Privacy Policy
This is an English translation of the Russian-language Privacy Policy published at https://leadplan.ru/privacy, provided for information only. In the event of any discrepancy between the Russian and English versions, the Russian version shall prevail.
Introduction
This Privacy Policy explains how your personal data is collected, processed and stored. The owner of the leadplan.ru service (hereinafter, “leadplan.ru” or the “Administration”) pays great attention to protecting users’ personal information. By using the leadplan.ru service, the user agrees to the rules for collecting, using and storing data set out in this document. If you do not agree with the terms of our privacy policy, do not use the leadplan.ru service.
Personal Data Processing Policy
Approved by Order of the General Director of Pismo LLC, Order No. 26/2025 of 28.08.2025. Published on September 2, 2025.
Introduction
This Privacy Policy explains how your personal data is collected, processed and stored. The owner of the leadplan.ru service (hereinafter, “leadplan.ru” or the “Administration”) pays great attention to protecting users’ personal information. By using the leadplan.ru service, the user agrees to the rules for collecting, using and storing data set out in this document. If you do not agree with the terms of our privacy policy, do not use the leadplan.ru service.
Personal Data Processing Policy
Approved by Order of the General Director of Pismo LLC, Order No. 26/2025 of 28.08.2025. Published on September 2, 2025.
1. General Provisions
1.1. This document sets out the policy of Pismo LLC regarding the processing of personal data of data subjects who use the Website https://leadplan.ru/ and the Leadplan.ru Service (hereinafter, the “User”).
1.2. Pismo LLC is the personal data Operator (hereinafter, the “Operator”).
1.3. This Personal Data Processing Policy (hereinafter, the “Policy”) has been developed pursuant to subclause 2 of part 1 of Article 18.1 of Federal Law No. 152-FZ of 27.07.2006 “On Personal Data” (hereinafter, the “Personal Data Law”) in order to protect the rights and freedoms of individuals and citizens in the processing of their personal data, including the rights to privacy and to personal and family secrets.
1.4. The Policy applies exclusively to Users as defined in Clause 1.1 of the Policy and does not apply to individuals whose personal data is collected through widgets. Pismo LLC processes such personal data as a person processing personal data under a separate written instruction.
1.5. Pismo LLC does not control and is not responsible for third-party websites that the User may visit via links available on the Website.
1.6. If the User does not agree with the terms of the Policy, the User must immediately stop using the Website and/or any services available through the Website.
2. Key Terms and Definitions
2.1. Leadplan.ru Information System (hereinafter, the “Leadplan.ru Service” or the “Service”) means a system for creating widgets for websites on the Internet, configured for the user for the purpose of collecting contact details of website visitors. The Service allows collecting and processing data of visitors to the User’s website according to the configured widgets and requires a mandatory Internet connection. Exclusive rights to the Leadplan.ru Service belong to Pismo LLC (certificate No. 2 020 661 174; date and number of state registration: 13.12.2023 No. RD451 975).
2.2. Automated processing of personal data means processing of personal data using computer technology.
2.3. Personal data information system means the set of personal data contained in databases, together with the information technologies and technical means that ensure its processing.
2.4. Confidentiality of personal data means the requirement, binding on the Operator or any other person who has gained access to personal data, not to disclose personal data to third parties or distribute it without the consent of the personal data subject or another legal ground.
2.5. Personal Account means an account created by the User upon registration in the Service and associated with the User by a login and password (authentication data), on the basis of which access to the Service is provided.
2.6. Processing of personal data means any action (operation) or set of actions (operations) performed with users’ personal data, with or without the use of automation tools, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), blocking, deletion and destruction of personal data.
2.7. Personal data means any information relating directly or indirectly to an identified or identifiable User.
2.8. Personal data subject means a legally capable individual who is directly or indirectly identified by personal data. Users may be individuals acting on their own behalf, as well as individuals representing legal entities who are authorized to act on behalf of such legal entities under a charter, power of attorney, employment contract, civil law contract or on other grounds.
2.9. Cookies means a small piece of data sent by a web server and stored on the User’s computer, which the web client or web browser sends back to the web server in an HTTP request each time it attempts to open a page of the corresponding website.
2.10. IP address means a unique network address of a node in a computer network through which the User accesses the website.
3. Key Rights and Obligations of the Operator and the User
3.1. The Operator may:
• independently determine the composition and list of measures necessary and sufficient to fulfil the obligations provided for by the Personal Data Law and the regulations adopted under it;
• entrust the processing of personal data to another person with the User’s consent, unless otherwise provided by federal law, on the basis of a contract concluded with that person. A person processing personal data on behalf of the Operator must comply with the principles and rules of personal data processing provided for by the Personal Data Law;
• if the User withdraws consent to the processing of personal data, continue processing personal data without the User’s consent where there are grounds specified in the Personal Data Law.
3.2. The Operator shall:
• organize the processing of personal data in accordance with the requirements of the Personal Data Law;
• respond to requests and inquiries from the User and the User’s legal representatives in accordance with the requirements of the Personal Data Law and in the manner provided for by the Policy;
• at the request of the authorized body for the protection of the rights of personal data subjects, provide that body with the necessary information within the established time limits.
3.3. The User may:
• at the User’s own discretion, of the User’s own free will and in the User’s own interest, provide the Operator with personal data for processing on the terms set out in the Policy;
• independently provide, change and delete personal data in the Personal Account, provided that such changes and corrections contain current and accurate information;
• submit demands to the Operator, including to clarify the User’s personal data, destroy personal data, withdraw consent to processing, or block personal data if the personal data is incomplete, outdated, inaccurate, unlawfully obtained or not necessary for the stated purpose of processing, and to receive information concerning the processing of the User’s personal data;
• independently delete the Personal Account or request that the Operator delete the Personal Account in the manner provided for in Section 7 of the Policy;
• take measures provided for by law to protect the User’s rights;
• request a list of the User’s personal data provided to the Operator for processing in a structured, commonly used and machine-readable format, and instruct the Operator to transfer the User’s personal data to a third party where the Operator has the technical capability to do so. In this case, the Operator is not responsible for any subsequent actions of the third party with the User’s personal data;
• obtain information concerning the processing of the User’s personal data by the means provided for by the Policy.
3.4. The User shall:
• provide the Operator with current and accurate information about themselves;
• update and change their personal information within 5 working days of any change, for the duration of the contractual relationship between the Operator and the User and the period of personal data processing, by submitting an application to update or change personal data in the manner provided for in Section 7 of the Policy;
• immediately notify the Operator of any violations of the User’s rights and legitimate interests in connection with the processing of personal data committed by the Operator or by other persons through the Operator’s fault;
• not mislead the Operator as to their identity and not provide false or inaccurate information about themselves;
• not provide the Operator in any way, whether through the Website and/or the Service or otherwise, with any information that relates in whole or in part to state, commercial and/or banking secrets, or to facts and information about their private life or the private life of third parties, and not provide special categories of personal data or other information whose provision is prohibited by the Policy.
4. Purposes of Collection and Categories of Personal Data Processed
4.1. The Operator processes personal data on a lawful and fair basis, and processing is limited to the achievement of specific, predetermined and legitimate purposes.
4.2. The Operator processes Users’ personal data exclusively for the following purposes:
4.2.1. Operation of the Website and analytics of Website visits using the Yandex.Metrica service.
Personal data processed:
• cookies;
• user data (page URL, page referrer, page title, browser data and versions, operating system and its version, device, screen size (height and width) and properties, whether cookies are enabled, whether JavaScript is enabled, time zone, browser language, screen color depth, width and height of the browser’s client area, visitors’ gender and age, visitors’ interests, geographic data, JavaScript events, page load parameters, page view, visit, external link click, file download, bounce, time on site, page depth).
The legal basis for processing is consent to the processing of personal data. Personal data is destroyed within 30 days after the purpose is achieved, unless otherwise provided by the legislation of the Russian Federation. The procedure for processing cookies is set out in Clause 4.4 of the Policy.
4.2.2. Registration of the User on the Website.
Personal data processed: e-mail address.
The legal basis for processing is consent to the processing of personal data. Personal data is destroyed within 30 days after the purposes are achieved, unless otherwise provided by the legislation of the Russian Federation. If an Agreement is concluded as a result of registration, processing continues on the basis of the Agreement.
4.2.3. Providing consultations to Users.
Personal data processed: e-mail address.
The legal basis for processing is consent to the processing of personal data. Personal data is destroyed within 30 days after the consultation/support ends or after receipt of the withdrawal of consent to the processing of personal data, whichever occurs first. If an Agreement is concluded as a result of the consultation, processing continues on the basis of the Agreement.
4.2.4. Sending informational and advertising mailings. To receive mailings, the User fills in the relevant form on the Website.
Personal data processed: e-mail address.
The legal basis for processing is the Agreement (Offer) / consent to the processing of personal data. Personal data is destroyed within 30 days after the User unsubscribes from the mailing or the Operator stops sending mailings, whichever occurs first.
4.3. The content and scope of personal data processed by the Operator correspond to the purposes of processing stated in the Policy.
4.4. To ensure the correct operation of the Website, the Operator uses cookies. The legal basis for processing personal data using cookies is consent, which the Operator requests when the User first visits the Website. Consent is deemed given by conclusive actions, namely continued use of the Website. If the User changes their decision to consent to the Operator’s processing of cookies, the User must delete the cookies stored on their device by clearing the browser history, unless a different procedure is provided by the developer of the browser the User uses to visit the Website. After doing so, the User may refuse to give the Operator consent to the processing of cookies on their next visit to the Website. Such refusal to use cookies may cause the Website and the Service to work incorrectly.
Data collected using cookies does not belong to special or biometric categories under Articles 10–11 of the Personal Data Law and is processed by automated means.
5. Legal Grounds for Processing Personal Data
5.1. The processing of Users’ personal data is based on the Personal Data Law, the Civil Code of the Russian Federation, the Tax Code of the Russian Federation, Federal Law No. 402-FZ of 06.12.2011 “On Accounting”, Federal Law No. 126-FZ of 07.07.2003 “On Communications”, the Charter of Pismo LLC, other regulations governing relations related to the Operator’s activities, and the Operator’s internal regulations.
5.2. The legal ground for processing personal data is at least one of the following:
• performance of a contract to which the User is a party, beneficiary or guarantor, as well as conclusion of a contract at the User’s initiative or a contract under which the User will be a beneficiary or guarantor;
• exercise of the rights and legitimate interests of the Operator or third parties, or achievement of socially significant goals, provided that the rights and freedoms of the User are not violated;
• achievement of the purposes of exercising and performing the functions, powers and duties imposed on the Operator by the legislation of the Russian Federation;
• in other cases, consent to the processing of personal data. The subject of consent is the User’s provision of their personal data in accordance with the purposes and on the terms defined by the consent. Website Users give their consent by ticking a checkbox provided for this purpose after reviewing the text of the consent and the Policy.
6. Procedure and Conditions for Processing Personal Data
6.1. Personal data is processed with the User’s consent, and without it in cases provided for by the Policy and the legislation of the Russian Federation.
6.2. The Operator processes personal data with and without the use of automation tools, complying with the requirements for automated and non-automated processing of personal data provided for by the Personal Data Law and the regulations adopted under it.
6.3. For the purposes specified in the Policy, the Operator may perform any action or set of actions, with or without the use of automation tools, provided for by subclause 3 of part 1 of Article 3 of the Personal Data Law, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, blocking, deletion, destruction, and transfer (distribution, provision, access) of personal data to third parties, subject to measures ensuring the protection of personal data from unauthorized access, to the extent necessary to achieve the purposes of processing.
6.4. The Operator does not place the User’s personal data in publicly available sources without the User’s prior consent.
6.5. The Operator does not process biometric personal data or special categories of personal data relating to race, nationality, political views, religious or philosophical beliefs, health, or intimate life.
6.6. The Operator does not verify the accuracy of information provided by the User and assumes that the User provides accurate and sufficient information and keeps it up to date.
6.7. The confidentiality of information relating to the User’s personal data that becomes known to the Operator is maintained.
6.8. Personal data is accessible to the Operator’s employees who need it to perform their job duties.
6.9. In order to provide access to the Website and improve its quality, the Operator transfers personal data to the following third parties:
• YANDEX LLC (INN 7736207543; 16 Lva Tolstogo St., Moscow, 19021, Russia), for collecting web analytics (Yandex.Metrica) in order to improve the quality of services. To block Yandex.Metrica, the User may download and install the add-on at https://yandex.com/support/metrica/general/opt-out.html?lang=ru. Further information is available in Yandex’s privacy policy: https://yandex.ru/legal/confidential/?lang=ru. If Yandex.Metrica is blocked, some Website functions may become unavailable to the User;
• inquiry and investigation bodies and other authorized bodies, on the grounds and for the purposes provided for by the legislation of the Russian Federation.
6.10. In accordance with Articles 18, 18.1 and 19 of the Personal Data Law, the Operator takes the necessary and sufficient legal, organizational and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, distribution, and other unlawful actions of third parties in relation to personal data.
The Operator protects personal data in the manner established by the current legislation of the Russian Federation and the Operator’s internal regulations by implementing a set of organizational and technical measures ensuring its security.
6.11. The periods of personal data processing by the Operator are generally determined in accordance with the periods established by the Personal Data Law; the term of the relevant contract; the periods specified in the instruction to process personal data; the retention periods for documents established by the legislation of the Russian Federation; the limitation period; the validity period of the consent given by the User; and other requirements of the legislation of the Russian Federation.
6.12. Personal data is stored in a form that allows the User to be identified for no longer than required by the purposes of processing, unless the retention period is established by federal law or contract.
6.13. Processed personal data is destroyed upon expiry of the retention period, achievement of the purposes of processing, or when there is no longer a need to achieve those purposes, unless otherwise provided by the legislation of the Russian Federation.
7. Updating, Correction, Deletion and Destruction of Personal Data; User Requests Concerning Personal Data
7.1. The Operator may enter, supplement, change, block or delete personal data in accordance with the legislation of the Russian Federation.
7.2. When the purposes of processing personal data have been achieved, or if the User withdraws consent to processing, personal data shall be destroyed unless:
• otherwise provided by a contract to which the User is a party, beneficiary or guarantor;
• the Operator is entitled to process the data without the User’s consent on the grounds provided for by the Personal Data Law or other federal laws;
• otherwise provided by another agreement between the Operator and the User.
7.3. Confirmation of the fact of personal data processing by the Operator, the legal grounds and purposes of processing, and other information specified in part 7 of Article 14 of the Personal Data Law are provided by the Operator to the User or the User’s representative upon contact or upon receipt of a request from the User or the User’s representative.
7.4. Information provided upon request does not include personal data relating to other personal data subjects, except where there are legal grounds for disclosing such personal data.
7.5. The User may send the Operator requests and any questions regarding the processing of personal data by the following means:
• to the Operator’s e-mail address info@leadplan.ru, as an electronic image of the document (example subject line: “Restriction/withdrawal of consent to the processing of personal data”);
• to the Operator’s current address. The current address can be found in the Unified State Register of Legal Entities by entering the Operator’s OGRN 1167847127909 at https://egrul.nalog.ru/index.html.
7.6. The User’s request must be specific and contain information identifying the User and the substance of the request. The request must be signed by the User or by the User’s representative, whose authority must be documented.
7.7. The User’s request is considered within 10 working days of its receipt by the Operator. This period may be extended by no more than 5 working days if the Operator sends the User a reasoned notice stating the reasons for extending the period for providing the requested information.
8. Changes to the Policy
8.1. The Operator may unilaterally amend the Policy in the event of changes to the regulations of the Russian Federation, as well as at its own discretion. The User is responsible for reviewing the text of the Policy each time they use the Website and the Service.
8.2. The new Policy takes effect upon its publication on the Website, unless otherwise provided by the new version of the Policy.
8.3. Continued use of the Website after publication of a new version of the Policy means that the User accepts the Policy and its terms. If the User does not agree with the terms of the Policy, the User must immediately stop using the Website.
9. Operator Details
• Pismo LLC (OOO «Pismo»)
• OGRN (Primary State Registration Number): 1167847127909
• INN/KPP (Taxpayer ID / Tax Registration Reason Code): 7811602601/784201001
• Legal (postal) address: premises 9-N, Letter A, 8 Khersonskaya St., Saint Petersburg, 191024, Russian Federation
• Technical support e-mail: help@leadplan.ru
• E-mail for administrative and legal matters: contact@leadplan.ru
1.2. Pismo LLC is the personal data Operator (hereinafter, the “Operator”).
1.3. This Personal Data Processing Policy (hereinafter, the “Policy”) has been developed pursuant to subclause 2 of part 1 of Article 18.1 of Federal Law No. 152-FZ of 27.07.2006 “On Personal Data” (hereinafter, the “Personal Data Law”) in order to protect the rights and freedoms of individuals and citizens in the processing of their personal data, including the rights to privacy and to personal and family secrets.
1.4. The Policy applies exclusively to Users as defined in Clause 1.1 of the Policy and does not apply to individuals whose personal data is collected through widgets. Pismo LLC processes such personal data as a person processing personal data under a separate written instruction.
1.5. Pismo LLC does not control and is not responsible for third-party websites that the User may visit via links available on the Website.
1.6. If the User does not agree with the terms of the Policy, the User must immediately stop using the Website and/or any services available through the Website.
2. Key Terms and Definitions
2.1. Leadplan.ru Information System (hereinafter, the “Leadplan.ru Service” or the “Service”) means a system for creating widgets for websites on the Internet, configured for the user for the purpose of collecting contact details of website visitors. The Service allows collecting and processing data of visitors to the User’s website according to the configured widgets and requires a mandatory Internet connection. Exclusive rights to the Leadplan.ru Service belong to Pismo LLC (certificate No. 2 020 661 174; date and number of state registration: 13.12.2023 No. RD451 975).
2.2. Automated processing of personal data means processing of personal data using computer technology.
2.3. Personal data information system means the set of personal data contained in databases, together with the information technologies and technical means that ensure its processing.
2.4. Confidentiality of personal data means the requirement, binding on the Operator or any other person who has gained access to personal data, not to disclose personal data to third parties or distribute it without the consent of the personal data subject or another legal ground.
2.5. Personal Account means an account created by the User upon registration in the Service and associated with the User by a login and password (authentication data), on the basis of which access to the Service is provided.
2.6. Processing of personal data means any action (operation) or set of actions (operations) performed with users’ personal data, with or without the use of automation tools, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), blocking, deletion and destruction of personal data.
2.7. Personal data means any information relating directly or indirectly to an identified or identifiable User.
2.8. Personal data subject means a legally capable individual who is directly or indirectly identified by personal data. Users may be individuals acting on their own behalf, as well as individuals representing legal entities who are authorized to act on behalf of such legal entities under a charter, power of attorney, employment contract, civil law contract or on other grounds.
2.9. Cookies means a small piece of data sent by a web server and stored on the User’s computer, which the web client or web browser sends back to the web server in an HTTP request each time it attempts to open a page of the corresponding website.
2.10. IP address means a unique network address of a node in a computer network through which the User accesses the website.
3. Key Rights and Obligations of the Operator and the User
3.1. The Operator may:
• independently determine the composition and list of measures necessary and sufficient to fulfil the obligations provided for by the Personal Data Law and the regulations adopted under it;
• entrust the processing of personal data to another person with the User’s consent, unless otherwise provided by federal law, on the basis of a contract concluded with that person. A person processing personal data on behalf of the Operator must comply with the principles and rules of personal data processing provided for by the Personal Data Law;
• if the User withdraws consent to the processing of personal data, continue processing personal data without the User’s consent where there are grounds specified in the Personal Data Law.
3.2. The Operator shall:
• organize the processing of personal data in accordance with the requirements of the Personal Data Law;
• respond to requests and inquiries from the User and the User’s legal representatives in accordance with the requirements of the Personal Data Law and in the manner provided for by the Policy;
• at the request of the authorized body for the protection of the rights of personal data subjects, provide that body with the necessary information within the established time limits.
3.3. The User may:
• at the User’s own discretion, of the User’s own free will and in the User’s own interest, provide the Operator with personal data for processing on the terms set out in the Policy;
• independently provide, change and delete personal data in the Personal Account, provided that such changes and corrections contain current and accurate information;
• submit demands to the Operator, including to clarify the User’s personal data, destroy personal data, withdraw consent to processing, or block personal data if the personal data is incomplete, outdated, inaccurate, unlawfully obtained or not necessary for the stated purpose of processing, and to receive information concerning the processing of the User’s personal data;
• independently delete the Personal Account or request that the Operator delete the Personal Account in the manner provided for in Section 7 of the Policy;
• take measures provided for by law to protect the User’s rights;
• request a list of the User’s personal data provided to the Operator for processing in a structured, commonly used and machine-readable format, and instruct the Operator to transfer the User’s personal data to a third party where the Operator has the technical capability to do so. In this case, the Operator is not responsible for any subsequent actions of the third party with the User’s personal data;
• obtain information concerning the processing of the User’s personal data by the means provided for by the Policy.
3.4. The User shall:
• provide the Operator with current and accurate information about themselves;
• update and change their personal information within 5 working days of any change, for the duration of the contractual relationship between the Operator and the User and the period of personal data processing, by submitting an application to update or change personal data in the manner provided for in Section 7 of the Policy;
• immediately notify the Operator of any violations of the User’s rights and legitimate interests in connection with the processing of personal data committed by the Operator or by other persons through the Operator’s fault;
• not mislead the Operator as to their identity and not provide false or inaccurate information about themselves;
• not provide the Operator in any way, whether through the Website and/or the Service or otherwise, with any information that relates in whole or in part to state, commercial and/or banking secrets, or to facts and information about their private life or the private life of third parties, and not provide special categories of personal data or other information whose provision is prohibited by the Policy.
4. Purposes of Collection and Categories of Personal Data Processed
4.1. The Operator processes personal data on a lawful and fair basis, and processing is limited to the achievement of specific, predetermined and legitimate purposes.
4.2. The Operator processes Users’ personal data exclusively for the following purposes:
4.2.1. Operation of the Website and analytics of Website visits using the Yandex.Metrica service.
Personal data processed:
• cookies;
• user data (page URL, page referrer, page title, browser data and versions, operating system and its version, device, screen size (height and width) and properties, whether cookies are enabled, whether JavaScript is enabled, time zone, browser language, screen color depth, width and height of the browser’s client area, visitors’ gender and age, visitors’ interests, geographic data, JavaScript events, page load parameters, page view, visit, external link click, file download, bounce, time on site, page depth).
The legal basis for processing is consent to the processing of personal data. Personal data is destroyed within 30 days after the purpose is achieved, unless otherwise provided by the legislation of the Russian Federation. The procedure for processing cookies is set out in Clause 4.4 of the Policy.
4.2.2. Registration of the User on the Website.
Personal data processed: e-mail address.
The legal basis for processing is consent to the processing of personal data. Personal data is destroyed within 30 days after the purposes are achieved, unless otherwise provided by the legislation of the Russian Federation. If an Agreement is concluded as a result of registration, processing continues on the basis of the Agreement.
4.2.3. Providing consultations to Users.
Personal data processed: e-mail address.
The legal basis for processing is consent to the processing of personal data. Personal data is destroyed within 30 days after the consultation/support ends or after receipt of the withdrawal of consent to the processing of personal data, whichever occurs first. If an Agreement is concluded as a result of the consultation, processing continues on the basis of the Agreement.
4.2.4. Sending informational and advertising mailings. To receive mailings, the User fills in the relevant form on the Website.
Personal data processed: e-mail address.
The legal basis for processing is the Agreement (Offer) / consent to the processing of personal data. Personal data is destroyed within 30 days after the User unsubscribes from the mailing or the Operator stops sending mailings, whichever occurs first.
4.3. The content and scope of personal data processed by the Operator correspond to the purposes of processing stated in the Policy.
4.4. To ensure the correct operation of the Website, the Operator uses cookies. The legal basis for processing personal data using cookies is consent, which the Operator requests when the User first visits the Website. Consent is deemed given by conclusive actions, namely continued use of the Website. If the User changes their decision to consent to the Operator’s processing of cookies, the User must delete the cookies stored on their device by clearing the browser history, unless a different procedure is provided by the developer of the browser the User uses to visit the Website. After doing so, the User may refuse to give the Operator consent to the processing of cookies on their next visit to the Website. Such refusal to use cookies may cause the Website and the Service to work incorrectly.
Data collected using cookies does not belong to special or biometric categories under Articles 10–11 of the Personal Data Law and is processed by automated means.
5. Legal Grounds for Processing Personal Data
5.1. The processing of Users’ personal data is based on the Personal Data Law, the Civil Code of the Russian Federation, the Tax Code of the Russian Federation, Federal Law No. 402-FZ of 06.12.2011 “On Accounting”, Federal Law No. 126-FZ of 07.07.2003 “On Communications”, the Charter of Pismo LLC, other regulations governing relations related to the Operator’s activities, and the Operator’s internal regulations.
5.2. The legal ground for processing personal data is at least one of the following:
• performance of a contract to which the User is a party, beneficiary or guarantor, as well as conclusion of a contract at the User’s initiative or a contract under which the User will be a beneficiary or guarantor;
• exercise of the rights and legitimate interests of the Operator or third parties, or achievement of socially significant goals, provided that the rights and freedoms of the User are not violated;
• achievement of the purposes of exercising and performing the functions, powers and duties imposed on the Operator by the legislation of the Russian Federation;
• in other cases, consent to the processing of personal data. The subject of consent is the User’s provision of their personal data in accordance with the purposes and on the terms defined by the consent. Website Users give their consent by ticking a checkbox provided for this purpose after reviewing the text of the consent and the Policy.
6. Procedure and Conditions for Processing Personal Data
6.1. Personal data is processed with the User’s consent, and without it in cases provided for by the Policy and the legislation of the Russian Federation.
6.2. The Operator processes personal data with and without the use of automation tools, complying with the requirements for automated and non-automated processing of personal data provided for by the Personal Data Law and the regulations adopted under it.
6.3. For the purposes specified in the Policy, the Operator may perform any action or set of actions, with or without the use of automation tools, provided for by subclause 3 of part 1 of Article 3 of the Personal Data Law, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, blocking, deletion, destruction, and transfer (distribution, provision, access) of personal data to third parties, subject to measures ensuring the protection of personal data from unauthorized access, to the extent necessary to achieve the purposes of processing.
6.4. The Operator does not place the User’s personal data in publicly available sources without the User’s prior consent.
6.5. The Operator does not process biometric personal data or special categories of personal data relating to race, nationality, political views, religious or philosophical beliefs, health, or intimate life.
6.6. The Operator does not verify the accuracy of information provided by the User and assumes that the User provides accurate and sufficient information and keeps it up to date.
6.7. The confidentiality of information relating to the User’s personal data that becomes known to the Operator is maintained.
6.8. Personal data is accessible to the Operator’s employees who need it to perform their job duties.
6.9. In order to provide access to the Website and improve its quality, the Operator transfers personal data to the following third parties:
• YANDEX LLC (INN 7736207543; 16 Lva Tolstogo St., Moscow, 19021, Russia), for collecting web analytics (Yandex.Metrica) in order to improve the quality of services. To block Yandex.Metrica, the User may download and install the add-on at https://yandex.com/support/metrica/general/opt-out.html?lang=ru. Further information is available in Yandex’s privacy policy: https://yandex.ru/legal/confidential/?lang=ru. If Yandex.Metrica is blocked, some Website functions may become unavailable to the User;
• inquiry and investigation bodies and other authorized bodies, on the grounds and for the purposes provided for by the legislation of the Russian Federation.
6.10. In accordance with Articles 18, 18.1 and 19 of the Personal Data Law, the Operator takes the necessary and sufficient legal, organizational and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, distribution, and other unlawful actions of third parties in relation to personal data.
The Operator protects personal data in the manner established by the current legislation of the Russian Federation and the Operator’s internal regulations by implementing a set of organizational and technical measures ensuring its security.
6.11. The periods of personal data processing by the Operator are generally determined in accordance with the periods established by the Personal Data Law; the term of the relevant contract; the periods specified in the instruction to process personal data; the retention periods for documents established by the legislation of the Russian Federation; the limitation period; the validity period of the consent given by the User; and other requirements of the legislation of the Russian Federation.
6.12. Personal data is stored in a form that allows the User to be identified for no longer than required by the purposes of processing, unless the retention period is established by federal law or contract.
6.13. Processed personal data is destroyed upon expiry of the retention period, achievement of the purposes of processing, or when there is no longer a need to achieve those purposes, unless otherwise provided by the legislation of the Russian Federation.
7. Updating, Correction, Deletion and Destruction of Personal Data; User Requests Concerning Personal Data
7.1. The Operator may enter, supplement, change, block or delete personal data in accordance with the legislation of the Russian Federation.
7.2. When the purposes of processing personal data have been achieved, or if the User withdraws consent to processing, personal data shall be destroyed unless:
• otherwise provided by a contract to which the User is a party, beneficiary or guarantor;
• the Operator is entitled to process the data without the User’s consent on the grounds provided for by the Personal Data Law or other federal laws;
• otherwise provided by another agreement between the Operator and the User.
7.3. Confirmation of the fact of personal data processing by the Operator, the legal grounds and purposes of processing, and other information specified in part 7 of Article 14 of the Personal Data Law are provided by the Operator to the User or the User’s representative upon contact or upon receipt of a request from the User or the User’s representative.
7.4. Information provided upon request does not include personal data relating to other personal data subjects, except where there are legal grounds for disclosing such personal data.
7.5. The User may send the Operator requests and any questions regarding the processing of personal data by the following means:
• to the Operator’s e-mail address info@leadplan.ru, as an electronic image of the document (example subject line: “Restriction/withdrawal of consent to the processing of personal data”);
• to the Operator’s current address. The current address can be found in the Unified State Register of Legal Entities by entering the Operator’s OGRN 1167847127909 at https://egrul.nalog.ru/index.html.
7.6. The User’s request must be specific and contain information identifying the User and the substance of the request. The request must be signed by the User or by the User’s representative, whose authority must be documented.
7.7. The User’s request is considered within 10 working days of its receipt by the Operator. This period may be extended by no more than 5 working days if the Operator sends the User a reasoned notice stating the reasons for extending the period for providing the requested information.
8. Changes to the Policy
8.1. The Operator may unilaterally amend the Policy in the event of changes to the regulations of the Russian Federation, as well as at its own discretion. The User is responsible for reviewing the text of the Policy each time they use the Website and the Service.
8.2. The new Policy takes effect upon its publication on the Website, unless otherwise provided by the new version of the Policy.
8.3. Continued use of the Website after publication of a new version of the Policy means that the User accepts the Policy and its terms. If the User does not agree with the terms of the Policy, the User must immediately stop using the Website.
9. Operator Details
• Pismo LLC (OOO «Pismo»)
• OGRN (Primary State Registration Number): 1167847127909
• INN/KPP (Taxpayer ID / Tax Registration Reason Code): 7811602601/784201001
• Legal (postal) address: premises 9-N, Letter A, 8 Khersonskaya St., Saint Petersburg, 191024, Russian Federation
• Technical support e-mail: help@leadplan.ru
• E-mail for administrative and legal matters: contact@leadplan.ru