Personal Data Processing Policy

1. General Provisions
This policy on the processing of personal data (the "Policy") is prepared in accordance with the requirements of the Federal Law of the Russian Federation No. 152-FZ "On Personal Data" dated July 27, 2006 (hereinafter referred to as the "Personal Data Law") and determines the procedure for processing personal data and measures to ensure the security of personal data undertaken by Excelena LLC (hereinafter referred to as the "Operator").
1.1. The Operator's most important goals and conditions for its activities are the observance of human and citizen's rights and freedoms during the processing of their personal data, including the protection of the rights to privacy, personal and family secrets.
1.2. This Policy of the Operator regarding the processing of personal data applies to all information that the Operator may obtain about visitors to the website https://accellena.com.

2. Basic Concepts Used in the Policy
2.1. Automated processing of personal data – processing of personal data using computer technology.
2.2. Blocking of personal data – temporary cessation of personal data processing (except where processing is necessary to clarify personal data).
2.3. Website – a combination of graphic and informational materials, as well as computer programs and databases ensuring their availability on the internet at the network address https://accellena.com.
2.4. Personal data information system – a set of personal data contained in databases and information technologies and technical means ensuring their processing.
2.5. Depersonalization of personal data – actions resulting in the inability to determine, without the use of additional information, the belonging of personal data to a specific User or other subject of personal data.
2.6. Processing of personal data – any action (operation) or a set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
2.7. Operator – a state body, municipal body, legal entity, or individual, independently or jointly with others, organizing and/or processing personal data, as well as determining the purposes of personal data processing, the composition of personal data to be processed, and the actions (operations) performed with personal data.
2.8. Personal data – any information relating directly or indirectly to a specific or identifiable User of the website https://accellena.com.
2.9. Personal data permitted by the subject for dissemination – personal data to which access by an unlimited number of persons is provided by the subject of personal data by giving consent to the processing of personal data permitted for dissemination in the manner prescribed by the Personal Data Law.
2.10. User – any visitor to the website https://accellena.com.
2.11. Provision of personal data – actions aimed at disclosing personal data to a specific person or a specific circle of persons.
2.12. Dissemination of personal data – actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or familiarizing an unlimited circle of persons with personal data, including the publication of personal data in the mass media, posting in information and telecommunication networks, or providing access to personal data in any other way.
2.13. Cross-border transfer of personal data – the transfer of personal data to the territory of a foreign state to an authority of a foreign state, a foreign individual, or a foreign legal entity.
2.14. Destruction of personal data – any actions resulting in the irreversible destruction of personal data with the impossibility of further restoring the content of personal data in the personal data information system and/or the destruction of material carriers of personal data.

3. Basic Rights and Obligations of the Operator
3.1. The Operator has the right to:

• Receive from the subject of personal data reliable information and/or documents containing personal data;
• In case the subject of personal data withdraws consent to the processing of personal data, or submits a request to cease the processing of personal data, the Operator has the right to continue processing personal data without the subject's consent if there are grounds specified in the Personal Data Law;
• Independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations under the Personal Data Law and adopted regulatory legal acts, unless otherwise provided by the Personal Data Law or other federal laws.
• 3.2. The Operator is obliged to:
• Provide the subject of personal data, upon their request, with information regarding the processing of their personal data;
• Organize the processing of personal data in the manner established by the current legislation of the Russian Federation;
• Respond to appeals and requests from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
• Provide the authorized body for the protection of the rights of personal data subjects with the necessary information within 10 days from the date of receipt of such a request;
• Publish or otherwise provide unrestricted access to this Policy regarding the processing of personal data;
• Take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision, dissemination, as well as from other unlawful actions regarding personal data;
• Cease the transfer (distribution, provision, access) of personal data, cease processing, and destroy personal data in the manner and cases provided for by the Personal Data Law;
• Perform other duties provided for by the Personal Data Law.

4. Basic Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects have the right to:

• Receive information regarding the processing of their personal data, except in cases provided for by federal laws. The information is provided to the subject by the Operator in an accessible form and shall not contain personal data relating to other subjects, unless there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
• Require the Operator to clarify, block, or destroy their personal data if the data is incomplete, outdated, inaccurate, illegally obtained, or not necessary for the stated purpose of processing, and take legal measures to protect their rights;
• Impose a condition of prior consent when processing personal data for the purpose of promoting goods, works, and services on the market;
• Withdraw consent to the processing of personal data, as well as submit a demand to cease the processing of personal data;
• Appeal to the authorized body for the protection of the rights of personal data subjects or in court against unlawful actions or inaction of the Operator in the processing of their personal data;
• Exercise other rights provided for by the legislation of the Russian Federation.
• 4.2. Personal data subjects are obliged to:
• Provide the Operator with reliable data about themselves;
• Inform the Operator about the clarification (updating, change) of their personal data.
• 4.3. Persons who have provided the Operator with false information about themselves, or information about another personal data subject without the latter's consent, shall be liable in accordance with the legislation of the Russian Federation.

5. Principles of Personal Data Processing
5.1. The processing of personal data is carried out on a lawful and fair basis.
5.2. The processing of personal data is limited to achieving specific, predetermined, and lawful purposes. Processing of personal data incompatible with the purposes of collection is not permitted.
5.3. The merging of databases containing personal data processed for incompatible purposes is not permitted.
5.4. Only personal data that meets the purposes of their processing is subject to processing.
5.5. The content and volume of processed personal data correspond to the stated purposes of processing. The processing of excessive personal data relative to the stated purposes is not permitted.
5.6. The processing of personal data ensures the accuracy, sufficiency, and, where necessary, relevance of personal data in relation to the purposes of processing. The Operator takes necessary measures to delete or clarify incomplete or inaccurate data.
5.7. The storage of personal data is carried out in a form that allows identification of the subject for no longer than required by the purposes of processing, unless the storage period is established by federal law, an agreement to which the subject is a party, beneficiary, or guarantor. Processed personal data is destroyed or depersonalized upon achieving the processing purposes or in case of loss of necessity to achieve them, unless otherwise provided by federal law.

6. Purposes of Personal Data Processing


7. Conditions for Personal Data Processing
7.1. The processing of personal data is carried out with the consent of the subject to the processing of their personal data.
7.2. Processing is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or law, for the performance of functions, powers, and duties imposed on the operator by the legislation of the Russian Federation.
7.3. Processing is necessary for the administration of justice, the execution of a judicial act, an act of another body or official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. Processing is necessary for the performance of a contract to which the subject is a party, beneficiary, or guarantor, as well as for concluding a contract on the initiative of the subject or a contract under which the subject will be a beneficiary or guarantor.
7.5. Processing is necessary for the exercise of the rights and legitimate interests of the operator or third parties, or for achieving socially significant purposes, provided that the rights and freedoms of the subject are not violated.
7.6. Processing of personal data is carried out, access to which is provided by the subject or at their request (hereinafter - publicly available personal data).
7.7. Processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.

8. Procedure for Collection, Storage, Transfer, and Other Types of Personal Data Processing
The security of personal data processed by the Operator is ensured through the implementation of legal, organizational, and technical measures necessary to fully comply with the requirements of current legislation in the field of personal data protection.
8.1. The Operator ensures the security of personal data and takes all possible measures to prevent access to personal data by unauthorized persons.
8.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to the execution of current legislation or if the subject has given consent to the Operator for the transfer of data to a third party to fulfill obligations under a civil law contract.
8.3. In case of inaccuracies in personal data, the User may update them independently by sending a notice to the Operator's email address info@accellena.com with the subject "Update of personal data."
8.4. The period of personal data processing is determined by the achievement of the purposes for which the personal data were collected, unless a different period is provided by the contract or current legislation.
The User may at any time withdraw their consent to the processing of personal data by sending a notice to the Operator via email to info@accellena.com with the subject "Withdrawal of consent to the processing of personal data."
8.5. All information collected by third-party services, including payment systems, communication means, and other service providers, is stored and processed by said persons (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data is obliged to familiarize themselves with these documents. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this clause.
8.6. Prohibitions established by the subject on the transfer (except for granting access), as well as on the processing or conditions of processing (except for obtaining access) of personal data permitted for dissemination, do not apply in cases of processing personal data in state, public, and other public interests defined by the legislation of the Russian Federation.
8.7. The Operator, when processing personal data, ensures the confidentiality of personal data.
8.8. The Operator stores personal data in a form that allows identification of the subject for no longer than required by the purposes of processing, unless the storage period is established by federal law, an agreement to which the subject is a party, beneficiary, or guarantor.
8.9. The cessation of personal data processing may be conditioned by the achievement of the processing purposes, the expiration of the subject's consent, the withdrawal of consent by the subject, a demand to cease processing personal data, or the identification of unlawful processing of personal data.

9. List of Actions Performed by the Operator with Received Personal Data
9.1. The Operator performs collection, recording, systematization, accumulation, storage, clarification (updating, changing), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
9.2. The Operator performs automated processing of personal data with the receipt and/or transmission of the obtained information via information and telecommunication networks or without it.

10. Cross-Border Transfer of Personal Data
10.1. Before commencing activities related to the cross-border transfer of personal data, the Operator is obliged to notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out such transfer (this notification is sent separately from the notification of the intention to process personal data).
10.2. Before submitting the aforementioned notification, the Operator is obliged to obtain relevant information from the authorities of the foreign state, foreign individuals, foreign legal entities to whom the cross-border transfer of personal data is planned.

11. Confidentiality of Personal Data
The Operator and other persons who have gained access to personal data are obliged not to disclose to third parties and not to distribute personal data without the consent of the subject, unless otherwise provided by federal law.

12. Final Provisions
12.1. The User can obtain any clarifications on questions regarding the processing of their personal data by contacting the Operator via email at info@accellena.com.
12.2. This document will reflect any changes to the Operator's personal data processing policy. The Policy is valid indefinitely until replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet at https://accellena.com/privacy.