As a personal data subject, I freely, of my own will and in my own interest grant Individual Entrepreneur Andrei Viktorovich Svirin, Taxpayer Identification Number (INN) 772872317733, Primary State Registration Number of the Individual Entrepreneur (OGRNIP) 322774600176722 (hereinafter the Controller), specific, purpose-specific, informed, conscious and unambiguous consent to the processing of my personal data on the terms set out below.
Controller’s postal address: P.O. Box 15, Moscow, 117647, Russian Federation.
Email address for personal data matters: privacy@complex.moscow.
The Controller's website: https://complex.moscow/ (hereinafter the Website).
Terms used in this document: INN — Taxpayer Identification Number; OGRNIP — Primary State Registration Number of the Individual Entrepreneur; OGRN — Primary State Registration Number; LLC — limited liability company.
1. Purpose and Legal Basis of Processing
1.1. Consent is granted for the purposes of promoting the Controller's services through direct email contact, creating and maintaining an advertising subscription, implementing the settings I have chosen for receiving advertising messages, recording the circumstances of form submission, and investigating technical failures or unauthorized submissions when subscribing.
1.2. Processing is carried out on the basis of Clause 1 of Part 1 of Article 6, Article 9 and Part 1 of Article 15 of Federal Law No. 152-FZ of 27.07.2006 “On Personal Data” (hereinafter the Personal Data Law).
1.3. Advertising may be sent where separately granted prior consent to receive it exists in accordance with Part 1 of Article 18 of Federal Law No. 38-FZ of 13.03.2006 “On Advertising”. This consent does not in itself constitute consent to receive advertising.
2. Categories of personal data
2.1. Consent covers the following personal data:
- a) email address;
- b) subscription identifier;
- c) information about consents given: the result of the choice, dates and times of the corresponding actions, and document versions;
- d) subscription status and information about unsubscribing, including the date of withdrawal;
- e) technical information about submission of the subscription form: the IP address of the connection to the server, browser and device information (User-Agent), browser language (Accept-Language), the approximate time from opening the current page to submission as reported by the browser, and the time from preparation of the protected form to submission according to the server clock.
2.2. Processing is carried out exclusively to the extent necessary for the purpose specified in Clause 1.1.
2.3. This consent does not cover use of the text of an inquiry, documents, photographs or other attachments to a request, or information about the object of examination, for advertising mailings or advertising profiling.
3. Data Operations and Processing Methods
3.1. Within the stated purpose, the Controller may collect, record, systematize, accumulate, store, clarify (update, amend), retrieve, use, transfer (provide, grant access) to the persons specified in Section 4 to the extent necessary, block, delete and destroy personal data.
3.2. Processing is carried out using automated means, without such means, or by a combination of both.
3.3. This consent is given by independently selecting a separate, previously unselected checkbox in the subscription form on the Website, which contains a link to this document, and clicking the “Subscribe” button. An opportunity to read the document is provided before consent is given. Consent takes effect from the moment the corresponding form is submitted.
3.4. Advertising messages may be sent only where separate prior consent to receive advertising has been given. Providing an address in an inquiry form does not in itself create an advertising subscription.
4. Persons Engaged in Processing
4.1. The Controller uses the infrastructure of TIMEWEB.CLOUD LLC (INN 7810945525, OGRN 1227800052215) to host the Website and mail server. The server is located in the Russian Federation, in Moscow, at the SPB-3 site.
4.2. A mail service provided by VK LLC is also used for electronic correspondence.
4.3. These entities are provided exclusively with information necessary to perform the relevant technical task. Where personal data processing is entrusted to another entity, such entrustment is formalized in compliance with Part 3 of Article 6 of the Personal Data Law. Engaging third parties does not relieve the Controller of its statutory obligations toward the personal data subject.
4.4. This consent does not authorize transfer of my address to third parties for independent advertising of their goods, work or services.
5. Term of Consent and Retention Periods
5.1. A subscription is created through a separate form on the Website after both consents have been given: to receive advertising and to the processing of data for advertising mailings. No email to confirm the address is sent when subscribing.
5.2. Consent is valid for no more than three years from the date it is given, unless it is withdrawn earlier, the purpose of processing is achieved, or the corresponding subscription is terminated. Data is processed no longer than required for the stated purpose. The term may be extended only on the basis of new consent.
5.3. When the purpose is achieved, the consent expires or the subscription is terminated, processing for advertising mailings ceases. In the absence of a separate lawful basis for further retention, the Controller ensures destruction of the data in the manner and within the periods established by the Personal Data Law.
5.4. Minimal information necessary to confirm the consents received, implement an opt-out from advertising, or protect rights and legitimate interests may be retained on a separate basis provided for in Clause 7 of Part 1 of Article 6 of the Personal Data Law, subject to respect for the subject's rights and freedoms. Such information is limited to the address or another necessary subscription identifier, its status, and information about consents and withdrawal.
5.5. The information specified in Clause 5.4 is retained exclusively for as long as it is actually necessary, but for no more than three years from the date the subscription is terminated. This information may not be used to resume advertising messages. It is retained on a separate lawful basis and does not mean that this consent remains in effect.
5.6. The technical information specified in subclause “e” of Clause 2.1 is retained for no more than 30 calendar days from the date of subscription, including in copies of internal notifications to the administrator. This information is not included in the minimal consent records retained for up to three years. It is not used for behavioral analytics or advertising profiling and does not confirm the sender's identity or the duration of their visit to the entire Website.
6. Procedure for Withdrawing Consent
6.1. I may withdraw this consent at any time by sending a notice to privacy@complex.moscow or to the Controller's mailing address. To identify the subscription, it is recommended that the corresponding email address be specified.
6.2. Using the “Unsubscribe” link in an advertising email or successfully submitting the unsubscribe form simultaneously constitutes an opt-out from receiving advertising and withdrawal of this consent to data processing for advertising mailings. No additional application or email confirmation is required.
6.3. Upon receipt of a request, the Controller immediately ceases processing personal data for the purpose of promoting services through direct contact. The statutory period for destruction of data does not confer a right to continue advertising-related processing or sending advertising after the request has been received.
6.4. If retention of data is no longer necessary for the purposes of processing and there is no separate lawful basis, the Controller ensures its destruction within the statutory periods; where consent is withdrawn, Part 5 of Article 21 of the Personal Data Law applies. Minimal information may be retained only subject to compliance with the conditions in Clauses 5.4 and 5.5.
6.5. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal was received.
7. Voluntary Nature and Final Provisions
7.1. Granting this consent is voluntary and is not a condition for consideration of an inquiry, receipt of a reply, conclusion of a contract or provision of services. Refusal to grant it or its withdrawal does not restrict the ability to use the Website and submit inquiries.
7.2. This consent is given separately from consent to receive advertising, consent to process an inquiry, and consent to optional analytics. It does not replace those consents or expand their scope.
7.3. Amendments to this document do not change the scope of previously granted consent. If processing for other purposes or expansion of the categories of data is necessary, new consent is obtained before the relevant processing begins.
7.4. The procedure for exercising the rights of personal data subjects and general safeguards are set out in the Personal Data Processing Policy: https://complex.moscow/legal/privacy-policy/.