Privacy Policy

for ODI Group and D&D Tech websites (hereinafter referred to as the "Operator" or "Website")

1. General Provisions

This personal data processing policy has been developed in accordance with the requirements of Federal Law No. 152-FZ dated July 27, 2006 "On Personal Data" (hereinafter referred to as the "Personal Data Law") and defines the procedure for personal data processing and security measures for personal data protection undertaken by D&D Tech and ODI Group (hereinafter referred to as the "Operator").
1.1. The Operator sets as its most important goal and condition for carrying out its activities the observance of human and civil rights and freedoms when processing personal data, including protection of rights to privacy, personal and family confidentiality.
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 websites https://ddtech.pro and https://odi.group/en

2. Key Terms Used in This Policy

2.1. Automated processing of personal data – 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 for clarification of personal data).
2.3. Website – a collection of graphic and informational materials, as well as computer programs and databases, ensuring their accessibility on the internet at the network addresses https://ddtech.pro and https://odi.group/en
2.4. Personal data information system – a collection of personal data contained in databases, and information technologies and technical means ensuring their processing.
2.5. Anonymization of personal data – actions resulting in the impossibility to determine, without using additional information, the ownership of personal data by a specific User or other personal data subject.
2.6. Processing of personal data – any action (operation) or set of actions (operations) performed with or without the use of automation means on personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), anonymization, blocking, deletion, destruction of personal data.
2.7. Operator – a state body, municipal body, legal entity or individual that independently or jointly with other persons organizes and/or carries out personal data processing, and also determines 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 – any information relating directly or indirectly to a specific or identifiable User of the websites https://ddtech.pro and https://odi.group/en
2.9. Personal data authorized by the data subject for distribution – personal data to which access by an unlimited number of persons is provided by the data subject by giving consent to the processing of personal data authorized by the data subject for distribution in the manner prescribed by the Personal Data Law (hereinafter referred to as "personal data authorized for distribution").
2.10. User – any visitor to the websites https://ddtech.pro and https://odi.group/en
2.11. Provision of personal data – actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Distribution of personal data – any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or familiarizing an unlimited number of persons with personal data, including publication of personal data in mass media, placement in information and telecommunication networks, or providing access to personal data by any other means.
2.13. 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.
2.14. Destruction of personal data – any actions resulting in irreversible destruction of personal data with the impossibility of further restoration of personal data content in the personal data information system and/or destruction of material carriers of personal data.

3. Basic Rights and Obligations of the Operator

3.1. The Operator has the right to:
– obtain reliable information and/or documents containing personal data from the personal data subject;
– in case of withdrawal of consent for personal data processing by the personal data subject, the Operator has the right to continue processing personal data without the consent of the personal data subject if there are grounds specified in the Personal Data Law;
– independently determine the composition and list of measures necessary and sufficient to ensure compliance with obligations provided for by the Personal Data Law and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.
3.2. The Operator is obligated to:
– provide the personal data subject, upon request, with information regarding the processing of their personal data;
– organize personal data processing in accordance with the procedure established by the current legislation of the Russian Federation;
– respond to appeals and requests from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
– provide necessary information to the authorized body for the protection of personal data subjects' rights upon request of such body within 30 days from the date of receiving such request;
– publish or otherwise ensure unlimited access to this Policy regarding personal data processing;
– take legal, organizational and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other unlawful actions regarding personal data;
– cease transfer (distribution, provision, access) of personal data, cease processing and destroy personal data in the manner and cases provided for by the Personal Data Law;
– fulfill other obligations provided for by the Personal Data Law.

4. Basic Rights and Obligations of Personal Data Subjects

4.1. Personal data subjects have the right to:
– obtain information regarding the processing of their personal data, except in cases provided for by federal laws. Information is provided to the personal data subject by the Operator in an accessible form, and it must not contain personal data relating to other personal data subjects, except in cases where there are legal grounds for disclosure of such personal data. The list of information and the procedure for obtaining it is established by the Personal Data Law;
– require the operator to clarify their personal data, block or destroy it if the personal data is incomplete, outdated, inaccurate, unlawfully obtained, or is not necessary for the stated purpose of processing, as well as take measures provided for by law to protect their rights;
– set forth the condition of prior consent when processing personal data for the purpose of promoting goods, works and services in the market;
– withdraw consent for personal data processing;
– appeal to the authorized body for the protection of personal data subjects' rights or through judicial procedures against unlawful actions or inaction of the Operator in processing their personal data;
– exercise other rights provided for by the legislation of the Russian Federation.
4.2. Personal data subjects are obligated to:
– provide the Operator with reliable data about themselves;
– inform the Operator about clarification (updating, modification) of their personal data.
4.3. Persons who have provided the Operator with unreliable information about themselves, or information about another personal data subject without the latter's consent, bear responsibility in accordance with the legislation of the Russian Federation.

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

5.1. Phone numbers.
5.2. The website also collects and processes anonymized data about visitors (including "cookie" files) using internet statistics services (Yandex Metrica, Google Analytics, and others).
5.3. The above-mentioned data is hereinafter referred to collectively in the Policy text as Personal Data.
5.4. The Operator does not process special categories of personal data concerning racial, ethnic origin, political views, religious or philosophical beliefs, or intimate life.
5.5. Processing of personal data authorized for distribution from among the special categories of personal data specified in Part 1 of Article 10 of the Personal Data Law is permitted if the prohibitions and conditions provided for in Article 10.1 of the Personal Data Law are observed.
5.6. User consent for processing personal data authorized for distribution is executed separately from other consents for processing their personal data. In this case, the conditions provided for, in particular, in Article 10.1 of the Personal Data Law are observed. Requirements for the content of such consent are established by the authorized body for the protection of personal data subjects' rights.
5.6.1 The User provides consent for processing personal data authorized for distribution directly to the Operator.
5.6.2 The Operator is obligated to publish information about processing conditions, the existence of prohibitions and conditions for processing by an unlimited number of persons of personal data authorized for distribution, no later than three working days from the moment of receiving the specified User consent.
5.6.3 Transfer (distribution, provision, access) of personal data authorized by the personal data subject for distribution must be ceased at any time upon request of the personal data subject. This request must include the surname, first name, patronymic (if available), contact information (phone number, email address, or postal address) of the personal data subject, as well as a list of personal data whose processing is subject to cessation. The personal data specified in this request may be processed only by the Operator to whom it is directed.
5.6.4 Consent for processing personal data authorized for distribution ceases to be effective from the moment the Operator receives the request specified in clause 5.6.3 of this Policy regarding personal data processing.

6. Principles of Personal Data Processing

6.1. Personal data processing is carried out on a lawful and fair basis.
6.2. Personal data processing is limited to achieving specific, predetermined and lawful purposes. Processing of personal data incompatible with the purposes of personal data collection is not permitted.
6.3. Combining databases containing personal data whose processing is carried out for incompatible purposes is not permitted.
6.4. Only personal data that meets the purposes of their processing is subject to processing.
6.5. The content and scope of processed personal data correspond to the stated processing purposes. Redundancy of processed personal data in relation to the stated purposes of their processing is not permitted.
6.6. When processing personal data, the accuracy of personal data, their adequacy, and where necessary, their relevance in relation to the purposes of personal data processing is ensured. The Operator takes necessary measures and/or ensures their adoption for removing or clarifying incomplete or inaccurate data.
6.7. Storage of personal data is carried out in a form that allows identification of the personal data subject for no longer than required by the purposes of personal data processing, unless the storage period for personal data is established by federal law or a contract to which the personal data subject is a party, beneficiary, or guarantor. Processed personal data is destroyed or anonymized upon achieving the processing purposes or in case of loss of necessity to achieve these purposes, unless otherwise provided by federal law.

7. Purposes of Personal Data Processing

7.1. The purpose of processing User's personal data:
– informing the User by sending electronic messages.
7.2. 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 opt out of receiving informational messages by sending the Operator a letter to the email address ma@ddtech.pro with the note "Opt-out from notifications about new products and services and special offers".
7.3. Anonymized User data collected using internet statistics services is used to gather information about User actions on the website, improve the quality of the website and its content.

8. Legal Grounds for Personal Data Processing

8.1. The legal grounds for personal data processing by the Operator are:
– charter (founding) documents of the Operator;
– federal laws and other regulatory legal acts in the field of personal data protection;
– User consents for processing their personal data, for processing personal data authorized for distribution.
8.2. The Operator processes User's personal data only when they are filled in and/or sent by the User independently through special forms located on the website https://ddtech.pro or sent to the Operator via email. By filling in the corresponding forms and/or sending their personal data to the Operator, the User expresses their consent to this Policy.
8.3. The Operator processes anonymized data about the User if this is permitted in the User's browser settings (saving "cookie" files and using JavaScript technology is enabled).
8.4. The personal data subject independently makes the decision to provide their personal data and gives consent freely, by their own will and in their own interest.

9. Conditions for Personal Data Processing

9.1. Personal data processing is carried out with the consent of the personal data subject for processing their personal data.
9.2. Personal data processing is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, to perform functions, powers and obligations imposed on the operator by the legislation of the Russian Federation.
9.3. Personal data processing is necessary for the administration of justice, execution of a judicial act, act of another body or official to be executed in accordance with the legislation of the Russian Federation on enforcement proceedings.
9.4. Personal data processing is necessary for the performance of a contract to which the personal data subject is a party, beneficiary or guarantor, as well as for concluding a contract at the initiative of the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor.
9.5. Personal data processing is necessary for exercising the rights and legitimate interests of the operator or third parties, or for achieving socially significant purposes, provided that the rights and freedoms of the personal data subject are not violated.
9.6. Processing of personal data is carried out when access to such data by an unlimited number of persons is provided by the personal data subject or at their request (hereinafter referred to as "publicly available personal data").
9.7. Processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.

10. Procedure for Collection, Storage, Transfer and Other Types of Personal Data Processing

The security of personal data processed by the Operator is ensured through the implementation of legal, organizational and technical measures necessary for full compliance with the requirements of current legislation in the field of personal data protection.
10.1. The Operator ensures the security of personal data and takes all possible measures to exclude access to personal data by unauthorized persons.
10.2. User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to compliance with current legislation or in case the personal data subject has given consent to the Operator to transfer data to a third party for fulfilling obligations under a civil law contract.
10.3. In case of identifying inaccuracies in personal data, the User can update them independently by sending the Operator a notification to the Operator's email address ma@ddtech.pro with the note "Personal data update".
10.4. The term of personal data processing is determined by achieving the purposes for which the personal data was collected, unless another term is provided by contract or current legislation.
The User may at any time withdraw their consent for personal data processing by sending the Operator a notification via email to the Operator's email address ma@ddtech.pro with the note "Withdrawal of consent for personal data processing".
10.5. All information collected by third-party services, including payment systems, communication means and other service providers, is stored and processed by the specified persons (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject and/or User is obligated to independently and timely familiarize themselves with the specified documents. The Operator bears no responsibility for the actions of third parties, including the service providers specified in this clause.
10.6. Prohibitions established by the personal data subject on transfer (except for providing access), as well as on processing or processing conditions (except for obtaining access) of personal data authorized for distribution, do not apply in cases of personal data processing in state, public and other public interests determined by the legislation of the Russian Federation.
10.7. The Operator ensures confidentiality of personal data when processing personal data.
10.8. The Operator stores personal data in a form that allows identification of the personal data subject for no longer than required by the purposes of personal data processing, unless the storage period for personal data is established by federal law or a contract to which the personal data subject is a party, beneficiary or guarantor.
10.9. Conditions for terminating personal data processing may include achieving the purposes of personal data processing, expiration of the personal data subject's consent or withdrawal of consent by the personal data subject, as well as identification of unlawful personal data processing.

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

11.1. The Operator performs collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), anonymization, blocking, deletion and destruction of personal data.
11.2. The Operator performs automated processing of personal data with receiving and/or transmitting the obtained information via information and telecommunication networks or without such transmission.

12. Cross-Border Transfer of Personal Data

12.1. Before commencing cross-border transfer of personal data, the Operator is obligated to ensure that the foreign state to whose territory the personal data transfer is intended provides reliable protection of personal data subjects' rights.
12.2. Cross-border transfer of personal data to the territories of foreign states that do not meet the above requirements may be carried out only in case of written consent of the personal data subject for cross-border transfer of their personal data and/or performance of a contract to which the personal data subject is a party.

13. Confidentiality of Personal Data

The Operator and other persons who have gained access to personal data are obligated not to disclose to third parties and not to distribute personal data without the consent of the personal data subject, unless otherwise provided by federal law.

14. Final Provisions

14.1. The User may obtain any clarifications on questions of interest regarding the processing of their personal data by contacting the Operator via email at ma@ddtech.pro.
14.2. This document will reflect any changes to the personal data processing policy by the Operator. The Policy is effective indefinitely until replaced by a new version.
14.3. The current version of the Policy is freely available on the Internet at https://ddtech.pro/privacy