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Personal Data Processing Policy

Version of «9» July 2026
This English text is provided for convenience. The Russian version is the legally binding one, as the Operator acts under the laws of the Russian Federation.

1. General provisions

1.1. This Policy defines the procedure for processing and protecting the personal data of individuals (“Users”) who contact Individual Entrepreneur Andrey Sergeevich Mordovkin (the “Operator”) through the website scutum2-18.ru and related services, including a chat-bot in the Telegram messenger.

1.2. This Policy is developed in accordance with Federal Law No. 152-FZ of 27.07.2006 “On Personal Data” (the “Law”).

1.3. Operator:

1.4. By using the Operator’s website and services, including by sending messages through the chat-bot, the User confirms agreement with this Policy.

2. Categories of data and purposes of processing

2.1. The Operator processes: name (or the name the User gives); contact details for communication (phone number or messenger username); information about the request, provided voluntarily; date and time of the enquiry, chosen communication channel and consultation time.

2.2. The Operator does not request special categories of personal data or data of third parties.

2.3. Purposes: arranging an introduction and consultation on request; agreeing on time and channel of communication; sending informational and contractual materials on request; communication with the User, including reminders about the consultation.

2.4. Legal grounds: the Law, the consent of the data subject, and a contract to which the data subject is a party.

3. Processing and storage. Localisation

3.1. Recording, systematisation, accumulation, storage, updating and retrieval of personal data of citizens of the Russian Federation are carried out using databases located within the territory of the Russian Federation (part 5, article 18 of the Law).

3.2. To operate the dialogue service, automated processing of the enquiry text is applied. Before such processing the data are de-identified: name, phone numbers, e-mail addresses, usernames and other identifiers are removed or replaced, so that the transmitted information does not allow the User to be identified. Data that allow the User to be identified are stored solely in the Operator’s database within the Russian Federation.

3.3. The dialogue text is stored for no more than 7 calendar days, after which it is automatically deleted. Information about the enquiry and the User’s contact details are stored for the period necessary to achieve the purposes, or until consent is withdrawn.

4. Data transfer

4.1. The Operator does not sell or disclose personal data to third parties, except as provided by this Policy and legislation. Only de-identified data are used for the technological processing of the dialogue.

5. User rights

5.1. The User has the right to obtain information about the processing of their data, to require its clarification, blocking or deletion, to withdraw consent, and to appeal the Operator’s actions to the authorised body or in court.

5.2. To exercise these rights and to withdraw consent, the User sends a request to info@scutum2-18.ru. Withdrawal of consent does not affect the lawfulness of processing carried out beforehand.

6. Data protection

6.1. The Operator takes legal, organisational and technical measures to protect data: restricting access, storing data on secure servers in the Russian Federation, de-identification during technological processing, and setting storage periods and deletion procedures.

7. Cookies

7.1. The site uses technically necessary cookies. Their use is governed by the Cookie Policy.

8. Final provisions

8.1. The Operator may amend this Policy; the new version takes effect upon publication on the site. For all questions — info@scutum2-18.ru.

Individual Entrepreneur Andrey Sergeevich Mordovkin · OGRNIP 324508100149732 · INN 501213494303 · info@scutum2-18.ru