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Personal Data Processing Policy

Personal Data Processing Policy

Tomsk, December 2025

 

This Personal Data Processing Policy (hereinafter referred to as the “Privacy Policy”) applies to all information that LLC “Lingvista” may obtain about a User while using the website of LLC “Lingvista” located at the domain name https://www.lingvista.ru

1. DEFINITIONS

1.1. For the purposes of this Privacy Policy, the following terms shall have the meanings set forth below:

1.1.1. “Confidentiality of Personal Data” means a mandatory requirement imposed on the Operator or any other person who has obtained access to personal data to ensure that such data are not disclosed to third parties without the consent of the personal data subject, unless otherwise provided for by applicable law.

1.1.2. “Depersonalization of Personal Data” means actions as a result of which it is no longer possible, without the use of additional information, to determine the association of personal data with a specific User or another personal data subject.

1.1.3. “Processing of Personal Data” means any action (operation) or set of actions (operations) performed with personal data, whether or not by automated means, including, but not limited to, collection, recording, systematization, accumulation, storage, clarification (updating or modification), retrieval, use, transfer (distribution, provision, or access), depersonalization, blocking, deletion, and destruction of personal data.

1.1.4. “Operator” means an organization and its duly authorized employees managing the Website, who, independently or jointly with other persons, organize and/or carry out the processing of personal data, as well as determine the purposes of personal data processing, the composition of personal data subject to processing, and the actions (operations) performed with such personal data.
The Operator is Limited Liability Company “Lingvista”, located at the following address: Russian Federation, 634054, Tomsk Region, Tomsk, Komsomolsky Lane, 16a, 2nd floor.

1.1.5. “Personal Data” means any information relating to an identified or identifiable natural person (personal data subject), whether such identification is direct or indirect.

1.1.6. “Website User” (hereinafter referred to as the “User”) means any individual who has access to the Website https://www.lingvista.ru via the Internet and uses the Website.

1.1.7. “Provision of Personal Data” means actions aimed at the disclosure of personal data to a specific person or a specific group of persons.

1.1.8. “Distribution of Personal Data” means any actions aimed at the disclosure of personal data to an indefinite number of persons or at making personal data available to an unlimited number of persons, including, without limitation, publication in mass media, placement in information and telecommunication networks, or granting access to personal data by any other means.

1.1.9. “Website” means a collection of interrelated web pages located on the Internet at the unique uniform resource locator (URL): https://www.lingvista.ru/.

1.1.10. “Cross-Border Transfer of Personal Data” means the transfer of personal data to the territory of a foreign state, to a foreign state authority, a foreign natural person, or a foreign legal entity.

1.1.11. “Destruction of Personal Data” means any actions resulting in the irreversible destruction of personal data, making it impossible to restore the content of such personal data in a personal data information system and/or resulting in the destruction of physical media containing personal data.

1.1.12. “Cookies” means small text files sent by a web server and stored on the User’s device, which are transmitted by the web client or web browser to the web server with each HTTP request when attempting to access a page of the relevant Website.

1.1.13. “IP Address” means a unique network address of a node in a computer network using the Internet Protocol (IP).

2. GENERAL PROVISIONS

2.1. This Privacy Policy applies to the website https://www.lingvista.ru/ when accessed from any device. By accessing and using the Website, the User confirms that he or she has read, understood, and agreed to this Privacy Policy and to the terms governing the processing of Personal Data.
The User acknowledges that consent provided electronically via the Website constitutes valid, informed, and freely given consent in accordance with applicable personal data protection laws and may be retained by the Operator as evidence of such consent.

2.2. If the User does not agree with the terms of this Privacy Policy, the User must immediately discontinue use of the Website.

2.3. This Privacy Policy applies exclusively to the Website operated by the Operator. The Operator does not exercise control over, and shall not be responsible for, the content, privacy policies, or data processing practices of third-party websites accessible via hyperlinks on the Website.

2.4. The Operator does not verify the accuracy, completeness, or relevance of Personal Data provided by the User and relies on the User to ensure that such data are accurate and up to date.

3. SUBJECT MATTER OF THE PRIVACY POLICY

3.1. This Privacy Policy defines the Operator’s obligations regarding the protection, confidentiality, and lawful processing of Personal Data submitted by the User at the request of Lingvista when ordering or requesting specific services via the Website.

3.2. The Personal Data processed under this Privacy Policy are provided by the User through the completion of forms on the Website and may include the following categories of data:

  • 3.2.1. full name of the User;
  • 3.2.2. contact telephone number of the User or designated contact person;
  • 3.2.3. email address;
  • 3.2.4. date and place of birth (where necessary for the provision of services);
  • 3.2.5. place of residence (where necessary);
  • 3.2.6. photograph (where necessary);
  • 3.2.7. any other information reasonably required by the Operator for the proper provision of services.

3.3. The Website uses analytics services, including Yandex.Metrica, to collect anonymized and aggregated information about Website usage, user interactions, and related statistical data. Such data may include, but are not limited to, IP address, browser type and version, operating system type and version, device type, screen resolution, referral source, language settings, approximate geographic location, access time, requested page addresses, and cookie-based information.
Such data are processed for analytical, technical, and service improvement purposes and do not directly identify individual Users.

3.4. The Operator may process IP address information for the purposes of ensuring Website security, preventing fraud or unauthorized access, and diagnosing technical issues.

3.5. Any Personal Data not expressly listed in this section shall be processed, stored, and disclosed only in accordance with applicable law and solely for legitimate purposes, except in cases expressly provided for in Clauses 5.2 and 5.3 of this Privacy Policy.

4. PURPOSES OF COLLECTION AND PROCESSING OF THE USER’S PERSONAL DATA

4.1. The Operator may process the User’s Personal Data for the following purposes:

4.1.1. identification of the User for the purpose of placing an order and/or entering into a contract for the provision of translation services;

4.1.2. establishment and maintenance of communication with the User, including the sending of notifications, requests, and information relating to the provision of services, as well as the processing of the User’s inquiries and applications;

4.1.3. determination of the User’s location, where necessary, for security purposes and for the prevention of fraud and unauthorized activity;

4.1.4. notification of the User regarding the status of orders and services;

4.1.5. processing of payments, verification of payment details, confirmation of tax obligations or tax benefits (where applicable), and handling of payment disputes;

4.1.6. provision to the User, subject to the User’s prior consent, of information regarding services, special offers, pricing information, newsletters, and other communications on behalf of the Operator;

4.1.7. conduct of marketing and promotional activities, subject to the User’s explicit consent;

4.1.8. analysis of Website traffic and User behavior using analytics services, including Yandex.Metrica, for the purposes of improving, maintaining, and optimizing the performance and functionality of the Website;

4.1.9. provision of effective customer support and technical assistance to the User in connection with issues arising from the use of the Website.

4.2. The processing of Personal Data by the Operator is carried out in accordance with the principles of lawfulness, fairness, transparency, data minimization, purpose limitation, accuracy, storage limitation, integrity, and confidentiality, and in compliance with the following:

4.2.1. Federal Law of the Russian Federation No. 152-FZ dated 27 July 2006 “On Personal Data”;

4.2.2. this Privacy Policy;

4.2.3. Decree of the Government of the Russian Federation No. 1119 dated 1 November 2012 “On Approval of Requirements for the Protection of Personal Data during Processing in Personal Data Information Systems”;

4.2.4. Order of the Federal Service for Technical and Export Control of the Russian Federation (FSTEC) No. 21 dated 18 February 2013 “On Approval of the Composition and Content of Organizational and Technical Measures to Ensure the Security of Personal Data during Processing in Personal Data Information Systems”;

4.2.5. other applicable regulatory and non-regulatory legal acts governing the processing and protection of personal data.

5. METHODS AND CONDITIONS OF PROCESSING OF PERSONAL DATA

5.1. The processing of the User’s Personal Data shall be carried out without limitation of time, by any lawful means, including within personal data information systems with or without the use of automated processing tools.

5.2. The User agrees that Lingvista may transfer Personal Data to third parties, including, but not limited to, courier services, postal service providers, and telecommunications operators, solely for the purpose of fulfilling the User’s request or order submitted via the Website or subsequently, including the delivery of the results of the Services.

5.3. The User’s Personal Data may be disclosed to authorized public authorities of the Russian Federation exclusively on the grounds and in accordance with the procedures established by the legislation of the Russian Federation.

5.4. In the event of loss or unauthorized disclosure of Personal Data, the Operator shall notify the User of such loss or disclosure in accordance with applicable legal requirements.

5.5. The Operator implements appropriate organizational and technical measures to protect the User’s Personal Data against unauthorized or accidental access, destruction, alteration, blocking, copying, distribution, as well as against other unlawful actions by third parties.

5.6. The Operator, in cooperation with the User where applicable, shall take all reasonable measures to prevent or mitigate losses or other adverse consequences resulting from the loss or unauthorized disclosure of the User’s Personal Data.

5.7. Retention periods for personal data.Personal Data shall be processed and stored only for the period necessary to achieve the purposes specified in Section 3 of this Privacy Policy, and in any case no longer than required by applicable law.

The specific retention periods are as follows:

  • Personal Data provided by the User via contact, feedback, or registration forms shall be retained for five (5) years from the date of the User’s last interaction, unless a longer or shorter retention period is required by law;
  • Automatically collected data (including IP addresses, cookies, and browser-related information) shall be retained for one (1) year from the date of collection;
  • Data collected through third-party analytics services (including Yandex.Metrica) shall be retained for eighteen (18) months, in accordance with the retention policies of such services.

Upon expiration of the applicable retention period, Personal Data shall be securely deleted or anonymized, unless further retention is required by law or justified by a lawful basis.

5.8. The User has the right, at any time, to modify, update, or supplement the Personal Data provided, as well as to adjust confidentiality and communication preferences, subject to applicable legal requirements.

5.9. Cross-border transfer of Personal Data is not carried out.

6. PROCESSING OF PERSONAL DATA THROUGH COOKIES

6.1. Cookies transmitted to and from the User’s device may be used by the Operator to enable personalized Website features, deliver targeted advertising displayed to the User, conduct statistical and research analysis, and improve the performance and functionality of the Website.

6.2. The User acknowledges that the hardware and software used to access websites on the Internet may include functionality to restrict or disable the acceptance of cookies (either for all websites or for specific websites), as well as to delete cookies previously stored on the User’s device.

7. OBLIGATIONS OF THE PARTIES

7.1. The User shall:

7.1.1. provide accurate Personal Data required for submitting a request or order;

7.1.2. update or supplement previously provided Personal Data in the event of any changes, where such updates are necessary for the provision of services.

7.2. The Operator shall:

7.2.1. use the Personal Data obtained solely for the purposes specified in Section 4 of this Privacy Policy;

7.2.2. ensure the confidentiality of Personal Data and refrain from disclosing, selling, exchanging, publishing, or otherwise making such data available without the User’s prior written consent, except as expressly provided for in Clauses 5.2 and 5.3 of this Privacy Policy or as required by applicable law;

7.2.3. implement appropriate safeguards to protect the confidentiality of the User’s Personal Data in accordance with generally accepted business practices and applicable data protection standards;

7.2.4. block or restrict the processing of Personal Data relating to the relevant User upon receipt of a request from the User, the User’s lawful representative, or an authorized data protection authority, for the duration of the verification process, in cases where inaccurate Personal Data or unlawful processing is identified.

8. LIABILITY OF THE PARTIES

8.1. The Operator that fails to fulfill its obligations shall be liable for losses incurred by the User as a result of unlawful processing or use of Personal Data, in accordance with the legislation of the Russian Federation, except for the cases provided for in Clauses 5.2, 5.3, and 7.2 of this Privacy Policy.

8.2. In the event of loss or unauthorized disclosure of Confidential Information, the Operator shall not be held liable if such Confidential Information:

8.2.1. became publicly available prior to its loss or disclosure;

8.2.2. was obtained from a third party before it was received by the Operator;

8.2.3. was disclosed with the User’s consent.

8.3. The Operator shall not be liable for any damage or losses suffered by Users as a result of errors or inaccuracies in information provided by the Operator or by Users on the Website. At the same time, the Operator shall make reasonable efforts to resolve disputes arising between the User and the Website.

8.4. The Operator shall not be liable for the complete or partial unavailability of the Website caused by preventive maintenance or other technical works necessary to ensure the proper functioning of the Website, including any failure by Users to receive information during such periods.

8.5. The User shall bear responsibility for any damage that may arise as a result of the use of materials obtained through the use of the Website services.

8.6. The User shall bear sole responsibility for any issues arising during registration on the Website or during its use. The Operator shall not be liable for any damage or losses incurred by the User as a result of errors, omissions, or negligence on the part of the User when using the Website.

9. DISPUTE RESOLUTION

9.1. Prior to initiating court proceedings regarding disputes arising between the User and the Operator, it is mandatory to submit a written claim proposing an attempt at voluntary dispute resolution.

9.2. The recipient of the claim shall, within thirty (30) calendar days from the date of receipt, notify the claimant in writing of the results of the review of the claim.

9.3. If an agreement is not reached through the voluntary resolution process, the dispute shall be submitted to the competent court in accordance with the applicable legislation of the Russian Federation.

9.4. This Privacy Policy and the relationships between the User and the Operator are governed by the current legislation of the Russian Federation.

10. ADDITIONAL TERMS

10.1. The Operator reserves the right to amend this Privacy Policy at any time without the User’s consent.

10.2. This Privacy Policy shall become effective from the date it is published on the Website.

10.3. This Privacy Policy shall remain in effect indefinitely until replaced by a new version. A new version of the Privacy Policy shall take effect from the moment it is published on the Website, unless otherwise specified in the new version.

10.4. Any suggestions, inquiries, or questions regarding this Privacy Policy should be directed to the Operator via email at info@lingvista.ru.

10.5. The current version of the Privacy Policy is published on the following page: https://www.lingvista.ru.

10.6. The Operator’s Website may contain links to third-party websites and services that are not under the Operator’s control. The Operator shall not be responsible for the security, privacy, or processing of any information collected by such third-party websites or services.