This Policy is approved by
General Director of Sapiens Solutions LLC
Yu.V. Efarov
February 10, 2025
1.1 This Policy (hereinafter - Policy, Privacy Policy) is developed in accordance with the requirements of the Federal Law of July 27, 2006, No. 152-FZ "On Personal Data" (hereinafter - Personal Data Law/Law) and determines the procedure for processing personal data collected and processed by Limited Liability Company "Sapiens Solutions", INN 7725294897, legal address: Moscow, Akademika Tupoleva Emb., house 15, building 22, premise 1N (hereinafter - Administration) on the Website https://sapiens.solutions in the information and communications network Internet (hereinafter - Website).
1.2 The Policy applies to all Personal Data received on the Website.
1.3 In pursuance of the requirements of Part 2 of Art. 18.1 of the Personal Data Law, this Policy is published in open access on the information and telecommunications network Internet at the following address: sapiens.solutions/pp and at each point of personal data collection on the Website.
1.4 The Administration does not verify the reliability of Personal Data received from the User. The Administration assumes that the User, when filling out the feedback form and sending information, provides reliable and sufficient personal information and maintains this information in an up-to-date state. The Administration takes and ensures the taking of necessary measures to delete or clarify incomplete or inaccurate personal data.
1.5 The Administration processes only those personal data that meet the purposes of their processing. The content and scope of the processed data correspond to the stated purposes of processing; redundancy of the processed data is not permitted.
1.6 The Administration processes personal data only of persons who have reached the age of 18.
1.7 The Administration stores personal data for no longer than the purposes of their processing require, and destroys personal data upon achievement of the purposes of their processing or in case of loss of the need to achieve these purposes, unless otherwise provided by Law.
1.8 In case of disagreement with the terms of this Policy, the User must stop using the Website.
2. BASIC TERMS
2.1 For the purposes of application and interpretation of this Policy, the following basic terms are used (unless expressly stated otherwise in the Policy). In the text of the Policy, these terms may be indicated with a capital or lowercase letter in the singular or plural, as well as in the form of abbreviations.
Personal Data - any information relating to a directly or indirectly identified or identifiable natural person (personal data subject);
Personal Data Operator (Administration) - Limited Liability Company "Sapiens Solutions" (INN 7725294897, OGRN 5157746019206)
Personal Data Subject (User) - a capable natural person using the Website and having sent their data to the Administration on the Website.
3. BASIC CONDITIONS FOR PERSONAL DATA PROCESSING
3.1 Processing of personal data is carried out in an automated manner.
3.2 Actions that may be performed in relation to personal data: collection, recording, systematization, accumulation, storage, clarification (update, change), use, transfer, blocking, deletion, destruction of personal data. When collecting personal data, the Administration ensures the recording, systematization, accumulation, storage, clarification (update, change), and extraction of personal data using databases located on the territory of the Russian Federation.
3.3 The Administration does not place the Personal Data of Users in publicly available sources, and does not distribute personal data to an indefinite circle of persons.
3.4 The Administration processes personal data of the User only if they are filled in and/or sent by the User independently through special forms located on the Website.
By filling out the relevant forms and/or sending their personal data to the Operator, consent to the processing of personal data is considered provided by the User through their performance of conclusive actions, namely by placing a special mark — a "web-tick" — in a special field next to text such as: "I give consent to the processing of personal data. All terms of personal data processing are specified in the Policy," provided that the User is given the opportunity to familiarize themselves with the full text of this Policy at each point of personal data collection.
4. LEGAL GROUNDS FOR PERSONAL DATA PROCESSING
4.1 The legal basis for the processing of personal data is a set of normative legal acts, in pursuance of and in accordance with which the Operator processes personal data, including, but not limited to:
The Constitution of the Russian Federation;
The Civil Code of the Russian Federation;
The Tax Code of the Russian Federation;
other normative legal acts regulating relations related to the activities of the Operator.
4.2 The legal basis for the processing of Users' personal data is:
consent to the processing of personal data.
4.3 The subjects of personal data processed by the Operator are:
Website Users.
5. PURPOSES OF COLLECTION AND PROCESSING OF PERSONAL DATA
5.1. Processing of personal data is limited to the achievement of specific, predetermined, and legitimate goals. Processing of personal data incompatible with the purposes of personal data collection is not permitted.
5.2. Only personal data that meet the purposes of their processing are subject to processing.
Purpose of personal data processing, category and list of processed personal data, categories of subjects whose personal data are processed, methods and periods of processing and storage, procedure for destruction of personal data upon achievement of processing goals or upon occurrence of other legal grounds
5.2.1. Purpose: informing about the Operator's services
List of processed personal data of other category: last name, first name, patronymic, phone number, email address, place of employment, position.
Categories of subjects whose personal data are processed: personal data subjects - Users.
Legal basis: User's consent to personal data processing.
Processing methods: automated.
Actions performed with data: collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer, blocking, deletion, destruction of personal data.
Processing and storage period: personal data of Users are subject to processing for 5 years and subject to storage for 1 year.
Upon reaching the specified processing periods, the User's personal data are destroyed by deletion from information systems using built-in tools of the information system with the preparation of an act of destruction.
5.2.2. Purpose: collection of statistical information
List of processed personal data of other category: information collected through metric programs, cookies, IP address.
Categories of subjects whose personal data are processed: personal data subjects - Users.
Legal basis: User's consent to personal data processing.
Processing methods: automated.
Actions performed with data: collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, depersonalization, transfer, blocking, deletion, destruction of personal data.
Processing and storage period: the storage period for cookies varies from the session time to several years, depending on the functional necessity of the specific cookie.
Upon reaching the specified processing periods, the User's personal data are destroyed by deletion from information systems using built-in tools of the information system with the preparation of an act of destruction.
5.2.3. Purpose: selection of a candidate for a vacant position
List of processed personal data of other category: Full name, phone number, email address, city of residence, citizenship, year of birth (age), gender, profession, position, information about work history, information about education, marital status.
Categories of subjects whose personal data are processed: personal data subjects - Users.
Legal basis: User's consent to personal data processing.
Processing methods: automated.
Actions performed with data: collection, recording, clarification (update, change), extraction, use, blocking, deletion, destruction, storage of personal data.
Processing and storage period: until the decision on employment/refusal of employment is made; storage period — no more than 30 days.
Upon reaching the specified processing periods, the User's personal data are destroyed by deletion from information systems using built-in tools of the information system with the preparation of an act of destruction.
5.2.4. Purpose: providing access to materials
List of processed personal data of other category: Full name, phone number, email address, position, place of work.
Categories of subjects whose personal data are processed: personal data subjects - Users.
Legal basis: User's consent to personal data processing.
Processing methods: automated.
Actions performed with data: collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer, blocking, deletion, destruction of personal data.
Processing and storage period: until the goal is achieved; storage period — no more than 30 days.
Upon reaching the specified processing periods, the User's personal data are destroyed by deletion from information systems using built-in tools of the information system with the preparation of an act of destruction.
5.2.5. Purpose: sending advertising mailings
List of processed personal data of other category: last name, first name, patronymic, phone number, email address, place of work, position.
Categories of subjects whose personal data are processed: personal data subjects - Users.
Legal basis: User's consent to personal data processing.
Processing methods: automated.
Actions performed with data: collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer, blocking, deletion, destruction of personal data.
Processing and storage period: personal data of Users are subject to processing for 5 years and subject to storage for 1 year.
Upon reaching the specified processing periods, the User's personal data are destroyed by deletion from information systems using built-in tools of the information system with the preparation of an act of destruction.
6. TRANSFER OF PERSONAL DATA TO THIRD PARTIES
6.1 The Administration notifies of the transfer of personal data of users of other categories in the scope of last name, first name, patronymic, phone number, email address, position, place of work to LLC "1C-Bitrix" (INN 7717586110, legal address: Moscow, Entuziastov Blvd, 2, 13th fl., room 8-19), which processes personal data on behalf of the Administration for the purposes of: hosting the Portal on the servers of LLC "1C-Bitrix" when using "1C-Bitrix24".
Processing method: automated. List of actions performed with personal data: accumulation, storage, transfer (provision, access), destruction, deletion.
LLC "1C-Bitrix", processing personal data on behalf of the operator, guarantees compliance with the principles and rules for processing personal data provided for by the Federal Law of July 27, 2006, No. 152-FZ "On Personal Data", and other requirements of normative legal acts in the field of personal data protection, confidentiality of personal data, and ensuring the security of personal data, protection from unlawful or accidental access, destruction, change, blocking, copying, distribution, and other unlawful actions.
7.1 Cookies: - this is a piece of data sent by the Operator's server and stored on the User's device. The content of such a file may or may not relate to personal data, depending on whether such a file contains personal data or contains depersonalized technical data.
The User has the right to prohibit their equipment from receiving these data or to limit the receipt of these data. When refusing to receive such data or when limiting the receipt of data, some functions of the Website may work incorrectly. The User undertakes to configure their equipment themselves in such a way that it provides the operating mode and level of protection of cookie data appropriate to their wishes, and the Operator does not provide technological or legal advice on such topics.
7.2 The Operator may use the following types of cookies for the following purposes:
technical cookies: these files are necessary for the normal operation of the Website and the provision of its functions; they allow the identification of hardware and software, including the type of browser, so that the Website works correctly on the specific User's equipment;
cookies for saving settings and preferences: these cookies allow the saving of User preferences, such as selected language, location, Website appearance settings. To remember your preferences, we need to use cookies so that this information can be called up whenever you interact with a page of the Website, and so that your settings do not reset;
statistical/analytical cookies: these cookies allow the recognition of Users, the counting of their number, and the collection of information such as operations performed on the Website, including information about the pages of the Website visited and the content that is most interesting to the User. Such cookies are used to collect, analyze, and organize Website statistics and analytics and to improve the Website;
behavioral cookies: these cookies collect information about how users interact with the Website, which allows for the detection of errors and the testing of new functions to increase Website performance;
form cookies: when you submit data through forms found on the contact page or in feedback forms, cookies may be used to remember you for future correspondence;
third-party and advertising cookies: these cookies collect information about users, traffic sources, pages visited, advertisements displayed for a specific User or groups of users, as well as the advertisements through which the User transitioned to the advertised page. They allow the display of advertising that may interest a specific User based on the analysis of their personal information, behavior, and preferences.
7.3 The use of cookies is regulated as follows:
a) cookies, the content of which is determined and processed exclusively by the Operator, are processed under the terms of this Policy;
b) cookies, the content of which is determined and processed by a third party — for example, a provider of third-party software or a service used by the Operator — are processed under the terms of this Policy, as well as under the terms of the privacy documents of such a third party, containing, among other things, the name of this person, the procedure and terms for working with cookies, and contact information for inquiries from personal data subjects:
For analytics of Website usage, we use the following third-party services that may use cookie technologies:
Yandex Metrica https://yandex.ru/legal/metrica_termsofuse/ru/.
8. RIGHTS AND OBLIGATIONS OF THE ADMINISTRATION AND THE USER
8.1 The Administration has the right:
8.1.1 To independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations provided for by the Personal Data Law and normative legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Law or other Federal laws;
8.1.2 To entrust the processing of Personal Data to another person on the basis of a contract concluded with this person. The person processing Personal Data on behalf of the Administration is obliged to comply with the principles and rules of Personal Data processing provided for by the Personal Data Law.
8.1.3 In the event of the User's withdrawal of consent to the processing of personal data, the Administration is entitled to continue processing Personal Data without the User's consent if there are grounds specified in the Personal Data Law.
8.2 The Administration is obliged:
8.2.1 To organize the processing of Personal Data in accordance with the requirements of the Personal Data Law;
8.2.2 To respond to inquiries and requests from the User and their legal representatives in accordance with the requirements of the Personal Data Law;
8.2.3 To maintain the confidentiality of personal data, not to disclose to third parties, and not to distribute personal data without the User's consent.
8.2.4 To block personal data relating to the relevant User from the moment of an inquiry or request by the User or their legal representative, or an authorized body for the protection of the rights of personal data subjects for the period of verification, in case of detection of unreliable personal data or illegal actions.
8.2.5 To clarify personal data in case of confirmation of the fact of inaccuracy of personal data.
8.2.6 To stop processing personal data or ensure its termination (if the processing of personal data is carried out by another person acting on behalf of the operator) and destroy personal data or ensure their destruction (if the processing of personal data is carried out by another person acting on behalf of the operator) within a period not exceeding thirty days from the date the purpose of personal data processing is achieved. The destruction of personal data is confirmed by an Act of Destruction.
8.2.7 To stop processing personal data or ensure the termination of such processing, in case of the User's request with the corresponding demand, within a period not exceeding ten working days from the date of receipt of the demand.
8.3 The User has the right:
8.3.1 To receive information concerning the processing of their Personal Data, except in cases provided for by federal laws. Information is provided to the User by the Administration in an accessible form, and it should not contain Personal Data relating to other Users, except in cases where there are legal grounds for disclosing such Personal Data;
8.3.2 To demand that the Administration clarify their Personal Data, block, or destroy them if the Personal Data are incomplete, outdated, inaccurate, illegally obtained, or are not necessary for the stated purpose of processing, and to take measures provided by law to protect their rights;
8.3.3 To withdraw consent to the processing of personal data;
8.3.4 To appeal to Roskomnadzor or in court against unlawful actions or inaction of the Administration during the processing of their Personal Data.
9. MEASURES TO FULFILL THE OPERATOR'S OBLIGATIONS IN ENSURING THE SECURITY OF PERSONAL DATA DURING THEIR PROCESSING
9.1. The Operator takes necessary legal, organizational, and technical measures to protect personal data from unlawful or accidental access to them, destruction, modification, blocking, distribution, and other unauthorized actions, including:
adopts local normative acts and other documents regulating relations in the field of personal data processing and protection;
appoints a person responsible for organizing the processing of personal data;
stores personal data in conditions under which their safety is ensured and unlawful access to them is excluded;
carries out an assessment of the harm that may be caused to the subject in case of violation of the legislation on personal data;
establishes rules for access to personal data processed in information systems, and ensures registration and accounting of actions performed with personal data in the information system;
carries out internal control and audit of compliance of personal data processing with the legislation of the Russian Federation;
acquaints employees directly involved in personal data processing with the provisions of the legislation of the Federation on personal data, signs a non-disclosure obligation with employees;
applies information protection tools that have passed the conformity assessment procedure in the prescribed manner;
carries out an assessment of the effectiveness of the measures taken to ensure the security of personal data before the commissioning of the personal data information system;
detects facts of unauthorized access to personal data and takes measures, including the detection, prevention, and elimination of the consequences of computer attacks on personal data information systems and response to computer incidents in them;
restores personal data modified or destroyed as a result of unauthorized access to them;
establishes rules for access to personal data processed in the personal data information system, as well as ensuring the registration and accounting of all actions performed with personal data in the personal data information system;
monitors the measures taken to ensure the security of personal data and the security level of personal data information systems.
10. PROCEDURE FOR CONTACTING THE ADMINISTRATION
10.1 The User or their Representative may send a withdrawal of consent to the processing of Personal Data, a request, or an inquiry regarding the clarification of Personal Data, the illegality of their processing, or the User's access to their Personal Data processed by the Administration by email: info@sapiens.solutions
10.2 The withdrawal, request, or inquiry of the User is considered by the Administration within 10 (ten) calendar days from the moment the corresponding withdrawal, request, or inquiry is received by the Administration.
11. LIMITATION OF LIABILITY
11.1 The Administration informs the User that this Policy is applicable only to the Website. The Administration does not control and is not responsible for the use of third-party websites to which the User may, at their own discretion and risk, transition via links placed on the Website.
11.2 The Administration is not responsible for the actions of third parties who, as a result of using the information and telecommunications network Internet or the Website, gained access to information about the User, and for the consequences of using information that, due to the functioning of the Website, is available to any person using the information and telecommunications network Internet.
12. FINAL PROVISIONS
12.1 This Policy comes into force from the moment of approval, is introduced into effect by an order of the Administration, and remains in effect indefinitely (until its cancellation or replacement by a new version of the Policy).
12.2 The Administration has the right to make changes to this Policy. When changes are made, the date of the last update is indicated in the current version. The new version of the Policy comes into force from the moment it is placed on the Website.
12.3 The place of expression of consent and the place of performance of the Policy is always the location of the Administration, and the law applicable to the relations between the Administration and the User is always the law of Russia, regardless of where the User or the equipment used by them is located. All disputes and disagreements are resolved at the location of the Administration, unless otherwise provided by law.
12.4 The current version of the Policy is located on the Website.
12.5 Last update: February 10, 2026.
INFORMATION ABOUT THE OPERATOR
Sapiens Solutions LLC
INN 7725294897
Address: Moscow, Akademika Tupoleva Emb., house 15, building 22, premise 1N
Email address: info@sapiens.solutions
This Policy is approved by
General Director of Sapiens Solutions LLC
Yu.V. Efarov
February 10, 2025
1.1 This Policy (hereinafter - Policy, Privacy Policy) is developed in accordance with the requirements of the Federal Law of July 27, 2006, No. 152-FZ "On Personal Data" (hereinafter - Personal Data Law/Law) and determines the procedure for processing personal data collected and processed by Limited Liability Company "Sapiens Solutions", INN 7725294897, legal address: Moscow, Akademika Tupoleva Emb., house 15, building 22, premise 1N (hereinafter - Administration) on the Website https://sapiens.solutions in the information and communications network Internet (hereinafter - Website).
1.2 The Policy applies to all Personal Data received on the Website.
1.3 In pursuance of the requirements of Part 2 of Art. 18.1 of the Personal Data Law, this Policy is published in open access on the information and telecommunications network Internet at the following address: sapiens.solutions/pp and at each point of personal data collection on the Website.
1.4 The Administration does not verify the reliability of Personal Data received from the User. The Administration assumes that the User, when filling out the feedback form and sending information, provides reliable and sufficient personal information and maintains this information in an up-to-date state. The Administration takes and ensures the taking of necessary measures to delete or clarify incomplete or inaccurate personal data.
1.5 The Administration processes only those personal data that meet the purposes of their processing. The content and scope of the processed data correspond to the stated purposes of processing; redundancy of the processed data is not permitted.
1.6 The Administration processes personal data only of persons who have reached the age of 18.
1.7 The Administration stores personal data for no longer than the purposes of their processing require, and destroys personal data upon achievement of the purposes of their processing or in case of loss of the need to achieve these purposes, unless otherwise provided by Law.
1.8 In case of disagreement with the terms of this Policy, the User must stop using the Website.
2. BASIC TERMS
2.1 For the purposes of application and interpretation of this Policy, the following basic terms are used (unless expressly stated otherwise in the Policy). In the text of the Policy, these terms may be indicated with a capital or lowercase letter in the singular or plural, as well as in the form of abbreviations.
Personal Data - any information relating to a directly or indirectly identified or identifiable natural person (personal data subject);
Personal Data Operator (Administration) - Limited Liability Company "Sapiens Solutions" (INN 7725294897, OGRN 5157746019206)
Personal Data Subject (User) - a capable natural person using the Website and having sent their data to the Administration on the Website.
3. BASIC CONDITIONS FOR PERSONAL DATA PROCESSING
3.1 Processing of personal data is carried out in an automated manner.
3.2 Actions that may be performed in relation to personal data: collection, recording, systematization, accumulation, storage, clarification (update, change), use, transfer, blocking, deletion, destruction of personal data. When collecting personal data, the Administration ensures the recording, systematization, accumulation, storage, clarification (update, change), and extraction of personal data using databases located on the territory of the Russian Federation.
3.3 The Administration does not place the Personal Data of Users in publicly available sources, and does not distribute personal data to an indefinite circle of persons.
3.4 The Administration processes personal data of the User only if they are filled in and/or sent by the User independently through special forms located on the Website.
By filling out the relevant forms and/or sending their personal data to the Operator, consent to the processing of personal data is considered provided by the User through their performance of conclusive actions, namely by placing a special mark — a "web-tick" — in a special field next to text such as: "I give consent to the processing of personal data. All terms of personal data processing are specified in the Policy," provided that the User is given the opportunity to familiarize themselves with the full text of this Policy at each point of personal data collection.
4. LEGAL GROUNDS FOR PERSONAL DATA PROCESSING
4.1 The legal basis for the processing of personal data is a set of normative legal acts, in pursuance of and in accordance with which the Operator processes personal data, including, but not limited to:
The Constitution of the Russian Federation;
The Civil Code of the Russian Federation;
The Tax Code of the Russian Federation;
other normative legal acts regulating relations related to the activities of the Operator.
4.2 The legal basis for the processing of Users' personal data is:
consent to the processing of personal data.
4.3 The subjects of personal data processed by the Operator are:
Website Users.
5. PURPOSES OF COLLECTION AND PROCESSING OF PERSONAL DATA
5.1. Processing of personal data is limited to the achievement of specific, predetermined, and legitimate goals. Processing of personal data incompatible with the purposes of personal data collection is not permitted.
5.2. Only personal data that meet the purposes of their processing are subject to processing.
Purpose of personal data processing, category and list of processed personal data, categories of subjects whose personal data are processed, methods and periods of processing and storage, procedure for destruction of personal data upon achievement of processing goals or upon occurrence of other legal grounds
5.2.1. Purpose: informing about the Operator's services
List of processed personal data of other category: last name, first name, patronymic, phone number, email address, place of employment, position.
Categories of subjects whose personal data are processed: personal data subjects - Users.
Legal basis: User's consent to personal data processing.
Processing methods: automated.
Actions performed with data: collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer, blocking, deletion, destruction of personal data.
Processing and storage period: personal data of Users are subject to processing for 5 years and subject to storage for 1 year.
Upon reaching the specified processing periods, the User's personal data are destroyed by deletion from information systems using built-in tools of the information system with the preparation of an act of destruction.
5.2.2. Purpose: collection of statistical information
List of processed personal data of other category: information collected through metric programs, cookies, IP address.
Categories of subjects whose personal data are processed: personal data subjects - Users.
Legal basis: User's consent to personal data processing.
Processing methods: automated.
Actions performed with data: collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, depersonalization, transfer, blocking, deletion, destruction of personal data.
Processing and storage period: the storage period for cookies varies from the session time to several years, depending on the functional necessity of the specific cookie.
Upon reaching the specified processing periods, the User's personal data are destroyed by deletion from information systems using built-in tools of the information system with the preparation of an act of destruction.
5.2.3. Purpose: selection of a candidate for a vacant position
List of processed personal data of other category: Full name, phone number, email address, city of residence, citizenship, year of birth (age), gender, profession, position, information about work history, information about education, marital status.
Categories of subjects whose personal data are processed: personal data subjects - Users.
Legal basis: User's consent to personal data processing.
Processing methods: automated.
Actions performed with data: collection, recording, clarification (update, change), extraction, use, blocking, deletion, destruction, storage of personal data.
Processing and storage period: until the decision on employment/refusal of employment is made; storage period — no more than 30 days.
Upon reaching the specified processing periods, the User's personal data are destroyed by deletion from information systems using built-in tools of the information system with the preparation of an act of destruction.
5.2.4. Purpose: providing access to materials
List of processed personal data of other category: Full name, phone number, email address, position, place of work.
Categories of subjects whose personal data are processed: personal data subjects - Users.
Legal basis: User's consent to personal data processing.
Processing methods: automated.
Actions performed with data: collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer, blocking, deletion, destruction of personal data.
Processing and storage period: until the goal is achieved; storage period — no more than 30 days.
Upon reaching the specified processing periods, the User's personal data are destroyed by deletion from information systems using built-in tools of the information system with the preparation of an act of destruction.
5.2.5. Purpose: sending advertising mailings
List of processed personal data of other category: last name, first name, patronymic, phone number, email address, place of work, position.
Categories of subjects whose personal data are processed: personal data subjects - Users.
Legal basis: User's consent to personal data processing.
Processing methods: automated.
Actions performed with data: collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer, blocking, deletion, destruction of personal data.
Processing and storage period: personal data of Users are subject to processing for 5 years and subject to storage for 1 year.
Upon reaching the specified processing periods, the User's personal data are destroyed by deletion from information systems using built-in tools of the information system with the preparation of an act of destruction.
6. TRANSFER OF PERSONAL DATA TO THIRD PARTIES
6.1 The Administration notifies of the transfer of personal data of users of other categories in the scope of last name, first name, patronymic, phone number, email address, position, place of work to LLC "1C-Bitrix" (INN 7717586110, legal address: Moscow, Entuziastov Blvd, 2, 13th fl., room 8-19), which processes personal data on behalf of the Administration for the purposes of: hosting the Portal on the servers of LLC "1C-Bitrix" when using "1C-Bitrix24".
Processing method: automated. List of actions performed with personal data: accumulation, storage, transfer (provision, access), destruction, deletion.
LLC "1C-Bitrix", processing personal data on behalf of the operator, guarantees compliance with the principles and rules for processing personal data provided for by the Federal Law of July 27, 2006, No. 152-FZ "On Personal Data", and other requirements of normative legal acts in the field of personal data protection, confidentiality of personal data, and ensuring the security of personal data, protection from unlawful or accidental access, destruction, change, blocking, copying, distribution, and other unlawful actions.
7.1 Cookies: - this is a piece of data sent by the Operator's server and stored on the User's device. The content of such a file may or may not relate to personal data, depending on whether such a file contains personal data or contains depersonalized technical data.
The User has the right to prohibit their equipment from receiving these data or to limit the receipt of these data. When refusing to receive such data or when limiting the receipt of data, some functions of the Website may work incorrectly. The User undertakes to configure their equipment themselves in such a way that it provides the operating mode and level of protection of cookie data appropriate to their wishes, and the Operator does not provide technological or legal advice on such topics.
7.2 The Operator may use the following types of cookies for the following purposes:
technical cookies: these files are necessary for the normal operation of the Website and the provision of its functions; they allow the identification of hardware and software, including the type of browser, so that the Website works correctly on the specific User's equipment;
cookies for saving settings and preferences: these cookies allow the saving of User preferences, such as selected language, location, Website appearance settings. To remember your preferences, we need to use cookies so that this information can be called up whenever you interact with a page of the Website, and so that your settings do not reset;
statistical/analytical cookies: these cookies allow the recognition of Users, the counting of their number, and the collection of information such as operations performed on the Website, including information about the pages of the Website visited and the content that is most interesting to the User. Such cookies are used to collect, analyze, and organize Website statistics and analytics and to improve the Website;
behavioral cookies: these cookies collect information about how users interact with the Website, which allows for the detection of errors and the testing of new functions to increase Website performance;
form cookies: when you submit data through forms found on the contact page or in feedback forms, cookies may be used to remember you for future correspondence;
third-party and advertising cookies: these cookies collect information about users, traffic sources, pages visited, advertisements displayed for a specific User or groups of users, as well as the advertisements through which the User transitioned to the advertised page. They allow the display of advertising that may interest a specific User based on the analysis of their personal information, behavior, and preferences.
7.3 The use of cookies is regulated as follows:
a) cookies, the content of which is determined and processed exclusively by the Operator, are processed under the terms of this Policy;
b) cookies, the content of which is determined and processed by a third party — for example, a provider of third-party software or a service used by the Operator — are processed under the terms of this Policy, as well as under the terms of the privacy documents of such a third party, containing, among other things, the name of this person, the procedure and terms for working with cookies, and contact information for inquiries from personal data subjects:
For analytics of Website usage, we use the following third-party services that may use cookie technologies:
Yandex Metrica https://yandex.ru/legal/metrica_termsofuse/ru/.
8. RIGHTS AND OBLIGATIONS OF THE ADMINISTRATION AND THE USER
8.1 The Administration has the right:
8.1.1 To independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations provided for by the Personal Data Law and normative legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Law or other Federal laws;
8.1.2 To entrust the processing of Personal Data to another person on the basis of a contract concluded with this person. The person processing Personal Data on behalf of the Administration is obliged to comply with the principles and rules of Personal Data processing provided for by the Personal Data Law.
8.1.3 In the event of the User's withdrawal of consent to the processing of personal data, the Administration is entitled to continue processing Personal Data without the User's consent if there are grounds specified in the Personal Data Law.
8.2 The Administration is obliged:
8.2.1 To organize the processing of Personal Data in accordance with the requirements of the Personal Data Law;
8.2.2 To respond to inquiries and requests from the User and their legal representatives in accordance with the requirements of the Personal Data Law;
8.2.3 To maintain the confidentiality of personal data, not to disclose to third parties, and not to distribute personal data without the User's consent.
8.2.4 To block personal data relating to the relevant User from the moment of an inquiry or request by the User or their legal representative, or an authorized body for the protection of the rights of personal data subjects for the period of verification, in case of detection of unreliable personal data or illegal actions.
8.2.5 To clarify personal data in case of confirmation of the fact of inaccuracy of personal data.
8.2.6 To stop processing personal data or ensure its termination (if the processing of personal data is carried out by another person acting on behalf of the operator) and destroy personal data or ensure their destruction (if the processing of personal data is carried out by another person acting on behalf of the operator) within a period not exceeding thirty days from the date the purpose of personal data processing is achieved. The destruction of personal data is confirmed by an Act of Destruction.
8.2.7 To stop processing personal data or ensure the termination of such processing, in case of the User's request with the corresponding demand, within a period not exceeding ten working days from the date of receipt of the demand.
8.3 The User has the right:
8.3.1 To receive information concerning the processing of their Personal Data, except in cases provided for by federal laws. Information is provided to the User by the Administration in an accessible form, and it should not contain Personal Data relating to other Users, except in cases where there are legal grounds for disclosing such Personal Data;
8.3.2 To demand that the Administration clarify their Personal Data, block, or destroy them if the Personal Data are incomplete, outdated, inaccurate, illegally obtained, or are not necessary for the stated purpose of processing, and to take measures provided by law to protect their rights;
8.3.3 To withdraw consent to the processing of personal data;
8.3.4 To appeal to Roskomnadzor or in court against unlawful actions or inaction of the Administration during the processing of their Personal Data.
9. MEASURES TO FULFILL THE OPERATOR'S OBLIGATIONS IN ENSURING THE SECURITY OF PERSONAL DATA DURING THEIR PROCESSING
9.1. The Operator takes necessary legal, organizational, and technical measures to protect personal data from unlawful or accidental access to them, destruction, modification, blocking, distribution, and other unauthorized actions, including:
adopts local normative acts and other documents regulating relations in the field of personal data processing and protection;
appoints a person responsible for organizing the processing of personal data;
stores personal data in conditions under which their safety is ensured and unlawful access to them is excluded;
carries out an assessment of the harm that may be caused to the subject in case of violation of the legislation on personal data;
establishes rules for access to personal data processed in information systems, and ensures registration and accounting of actions performed with personal data in the information system;
carries out internal control and audit of compliance of personal data processing with the legislation of the Russian Federation;
acquaints employees directly involved in personal data processing with the provisions of the legislation of the Federation on personal data, signs a non-disclosure obligation with employees;
applies information protection tools that have passed the conformity assessment procedure in the prescribed manner;
carries out an assessment of the effectiveness of the measures taken to ensure the security of personal data before the commissioning of the personal data information system;
detects facts of unauthorized access to personal data and takes measures, including the detection, prevention, and elimination of the consequences of computer attacks on personal data information systems and response to computer incidents in them;
restores personal data modified or destroyed as a result of unauthorized access to them;
establishes rules for access to personal data processed in the personal data information system, as well as ensuring the registration and accounting of all actions performed with personal data in the personal data information system;
monitors the measures taken to ensure the security of personal data and the security level of personal data information systems.
10. PROCEDURE FOR CONTACTING THE ADMINISTRATION
10.1 The User or their Representative may send a withdrawal of consent to the processing of Personal Data, a request, or an inquiry regarding the clarification of Personal Data, the illegality of their processing, or the User's access to their Personal Data processed by the Administration by email: info@sapiens.solutions
10.2 The withdrawal, request, or inquiry of the User is considered by the Administration within 10 (ten) calendar days from the moment the corresponding withdrawal, request, or inquiry is received by the Administration.
11. LIMITATION OF LIABILITY
11.1 The Administration informs the User that this Policy is applicable only to the Website. The Administration does not control and is not responsible for the use of third-party websites to which the User may, at their own discretion and risk, transition via links placed on the Website.
11.2 The Administration is not responsible for the actions of third parties who, as a result of using the information and telecommunications network Internet or the Website, gained access to information about the User, and for the consequences of using information that, due to the functioning of the Website, is available to any person using the information and telecommunications network Internet.
12. FINAL PROVISIONS
12.1 This Policy comes into force from the moment of approval, is introduced into effect by an order of the Administration, and remains in effect indefinitely (until its cancellation or replacement by a new version of the Policy).
12.2 The Administration has the right to make changes to this Policy. When changes are made, the date of the last update is indicated in the current version. The new version of the Policy comes into force from the moment it is placed on the Website.
12.3 The place of expression of consent and the place of performance of the Policy is always the location of the Administration, and the law applicable to the relations between the Administration and the User is always the law of Russia, regardless of where the User or the equipment used by them is located. All disputes and disagreements are resolved at the location of the Administration, unless otherwise provided by law.
12.4 The current version of the Policy is located on the Website.
12.5 Last update: February 10, 2026.
INFORMATION ABOUT THE OPERATOR
Sapiens Solutions LLC
INN 7725294897
Address: Moscow, Akademika Tupoleva Emb., house 15, building 22, premise 1N
Email address: info@sapiens.solutions