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Personal Data Processing Policy

Personal Data Processing Policy

1. General Provisions
This Personal Data Processing Policy (hereinafter referred to as the "Policy") has been prepared in accordance with the requirements of Federal Law No. 152-FZ of July 27, 2006 "On Personal Data". The Policy stipulates the procedure for processing personal data, and determines the personal data security measures taken by WINGS Solutions Ltd. ("Operator").
1.1. The Operator's main goal and condition in its activities is to observe human and civil rights and freedoms while processing personal data. This includes protection of the rights to privacy, personal and family secrets.
1.2. This Policy applies to all user information the Operator may obtain/receive from the website:

2. Basic concepts used in the Policy
2.1. Automated processing of personal data is the processing of personal data by means of computer technology;
2.2. Blocking of personal data is the temporary termination of personal data processing (except for cases where processing is necessary to clarify personal data);
2.3. Website is a set of graphic and information materials, as well as computer programs and databases, ensuring online availability of the materials at network address;
2.4. Personal data information system is a set of personal data contained in databases, as well as information technologies and technical means ensuring the data processing;
2.5. Depersonalization of personal data involves actions taken which makes it impossible to identify the specific User or other subject of a personal data without using additional information;
2.6. Personal data processing is any action (operation) or a set of actions (operations) performed on personal data with or without automation tools. Such actions include collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data;
2.7. Operator is a public authority, municipal body, legal entity or individual, organizing and (or) carrying out personal data processing independently or jointly with other persons, as well as determining the purposes of personal data processing, the composition of personal data to be processed, and actions (operations) performed with personal data;
2.8. Personal data is any information relating directly or indirectly to a specific or identifiable User of the website;
2.9. User is any visitor to the website;
2.10. Provision of personal data involves actions aimed at disclosing personal data to a certain person or a certain circle of persons;
2.11. Dissemination/distribution of personal data is any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or making available the personal data to an unlimited number of persons, including disclosure of personal data in the media, posting in information and telecommunication networks or providing access to personal data in any other way;
2.12. Cross-border transfer of personal data is the transfer of personal data outside the territories of the Russian Federation to a foreign state authority, to a foreign individual or to a foreign legal entity;
2.13. Destruction of personal data involves any actions by which personal data and (or) material media carrying the personal data are/is destroyed irretrievably, making it impossible to restore the personal data in the personal data information system.

3. The Operator can process the following User personal data
3.1. Full name;
3.2. Email address;
3.3. Phone numbers;
3.4. The site also collects and processes anonymized data about visitors (including cookies) using Internet statistics services (Yandex Metrica, Google Analytics and others).
3.5. The above-mentioned data is hereinafter collectively referred to as "personal data".

4. Purposes of personal data processing
4.1. The purpose of processing User's personal data is to process requests received through feedback forms.
4.2. The Operator may also send notifications to the User about new products and services, special offers and various events. The User can always opt out of receiving information messages by sending an email to the Operator at with the note "Unsubscribe from notifications about new products and services and special offers".
4.3. Anonymized user data collected using Internet statistics services serves for collecting information about Users' actions on the site and improving the quality of the site and its content.

5. Legal basis for personal data processing
5.1. The Operator processes the User's personal data only if the User fills and/or sends them himself through special forms hosted on the website By filling out the appropriate forms and/or sending his personal data to the Operator, the User agrees to this Policy.
5.2. The Operator processes anonymized User data if such is enabled (if cookies and JavaScript are enabled) in the User's browser settings.

6. Procedure for collecting, storing, transferring personal data, and other types of personal data processing
In processing personal data, the Operator takes all the necessary legal, managerial and technical measures necessary to fully comply with existing personal data protection laws.
6.1. The Operator ensures personal data safety and takes all possible measures to prevent unauthorized access to personal data.
6.2. User's personal data will never, under any circumstances, be transferred to third parties, except in cases where the existing laws permit.
6.3. If inaccuracies in personal data are detected, the User can update them independently by sending a notice to the Operator via the Operator's e-mail address with the subject "Updating of personal data".
6.4. The personal data processing period is unlimited. The user can at any time withdraw his consent to the processing of his personal data by sending a notice to the Operator using the Operator's email address with the subject "Withdrawal of consent to the processing of personal data".

7. Cross-border transfer of personal data
7.1. Before transferring personal data outside the territories of Russia, the operator must make sure that the foreign state where the data is being transferred to, provides reliable protection of the rights of personal data subjects.
7.2. Cross-border transfer of personal data to the territory of foreign states that do not meet the above requirements can be carried out only if there is a written consent from the personal data subject authorizing such cross-border transfer of his personal data and/or there is an agreement (for which the personal data subject is a party) authorizing such transfer.

8. Miscellaneous
8.1. The User can receive any clarifications on issues of interest concerning the processing of his personal data by contacting the Operator via e-mail
8.2. This Policy will reflect any changes by the Operator in the personal data processing policy. The Policy is valid for an unlimited amount of time until it is replaced by a new version.
8.3. The current version of the Policy is freely available online at