Privacy Policy on the processing of personal data
Version of 06.10.2026. Publication date 06.10.2026. Effective date 06.10.2026.
This document is drafted as a policy under part 2 of art. 18.1 of Federal Law No. 152-FZ of 27.07.2006, and not as a freely written “privacy policy”. Publication of such a document in open access is a duty of the Operator.
1. General provisions
1.1. This Policy defines the procedure for the processing and protection of personal data of individuals (hereinafter - Subjects), carried out by Anton Filimonov (hereinafter - the Operator) when using the “Po lapam!” service (English name - “Po lapam!”) - the polapam.ru website and two mobile applications: “Po lapam!” (“Po lapam!”) - for Clients and “Po lapam! Pro” (“Po lapam! Pro”) - for Specialists (hereinafter jointly - the Service). The Russian-language and English-language names are equivalent and denote one and the same Service. The exclusive rights to the Service belong jointly to Anton Filimonov and Artem Yakovlev; the personal data operator within the meaning of the Law is Anton Filimonov (section 2).
1.2. The Policy has been developed in accordance with the Constitution of the Russian Federation, the Civil Code of the Russian Federation, Federal Law No. 152-FZ of 27.07.2006 “On Personal Data” (hereinafter - Law No. 152-FZ), Federal Law No. 149-FZ of 27.07.2006 “On Information, Information Technologies and the Protection of Information”, and the resolutions of the Government of the Russian Federation of 01.11.2012 No. 1119 and of 15.09.2008 No. 687.
1.3. The Policy applies to all personal data that the Operator receives from Subjects or about Subjects, regardless of the manner in which they are received and regardless of whether they are processed using automated means or without such means.
1.4. The current version of the Policy is published at polapam.ru/en/privacy/ and is available without restrictions. The text of the Policy is also available in every mobile application: on the registration screen - before an Account is created, and in the Account settings - at any time afterwards.
1.5. The basic concepts are used in the meanings established by art. 3 of the Law. The terms “Client”, “Specialist”, “User”, “Name”, “Order”, “Profile”, “Pet”, “Pet card” and “Photo Report” are used in the meanings established by the User Agreement published at polapam.ru/en/agreement/.
2. Information about the Operator
2.1. The Operator: Anton Filimonov, an individual person.
Tax ID 631816218908.
Address: 91 Lva Tolstogo St., Samara.
Address for sending requests on matters of personal data processing: support@polapam.ru.
2.2. The person responsible for organising the processing of personal data (art. 22.1 of the Law): the Operator - Anton Filimonov, contact details: support@polapam.ru.
3. Legal grounds for processing
3.1. The Operator processes personal data on the following legal grounds:
a) performance of a contract to which the Subject is a party - the User Agreement (cl. 5 part 1 art. 6 of the Law);
b) performance of the obligations imposed on the Operator by legislation (cl. 2 part 1 art. 6 of the Law);
c) exercise of the rights and legitimate interests of the Operator or of third parties, provided that the rights and freedoms of the Subject are not violated (cl. 7 part 1 art. 6 of the Law), - including for the prevention of violations, the consideration of incident reports and the protection of rights in court;
d) the Subject's consent (cl. 1 part 1 art. 6 of the Law) - for the purposes expressly indicated in section 7 as requiring consent;
e) consent to the dissemination of personal data (art. 10.1 of the Law) - for the publication of the Specialist's Profile;
f) processing of personal data to which access by an unlimited circle of persons has been provided by the Subject (cl. 10 part 1 art. 6 of the Law) - in respect of the information that the User has published independently in the Service.
3.2. The processing of personal data is limited to the achievement of specific, predetermined and lawful purposes. Processing that is incompatible with the purposes of collection is not permitted, nor is the merging of databases created for incompatible purposes.
4. Categories of Subjects and the composition of the data processed
4.1. Clients - the owners of Pets who post Requests and order Services
The Name specified by the Subject at registration (cl. 4.8); the mobile phone number, which is also the login of the Account; the email address; the profile photo (if uploaded); the district of residence; the address at which the Service is provided - for visits and boarding; the information of the Pet card relating to the Client as the owner of the Pet (species, breed, name, sex, date of birth or age, colour, sterilisation details, the Pet's photo, the microchip number with the date and place of chipping, the tattoo number with the date, as well as the Client's note about the Pet - what it is afraid of, which medicines it takes and any other particular the Client saw fit to mention); the Order history; messages in the Service chat; reviews and ratings; requests to Support and the correspondence about them; the technical data under cl. 4.6.
4.2. Specialists - persons providing Services for the care of Pets
The Name specified by the Subject at registration (cl. 4.8); the name under which the Subject carries on activity, if specified by the Subject; the mobile phone number, which is also the login of the Account; the email address; the profile photo; the city and the districts in which Services are provided; the information about experience, education, completed courses and place of work specified by the Subject; the assurances provided under section 7.2 of the User Agreement - in the form of a mark about their submission; the status of the Profile's review by a moderator; the Order history; Photo Reports, including the coordinates and the time of capture; the rating, the badges and the history of their changes; messages in the Service chat; reviews; requests to Support; the technical data under cl. 4.6.
4.3. Persons who have not completed registration
The Service does not envisage use without registration: the browsing of Profiles and Requests, search and other functions are unavailable to persons who have not created an Account. Until registration is completed, the Operator processes only the technical data under cl. 4.6 that arises when the application contacts the server, including during registration and sign-in.
4.4. Representatives of advertising partners
Surname, first name and patronymic; job title; work phone number; work email address; name of the organisation. They are processed for the conclusion and performance of contracts on the placement of advertising. As of the date of this version, data of this category is not processed: no advertising is placed in the Service and no contracts with advertisers are concluded.
4.5. Persons specified by Users
The Emergency Contact and any other representative of the Client authorised to take in the Pet: name, relationship to the Client. The data is provided by the Client. Processing is limited to arranging contact with that person in respect of a specific Order and in connection with an incident.
4.6. Technical data
The IP address; the device identifier; information about the device, the operating system and the browser; the data of files cookie and similar technologies; the date, time and duration of sessions; the pages and screens viewed; the source of the transition; information about malfunctions of the application; the device location data - in the cases indicated in cl. 6.5, including the recording of the route of the walking Service (a sequence of coordinates with timestamps and stated accuracy).
4.7. Data that the Operator does not process
4.7.1. The Operator does not process special categories of personal data concerning racial and national origin, political views, religious and philosophical beliefs, state of health and intimate life (art. 10 of the Law).
4.7.2. The Operator does not process information about criminal record. The processing of such information is permitted only in the cases and in the procedure established by federal laws (part 3 art. 10 of the Law); the Operator has no legal grounds for processing it. The Operator does not request, accept or store certificates of the presence (absence) of a criminal record.
4.7.3. The Operator does not establish the identity of the Subject and does not process biometric personal data. Images and the details of an identity document are not requested, not accepted and not stored; the profile photo is not compared with the photo in the document. Sign-in to the application by fingerprint or by facial image, if the Subject has enabled it, is performed by means of the device's operating system: the application receives from it only the result of the check - whether it was confirmed or not - while the biometric data never leaves the device and is not transmitted to the Operator. The Operator does not create or operate information systems that ensure identification and authentication by biometric personal data (art. 15 of Federal Law No. 572-FZ of 29.12.2022). The procedure for confirming information about a Specialist is established by cl. 6.4.
4.7.4. The Operator does not process the Subject's surname and patronymic, their date of birth, information about their tax status and Tax ID.
4.7.5. The Operator does not process the personal data of minors. Use of the Service by persons under 18 years of age is not permitted. When data of a minor is detected, the Operator terminates the processing and destroys such data in the procedure set out in section 11.
4.7.6. If the Subject independently sends the Operator the data listed in cls. 4.7.1 - 4.7.2 and 4.7.4, the Operator does not enter it into information systems and destroys it in the procedure set out in section 11 within a period of no more than 7 working days.
4.8. The Subject's Name
4.8.1. A Name is the designation that the Subject chooses independently and under which they are displayed in the Service. A Name may be a personal name, a pseudonym, a network handle or the name under which the Subject carries on activity. The Operator does not verify whether the Name matches the Subject's documents, nor whether the Subject holds the rights to the trademarks, trade names and other means of individualisation used in the Name. The Subject bears responsibility for the choice of the Name; the requirements for it are established by the User Agreement.
4.8.2. The Subject is entitled to change the Name in the Account settings. Changing the Name does not affect reviews, the Order history or any other records created before the change; the current Name is displayed in them.
5. Purposes of processing and retention periods
| Purpose | Which data (clauses of this Policy) | Legal basis | Retention period |
|---|---|---|---|
| Registration and maintenance of the Account, authentication | cl. 4.1, 4.2 | Contract | The entire term of the Account + 1 year |
| Providing access to the functionality of the Service, matching and displaying Profiles and Requests | cl. 4.1, 4.2, geodata | Contract | The entire term of the Account |
| Publication of the Specialist's Profile in open access | Name, photo, district, services, prices, experience, rating, reviews | Consent to dissemination (art. 10.1 of the Law) | Until the consent is withdrawn |
| Review of the Profile by a moderator | Name, contents and photos of the Profile | Contract; legitimate interest | The entire term of the Account; the mark about the result of the review - 3 years |
| Arranging communication between Users, chat, notifications | cl. 4.1, 4.2 | Contract | 3 years from the date of the Order |
| Compiling and storing the Photo Report | Photo and video materials, coordinates, time | Contract | 1 year from the date of the Order |
| Recording and displaying the route of the walking Service (cl. 6.5.1) | Coordinates of the Specialist's device with timestamps and accuracy marks | Contract | 1 year from the date of the Order |
| Calculating the rating, the badges and the access levels | Order history, reviews, marks about the Photo Report, cancellations | Contract | The entire term of the Account |
| Consideration of requests and incidents, settlement of disputes, protection of the rights of the Operator and of Users | cl. 4.1, 4.2, correspondence, Photo Report | Legitimate interest | 3 years from the date the consideration is completed; in a court dispute - until the court act enters into force + 3 years |
| Ensuring the security of the Service, prevention of fraud and abuse | Technical data, action history | Legitimate interest | 1 year |
| Sending service notifications | Phone number, email address, device identifier | Contract | The entire term of the Account |
| Contacting the Emergency Contact about an Order and in the event of an incident | cl. 4.5 | Legitimate interest; protection of vital interests | 1 year from the date of the Order |
| Providing a party to an Order with information about the other party when harm is caused | Name, email address | Legitimate interest (cl. 7 part 1 art. 6 of the Law) | 3 years from the date of disclosure |
| Analytics of the use of the Service and improvement of the product | Technical data, de-identified statistical data | Legitimate interest; consent - for analytics cookies | 2 years |
| Performance of the obligations established by legislation | cl. 4.1, 4.2, 4.4 | Requirement of the law | Periods established by legislation |
5.1. Once the retention period has expired, or when the purpose of processing has been achieved, the personal data is destroyed or de-identified within a period not exceeding 30 days, in the procedure set out in section 11.
5.2. De-identified statistical data that does not allow the Subject to be identified may be stored without a time limit.
6. Procedure and conditions of processing
6.1. Processing is carried out both with the use of automated means and without such means, and includes collection, recording, systematisation, accumulation, storage, clarification (updating, modification), extraction, use, transfer (provision, access), de-identification, blocking, deletion and destruction. The measures for the protection of data during storage and processing are established by section 10, and the destruction procedure by section 11.
6.2. Sources of receiving the data. Personal data is provided by the Subject independently when registering, filling in a Profile, posting a Request, and in correspondence and requests; it is generated automatically when the Service is used; it is provided by other Users in reviews and in incident reports.
6.3. Accuracy. The Operator does not verify the accuracy of the data provided by the Subject, except in the cases expressly indicated in cl. 6.4, and proceeds from the assumption that the Subject provides accurate data and updates it in a timely manner.
6.4. Confirmation of information about a Specialist.
6.4.1. The Operator confirms the Subject's access to the mobile phone number they specified - by a one-time code sent to that number. Confirmation of the number is the first stage of the check of a Specialist and a condition for their Profile to be displayed to Clients. The Operator also confirms the Subject's access to the email address they specified - by a one-time code sent to that address when access to the Account is restored. Such confirmation verifies access to the number or to the mailbox and does not constitute the establishment of identity.
6.4.2. The Specialist's Profile is checked by a member of the Operator's staff before its publication: the completeness of the entries is assessed, as well as whether the contents and the photos match the declared Services and the requirements of the User Agreement. Until a decision is taken, the Profile is not displayed to Clients. The result of the check is stored in the information system.
6.4.3. The Operator does not establish the identity of the Specialist (cl. 4.7.3). Education and qualification documents, if the Specialist states them in the Profile, are checked only for the existence of the document, not for its authenticity.
6.5. Location data. The Operator processes device location data in three cases: when compiling a Photo Report - to record the place and the time at which the Service was provided; when matching Profiles and Requests - to display offers in the selected district; when providing the walking Service - to record the route in the procedure of cl. 6.5.1. Processing takes place only when the Subject grants permission at the level of the device's operating system. The permission may be withdrawn in the device settings; in that case the relevant functions of the Service become unavailable. Location data is not used to track the movements of the Subject outside the period during which the Service is provided.
6.5.1. Recording of the walking Service route. In the Specialist's application, from the moment an Order for the walking Service begins and until it is completed, a route record is kept: the application records the coordinates of the Specialist's device with timestamps and stated accuracy. The recording continues while the application is minimised and the screen is switched off; the operating system then displays an indicator of work with geodata - an icon in the status bar or a persistent notification. The recorded points are stored on the Specialist's device and are transmitted to the Operator; for the Client who posted the Order, the route is displayed on a map in the Order card. The recording begins only for an Order for the walking Service accepted by the Specialist and stops when the Order is completed; outside such an Order the application does not request location in the background mode. The Specialist is entitled not to grant permission for access to location, or to withdraw it in the device settings; in that case the route is not recorded and a mark about the absence of a route is displayed to the Client. Other Services do not involve the recording of a route.
6.6. Automated processing. The Specialist's rating, the awarding of badges and proposals to change access to particular kinds of Services are calculated automatically on the basis of the Order history, the availability of Photo Reports, ratings and cancellations, according to the rules published in the Service. A decision to restrict access to particular kinds of Orders is taken by a member of the Operator's staff with regard to these indicators. The Operator does not take decisions that give rise to legal consequences or otherwise affect the rights of the Subject on the basis of automated processing alone. The Subject is entitled to receive an explanation of the factors that influenced the decision, to lodge an objection and to demand a review of the decision.
6.7. Localisation. The recording, systematisation, accumulation, storage, clarification (updating, modification) and extraction of the personal data of citizens of the Russian Federation are carried out with the use of databases located in the territory of the Russian Federation (part 5 art. 18 of the Law).
6.8. Cross-border transfer.
6.8.1. Presence of the Service in application stores. The distribution of the “Po lapam!” mobile application through the App Store and Google Play does not in itself entail a cross-border transfer of personal data by the Operator. The data that Apple and Google collect about the users of their stores when searching for, downloading and updating the application and when posting reviews in the store is processed by those persons as independent operators on the basis of their own agreements with users. The Operator does not determine the purposes and the composition of such processing and does not transfer data for it. The statistical information that the Operator receives from App Store Connect and Google Play Console is provided in de-identified form.
6.8.2. Software components of foreign persons. A cross-border transfer arises when the Service uses software components and services of foreign persons that process data on the instructions of the Operator.
As of the date of this version, the Operator's mobile applications do not include any analytics libraries, crash-reporting tools or advertising identifiers from foreign vendors. There is a single cartographic component - a service of a Russian person (see section 8).
The delivery of push notifications to Apple devices is performed by the Apple Push Notification service (Apple Inc., United States of America). Such delivery does not give rise to a cross-border transfer of personal data:
a) the notification contains no personal data: it holds the type of event and the identifiers of Service records, but neither a name, nor a phone number, nor an email address, nor the address at which the Service is provided, nor Pet details, nor the contents of correspondence. The Subject receives the text of the notification from the Service over a secure connection after opening the application;
b) the device address (token) is generated by the Apple Push Notification service itself and is known to it; the Operator does not disclose to that service any information that would allow the device address to be linked to a particular Subject;
c) Apple Inc. acts as the delivery channel of the message and does not determine the purposes and the composition of the processing of the data of the Subjects of the Service.
The list of foreign components processing personal data on the instructions of the Operator, and the states of the recipients:
| Component | Recipient, state | Data transferred | Purpose |
|---|---|---|---|
| (none as of the version date) | - | - | - |
6.8.3. Before the beginning of a cross-border transfer, the Operator sends Roskomnadzor a notice of the intention to carry out a cross-border transfer of personal data (part 3 art. 12 of the Law). Such a notice is filed separately from the notice provided for by art. 22 of Law No. 152-FZ. As of the date of this version, the Operator carries out no cross-border transfer of personal data (cl. 6.8.2) and no notice has been sent; its details will be indicated in this clause from the moment the notice is sent.
6.8.4. Before filing the notice, the Operator obtains from the foreign recipients the information provided for by part 5 art. 12 of the Law: about the protection measures applied to the transferred data and about the conditions for terminating its processing, and, for states not included in the list of states ensuring adequate protection of the rights of personal data subjects - also information about the legal regulation of personal data in the respective state.
6.8.5. A transfer to the territory of states not included in the said list (including the United States of America) does not begin until the period for the consideration of the notice by Roskomnadzor established by part 9 art. 12 of the Law has expired. A transfer to the territory of the states included in the list may be carried out from the date the notice is sent.
6.8.6. A cross-border transfer is carried out only after the localisation requirement has been met (cl. 6.7): the primary collection, recording, systematisation, accumulation, storage, clarification and extraction of the data of citizens of the Russian Federation takes place in databases in the territory of the Russian Federation, while the transfer abroad is of a secondary nature.
6.8.7. A change to the list given in cl. 6.8.2 entails the sending of a new notice to Roskomnadzor and the introduction of amendments to this Policy before the transfer to a new recipient begins.
6.9. Data not obtained from the Subject. The Operator receives the data of the Emergency Contact and of the Client's representative from the Client. Before beginning to process it, the Operator provides such a person, upon the first appeal to them, with the information provided for by part 3 art. 18 of the Law: the name and address of the Operator, the purpose of the processing and its legal basis, the expected users of the data, the rights of the subject and the source from which the data was received. The Client who has specified such a person must notify them in advance of the transfer of the data (cl. 8.9 of the User Agreement).
7. Consents of the Subject
7.1. Acceptance of the User Agreement is not, and does not replace, consent to the processing of personal data. Each consent is formalised as a separate action of the Subject in the interface of the Service, and is specific, targeted, informed, deliberate and unambiguous (part 1 art. 9 of the Law).
7.2. Separate consents are requested for:
a) the dissemination of the Specialist's personal data by publishing the Profile in open access (art. 10.1 of the Law). The consent is formalised separately from the other consents, contains the list of the data being disseminated and allows prohibitions and conditions of dissemination to be set. Silence or inaction of the Subject is not consent;
b) the receipt of advertising messages over telecommunications networks;
c) the personalisation of the advertising of partners;
d) the use of the User's materials (photos, reviews, Photo Report) in the Operator's marketing materials outside the Service;
e) the public display of Photo Report materials in the Specialist's Profile - requested from the Client whose Order the Photo Report relates to;
f) the use of analytics and advertising cookies (section 9).
As of the date of this version, the consents provided for by letters “b”, “c” and “f” are not requested: no advertising is placed in the Service, and no analytics or advertising files cookie are used.
7.3. Withdrawal of consent. Consent may be withdrawn at any moment through the Account settings, or by sending a request to the address indicated in cl. 2.1. The Operator terminates the processing based on the withdrawn consent within a period of no more than 10 working days and destroys the corresponding data if there is no other legal basis for processing it. Withdrawal of the consent to dissemination entails the removal of the Profile from publication.
7.4. Refusal of the consents listed in letters “b” - “f” of cl. 7.2 does not entail a refusal of access to the Service. Refusal of the consent indicated in letter “a” makes the publication of the Profile, and accordingly the receipt of Orders through the Service, impossible. For a Client there is no such restriction: the Client's Profile is not published in open access, and no refusal of consents restricts their access to the Service.
8. Transfer of personal data to third parties
8.1. Transfer between Users. After the conclusion of the Contract between the Users, the Client and the Specialist gain access to the information necessary for the provision of the Service: the name, the address at which the Service is provided, details of the Pet. For an Order for the walking Service, the Client is additionally shown the route recorded by the Specialist's application (cl. 6.5.1). Each User is obliged to use the information obtained exclusively for the purpose of performing the Order and not to disseminate it.
8.2. Entrusted processing. The Operator is entitled to entrust the processing of personal data to third parties on the basis of a contract containing the terms provided for by part 3 art. 6 of the Law, including the duty to maintain confidentiality and the requirements for data protection. The Operator bears responsibility to the Subject for the actions of such persons.
8.3. Categories of persons to whom processing may be entrusted:
| Category | Purpose | Data transferred |
|---|---|---|
| Cloud infrastructure and hosting provider: individual entrepreneur E. A. Kokunov (brand HostiMan, hostiman.ru), PSRNIP 316325600074565; the servers are located in the territory of the Russian Federation (Moscow, TIER 3 data centres) | Hosting of the Service's information system: production environment, databases, backups and logs, as well as the mail server mail.polapam.ru, from which one-time codes and service letters are sent | All data processed in the Service, including the email address and the text of the letter |
| Push notification delivery service: Apple Inc. (United States of America), Apple Push Notification service | Delivery of notifications to iOS devices | Device address (token), notification title and text, identifiers of Service records (Order number, Account number) |
| Push notification delivery service: Google LLC (United States of America), Firebase Cloud Messaging | Delivery of notifications to Android devices | Not connected as of the date of this version, no data is transferred |
| Mapping service: YANDEX LLC (Russian Federation), Geocoder | Determining the city and the district from an address or coordinates | Coordinates, text address, IP address of the request |
| Mapping service: YANDEX LLC (Russian Federation), MapKit Lite - a software component of the mobile application | Displaying the map, selecting an address, displaying the route | Coordinates of the view area, IP address, technical information about the software component and the device type; no personal data is transferred |
The up-to-date list with the names and details of such persons is published at polapam.ru/en/privacy/processors.
8.4. Transfer as required by the law. The Operator transfers personal data to state bodies, to the bodies of local self-government and to courts to the extent and in the procedure established by legislation, on the basis of a reasoned request.
8.5. The Operator does not sell personal data and does not transfer it to third parties for their independent use for marketing purposes.
8.6. If any of the persons entrusted with processing are foreign persons, such a transfer is additionally governed by cl. 6.8 of this Policy and is carried out in compliance with art. 12 of the Law.
8.7. Provision of information when harm is caused. Upon the receipt of a request concerning harm caused to the life or health of a human being or an animal, or harm to property, the Operator: (1) suggests that the applicant send a claim to the other party to the Order through the Service without disclosing data; (2) if that is insufficient and the request is well-founded, discloses to the injured party the Name and the contact details of the other party to the extent minimally necessary for submitting a claim. The Operator does not hold the surname and the patronymic of the other party and cannot disclose them; the establishment of the identity of the person who caused the harm is carried out by the court or by the law enforcement bodies, including on the basis of the information that the Operator provides upon their reasoned request (cl. 8.4): the Name, the phone number, the email address, the device details and the Order history.
9. Files cookie and similar technologies
9.1. The mobile applications use local storage and device identifiers; files cookie are not used in the applications. As of the date of this version, the polapam.ru website contains only the texts of the Operator's documents and uses strictly necessary files cookie; no analytics or advertising technologies are used on it. For each technology the Operator determines the category, the purpose, the retention period and the way to opt out.
9.2. Categories:
a) strictly necessary - ensure the operation of the Service, authentication and security. Applied on the basis of the performance of a contract, no consent is required, switching them off makes the Service unusable;
b) functional - store the selected settings, the district, the language. Applied on the basis of consent;
c) analytics - allow the use of the Service to be assessed. Applied on the basis of consent;
d) advertising - ensure the display of advertising of partners and the measurement of its effectiveness. Applied on the basis of consent. As of the date of this version, technologies of categories “c” and “d” are not used.
9.3. If the Operator uses technologies of categories “b” - “d”, the Subject is given, on their first visit, the opportunity to accept or to reject each category separately. Refusal of the optional categories does not restrict access to the Service. The choice may be changed at any moment in the settings of the Service. As of the date of this version, only the strictly necessary technologies of category “a” are used.
9.4. The retention period of files cookie does not exceed the period necessary for achieving the purpose of their use and is no more than 12 months for each category, with the exception of the strictly necessary ones.
10. Measures for ensuring security
10.1. The Operator takes the legal, organisational and technical measures provided for by arts. 18.1 and 19 of the Law, including:
a) has appointed the person responsible for organising the processing of personal data;
b) has approved the internal documents defining the policy in respect of the processing of personal data, the procedure for preventing and detecting violations, and the procedure for responding to requests from Subjects and to incidents;
c) has determined the security threats and the required level of protection of the information systems in accordance with the resolution of the Government of the Russian Federation of 01.11.2012 No. 1119;
d) has restricted access to personal data to the circle of persons for whom it is necessary for the performance of their duties to the Operator, and keeps records of such access;
e) uses means of information protection, the differentiation of access rights, the encryption of data transmission channels, backup copying and the logging of security events;
f) ensures the separate storage of data processed for incompatible purposes;
g) carries out internal control of the compliance of processing with the requirements of legislation no less than once a year;
h) acquaints the persons admitted to processing with the requirements of legislation and of internal documents;
i) assesses the harm that may be caused to Subjects in the event of a violation of the requirements of the Law and correlates it with the protection measures being taken (part 5 art. 18.1 of the Law);
j) keeps a list of the persons admitted to the processing of personal data and records of the machine-readable media of personal data.
10.2. Actions upon an incident. When the fact of an unlawful or accidental transfer (provision, dissemination, access) of personal data is established, which has entailed a violation of the rights of Subjects, the Operator notifies Roskomnadzor:
a) within 24 hours from the moment the incident is detected - of the fact of the incident, its presumed cause, the presumed harm, the measures taken and of the person authorised to interact;
b) within 72 hours from the moment the incident is detected - of the results of the internal investigation and of the persons whose actions caused the incident (part 3.1 art. 21 of the Law).
10.3. Subjects are notified of an incident affecting their data within a reasonable period - by email, in push notifications and in the interface of the Service (cl. 3.7 of the User Agreement).
11. Destruction of personal data
11.1. Personal data is subject to destruction when: the purpose of processing is achieved; the consent is withdrawn, if there is no other legal basis; the retention period expires; unlawful processing is detected; the Account is deleted; a corresponding request is received from the Subject or from Roskomnadzor.
11.2. Destruction is carried out by a method that precludes the recovery of the data and is confirmed by an act, and, in the case of automated processing, by an extract from the log of recorded events (the order of Roskomnadzor on the requirements for confirming destruction).
11.3. If destruction within the established period is technically impossible, the Operator blocks the data and destroys it within a period of no more than six months.
11.4. Not destroyed before the respective periods expire: data whose storage is required by legislation; data necessary for the consideration of a pending dispute or of a request concerning an incident; information about the access restrictions applied - to the extent minimally necessary for preventing repeated registration by the offender (the email address in hashed form and the date of the decision), for 3 years from the date of the decision, with a subsequent review of the necessity of storage.
12. Rights of the Subject and the procedure for exercising them
12.1. The Subject is entitled to:
a) receive information concerning the processing of their personal data to the extent established by part 7 art. 14 of the Law;
b) demand the clarification, blocking or destruction of personal data if it is incomplete, obsolete, inaccurate, unlawfully obtained, or is not necessary for the stated purpose;
c) withdraw consent to the processing;
d) object to the processing carried out on the basis of a legitimate interest;
e) demand a review of a decision taken exclusively on the basis of automated processing (cl. 6.6);
f) appeal against the actions or the inaction of the Operator to Roskomnadzor or in judicial proceedings;
g) the protection of their rights and legitimate interests, including the compensation for losses and compensation for moral damage.
12.2. Procedure for requests. A request is sent to the address support@polapam.ru or through the interface of the Service. A request sent from the Account, or from the email address specified in it, is recognised as having been sent by the Subject. If the Subject cannot be identified by the said means, the Operator is entitled to request additional information confirming the fact of the processing of their data, to the minimally necessary extent.
12.3. Time limits for the reply. The Operator provides a reply within 10 working days from the date of receipt of the request. The period may be extended by no more than 5 working days, with notification of the Subject and the indication of the reasons.
12.4. The Operator is entitled to refuse to provide information in the cases established by part 8 art. 14 of the Law, with a reasoned justification of the refusal.
12.5. Some of the rights may be exercised by the Subject independently through the interface of the Service: changing the information of the Profile, withdrawing consents, removing the Profile from publication, deleting the Account, exporting the data of the Account.
13. Amendments to the Policy
13.1. The Operator is entitled to introduce amendments to this Policy. A new version is published at polapam.ru/en/privacy/ with the indication of the publication date and the date on which it enters into force.
13.2. About material changes affecting the purposes of processing, the composition of the data processed or the list of persons entrusted with processing, the Operator notifies the Subjects no later than 15 calendar days before the amendments enter into force - by email, in push notifications and in the interface of the Service (cl. 3.7 of the User Agreement). If an amendment introduces a purpose of processing that requires consent, the processing for such a purpose begins only after the consent has been obtained, and not upon the expiry of the notification period.
13.3. Previous versions are kept at polapam.ru/en/privacy/archive.