1. General Provisions
This Personal Data Processing Policy has been prepared in accordance with the requirements of Federal Law No. 152-FZ of July 27, 2006 “On Personal Data” (hereinafter referred to as the Personal Data Law) and defines the procedure for processing personal data and the measures taken by Knari Consulting Ltd (hereinafter referred to as the Operator) to ensure the security of personal data.
1.1. The Operator considers respect for human and civil rights and freedoms in the processing of personal data, including the protection of the rights to privacy, personal and family secrets, to be its most important goal and condition for carrying out its activities.
1.2. This Policy of the Operator regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator may receive about visitors to the website https://swaggy.agency/.

2. Key Terms Used in the Policy
2.1. Automated processing of personal data — processing of personal data using computer technology.
2.2. Blocking of personal data — temporary suspension of the processing of personal data (except when processing is necessary to clarify personal data).
2.3. Website — a collection of graphic and informational materials, as well as software and databases, ensuring their availability on the Internet at the address https://swaggy.agency/.
2.4. Personal data information system — a set of personal data contained in databases and the information technologies and technical means ensuring their processing.
2.5. Depersonalization of personal data — actions that result in it being impossible, without additional information, to determine the affiliation of personal data to a specific User or other personal data subject.
2.6. Processing of personal data — any action (operation) or set of actions (operations) performed using automation tools or without using such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
2.7. Operator — a state body, municipal body, legal entity, or natural person that independently or jointly with other persons organizes and/or carries out the processing of personal data, as well as determines the purposes of processing personal data, the composition of personal data to be processed, and the actions (operations) performed with personal data.
2.8. Personal data — any information that relates directly or indirectly to an identified or identifiable User of the website https://swaggy.agency/.
2.9. Personal data allowed by the personal data subject for distribution — personal data to which an unlimited number of persons has been granted access by the personal data subject by giving consent to the processing of such personal data for distribution in the manner prescribed by the Personal Data Law (hereinafter referred to as personal data allowed for distribution).
2.10. User — any visitor to the website https://swaggy.agency/.
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 at making personal data available to an unlimited number of persons, including publication of personal data in mass media, posting in information and telecommunication networks, or providing access to personal data in any other way.
2.13. Cross-border transfer of personal data — transfer of personal data to the territory of a foreign state to a foreign state authority, a foreign individual, or a foreign legal entity.
2.14. Destruction of personal data — any actions that result in personal data being destroyed irreversibly, making it impossible to further restore the content of personal data in the personal data information system and/or resulting in the destruction of tangible media on which personal data is stored.

3. Basic Rights and Obligations of the Operator
3.1. The Operator has the right to:

• receive accurate information and/or documents containing personal data from the personal data subject;
• in the event that the personal data subject withdraws consent to the processing of personal data, or sends a request to cease processing, the Operator has the right to continue processing personal data without the subject’s consent if there are grounds specified in the Personal Data Law;
• independently determine the scope and list of measures necessary and sufficient to ensure fulfillment of the 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 obliged to:

• provide the personal data subject, upon request, with information regarding the processing of their personal data;
• organize the processing of personal data in accordance with the current legislation of the Russian Federation;
• respond to requests and inquiries from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
• provide the authorized body for the protection of the rights of personal data subjects, upon request, with the necessary information within 10 days from the date of receiving such request;
• publish or otherwise ensure unrestricted access to this Policy regarding the processing of personal data;
• take legal, organizational, and technical measures to protect personal data against unlawful or accidental access, destruction, alteration, blocking, copying, provision, distribution, as well as against other unlawful actions with respect to personal data;
• cease transfer (distribution, provision, access), stop processing, and destroy personal data in the manner and cases provided for by the Personal Data Law;
• fulfill other obligations established 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. Such information is provided to the personal data subject by the Operator in an accessible form and must not contain personal data relating to other personal data subjects, unless there are legal grounds for disclosure of such data. The list of information and the procedure for obtaining it are 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 not necessary for the stated purpose of processing, as well as take measures provided by law to protect their rights;
• demand prior consent to the processing of personal data for the purpose of promoting goods, works, and services on the market;
• withdraw consent to the processing of personal data and send a request to cease processing of personal data;
• appeal to the authorized body for the protection of the rights of personal data subjects or in court against unlawful actions or inaction of the Operator during the processing of their personal data;
• exercise other rights provided by the legislation of the Russian Federation.

4.2. Personal data subjects are obliged to:

• provide the Operator with accurate information about themselves;
• inform the Operator about clarification (updating, changing) of their personal data.

4.3. Persons who provide the Operator with inaccurate 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. Principles of Personal Data Processing
5.1. The processing of personal data is carried out on a lawful and fair basis.
5.2. The processing of personal data is limited to achieving specific, predetermined, and lawful purposes. Processing of personal data that is incompatible with the purposes of collecting personal data is not permitted.
5.3. The combination of databases containing personal data, the processing of which is carried out for purposes incompatible with each other, is not permitted.
5.4. Only personal data that meets the purposes of its processing is subject to processing.
5.5. The content and scope of the processed personal data correspond to the declared purposes of processing. Excessive processing of personal data in relation to the declared purposes is not permitted.
5.6. When processing personal data, the accuracy, sufficiency, and, where necessary, relevance of the personal data in relation to the purposes of personal data processing is ensured. The Operator shall take the necessary measures and/or ensure the adoption of such measures to remove or clarify incomplete or inaccurate data.
5.7. Personal data shall be stored in a form that allows the identification of the personal data subject for no longer than is required by the purposes of personal data processing, unless a longer retention period is established by federal law or a contract to which the personal data subject is a party, beneficiary, or guarantor. The processed personal data shall be destroyed or anonymized upon achieving the purposes of processing or when there is no further need to achieve such purposes, unless otherwise provided by federal law.

6. Purposes of Personal Data Processing
Purpose of processing: informing the User by sending electronic messages.
Personal data: email address.
Legal grounds: the Operator’s constituent documents.
Types of personal data processing: sending informational emails to the email address.

7. Conditions for Personal Data Processing
7.1. The processing of personal data is carried out with the consent of the personal data subject to the processing of his/her personal data.
7.2. The processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, for the exercise of the functions, powers, and duties imposed on the Operator by the legislation of the Russian Federation.
7.3. The processing of personal data is necessary for the administration of justice, enforcement of a judicial act, or an act of another body or official subject to enforcement in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. The processing of personal data is necessary for the performance of a contract to which the personal data subject is a party, beneficiary, or guarantor, as well as for the conclusion of 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.
7.5. The processing of personal data is necessary for the exercise of the rights and legitimate interests of the Operator or third parties, or for the achievement of socially significant purposes, provided that this does not violate the rights and freedoms of the personal data subject.
7.6. The processing of personal data made publicly available by the personal data subject or at his/her request (hereinafter — publicly available personal data) is carried out.
7.7. The processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.

8. Procedure for the Collection, Storage, Transfer, and Other Types of Processing of Personal Data
The security of personal data processed by the Operator is ensured through the implementation of legal, organizational, and technical measures necessary to fully comply with the requirements of the applicable legislation in the field of personal data protection.
8.1. The Operator ensures the safekeeping of personal data and takes all possible measures to prevent unauthorized access to personal data.
8.2. The User’s personal data will never, under any circumstances, be transferred to third parties, except in cases related to compliance with applicable legislation or if the personal data subject has given consent to the Operator for the transfer of data to a third party for the fulfillment of obligations under a civil contract.
8.3. In case of inaccuracies in personal data, the User may update them independently by sending a notification to the Operator at the Operator’s email address order@swaggy.agency with the note “Personal Data Update.”
8.4. The period of personal data processing is determined by achieving the purposes for which the personal data was collected, unless otherwise specified by a contract or applicable legislation. The User may withdraw consent to the processing of personal data at any time by sending a notification to the Operator via email to order@swaggy.agency with the note “Withdrawal of Consent to the Processing of Personal Data.”
8.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by such parties (Operators) in accordance with their User Agreements and Privacy Policies. The personal data subject should familiarize themselves with these documents. The Operator shall not be liable for the actions of third parties, including the service providers specified in this clause.
8.6. Restrictions imposed by the personal data subject on transfer (other than granting access), as well as on processing or conditions of processing (other than obtaining access) of personal data permitted for distribution, shall not apply in cases of processing personal data for state, public, or other public interests as defined by the legislation of the Russian Federation.
8.7. The Operator ensures the confidentiality of personal data during its processing.
8.8. The Operator stores personal data in a form that allows the identification of the personal data subject no longer than required by the purposes of personal data processing, unless a longer storage period is provided by federal law or a contract to which the personal data subject is a party, beneficiary, or guarantor.
8.9. The termination of personal data processing may occur upon achievement of the purposes of personal data processing, expiration of the validity of the consent of the personal data subject, withdrawal of consent by the personal data subject, or a request to cease processing of personal data, as well as upon detection of unlawful processing of personal data.

9. List of Actions Performed by the Operator with the Collected Personal Data
9.1. The Operator carries out the collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
9.2. The Operator performs automated processing of personal data with the receipt and/or transfer of the obtained information via information and telecommunication networks or without such networks.

10. Cross-Border Transfer of Personal Data
10.1. Before commencing activities involving the cross-border transfer of personal data, the Operator shall notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out such cross-border transfer (this notification shall be submitted separately from the notification of the intention to process personal data).
10.2. Prior to submitting the above-mentioned notification, the Operator must obtain the relevant information from the authorities of the foreign state, foreign individuals, or foreign legal entities to which the cross-border transfer of personal data is planned.

11. Confidentiality of Personal Data
The Operator and other persons who have obtained access to personal data are obliged not to disclose such data to third parties and not to distribute personal data without the consent of the personal data subject, unless otherwise required by federal law.

12. Final Provisions
12.1. The User may obtain any clarifications regarding the processing of their personal data by contacting the Operator via email at order@swaggy.agency.
12.2. Any changes to the Operator’s personal data processing policy will be reflected in this document. The Policy remains in effect indefinitely until it is replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet at: https://swaggy.agency/.