. Phone numbers;

3.2. Year, month, date, and place of birth;

3.3. Photographs;

3.4. The website also collects and processes anonymized data about visitors (including “cookie” files) using internet statistics services (Yandex Metrica and Google Analytics and others).

3.5. The above data are hereinafter referred to collectively as Personal Data in this Policy.

4. Purposes of Personal Data Processing

4.1. The purpose of processing User's personal data is to inform the User by sending emails; to provide the User with access to services, information, and/or materials contained on the website;

4.2. 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 an email to the Operator at info@abox.su with the subject line “Refusal of notifications about new products and services and special offers.”

4.3. Anonymized User data collected through internet statistics services are used to gather information about User actions on the site, improve site quality and content.

5. Legal Grounds for Personal Data Processing

5.1. 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 wifly.tech website. By filling in the relevant forms and/or sending their personal data to the Operator, the User expresses their consent to this Policy.

5.2. The Operator processes anonymized data about the User if this is allowed in the User's browser settings (saving “cookie” files and using JavaScript technology are enabled).

6. 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.

6.1. The Operator ensures the safety of personal data and takes all possible measures to exclude access to personal data by unauthorized persons.

6.2. User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to the execution of current legislation.

6.3. Should the User identify inaccuracies in their personal data, they may update it independently by sending a notification to the Operator's email address info@abox.su with the subject line "Personal Data Update."

6.4. The period for processing personal data is unlimited. The User may withdraw their consent to personal data processing at any time by sending a notification to the Operator via email at info@abox.su with the subject line "Withdrawal of Consent for Personal Data Processing."

7. Cross-Border Transfer of Personal Data

7.1. Before initiating cross-border transfer of personal data, the Operator must ensure that the foreign state to which the personal data is intended to be transferred provides adequate protection for the rights of personal data subjects.

7.2. Cross-border transfer of personal data to foreign states that do not meet the above requirements may only occur with the written consent of the personal data subject for the cross-border transfer of their personal data and/or for the performance of a contract to which the personal data subject is a party.

8. Final Provisions

8.1. The User can obtain any clarifications regarding questions concerning the processing of their personal data by contacting the Operator via email at info@abox.su.

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

8.3. The current version of the Policy is freely available online at wifly.tech/personal.