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 Digital Marketing Solutions LLC, Primary State Registration Number (OGRN) 1237700610180, Taxpayer Identification Number (INN) 9729354519, registered address: 42 Bolshoy Boulevard, Building 1, Skolkovo Innovation Center Territory, Mozhaysky Municipal District, Moscow, 121205, Russian Federation (hereinafter referred to as the Operator), located on the Internet at: https://www.retailinsight.pro (hereinafter referred to as the Website).
1.2. This Policy has been developed pursuant to Clause 2, Part 1, Article 18.1 of Federal Law No. 152-FZ dated July 27, 2006 “On Personal Data”, as well as the Recommendations on drafting a document defining the operator’s policy regarding personal data processing.
1.3. In compliance with Part 2, Article 18.1 of Federal Law No. 152-FZ “On Personal Data”, this Policy is publicly available on the Operator’s Website at https://www.retailinsight.pro.
1.4. This Privacy Policy applies only to the Website. 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. Terms defined in Article 3 of Federal Law No. 152-FZ “On Personal Data” are used in this Policy with the same meanings.
1.6. The following terms are also used in this Policy:

• Personal Data — any information relating directly or indirectly to an identified or dentifiable individual (personal data subject).
• User — any person visiting the Website and using its information, materials, and services. A Website User is a personal data subject within the meaning of Federal Law No. 152-FZ.
• Personal Data Operator — a state body, municipal body, legal entity, or individual that independently or jointly with others organizes and/or carries out personal data processing and determines the purposes and scope of personal data processing.
• Personal Data Processing — any action or set of actions performed with personal data, with or without automation, including collection, recording, systematization, accumulation, storage, updating, extraction, use, transfer, anonymization, blocking, deletion, and destruction.
• Website — a set of graphic and informational materials, as well as software and databases, ensuring their availability on the Internet.
• Personal Data Information System — databases containing personal data and information technologies and technical means ensuring their processing.
• Automated Processing — processing using computing technology.
• Distribution — disclosure of personal data to an indefinite number of persons.• Provision — disclosure of personal data to a specific person or group.
• Blocking — temporary suspension of personal data processing.
• Destruction — actions resulting in the impossibility of restoring personal data content.
• Anonymization — actions making it impossible to identify a subject without additional information.
• Cross-border Transfer — transfer of personal data to a foreign state authority, individual, or legal entity.
• Website Services — interactive components such as user account forms, callback forms, and feedback forms.

1.7. RIGHTS AND OBLIGATIONS OF THE OPERATOR
1.7.1. The Operator shall:

• Process personal data solely for the purposes specified in this Policy
• Ensure compliance with Russian legislation
• Not distribute personal data without User consent unless required by law
• Implement personal data protection measures
• Respond to User inquiries
• Provide free access to personal data
• Block, update, or destroy data when required by law

1.7.2. The Operator has the right to:

• Determine necessary protective measures
• Entrust processing to third parties with User consent
• Continue processing after withdrawal of consent when legally permitted
• Request accurate information from Users
• Require Users to update their personal data

1.8. RIGHTS AND OBLIGATIONS OF THE USER
1.8.1. The User shall:

• Provide accurate personal data
• Update personal data when necessary

1.8.2. The User has the right to:

• Obtain full information about data processing
• Request correction, blocking, or destruction of data
• Withdraw consent
• Protect their rights
• Appeal to authorities or court
• Give prior consent to advertising-related processing

2. PURPOSES OF PERSONAL DATA PROCESSING
2.1. Processing is limited to lawful, specific purposes.
2.2. The Operator processes User personal data for:

• 2.2.1. Communication, notifications, service provision, and request processing
• 2.2.2. Collecting Website usage data to improve Website quality
• 2.2.3. Carrying out marketing, analytical, and consulting activities

3. LEGAL GROUNDS FOR PROCESSING
Processing is based on:

• The Constitution of the Russian Federation
• Federal Law No. 149-FZ “On Information…”
• Federal Law No. 294-FZ
• Presidential Decree No. 188
• Government Resolution No. 1119
• FSTEC Order No. 21
• User consent obtained on the Website

4. SCOPE AND CATEGORIES OF PERSONAL DATA
4.1. Categories of subjects
Website visitors.
4.2. Data for communication purposes

• Name
• Mobile phone number
• Email address

4.3. Automatically collected data

• IP address
• Cookies
• Browser data
• Device technical characteristics
• Date and time of access
• Pages visited
• Browsing history

4.5. Biometric and special categories of personal data are not processed.

5. COOKIES AND WEB ANALYTICS
Cookies may be stored for up to 1 year.
The Website uses:

• Strictly necessary cookies
• Functional cookies
• Analytical cookies
• Third-party cookies

6. PROCEDURE AND CONDITIONS OF PROCESSING

• Processing is automated
• Includes collection, storage, use, transfer, anonymization, blocking, deletion, destruction
• Requires User consent except where legally permitted
• Processing continues until purposes are achieved or consent is withdrawn
• Consent withdrawal via email: v.nekrasov@retailinsight.ru
• Data may be processed via third-party systems under contract
• Bitrix24 CRM is used
• Yandex Metrica is used
• Cross-border transfer is not carried out
• Users are notified of breaches within 5 business days

7. BLOCKING, UPDATING, DESTRUCTION OF DATA
The Operator shall:

• Block data during verification
• Correct inaccurate data within 7 business days
• Stop unlawful processing within 3 business days
• Destroy data within 30 days when purposes are achieved or consent withdrawn
• Respond to requests via email from v.nekrasov@retailinsight.ru8. LIABILITY

The Operator is liable under Russian law. Users may claim damages and moral harm compensation.

9. DISPUTE RESOLUTION
Disputes are resolved under Russian law.
10. FINAL PROVISIONS

• The Operator may amend this Policy without User consent
• New versions take effect upon publication on https://www.retailinsight.pro
• Questions should be sent to v.nekrasov@retailinsight.ru