1.1. This Personal Data Processing Policy (hereinafter, the Policy) of Individual Entrepreneur Mikhail Andreevich Klimko (INN: 784811796920, OGRNIP: 323784700166842) sets out the procedure for processing personal data and the measures for ensuring the security of personal data that the Operator, as well as visitors and Users of the website located at https://www.klims.pro/ (hereinafter, the Website), may obtain about a user while they use the Website and its services, programs and products (to the extent permitted by the policy and range of services of the Website), in order to protect the rights and freedoms of individuals and citizens when their personal data is processed, including the right to privacy and to personal and family confidentiality. The Policy has been developed in accordance with Clause 2, Part 1, Article 18.1 of Federal Law No. 152-FZ “On Personal Data” of 27 July 2006 (hereinafter, the Personal Data Law) in order to protect the rights and freedoms of individuals and citizens when their personal data is processed, including the right to privacy and to personal and family confidentiality.
1.2. This Policy applies solely to the Website. The Operator does not control and is not responsible for third-party websites that the User may access via links available on the Website.
1.3. The Operator’s processing of personal data of other categories of personal data subjects is governed by separate internal regulations of the Operator.
1.4. This Policy enters into force upon its approval and remains in effect indefinitely until it is replaced by a new Policy.
1.5 The Operator has the right to amend this Policy. The new version of the Policy enters into force upon its publication on the Website.
1.6 The Policy applies to relations in the field of personal data processing that arose for the Operator both before and after the approval of this Policy.
1.7 In accordance with Part 2, Article 18.1 of the Personal Data Law, this Policy is published in open access on the Internet on the Operator’s website at: https://www.klims.pro/privacy
1.8 Compliance with the requirements of this Policy is monitored directly by the Operator.
1.9 Liability for violations of the requirements for the processing and protection of personal data is determined in accordance with the legislation of the Russian Federation.
1.20. This Policy (Sections 1–13) applies to Users from the Russian Federation. When the Website is visited by Users from the European Union, the personal data of such Users is processed in accordance with Section 14 “Personal Data Processing Policy under the GDPR”.

2.1. The following terms are used in this Policy:
2.1.1. Personal data information system – the set of personal data contained in databases, together with the information technologies and technical means that ensure its processing.
2.1.2. Processing of personal data – any action (operation) or set of actions (operations) performed with personal data, with or without the use of automation tools, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (dissemination, provision, access), depersonalization, blocking, deletion and destruction of personal data.
2.1.3. Depersonalization of personal data – actions as a result of which it becomes impossible, without the use of additional information, to determine whether personal data belongs to a specific User or other personal data subject.
2.1.4. Personal data operator (also, the Operator) – Individual Entrepreneur Mikhail Andreevich Klimko (OGRNIP 323784700166842), including employees authorized to manage the Website acting on behalf of IE M. A. Klimko, who organize and/or carry out the processing of personal data and determine the purposes of processing, the scope of personal data to be processed, and the actions (operations) performed with personal data;
2.1.5. Personal data – any information relating directly or indirectly to an identified or identifiable individual (personal data subject);
2.1.6. Website User (also, the User) – any legally capable individual who has reached the age at which, under the legislation of the Russian Federation, they may enter into a user agreement, who visits the Website and uses the information, materials and/or services of the Website, including, without limitation, viewing Website pages, downloading files, registering on the Website, participating in forums, sending messages, etc., in accordance with the terms of the User Agreement published on the Website.
2.1.7. Cookies – a small piece of data that the Website requests from the browser used on the Visitor’s computer or mobile device. Cookies reflect the Visitor’s preferences or actions on the Website, as well as information about their device and the date and time of the session. Cookies are stored locally on the Visitor’s computer or mobile device. The Visitor may delete stored cookies in the settings of the relevant browser.
2.1.8. IP address – a unique network address of a node in a computer network through which the User accesses the Website.
2.1.9. Website on the Internet – a set of computer programs and other information contained in an information system, access to which is provided via the Internet information and telecommunications network (hereinafter, the Internet) by domain names and/or network addresses that make it possible to identify websites on the Internet;
2.1.10. Owner of the website on the Internet (hereinafter, the Owner) – Individual Entrepreneur Mikhail Andreevich Klimko.

3.1. The legal grounds for processing personal data are:3.1.1. The federal legislation of the Russian Federation governing relations in the field of personal data, namely:
• Federal Law No. 152-FZ “On Personal Data” of 27 July 2006;
• Federal Law No. 149-FZ “On Information, Information Technologies and Information Protection” of 27 July 2006.
3.1.2. Contractual obligations arising between Individual Entrepreneur M. A. Klimko and the personal data subject. 3.1.3. The consent of the personal data subject obtained in accordance with Article 9 of Federal Law No. 152-FZ “On Personal Data” of 27 July 2006.

4.1. Personal data is processed with the User’s consent to the processing of their personal data.
4.1.1. Website Users give their consent to the processing of their personal data voluntarily and knowingly in the following cases:
• when signing in via social networks;
• when filling out the contact form on the Website;
• when subscribing to a newsletter;
• when submitting reviews;
• when registering and being identified on the Website
• during any use of the Website
4.2. If the User does not agree with the terms of this Policy, they must stop using the Website immediately.
4.3. The Operator performs the following actions with personal data: collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (dissemination, provision, access), blocking, deletion and destruction.
4.4. Personal data is stored in a form that allows the personal data subject to be identified for no longer than required by the purposes of processing.
4.5. Processing of personal data may be terminated upon achievement of the purposes of processing, expiry of the processing period, withdrawal of the Website User’s consent to the processing of their personal data, or detection of unlawful processing of personal data.
4.6. The period of storage and processing of personal data is limited by the purposes of processing. The User may withdraw their consent to the processing of personal data at any time by sending a notice to the Operator by email at media@klimspro.com with the subject line “Withdrawal of consent to the processing of personal data”.
4.7. The User consents to receiving SMS messages from the Operator/Owner, as well as other types of mailings and informational notices (oral and written), by any means of communication, including but not limited to email, telephone and postal mail. This consent is valid from the date of the User’s registration on the Website.
4.8. The User may withdraw this consent at any time by sending a notice by email to media@klimspro.com. Since this consent is required for the Website to function correctly, if consent under this clause is withdrawn, the User’s access to the Website may be restricted.
4.9. By providing their personal data, the User confirms that they:
• Are a legally capable person under the legislation of the Russian Federation. If the person using the Website lacks legal capacity, consent to the processing of personal data is given by their legal representative, who has read and accepted the terms of this Policy.
• Provide accurate and up-to-date information about themselves or about the legally incapable person they represent. The User is responsible for providing inaccurate information.
• Understand that information they post on the Website may be accessible to other Users and may be copied and distributed by them in accordance with the functionality of the Website and the terms of this Policy.

5.1. Only personal data that meets the purposes of processing is subject to processing.
5.2. The personal data of Website Users is processed for the following purposes:
5.2.1. Establishing communication with the Website User, including sending notices and requests and processing them, as well as processing requests and applications from the User for the purpose of subsequently concluding and performing a contract;
5.2.2. Receiving and publishing reviews;
5.2.3. Concluding contracts and performing the Operator’s/Owner’s obligations to the User under them
5.2.4. Recruitment;
5.2.5. Keeping statistics and analyzing the performance of the Website.
5.2.6. Posting on the Website, in the Operator’s/Owner’s official social media groups and other online communities, and in other advertising and information sources, for purposes not related to identifying the User.
5.2.7. Improving the quality of service to the User and upgrading the Website by processing requests and applications from the User, as well as recording telephone conversations with the Operator/Owner in order to improve service quality and to preserve evidence in the event of disputes between the Operator/Owner and the User.
5.2.8. Sending the User advertising messages and newsletters about the products and services of the Operator/Owner and its partners, special offers, promotions, prize draws, contests and surveys to the User’s email address via email newsletters, SMS messages and push notifications. The User may opt out of receiving informational messages by sending the Operator an email at media@klimspro.com with the subject line “Opt-out of notifications about new products, services and special offers” or by unsubscribing using the functionality of the message itself.

6.1. The Operator processes, using automation tools, the following personal data, including but not limited to:
• surname, first name, patronymic;
• telephone number;
• email address;
• other personal data that the User provides to the Operator.
6.2. To keep statistics and analyze the performance of the Website, the Operator uses web analytics services (Yandex Metrica) to process data such as:
• IP address;
• browser information;
• cookie data;
• time of access;
• referrer (address of the previous page).
6.3. Depersonalized User data collected through web analytics services is used to gather information about Users’ actions on the Website and to improve the quality of the Website and its content.
6.4. The Operator processes depersonalized data about the User if this is permitted by the User’s browser settings (storage of cookies and use of JavaScript are enabled).
6.4.1 If the User does not agree to the processing of cookies, they must stop using the Website or disable cookies in their browser settings; in this case, some Website functions may become unavailable.
6.5. Biometric personal data and special categories of personal data are not processed on the Website.
6.6. The Operator does not verify the accuracy of the information provided by the User and assumes that the User provides accurate and sufficient information and keeps it up to date, unless otherwise provided by law.

7.1. The security of personal data processed by the Operator is ensured by implementing the legal, organizational, technical and software measures necessary and sufficient to meet the requirements of the legislation of the Russian Federation.
7.2. The User’s personal data will not be transferred by the Operator to third parties, except in cases related to compliance with applicable law.
7.3. The Operator takes the following measures to ensure the security of personal data:
• appointing persons responsible for organizing the processing and ensuring the protection of personal data;
• limiting the number of the Operator’s employees who have access to personal data;
• determining the level of protection of personal data when processed in personal data information systems;
• establishing rules for access to personal data processed in personal data information systems, and ensuring the registration and recording of all actions performed with personal data;
• restricting access to premises where the main technical equipment and systems of personal data information systems are located and where non-automated processing of personal data is carried out;
• organizing backup and recovery of personal data information systems and of personal data modified or destroyed as a result of unauthorized access;
• establishing password complexity requirements for access to personal data information systems;
• carrying out anti-virus control and preventing the introduction of malware (viruses) and software backdoors into the corporate network;
• organizing timely updates of the software used in personal data information systems and of information security tools;
• regularly assessing the effectiveness of the measures taken to ensure the security of personal data;
• detecting unauthorized access to personal data and taking measures to establish its causes and eliminate possible consequences;
• monitoring the measures taken to ensure the security of personal data and the security levels of personal data information systems.

8.1. The Website User has the right to receive information concerning the processing of their personal data, including:
• confirmation that the Operator processes personal data;
• the legal grounds and purposes of processing personal data;
• the methods of processing personal data used by the Operator;
• the name and location of the Operator, and information about persons (other than the Operator’s employees) who have access to personal data or to whom personal data may be disclosed on the basis of a contract with the Operator or on the basis of federal law;
• the personal data processed that relates to the relevant personal data subject and the source from which it was obtained, unless a different procedure for providing such data is established by federal law;
• the periods of processing personal data, including the periods of storage;
• the procedure for the personal data subject to exercise the rights provided for by the Federal Law “On Personal Data”;
• information on completed or intended cross-border transfer of personal data;
• the name or surname, first name, patronymic and address of the person processing personal data on behalf of the Operator, if processing has been or will be entrusted to such person;
• other information provided for by the Federal Law “On Personal Data” or other federal laws.
8.2. The User has the right to require the Operator to clarify, block or destroy their personal data if it is incomplete, outdated, inaccurate, unlawfully obtained or not necessary for the stated purpose of processing, and to take measures provided for by law to protect their rights.
8.3. All questions regarding the processing of personal data should be sent to: media@klimspro.com

The User bears full responsibility for complying with the requirements of the applicable legislation of the Russian Federation, including, without limitation, laws on advertising, on the protection of copyright and related rights, and on the protection of trademarks and service marks, including full responsibility for the content and form of materials when quoting or otherwise using information obtained in connection with the use of the Website’s services.

10.1. The Operator processes personal data based on the following principles:
• lawfulness and fairness;
• limiting the processing of personal data to the achievement of specific, predetermined and lawful purposes;
• preventing processing of personal data that is incompatible with the purposes for which it was collected;
• preventing the merging of databases containing personal data processed for mutually incompatible purposes;
• processing only personal data that meets the purposes of processing;
• ensuring that the content and scope of the personal data processed correspond to the stated purposes of processing;
• preventing processing of personal data that is excessive in relation to the stated purposes of processing;
• ensuring the accuracy, sufficiency and relevance of personal data in relation to the purposes of processing;
• destroying or depersonalizing personal data once the purposes of processing have been achieved or are no longer necessary, upon receipt of a User’s request to destroy personal data, or upon receipt of a User’s withdrawal of consent to the processing of personal data.
10.2. The Operator processes Users’ personal data (recording, systematization, accumulation, storage, clarification (updating, modification), retrieval) using databases located in the Russian Federation.
10.3. The Operator processes Users’ personal data both with and without the use of automation tools.
10.4. The Operator and other persons who have obtained access to personal data are obliged not to disclose personal data to third parties or disseminate it without the consent of the personal data subject, unless otherwise provided by federal law.
10.5. Personal data is stored for the period established by the legislation of the Russian Federation on archiving. Personal data is stored (whichever occurs first):
• until it is destroyed by the Operator
upon receipt from the User of a withdrawal of consent to the processing of personal data or a request to destroy personal data;
• until the consent expires.
10.6. The Operator may transfer personal data to third parties in accordance with the legislation of the Russian Federation or with the consent of the personal data subject, namely:
10.6.1 To partners, such as owners of websites and applications, advertising networks and other partners that provide the Operator with services related to the placement and display of advertising on websites, programs, products or services owned or controlled by such partners;
10.6.2. To partners engaged by the Operator to provide services to Users on the platform at https://www.klims.pro
10.6.3. To partners in order to provide Users with specialized offers to conclude civil law contracts;
10.7. Personal data is transferred to the third parties specified in Clause 10.6 of the Policy subject to the following conditions:
• The third party processes personal data using databases located in the Russian Federation.
• The third party ensures the confidentiality of personal data during its processing and use, and undertakes not to disclose Users’ personal data to other persons or disseminate it without their consent.
• The third party guarantees compliance with the following measures to ensure the security of personal data during processing: use of information security tools; detection and recording of unauthorized access to personal data and taking measures to restore personal data; restriction of access to personal data; registration and recording of actions with personal data; monitoring and evaluation of the effectiveness of the measures applied to ensure the security of personal data. The third party is prohibited from transferring and disseminating personal data.

11.1. The personal data subject has the right to require the Operator to clarify, block or destroy their personal data if it is incomplete, outdated, inaccurate, unlawfully obtained or not necessary for the stated purpose of processing, and to take measures provided for by law to protect their rights.
11.2. If the User withdraws their consent to the processing of their personal data, the Operator undertakes to stop processing it or ensure that such processing is stopped and, if storage of the personal data is no longer required for the purposes of processing, to destroy the personal data or ensure its destruction within a period not exceeding thirty days from the date of receipt of the withdrawal.
11.3. If it is not possible to destroy the personal data within the period specified in subclauses 8.4, 8.5, 8.6 of this Policy, the Operator blocks such personal data or ensures that it is blocked, and ensures that the personal data is destroyed within no more than six months, unless a different period is established by federal laws.

12.1. Users may send the Operator their requests, including requests regarding the use of their personal data as provided for in Clause 11.1 of this Policy, in the form of an electronic document to the email address: media@klimspro.com
12.2. The Operator undertakes to review a User’s request and send a response within 30 days of receipt.
12.3. All correspondence received by the Operator from Users (requests in electronic form) is restricted-access information and is not disclosed without the User’s written consent. The personal data and other information about the User who sent the request may not be used without the User’s specific consent other than to respond to the subject of the request or in cases expressly provided for by law.

13.1. The Operator has the right to amend this Policy unilaterally in the event of changes to the regulatory legal acts of the Russian Federation, as well as at its own discretion.
13.2. Compliance with the requirements of this Policy is monitored by the person responsible for organizing the processing of personal data.
13.3. Persons found guilty of violating the rules governing the processing and protection of personal data bear material, disciplinary, administrative, civil or criminal liability in accordance with the legislation of the Russian Federation.

14.1. What is this policy about?
- We aim to give you the most accessible and, at the same time, complete information about the personal data we collect and how we process it.
- We will use the personal data and other information you provide for the purposes described in our Policy, including providing you with the services you request and the goods you order, and improving your experience with us. We process only the minimum personal data necessary.
- We will also use this information to better understand you and your needs, so that the products we offer best match your interests.
- If you tell us that you do not want to receive promotional messages, we will not send them to you. Of course, opting out of promotional messages does not prevent you from receiving important messages about the product you ordered or the services provided; you will continue to receive such messages.
- The personal data you provide is protected, and we take all necessary measures to protect it. However, if a breach occurs and your personal data is compromised, we will inform you of the breach and of the measures taken to address it.
- If you find that your personal data is inaccurate, you can write to us and we will correct it.
- If you no longer want us to process your personal data and let us know, we will stop doing so. However, if the law requires us to continue processing and/or storing your data, we will comply with the law and inform you of our obligations.
- We respect your right to control your personal data.
Below is the full text of the Policy, in which we explain in more detail what kinds of personal information (personal data) we collect, how we collect it, why and with whom we may use it, how you can influence it, and other important matters.
We have tried to make the text of the Policy as clear and simple as possible, but we could not avoid some legal wording needed to describe the terms as accurately as possible.
If you still have questions after reading our Privacy Policy, you can write to us at: media@klimspro.com
14.2. Who processes your personal data.
This Personal Data Privacy Policy (hereinafter, the Privacy Policy) has been created in accordance with the General Data Protection Regulation (GDPR) to regulate the processing of personal data and describes the measures taken to ensure the security of personal data collected by the Owner specified in Section 15. For the purposes of determining obligations under the GDPR, the above-mentioned person is considered the “Data Controller”.
14.3. What do we mean by personal data?
Personal data is data that identifies you or can be used to identify you, such as your name and contact details. It may also include other information about how you use our Website.
We do not verify the accuracy of the data you provide; we trust you and assume that you are telling the truth about yourself.
14.4. When and how does this Privacy Policy apply?
14.4.1. This Privacy Policy applies to personal data about you that we collect, use and otherwise process not only when you are our client (Customer), but also when you browse our website (as a User).
Let us explain what this means:
Website – the set of graphic and informational materials, as well as computer programs and databases that make them available on the Internet at: https://www.klims.pro and on all subdomains created on its basis.
User – the person to whom the relevant personal data relates, who views the content of the Website and/or uses the functionality of the Website.
Customer – any legally capable person who has placed an order through the Website.
14.4.2. The current version of the Privacy Policy is available on the Website at: https://www.klims.pro/privacy. Before using our Website, you should read the Privacy Policy and, if its terms are unacceptable to you, refrain from providing us with personal data.
If you provide your personal data, this means your unconditional agreement with the terms of this Privacy Policy and the conditions and purposes of personal data processing set out in it. However, you have the right to withdraw your consent; more on this below.
14.4.3. The Privacy Policy (including any part of it) may be amended by the Data Controller, and we will immediately publish it on the Website for public review. The new version of the Privacy Policy enters into force upon its publication on the Website. If you do not agree with the new terms of the Privacy Policy, please refrain from providing personal data.
14.4.4. We are committed to protecting and respecting your privacy and will continue to do so, taking into account any changes we make to this Privacy Policy.
14.4.5. Use of the Website and its services, and use of a web browser that accepts cookie data, means that you agree that the Data Controller may collect and process cookie data in order to improve the Website, its content and functionality. Disabling and/or blocking your web browser’s option to accept cookie data means that your use of the Website may be limited, in particular with regard to some of its functions.
Let us explain this:
Cookies are a small piece of data sent by a web service and stored on your computer, which the browser sends to the web server in every HTTP request when you try to open a page of the corresponding website.
14.5. When do we collect your personal data?
We collect personal data about you whenever you use our services in any form. Most often this happens when you place an order, when you contact our specialists and when you use our Website, namely:
• when signing in via social networks;
• when filling out the contact form on the Website;
• when subscribing to a newsletter;
• when submitting reviews;
• when registering and being identified on the Website;
• during any use of the Website.
14.6. Do we collect “sensitive personal data”?
Some types of personal data, for example data about race, ethnicity or health, belong to special categories of data that require additional protection under European Union law. Biometric personal data and special categories of personal data are not processed on the Website
14.7. Purposes of processing and types of Users’ personal data received and processed by the Data Controller.
14.7.1. Types of personal data:
14.7.1.1. Personal data provided by Users. This may include, in particular:
- surname, first name, patronymic;
- telephone number;
- email address;
- other personal data that the User provides on their own.
The User is prohibited from providing personal data of third parties without their consent to such transfer, unless such personal data of third parties was obtained by the User independently from publicly available sources.
14.7.1.2. Data automatically transmitted to the Website in the course of its receipt by software installed on the User’s device, including IP address, cookie data, information about the browser, operating system, time of access, the User’s search queries, and the referrer (address of the previous page).
Let us explain what this means:
An IP address is a unique network address of a node in a computer network through which you access the Website.
14.7.2. We collect and process only such information about Users, including their personal data, as is related to achieving the following purposes:
- establishing communication with the Website User, including sending notices and requests and processing them, as well as processing requests and applications from the User for the purpose of subsequently concluding and performing a contract;
- receiving and publishing reviews;
- concluding contracts and performing the Controller’s obligations to the User under them
- recruitment;
- keeping statistics and analyzing the performance of the Website.
- posting on the Website, in the Controller’s official social media groups and other online communities, and in other advertising and information sources, for purposes not related to identifying the User.
- improving the quality of service to the User and upgrading the Website by processing requests and applications from the User, as well as recording telephone conversations with the Controller in order to improve service quality and to preserve evidence in the event of disputes between the Controller and the User.
- sending the User advertising messages and newsletters about the products and services of the Controller and its partners, special offers, promotions, prize draws, contests and surveys to the User’s email address via email newsletters, SMS messages and push notifications. The User may opt out of receiving informational messages by sending the Controller an email at media@klimspro.com with the subject line “Opt-out of notifications about new products, services and special offers” or by unsubscribing using the functionality of the message itself.
If it becomes necessary to use personal information about Users for purposes not provided for by the Privacy Policy, we request the User’s consent to such actions.
14.8. When do we send you promotional messages?
If you give your consent, we will send you promotional messages about our products and services from time to time.
We respect your right to opt out of receiving promotional messages, as described above.
14.9. Legal basis for data processing.
14.9.1. We process your personal data only if we have a lawful basis to do so. This basis depends on the reasons for which we collect and process your personal data.
14.9.2. Most often, the basis for data processing is:
- contracts concluded between us and you, i.e. we will process your personal data to fulfil our obligations to you (for example, to deliver goods);
- the consent to the processing of personal data that you have given us (covering a specific list of such data and specific purposes).
14.9.3. In addition, the law permits us to process personal data in the following cases:
- if the use of your personal data is necessary to comply with a legal obligation to which we are subject;
- to protect your vital interests or those of another person.
14.9.4. We process personal information, including personal data, only if:
- processing is necessary to fulfil our contractual obligations to you.
- processing is necessary to comply with legal obligations.
- you consent to the use of your personal data for the purpose of providing promotional materials or for other specific purposes
- under applicable law, processing is necessary for our legitimate interests, provided that such processing does not significantly affect your interests, fundamental rights and freedoms. When processing personal information on this basis, we will always seek to strike a balance between our legitimate interests and the protection of your privacy.
14.10. How long do we keep personal data?
We will keep your information for as long as we need it for the purposes of processing. For example, we keep your data to fulfil our contractual obligations and, after they have been fulfilled, to be able to respond to any request, complaint or claim from you. Information may also be kept so that we can continue to improve our service and reward you for your loyalty. We regularly review whether it is still necessary to process personal data, and if there is no legal, business or customer need to keep this information, we will securely delete it.
14.11. Who has access to your personal data?
In most cases, personal data is processed automatically, without access by employees. Where such access exists, it may be granted to those persons who need it to perform their tasks. To ensure the security of internal data, all employees must follow the rules and procedures for data processing. They must also comply with all technical and organizational security measures adopted to protect personal data.
Agreeing to this Privacy Policy implies consent to the receipt of statistical depersonalized data (without identifying the Personal Data Subject) about the actions of the Personal Data Subject when using the Website.
14.12. How do we protect your personal data?
We have implemented adequate technical and organizational measures to protect personal data against unauthorized, accidental or unlawful destruction, loss, alteration, misuse, disclosure or access, as well as against other unlawful forms of processing. These security measures have been adopted taking into account the state of the art, the cost of implementation, the risks associated with processing and the nature of the personal data, and include the following:
- anti-virus protection with database updates;
- data backup;
- limiting the number of persons with access to personal data.
- appointing persons responsible for organizing the processing and ensuring the protection of personal data;
- assessing how well personal data is protected, whether the measures taken are effective and whether they are being implemented;
- establishing rules for access to personal data, and registering and recording all actions performed with personal data;
- restricting access to premises where personal data carriers are located and where processing is carried out;
- establishing password complexity requirements for access to systems containing personal data;
- timely software updates;
- detecting unauthorized access to personal data and taking measures to establish its causes and possible consequences;
14.13. With whom do we share personal data?
14.13.1. We may transfer your personal data:
- To partners, such as owners of websites and applications, advertising networks and other partners that provide the Controller with services related to the placement and display of advertising on websites, programs, products or services owned or controlled by such partners;
- To partners engaged by the Controller to provide services to Users on the platform at https://www.klims.pro
- To partners in order to provide Users with specialized offers to conclude civil law contracts.
We provide personal data only to partners who maintain high standards of personal data protection (the GDPR or similar applicable standards) on their side and guarantee that we process personal data in accordance with the GDPR or similar applicable principles and standards.
14.13.2. We may transfer your personal data to other third parties if you have made such a request or if we are required to do so by law (the transfer is provided for by applicable law).
14.13.3. If our company takes part in a merger, acquisition or any other form of sale of some or all of its assets, the data set is transferred together with them. In this case, all obligations to comply with the Privacy Policy pass to the acquirer of the assets.
14.13.4. We will also provide your information in response to a reasonable request from law enforcement or other government authorities, or when contacting government authorities such as the police and regulators, to protect our rights, property or the safety of our clients, staff and assets.
14.13.5. We may be required to transfer your personal data in order to fulfil legal or regulatory obligations in any jurisdiction, including where this obligation arises from our voluntary actions or decisions (for example, our decision to operate in a particular country or related decisions).
14.13.6. We do not sell personal information, including personal data, to third parties.
14.14. Cross-border transfer
The Controller processes personal data using databases located in the Russian Federation; therefore, your personal data may be transferred and stored by us and/or third parties in countries outside the country in which you are located and outside the European Economic Area.
This may involve sending your data to countries where, under local law, you may have fewer legal rights.
We will take precautions to ensure that your data is protected in accordance with the standards set out in this Privacy Policy.
14.15. What are your legal rights regarding the personal data we process?
14.15.1. Personal data protection laws give you a number of rights. To exercise them, it is usually enough to contact us in writing (by post or email), free of charge. We will respond within 30 days, but will make every effort to do so much sooner.
Sometimes we will have to decline your request (in whole or in part) because we are obliged to comply with applicable law. In such cases, we will always explain in our response why we cannot fulfil your request.
14.15.2. You have the following rights:
A) You can ask us to stop sending you promotional materials. You will find information on how to do this in the section “When do we send you promotional messages?”. Opting out of promotional mailings will not prevent you from receiving messages about the progress of services and the fulfilment of our contractual obligations.
B) You can ask us to stop processing your personal information for marketing purposes, including analytics for targeted marketing purposes, including online advertising.
C) You can request information about the processing of your personal data, including confirmation of processing, the place and purpose of processing, the types of data, the third parties to whom the data is disclosed, the storage period and the source from which it was obtained.
D) You can ask us to correct the personal data you provided if it is inaccurate or outdated.
E) You can ask us to delete your personal data.
However, we must warn you that some data will be kept in the archive to fulfil our obligations to law enforcement agencies, government authorities and in legal proceedings. We will give you a full answer as to what information will be kept. Once the retention period required by applicable law obliging us to keep this data has expired, we will delete it.
F) Ask us to provide an electronic copy of your personal data to another company free of charge.
G) File a complaint with the competent authorities.
14.16. Forms of requests and what we will check after receiving your request.
14.16.1. You can send your request in writing or electronically.
14.16.2. Written requests include any written requests you send us, including requests sent by post.
14.16.3. Electronic requests include requests sent from the email address you used when registering with our service. We do not process requests relating to personal data received by telephone or fax, as it is not possible to verify the identity of the requester.
14.16.4. The procedure for reviewing requests is as follows:
14.16.4.1. A written request is sent to our address regardless of its form (written or electronic). Responses are prepared by our responsible specialist.
14.16.4.2. Requests and inquiries are checked for:
- the surname and first name of the applicant;
- the surname, first name and patronymic of the person whose personal data is being processed (the personal data subject);
14.16.5. If necessary, we will ask you for additional information.
14.17. What should you refer to in your request?
14.17.1. The data subject has the right to withdraw any consent and permission given for the processing of personal data at any time by sending a message to the email address weare@29.agency.
14.17.2. The data subject has the right to request the deletion, correction or updating of personal data, to request restriction of processing of personal data, or to object to the processing of personal data where provided for by applicable law. The Data Controller responds to these requests in accordance with applicable law.
14.17.3. If it is confirmed that personal data is inaccurate or that its processing is unlawful, the personal data must be updated by the Data Controller, and the processing of unlawfully obtained data must be stopped.
14.17.4. Once the purposes of processing personal data have been achieved, and in the event of withdrawal of consent to the processing of personal data, the personal data must be destroyed if:
- not otherwise provided for by a contract to which the personal data subject is a party, beneficiary or guarantor;
- the Data Controller has no right to carry out processing without the consent of the data subject given in accordance with applicable law or another agreement between the Data Controller and the data subject.

Individual Entrepreneur Mikhail Andreevich Klimko
• OGRNIP: 313784702500631
• INN: 784811796920
• media@klimspro.com