Personal data processing policy

1. General provisions

1.1. This Personal Data Processing Policy (the "Policy") sets out how Method Media LLC (ООО «Метод Медиа») (the "Operator") processes personal data and what measures it takes to protect it in connection with the website methodmedia.agency (the "Site").

1.2. The Policy is drawn up in accordance with Federal Law No. 152-FZ of 27 July 2006 "On Personal Data" and other applicable Russian legislation on personal data.

1.3. Operator: Method Media LLC (ООО «Метод Медиа»). Address: 117105, Moscow, Varshavskoye sh., 1A, office 50/B4Yu 4. E-mail for enquiries: info@methodmedia.agency.

1.4. The Policy applies to all information the Operator receives about visitors to the Site, including information submitted through forms published on the Site.

2. Definitions

2.1. Personal data means any information relating directly or indirectly to an identified or identifiable natural person (the data subject).

2.2. Processing means any action or set of actions performed with personal data, including collection, recording, systematisation, accumulation, storage, clarification, extraction, use, transfer, blocking, deletion and destruction.

2.3. User means a visitor to the Site.

2.4. Cookies are small files stored in the User's browser when the Site is visited.

3. Legal grounds

3.1. The Operator processes personal data on the following grounds:

• the consent of the data subject to the processing of their personal data (Article 6, part 1, clause 1 of 152-FZ);
• performance of a contract to which the data subject is a party, or conclusion of a contract at the data subject's initiative (Article 6, part 1, clause 5 of 152-FZ);
• performance of obligations imposed on the Operator by Russian law.

4. What data we process

4.1. Data provided by the User

Through forms on the Site the Operator may receive:

• name or form of address;
• company name and job title;
• e-mail address;
• phone number;
• the content of the message, the subject of the enquiry, information about the task and timelines;
• any other information the User chooses to provide.

Forms on the Site include: the contact and enquiry form (including tender enquiries), the newsletter subscription form, the job application form and the registration form for events organised by the Operator. Data submitted through any of these forms is processed under the same rules of this Policy.

4.2. Data transmitted automatically

• IP address;
• information about the browser, device and screen resolution;
• date and time of access to the Site;
• the address of the page from which the User navigated to the Site;
• the pages of the Site visited by the User and actions performed on them;
• cookies and identifiers of web analytics systems.

4.3. The Operator does not process special categories of personal data (racial or ethnic origin, political opinions, religious beliefs, health, private life) or biometric personal data. The Operator does not collect data of persons under 18 and asks that such data not be submitted through the Site.

4.4. The User is not obliged to provide personal data. However, without a name and an e-mail address the Operator cannot respond to an enquiry.

5. Purposes of processing

5.1. The Operator processes personal data for the following purposes:

• contacting the User and responding to their enquiry, advising on services;
• preparing a commercial proposal, concluding and performing a contract;
• handling tender and procurement enquiries;
• sending information and marketing messages — only with separate consent, with the option to opt out at any time;
• reviewing job applications and contacting candidates;
• registering participants for Operator events;
• ensuring the operation and security of the Site, analysing its performance and improving the Site.

5.2. The Operator does not use personal data to make decisions based solely on automated processing that produce legal effects for the User.

6. Cookies and web analytics

6.1. The Site uses cookies to keep the interface working correctly, remember settings and collect visit statistics.

6.2. Visit analytics is provided by Yandex.Metrica, which collects anonymised information about visits: pages viewed, referral source, device type and approximate location derived from the IP address. The processing of data by this service is governed by the documents of YANDEX LLC.

6.3. The User may disable cookies in the browser settings. Some features of the Site may then work incorrectly. The User may also use the Yandex.Metrica opt-out tool.

6.4. The Site uses external technical libraries (for example, the Google Fonts library), which receive the User's IP address when loaded.

7. Transfer to third parties

7.1. The Operator does not sell personal data or transfer it to third parties for their own marketing purposes.

7.2. Personal data may be transferred to third parties in the following cases:

• to contractors supporting the Site (hosting, website management platform, e-mail services) to the extent required for technical operation;
• to the web analytics services listed in section 6;
• to state authorities and other persons where expressly required by Russian law.

7.3. Contractors process personal data under agreements with the Operator and are obliged to keep it confidential.

8. Retention and destruction

8.1. Personal data received through the Site's forms is retained until the purpose of processing is achieved, but no longer than three years from the last interaction with the User, unless another period is set by a contract or by law.

8.2. If consent is withdrawn, personal data is destroyed within 30 days of receipt of the withdrawal, unless otherwise required by law or by a contract.

8.3. Data processed for accounting and tax purposes is retained for the periods established by Russian law.

8.4. Personal data is destroyed by deletion from the Operator's information systems.

9. User rights

9.1. The User has the right to:

• obtain information about the processing of their personal data;
• request clarification, blocking or destruction of personal data that is incomplete, outdated, inaccurate or obtained unlawfully;
• withdraw consent to the processing of personal data;
• object to processing for marketing purposes;
• appeal against the Operator's actions or omissions to Roskomnadzor or to a court.

9.2. Requests should be sent to info@methodmedia.agency or to the address: 117105, Moscow, Varshavskoye sh., 1A, office 50/B4Yu 4. The request should identify the applicant's identity document and state the substance of the request.

9.3. The Operator reviews and responds to requests within the period established by Russian law.

10. Withdrawal of consent

10.1. Consent to the processing of personal data may be withdrawn by the User at any time by sending a written request to info@methodmedia.agency.

10.2. Upon receipt of a withdrawal, the Operator stops processing and destroys the personal data within the period set out in section 8, except where processing must continue by law.

11. Security measures

11.1. The Operator takes the legal, organisational and technical measures required to protect personal data from unlawful access, destruction, alteration, blocking, copying and distribution.

11.2. Access to personal data is granted only to employees who need it to perform their duties.

11.3. Data transmitted through the Site is sent over the HTTPS protocol.

12. Changes to the Policy

12.1. The Operator may amend this Policy. The current version is always published on this page.

12.2. A new version takes effect upon publication unless it states otherwise.

12.3. Continued use of the Site after changes are published constitutes the User's acceptance of the new version.