The Personal Data Processing Policy (hereinafter referred to as the “Policy”) has been developed in
accordance with Federal Law No. 152-FZ “On Personal Data” dated July 27, 2006 (hereinafter —
FZ-152).
This Policy defines the procedure for processing personal data and measures to ensure the security
of personal data in LLC "65 Gigabyte" (hereinafter — the Operator), with the purpose of protecting
the rights and freedoms of an individual when processing his/her personal data, including the
protection of the rights to privacy, personal and family secrets.
The following basic terms are used in the Policy:
Automated processing of personal data — processing of personal data using computing equipment.
Blocking of personal data — temporary suspension of the processing of personal data (except in
cases where processing is necessary to clarify personal data).
Information system of personal data — a set of personal data contained in databases and the
technologies and technical means ensuring their processing.
Depersonalization of personal data — actions that make it impossible to determine, without
additional information, whether personal data belongs to a specific subject of personal data.
Processing of personal data — any action (operation) or set of actions (operations) performed with
or without the use of automation tools on personal data, including collection, recording,
systematization, accumulation, storage, clarification (updating, modification), extraction, use,
transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of
personal data.
Operator — a state body, municipal body, legal or physical person, independently or jointly with
other persons organizing and/or carrying out the processing of 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.
Personal data — any information relating directly or indirectly to a specific or identifiable
individual (personal data subject).
Provision of personal data — actions aimed at disclosing personal data to a certain person or a
certain group of persons.
Distribution of personal data — actions aimed at disclosing personal data to an indefinite group of
persons (transfer of personal data) or making personal data available to an unlimited number of
persons, including publication in the media, placement in information and telecommunication
networks, or providing access to personal data by any other means.Cross-border transfer of personal data — transfer of personal data to the territory of a foreign state
to the authority of a foreign state, a foreign individual or a foreign legal entity.
Destruction of personal data — actions as a result of which it becomes impossible to restore the
content of personal data in the personal data information system and/or as a result of which tangible
media containing personal data are destroyed.
The company is obliged to publish or otherwise ensure unrestricted access to this Policy in
accordance with Part 2, Article 18.1 of FZ-152.
The Operator processes personal data based on the following principles:
legality and fairness;
limitation of processing personal data to achieving specific, predetermined, and legitimate purposes;
prevention of processing of personal data incompatible with the purposes of collecting personal
data;
prevention of combining databases containing personal data, processing of which is carried out for
incompatible purposes;
processing only personal data that meets the purposes of processing;
compliance of the content and volume of processed personal data with the stated purposes of
processing;
prevention of processing personal data that is excessive in relation to the stated purposes of
processing;
kristina, [10.09.2025 16:20]
ensuring accuracy, sufficiency, and relevance of personal data with regard to the purposes of
processing;
destruction or depersonalization of personal data upon achieving the purposes of processing or
when it is no longer necessary to achieve these purposes, unless otherwise provided by federal law.
The Operator processes personal data if at least one of the following conditions is met:
processing of personal data is carried out with the consent of the personal data subject;
processing of personal data is necessary for achieving purposes provided by an international treaty
of the Russian Federation or law, for fulfilling functions, powers, and duties imposed by legislation
of the Russian Federation;
processing of personal data is necessary for the administration of justice, execution of a judicial act,
act of another body or official, subject to execution under the legislation of the Russian Federation;processing of personal data is necessary for the execution of a contract to which the personal data
subject is a party or beneficiary, as well as for the conclusion of a contract at the initiative of the
personal data subject;
processing of personal data is necessary to protect the rights and legitimate interests of the Operator
or third parties, provided that the rights and freedoms of the personal data subject are not violated;
processing of personal data is carried out for statistical or other research purposes, subject to
depersonalization of personal data;
processing of personal data subject to publication or mandatory disclosure in accordance with
federal law.
The Operator and other persons who have access to personal data are obliged not to disclose it to
third parties or distribute it without the consent of the personal data subject, unless otherwise
provided by federal law.
To provide information support, the Operator may create publicly available sources of personal data
(directories, address books). With the written consent of the subject, such sources may include their
surname, name, patronymic, date and place of birth, job title, contact phone numbers, email address,
and other personal data provided by the subject.
The information about the subject must be excluded from publicly available sources of personal
data at any time at the request of the subject or by decision of a court or authorized state bodies.
The processing of special categories of personal data relating to race, nationality, political views,
religious or philosophical beliefs, health, and intimate life is allowed only in cases where:
the personal data subject has given written consent;
the personal data has been made public by the subject;
processing is carried out in accordance with laws on state social assistance, labor legislation,
pensions, and mandatory social insurance;
processing is necessary to protect the life, health, or other vital interests of the subject or other
persons when obtaining consent is impossible;
processing is carried out for medical and preventive purposes by authorized persons while
maintaining medical confidentiality;
processing is necessary for the establishment or exercise of the rights of the subject or third parties,
as well as in connection with justice;
processing is carried out in accordance with legislation on mandatory types of insurance.Processing of special categories of personal data must be stopped immediately if the reasons for
processing are eliminated.
Data characterizing physiological and biological features of a person, which allow establishing their
identity — biometric personal data — may be processed only with the written consent of the
subject.
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COMPANY POLICY ON PERSONAL DATA PROCESSING
The Personal Data Processing Policy (hereinafter referred to as the “Policy”) has been developed in
accordance with Federal Law No. 152-FZ “On Personal Data” dated July 27, 2006 (hereinafter —
FZ-152).
This Policy defines the procedure for processing personal data and measures to ensure the security
of personal data in LLC "65 Gigabyte" (hereinafter — the Operator), with the purpose of protecting
the rights and freedoms of an individual when processing his/her personal data, including the
protection of the rights to privacy, personal and family secrets.
The following basic terms are used in the Policy:
Automated processing of personal data — processing of personal data using computing equipment.
Blocking of personal data — temporary suspension of the processing of personal data (except in
cases where processing is necessary to clarify personal data).
Information system of personal data — a set of personal data contained in databases and the
technologies and technical means ensuring their processing.
Depersonalization of personal data — actions that make it impossible to determine, without
additional information, whether personal data belongs to a specific subject of personal data.
Processing of personal data — any action (operation) or set of actions (operations) performed with
or without the use of automation tools on personal data, including collection, recording,
systematization, accumulation, storage, clarification (updating, modification), extraction, use,
transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of
personal data.
Operator — a state body, municipal body, legal or physical person, independently or jointly with
other persons organizing and/or carrying out the processing of 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.
Personal data — any information relating directly or indirectly to a specific or identifiable
individual (personal data subject).
Provision of personal data — actions aimed at disclosing personal data to a certain person or a
certain group of persons.
Distribution of personal data — actions aimed at disclosing personal data to an indefinite group of
persons (transfer of personal data) or making personal data available to an unlimited number of
persons, including publication in the media, placement in information and telecommunication
networks, or providing access to personal data by any other means.Cross-border transfer of personal data — transfer of personal data to the territory of a foreign state
to the authority of a foreign state, a foreign individual or a foreign legal entity.
Destruction of personal data — actions as a result of which it becomes impossible to restore the
content of personal data in the personal data information system and/or as a result of which tangible
media containing personal data are destroyed.
The company is obliged to publish or otherwise ensure unrestricted access to this Policy in
accordance with Part 2, Article 18.1 of FZ-152.
The Operator processes personal data based on the following principles:
kristina, [10.09.2025 16:26]
legality and fairness
limitation of processing personal data to achieving specific, predetermined, and legitimate purposes
prevention of processing of personal data incompatible with the purposes of collecting personal data
prevention of combining databases containing personal data, processing of which is carried out for
incompatible purposes
processing only personal data that meets the purposes of processing
compliance of the content and volume of processed personal data with the stated purposes of
processing
prevention of processing personal data that is excessive in relation to the stated purposes of
processing
ensuring accuracy, sufficiency, and relevance of personal data with regard to the purposes of
processing
destruction or depersonalization of personal data upon achieving the purposes of processing or
when it is no longer necessary to achieve these purposes, unless otherwise provided by federal law
The Operator processes personal data if at least one of the following conditions is met:
processing of personal data is carried out with the consent of the personal data subject
processing of personal data is necessary for achieving purposes provided by an international treaty
of the Russian Federation or law, for fulfilling functions, powers, and duties imposed by legislation
of the Russian Federation
processing of personal data is necessary for the administration of justice, execution of a judicial act,
act of another body or official, subject to execution under the legislation of the Russian Federation
processing of personal data is necessary for the execution of a contract to which the personal data
subject is a party or beneficiary, as well as for the conclusion of a contract at the initiative of the
personal data subject
processing of personal data is necessary to protect the rights and legitimate interests of the Operator
or third parties, provided that the rights and freedoms of the personal data subject are not violated
processing of personal data is carried out for statistical or other research purposes, subject to
depersonalization of personal data
processing of personal data subject to publication or mandatory disclosure in accordance with
federal law2.3 Confidentiality of personal data
The Operator and other persons who have access to personal data are obliged not to disclose it to
third parties or distribute it without the consent of the personal data subject, unless otherwise
provided by federal law.
To provide information support, the Operator may create publicly available sources of personal data
(directories, address books). With the written consent of the subject, such sources may include their
surname, name, patronymic, date and place of birth, job title, contact phone numbers, email address,
and other personal data provided by the subject.
The information about the subject must be excluded from publicly available sources of personal
data at any time at the request of the subject or by decision of a court or authorized state bodies.
The processing of special categories of personal data relating to race, nationality, political views,
religious or philosophical beliefs, health, and intimate life is allowed only in cases where:
kristina, [10.09.2025 16:26]
the personal data subject has given written consent
the personal data has been made public by the subject
processing is carried out in accordance with laws on state social assistance, labor legislation,
pensions, and mandatory social insurance
processing is necessary to protect the life, health, or other vital interests of the subject or other
persons when obtaining consent is impossible
processing is carried out for medical and preventive purposes by authorized persons while
maintaining medical confidentiality
processing is necessary for the establishment or exercise of the rights of the subject or third parties,
as well as in connection with justice
processing is carried out in accordance with legislation on mandatory types of insurance
Processing of special categories of personal data must be stopped immediately if the reasons for
processing are eliminated.
Data characterizing physiological and biological features of a person, which allow establishing their
identity — biometric personal data — may be processed only with the written consent of the
subject.
The Operator has the right to entrust the processing of personal data to another person with the
consent of the personal data subject, unless otherwise provided by federal law. The person
processing data on behalf of the Operator must comply with the principles and rules of personal
data processing established by FZ-152.
The Operator must ensure that the foreign state, to whose territory the transfer of personal data is
intended, provides adequate protection of the rights of personal data subjects. Cross-border transfer
of personal data may take place only if:
there is written consent of the personal data subject
it is necessary for the execution of a contract to which the personal data subject is a party
The personal data subject decides to provide their personal data and gives consent to its processing
voluntarily, by their will and in their interest. Consent may be given in any form that allows
confirmation of its receipt, unless otherwise provided by federal law.
The subject has the right to receive information from the Operator regarding the processing of their
personal data. The subject has the right to demand clarification, blocking, or destruction of their
personal data if it is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the
stated purpose of processing.
The subject has the right to take legal measures to protect their rights, including compensation for
damages and moral harm.
The Operator takes legal, organizational, and technical measures necessary to protect personal data.
Organizational and technical measures include:
appointment of responsible persons
restriction of access to personal data
familiarization of employees with legal requirements
organization of accounting and storage of data carriers
threat modeling
security checks
use of antivirus and cryptographic protection
registration and accounting of user actions
access control to premises
Other rights and obligations of the Operator are determined by the legislation of the Russian
Federation.
Officials of the Operator guilty of violating personal data processing rules bear disciplinary, civil,
administrative, or criminal liability in accordance with federal laws. 6. Consent to personal data processing
In accordance with Federal Law No. 152-FZ “On Personal Data” dated July 27, 2006, the User of
the website https://65apps.com hereby gives consent to LLC "65 Gigabyte", 426077, Udmurt
Republic, Izhevsk, Pushkinskaya St., 165, office 159-183, to process their personal data for the
purposes of:
ensuring processing of applications for feedback with the user
List of personal data for processing:
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surname, name, patronymic
And other personal data that may be provided during the use of https://65apps.com.
Consent is granted for five years.