Privacy Policy

1. General Provisions
This Privacy Policy (hereinafter – the “Policy”) has been prepared in accordance with the requirements of Federal Law No. 152-FZ of July 27, 2006 On Personal Data (hereinafter – the “Personal Data Law”) and establishes the procedure for processing personal data as well as the measures implemented by Individual Entrepreneur Evgeny Gennadievich Oputin (hereinafter – the “Operator”) to ensure the security of personal data.
1.1. The Operator considers the observance of the rights and freedoms of individuals and citizens in the processing of their personal data, including the protection of the right to privacy, personal and family secrets, as its primary objective and essential condition for conducting its activities.
1.2. This Policy of the Operator regarding the processing of personal data applies to all information that the Operator may obtain about visitors to the website https://vagabondagency.com.


2. Key Terms Used in the Policy
2.1. Automated processing of personal data – processing of personal data by means of computer technology.
2.2. Blocking of personal data – the temporary suspension of personal data processing (except in cases where processing is necessary for the clarification of personal data).
2.3. Website – a set of graphic and informational materials, as well as software and databases, ensuring their availability on the Internet at the network address https://vagabondagency.com.
2.4. Personal data information system – a set of personal data contained in databases and the information technologies and technical means that ensure their processing.
2.5. Depersonalization of personal data – actions that result in it being impossible, without the use of additional information, to determine whether personal data belongs to a specific User or another personal data subject.
2.6. Processing of personal data – any action (operation) or set of actions (operations) performed with or without the use of automated tools with respect to 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 authority, municipal authority, legal entity, or natural person which, independently or jointly with other persons, organizes and/or carries out the processing of personal data, and also determines the purposes of personal data processing, the composition of personal data to be processed, and the actions (operations) performed with personal data.
2.8. Personal data – any information relating directly or indirectly to a specific or identifiable User of the website https://vagabondagency.com.
2.9. Personal data made publicly available by the personal data subject – 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 personal data made publicly available in accordance with the procedure established by the Personal Data Law (hereinafter – “personal data made publicly available”).
2.10. User – any visitor of the website https://vagabondagency.com.
2.11. Provision of personal data – actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Dissemination of personal data – any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or making personal data available to an unlimited number of persons, including publication of personal data in mass media, placement in information and telecommunication networks, or granting access to personal data in any other manner.
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 resulting in the irreversible elimination of personal data with no possibility of subsequent restoration of the content of personal data in the personal data information system and/or the destruction of the physical media on which personal data is stored.

3. Basic Rights and Obligations of the Operator
3.1. The Operator shall have the right:
— to obtain from the personal data subject accurate information and/or documents containing personal data;
— in the event that the personal data subject withdraws consent to the processing of personal data, or submits a request to terminate the processing of personal data, continue processing personal data without the consent of the personal data subject if there are legal grounds specified in the Personal Data Law;
— independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of the obligations stipulated by the Personal Data Law and regulatory legal acts adopted in accordance therewith, unless otherwise provided for by the Personal Data Law or other federal laws.
3.2. The Operator shall be obliged to:
— provide the personal data subject, upon request, with information relating to the processing of his/her personal data;
— organize the processing of personal data in accordance with the procedure established by the applicable 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 receipt of such request;
— publish or otherwise ensure unrestricted access to this Policy regarding the processing of personal data;
— implement legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, alteration, blocking, copying, provision, dissemination, as well as from other unlawful actions with respect to personal data;
— cease the transfer (dissemination, provision, access) of personal data, cease processing, and destroy personal data in the manner and in the cases provided for by the Personal Data Law;
— fulfill other obligations stipulated by the Personal Data Law.

4. Basic Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects shall have the right:
— to receive information relating to the processing of their personal data, except in cases provided for by federal laws. Such information shall be provided by the Operator to the personal data subject in an accessible form and shall not contain personal data relating to other personal data subjects, except where there are lawful grounds for disclosure of such personal data. The scope of information and the procedure for obtaining it shall be established by the Personal Data Law;
— request that the Operator clarify, block, or destroy their personal data if such data is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, and take statutory measures to protect their rights;
— stipulate a condition of prior consent for the processing of personal data for the purposes of promoting goods, works, and services on the market;
— withdraw consent to the processing of personal data, as well as submit a demand to terminate the processing of personal data;
— appeal to the authorized body for the protection of the rights of personal data subjects or to a court against unlawful actions or inaction of the Operator in the processing of their personal data;
— exercise other rights provided for by the legislation of the Russian Federation.
4.2. Personal data subjects shall be obliged to:
— provide the Operator with accurate information about themselves;
— inform the Operator of the clarification (updating, modification) of their personal data.
4.3. Persons who have provided the Operator with inaccurate information about themselves, or with information about another personal data subject without the latter’s consent, shall bear liability in accordance with the legislation of the Russian Federation.

5. Principles of Personal Data Processing
5.1. The processing of personal data shall be carried out on a lawful and fair basis.
5.2. The processing of personal data shall be limited to the achievement of specific, predetermined, and legitimate purposes. Processing of personal data that is incompatible with the purposes for which the personal data was collected shall not be permitted.
5.3. The merging of databases containing personal data, the processing of which is carried out for purposes that are incompatible with each other, shall not be permitted.
5.4. Only personal data that corresponds to the purposes of its processing shall be subject to processing.
5.5. The content and scope of the personal data being processed shall correspond to the stated purposes of processing. The processing of personal data that is excessive in relation to the stated purposes of its processing shall not be permitted.
5.6. When processing personal data, the accuracy, sufficiency, and, where necessary, relevance of personal data in relation to the purposes of its processing shall be ensured. The Operator shall take necessary measures and/or ensure that such measures are taken to remove or clarify incomplete or inaccurate data.
5.7. Personal data shall be stored 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 is established by federal law or by an agreement to which the personal data subject is a party, beneficiary, or guarantor. Processed personal data shall be destroyed or depersonalized upon the achievement of the processing purposes or where the necessity to achieve such purposes is lost, unless otherwise provided for by federal law.

6. Purposes of Personal Data Processing
The purpose of processing – collection of application forms in response to the Agency’s job vacancies.
Personal data:
— surname, first name, patronymic;
— email address;
— telephone numbers;
— year, month, date, and place of birth;
— photographs;
— details of an identity document;
— taxpayer identification number, date of registration, and details of the certificate of registration with the tax authority;
— information regarding education, profession, specialty, and qualifications, as well as details of education documents.Legal basis – the Operator’s constituent (founding) documents.

Types of personal data processing – collection, recording, systematization, accumulation, storage, destruction, and depersonalization of personal data.

7. Conditions for Processing Personal Data
7.1. The processing of personal data shall be 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 shall be necessary for the achievement of purposes provided for by an international treaty of the Russian Federation or by law, and for the performance of the functions, powers, and duties imposed on the Operator by the legislation of the Russian Federation.
7.3. The processing of personal data shall be necessary for the administration of justice, for the execution of a judicial act, or for the execution of an act of another body or official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. The processing of personal data shall be 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 of a contract under which the personal data subject will be a beneficiary or guarantor.
7.5. The processing of personal data shall be 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 shall be carried out where the personal data subject has granted access to an unlimited number of persons or at his/her request (hereinafter – “publicly available personal data”).
7.7. The processing of personal data shall be carried out where such personal data is subject to publication or mandatory disclosure in accordance with federal law.
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8. Procedure for Collection, Storage, Transfer, and Other Types of Processing of Personal Data
The security of personal data processed by the Operator shall be ensured through the implementation of legal, organizational, and technical measures necessary to fully comply with the requirements of applicable legislation in the field of personal data protection.
8.1. The Operator shall ensure the safekeeping of personal data and shall take all possible measures to prevent unauthorized access to personal data.
8.2. The User’s personal data shall never, under any circumstances, be transferred to third parties, except in cases related to compliance with applicable legislation or where 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 law contract.
8.3. In the event of inaccuracies in personal data, the User may update such data independently by sending a notice to the Operator at the email address hello@vagabondagency.com marked “Update of personal data.”
8.4. The period of personal data processing shall be determined by the achievement of the purposes for which the personal data was collected, unless a different period is provided for by contract or applicable legislation. The User may at any time withdraw consent to the processing of personal data by sending a notice to the Operator at the email address hello@vagabondagency.com marked “Withdrawal of consent to the processing of personal data.”
8.5. All information collected by third-party services, including payment systems, communication providers, and other service providers, shall be stored and processed by such parties (Operators) in accordance with their User Agreements and Privacy Policies. The personal data subject shall independently familiarize himself/herself with such documents. The Operator shall not be liable for the actions of third parties, including the service providers referred to in this clause.
8.6. Restrictions established by the personal data subject on the transfer (other than the provision of access), as well as on the processing or conditions of processing (other than access) of personal data made publicly available, shall not apply in cases where personal data is processed in state, public, or other public interests as defined by the legislation of the Russian Federation.
8.7. The Operator shall ensure the confidentiality of personal data when processing personal data.
8.8. The Operator shall store personal data in a form that makes it possible to identify the personal data subject for no longer than required by the purposes of personal data processing, unless a longer storage period is established by federal law or by a contract to which the personal data subject is a party, beneficiary, or guarantor.
8.9. Grounds for termination of personal data processing may include the achievement of the purposes of personal data processing, the expiration of the personal data subject’s consent, the withdrawal of consent by the personal data subject, a demand to terminate personal data processing, or the identification of unlawful personal data processing.

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

10. Cross-Border Transfer of Personal Data
10.1. Prior to 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 transfer (such notification shall be submitted separately from the notification of the intention to process personal data).
10.2. Prior to submitting the above notification, the Operator shall be obliged to obtain the relevant information from the authorities of the foreign state, or from foreign individuals or foreign legal entities, to whom 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 shall not disclose such personal data to third parties or disseminate such personal data without the consent of the personal data subject, unless otherwise provided for by federal law.

12. Final Provisions
12.1. The User may obtain any clarifications on issues of interest relating to the processing of his/her personal data by contacting the Operator via email at hello@vagabondagency.com.
12.2. Any changes to the Operator’s personal data processing policy shall be reflected in this document. This Policy shall remain in effect indefinitely until replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet at https://vagabondagency.com/en/privacy.