Privacy Policy

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” and defines the procedure for processing personal data and measures to ensure the security of personal data at RISKI LLC (hereinafter referred to as the “Controller”).

1. The Operator considers the observance of human and civil rights and freedoms in the processing of personal data—including the protection of the rights to privacy and personal and family confidentiality—to be its most important goal and a prerequisite for conducting its activities.
2. This Operator’s policy regarding the processing of personal data (hereinafter referred to as the “Policy”) applies to all information that the Operator may obtain about visitors to the website https://ru.riscy.com/.

2. Key Terms Used in the Policy

1. Automated processing of personal data—the processing of personal data using computer technology;
2. Blocking of personal data — the temporary suspension of the processing of personal data (except in cases where processing is necessary to verify the accuracy of the personal data);
3. Website — a collection of graphic and informational materials, as well as computer programs and databases, that make them accessible on the Internet at the web address https://ru.riscy.com/;
4. Personal data information system — a collection of personal data contained in databases, along with the information technologies and technical means that enable their processing;
5. Anonymization of personal data — actions that make it impossible to determine, without the use of additional information, that the personal data belongs to a specific User or other data subject;
6. Processing of personal data — any action (operation) or set of actions (operations) performed with or without the use of automated means on personal data, including the collection, recording, organization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, disclosure, access), anonymization, blocking, deletion, and destruction of personal data;
7. Controller—a state agency, a municipal agency, a legal entity or an individual who, independently or jointly with other persons, organizes and/or carries out the processing of personal data, as well as determines the purposes of personal data processing, the scope of personal data to be processed, and the actions (operations) performed on personal data;
8. Personal Data — any information relating directly or indirectly to an identified or identifiable User of the website https://ru.riscy.com/;
9. User—any visitor to the website https://ru.riscy.com/;
10. Provision of personal data—actions aimed at disclosing personal data to a specific person or a specific group of persons;
11. Dissemination of personal data — any actions aimed at disclosing personal data to an unspecified group of persons (transfer of personal data) or at making personal data available to an unlimited group of persons, including the publication of personal data in the media, posting on information and telecommunications networks or providing access to personal data by any other means;
12. Destruction of personal data—any actions resulting in the irreversible destruction of personal data, making it impossible to subsequently restore the content of the personal data in the personal data information system, and/or resulting in the destruction of physical media containing personal data.

3. The Operator may process the following personal data of the User

1. Last name, first name, patronymic;
2. Email address;
3. Phone numbers;
4. Unique identifiers;
5. Information about how your browsers and devices interact with our services, including your IP address, crash reports, system activity logs, the date and time you visited our website, and the URL from which you accessed it (referrer URL);
6. The website also collects and processes anonymized data about visitors (including “cookies”) using web analytics services (Yandex Metrica).

The data listed above is collectively referred to as “Personal Data” throughout this Policy.

4. Purposes of Personal Data Processing

1. The Operator processes the User’s personal data for the following purposes:
   1. 1.1 to provide services to Users and ensure the performance of contracts with Users, including through the use of technological tools;
   2. 1.2 to communicate with Users: sending notifications, emails, information, and other messages; informing Users about services and promotions by phone;
   3. 1.3 to monitor the Operator’s website: to review data on the use of the website and other technological services, as well as to optimize their functionality;
   4. 1.4 providing Users with technical support for products and services and improving the quality of the Operator’s products and services;
   5. 1.5 ensuring the security of the Operator’s website and protecting User data;
   6. 1.6 fulfilling the obligations imposed on the Operator by Russian Federation law.
2. The Operator also has the right to send Users notifications about new products and services, special offers, and various events. Users may opt out of receiving these informational messages at any time by sending an email to the Operator at info@riscy.com with the subject line “Opt-out of notifications about new products, services, and special offers.”
3. Anonymized User data collected through web analytics services is used to gather information about User activity on the website and to improve the quality of the website and its content.

5. Legal Basis for the Processing of Personal Data

1. The Operator processes the User’s personal data only if the User voluntarily enters and/or submits it via the forms provided on the website https://ru.riscy.com/. By filling out the relevant forms and/or submitting their personal data to the Operator, the User expresses their consent to this Policy.
2. The Operator processes anonymized data about the User if this is permitted in the User’s browser settings (cookie storage and the use of JavaScript are enabled).
3. The legal grounds for the Operator’s processing of personal data are:
   • Federal Law No. 152-FZ of July 27, 2006, “On Personal Data”;
   • The Civil Code of the Russian Federation;
   • Federal Law No. 149-FZ of July 27, 2006, “On Information, Information Technologies, and Information Protection”;
   • The User’s consent to the processing of their personal data;
   • Agreements concluded between the Operator and the User.

6. Procedure for the Collection, Storage, Transfer, and Processing of Personal Data.

1. The Operator ensures the security of personal data and takes all possible measures to prevent unauthorized persons from accessing personal data.

2. The User’s personal data will never, under any circumstances, be transferred to third parties, except in cases related to compliance with applicable law, as well as to the following categories of contractors (processors):

   • Hosting providers and technical support services;
   • Analytics services (Yandex.Metrica);
   • Email marketing services and CRM systems;
   • Partners involved in providing services to the User.

   In all cases where data is transferred to third parties, the Operator enters into a confidentiality and personal data protection agreement with them, obligating them to comply with the requirements of this Policy.

3. If inaccuracies are found in personal data, the User may update them independently by sending a notification to the Operator’s email address info@riscy.com with the subject line “Update of Personal Data.”
4. Users’ personal data is processed for the entire duration of the service. The User may withdraw their consent to the processing of personal data at any time by sending a notice to the Operator via email to the Operator’s email address info@riscy.com, marked “Withdrawal of Consent to the Processing of Personal Data.”
5. Withdrawal of consent will not affect the lawfulness of processing carried out prior to the withdrawal. In the event of withdrawal of consent, the Operator is obligated to cease processing personal data and destroy it within a period not exceeding 30 (thirty) days from the date of receipt of the withdrawal, unless otherwise provided by the agreement with the User or the legislation of the Russian Federation.

7. Final Provisions

1. The User may obtain any clarifications regarding questions of interest concerning the processing of their personal data by contacting the Operator via email at info@riscy.com or by sending a written request to the Operator’s mailing address specified in Section 1.1.
2. This document will reflect any changes to the Operator’s personal data processing policy. The policy remains in effect indefinitely until replaced by a new version.
3. The period for processing personal data is determined by the achievement of the purposes for which it was collected, unless a different period is provided for by contract or the legislation of the Russian Federation.
4. The current version of the Policy is freely available on the Internet at https://ru.riscy.com/privacy-policy.