Personal Data Processing Terms

Privacy Policy

Natalia V. Golik, Sole Proprietor (hereinafter referred to as the «administration of smmgolik.com,» the «Operator,» «we,» «our,» or «us»), registered at 42a Kishinevskaya St., Orenburg, 460019, Russia, is committed to protecting your privacy and safeguarding your personal data.

This Policy is designed to inform you about how we collect, process, and protect your personal data in pursuit of the stated purposes on smmgolik.com.

We comply with the requirements of Russian legislation on personal data. In processing personal data, we adhere to the principles set forth in Article 5 of Federal Law No. 152-FZ dated July 27, 2006, «On Personal Data» (hereinafter referred to as «152-FZ»).

We encourage you to review this Privacy Policy (hereinafter referred to as the «Policy») carefully so you can understand why we process your personal data and how you can exercise your rights with respect to the data we hold.

If you have any questions regarding this Policy — including suggestions for improving its clarity or navigation — or about how we process and protect your personal data, please reach out to us using any of the methods listed in the «Contacts» section.

Definitions

Personal Data — any information relating directly or indirectly to an identified or identifiable individual (the «data subject»).

Personal Data Operator («Operator») — a government body, municipal authority, legal entity, or individual who independently or jointly with others organizes and/or carries out the processing of personal data and determines the purposes, scope, and methods of such processing.

Processing of Personal Data — any action (operation) or set of actions (operations) performed on personal data, whether by automated or non-automated means.

Processing of personal data includes, but is not limited to:

• Collection
• Recording
• Organization
• Accumulation
• Storage
• Modification (updating, amendment)
• Retrieval
• Use
• Transfer (distribution, provision, access)
• Anonymization
• Restriction
• Deletion
• Destruction

Automated Processing of Personal Data — the processing of personal data using computing technology.

Distribution of Personal Data — actions aimed at disclosing personal data to an indefinite number of persons.

Provision of Personal Data — actions aimed at disclosing personal data to a specific individual or a defined group of persons.

Restriction of Personal Data — the temporary cessation of personal data processing (except where processing is necessary to update or correct such data).

Destruction of Personal Data — actions that render it impossible to recover the content of personal data within a personal data information system and/or result in the destruction of physical media containing personal data.

Anonymization of Personal Data — actions that render it impossible, without the use of additional information, to attribute personal data to a specific data subject.

Personal Data Information System — the aggregate of personal data contained in databases, together with the information technologies and technical means that enable their processing.

Cross-Border Transfer of Personal Data — the transfer of personal data to the territory of a foreign state, to a foreign government authority, a foreign individual, or a foreign legal entity.

Scope

This Policy is designed to inform you about how we collect, process, and protect your personal data in pursuit of the stated purposes on smmgolik.com.

The specific data processing activities covered by this Policy are listed in the section «Why We Process Your Personal Data.»

Please note that our website may contain links to third-party resources that are beyond our control and are not governed by this Policy.

Collection of Minors’ Personal Data

Our website is not intended for the processing of personal data belonging to minors. If you have reason to believe that a minor has submitted personal data to us through the website, please notify us by writing to email@smmgolik.com.

Why We Process Your Personal Data

We process your personal data on this website for the purposes described below. Please treat the text under each numbered heading (e.g., «3.1.1. Title») as the text of your consent to personal data processing. Information on how to withdraw such consent is provided in Sections 4.9 and 4.10.

3.1.1 Personal Data Input Form 1

Purpose of processing: Requesting a callback.

Personal data processed for this purpose: Name; phone number.

Actions we may perform with your personal data: Collection, recording, organization, accumulation, storage, modification (updating, amendment), retrieval, use, transfer (provision, access), restriction, deletion, destruction.

Legal basis for processing: Consent to the processing of personal data.

Retention period: Until the completion of the phone call and any subsequent correspondence with the individual.

3.1.2 Personal Data Input Form 2

Purpose of processing: Processing incoming service inquiries.

Personal data processed for this purpose: Name; phone number; email.

Actions we may perform with your personal data: Collection, recording, organization, accumulation, storage, modification (updating, amendment), retrieval, use, transfer (provision, access), restriction, deletion, destruction.

Legal basis for processing: Consent to the processing of personal data.

Retention period: Until the inquiry is declined or a service agreement is executed, whichever occurs first.

3.1.3 Personal Data Input Form 3

Purpose of processing: Newsletter subscription.

Personal data processed for this purpose: Name; phone number; email.

Actions we may perform with your personal data: Collection, recording, organization, accumulation, storage, modification (updating, amendment), retrieval, use, transfer (provision, access), restriction, deletion, destruction.

Legal basis for processing: Consent to the processing of personal data.

Retention period: Until the individual unsubscribes from the mailing list.

3.1.4 Personal Data Input Form 4

Purpose of processing: Collecting applications from job candidates for open positions.

Personal data processed for this purpose: Full name; phone number; email; position applied for; age; education; place of residence.

Actions we may perform with your personal data: Collection, recording, organization, accumulation, storage, modification (updating, amendment), retrieval, use, transfer (provision, access), restriction, deletion, destruction.

Legal basis for processing: Consent to the processing of personal data.

Retention period: Until the candidate is hired or until the application is declined, whichever occurs first.

What Are Your Rights?

4.1. Overview of Your Rights

In accordance with 152-FZ, you have the following rights with respect to the processing of your personal data:

• Right of access to your personal data;
• Right to rectification of your personal data;
• Right to challenge our actions or inaction;
• Right to contest decisions made solely on the basis of automated processing of your personal data;
• Right to withdrawconsent.

4.2. Additional Information Requests for Identity Verification

In the course of exercising your rights, we may request additional information to reliably verify your identity. Such requests will be made only in rare cases.

We endeavor to request only the minimum information necessary for verification.

We will be unable to fulfill your request if you do not provide the additional information required for identity verification.

4.3. Terms for Providing Information Regarding Your Rights

Information related to the exercise of your rights is provided free of charge. If your request is manifestly unfounded or excessive — particularly due to its repetitive nature — we may decline to respond or charge a reasonable fee for providing the requested information.

4.4. Right of Access to Your Personal Data

You have the right to obtain accurate information from us about the processing of your personal data and, where possible, access to such data, including the following details:

• Confirmation that your personal data is being processed by the Operator;
• The legal basis and purposes of data processing;
• The methods employed by the Operator for data processing;
• The name and location of the Operator, and information about persons (other than the Operator’s employees) who have access to personal data or to whom personal data may be disclosed under a contract with the Operator or under applicable law;
• The specific personal data being processed and the source from which it was obtained;
• The data processing timeline, including retention periods;
• The procedure for exercising your rights under 152-FZ;
• Information about any completed or planned cross-border data transfers;
• The name or full name and address of any person processing personal data on behalf of the Operator, if such processing has been or will be delegated.

4.5. Right to Rectification of Your Personal Data

We take reasonable steps to identify inaccurate, incomplete, or outdated data.

If your data is inaccurate, incomplete, or outdated, you have the right to request that we correct it without undue delay.

Once your personal data has been corrected, we will notify you accordingly.

4.6. Right to Challenge Our Actions or Inaction

You have the right to object to the processing of your personal data in response to our actions or inaction.

To do so, you may contact the territorial office of Roskomnadzor in your region.

4.7. Right to Contest Decisions Based Solely on Automated Processing

You have the right not to be subject to a decision based solely on automated processing — including profiling — that produces legal effects concerning you or similarly significantly affects you.

You may contact us to challenge any such decision, if applicable.

4.8. Right to Withdraw Consent

If your data is processed on the basis of consent, you have the right to withdraw that consent at any time.

4.9. How Can You Exercise Your Rights?

We offer several ways for you to exercise your rights:

• By mail: Send a written request to 42a Kishinevskaya St., Orenburg, 460019, Russia, including your identity document details (document type, series and number, issuing authority and date), your full name (or that of your representative), information about your relationship with us that confirms the processing of your personal data, and your signature (or that of your representative). This request may also be sent to our email address as an electronic document signed in accordance with Russian legislation on electronic signatures.
• By email: You may also contact us directly at email@smmgolik.com.

4.10. When and How We May Be Unable to Fulfill Your Rights

We may limit the scope of our obligations and your rights (including access, rectification, restriction, or deletion of data) in the following circumstances:

• The processing of personal data — including data obtained through investigative, counterintelligence, or intelligence activities — is carried out for the purposes of national defense, state security, or law enforcement;
• The processing is carried out by authorities that have detained the data subject on suspicion of a crime, brought criminal charges against the data subject, or imposed a pretrial restraining measure — except where criminal procedure law permits the suspect or accused to access such data;
• The processing is carried out in compliance with anti-money laundering and counter-terrorism financing legislation;
• Granting the data subject access to their data would infringe upon the rights and legitimate interests of third parties;
• The processing is carried out in accordance with Russian transport security legislation for the purposes of ensuring the stable and safe operation of transport infrastructure and protecting individuals, society, and the state from unlawful interference;
• We have other lawful grounds for continuing to process your personal data.

Certain rights may be subject to specific conditions that must be met before the right can be exercised.

If we are unable to fulfill your request, we will provide you with a reasoned explanation.

Cookies and Automatic Logging

Cookies are one of the technologies we use to automatically collect information and improve content quality. A cookie is a small text file stored on your device (computer, tablet, smartphone, etc.) that contains information about your online activity.

Like most other organizations’ web resources, our web servers and security systems periodically store certain temporary technical data in their log files.

Cookies collected on our website:

Name	Provider	Lifespan
_ga	.smmgolik.com/en	399 д. 23 ч.
_ga_54EPJTYVS1	.smmgolik.com/en	399 д. 23 ч.
_yasc	.yandex.ru	399 д. 23 ч.
_ym_d	.yandex.ru	351 д. 23 ч.
_ym_d	.smmgolik.com/en	197 д. 3 ч.
_ym_isad	.yandex.ru	366 д. 23 ч.
_ym_isad	.smmgolik.com/en	366 д. 23 ч.
_ym_uid	.smmgolik.com/en	197 д. 3 ч.
_ym_uid	.yandex.ru	351 д. 23 ч.
_ym_visorc	.smmgolik.com/en	364 д. 23 ч.
amcuid	.yandex.ru	364 д. 23 ч.
balance_cookie	.yandex.ru	397 д. 23 ч.
bh	.yandex.ru	399 д. 23 ч.
bh	mc.yandex.ru	414 д. 23 ч.
font_loaded	.yandex.ru	334 д. 23 ч.
gdpr	.yandex.ru	364 д. 23 ч.
i	.yandex.ru	399 д. 23 ч.
is_gdpr	.yandex.ru	385 д. 23 ч.
is_gdpr_b	.yandex.ru	385 д. 23 ч.
L	.yandex.ru	399 д. 23 ч.
my	.yandex.ru	385 д. 23 ч.
receive-cookie-deprecation	.yandex.ru	364 д. 23 ч.
sessar	.yandex.ru	399 д. 23 ч.
Session_id	.yandex.ru	399 д. 23 ч.
sessionid2	.yandex.ru	399 д. 23 ч.
usst	.mc.yandex.ru	397 д. 23 ч.
yabs-sid	mc.yandex.ru	0 ч.
yandex_login	.yandex.ru	364 д. 23 ч.
yandexuid	.yandex.ru	117 д. 23 ч.
yashr	.yandex.ru	134 д. 23 ч.
ymex	.yandex.ru	44 д. 23 ч.
yp	.yandex.ru	399 д. 23 ч.
ys	.yandex.ru	0 ч.
yuidss	.yandex.ru	79 д. 23 ч.

Data Security

The personal data we collect and store is treated as confidential information. It is protected against loss, alteration, or unauthorized access in accordance with the personal data legislation of the Russian Federation. To this end, we employ both technical safeguards and organizational measures. We continuously enhance our data protection systems.

Changes to This Policy

We reserve the right to update this Policy at any time. We encourage you to review any changes on a regular basis. In the event of material changes, we will make reasonable efforts to notify you through all available channels.

Contacts

Please note that the contact details provided in this section are intended solely for inquiries related to the processing and protection of your personal data. Any communications sent to the contacts listed in this Policy that are unrelated to data protection will not be addressed. For questions regarding the processing and protection of personal data, please contact our designated Data Protection Officer directly: Natalia V. Golik, email@smmgolik.com.