1. General Provisions
This Personal Data Processing Policy has been made in accordance with the requirements of Federal Law No. 152-FZ  “On Personal Data” of July 27, 2006 (hereinafter referred to as the Law on Personal Data) and determines the procedure for processing of personal data and the measures for ensuring the security of personal data taken by OOO “SWCats” (hereinafter referred to as the Operator).

1.1. The Operator is committed to and operates under the condition of respect of human and civil rights and freedoms during the processing of their personal data, including the protection of rights to privacy, personal and family secrets.

1.2. The Operator's Personal Data Processing Policy (hereinafter referred to as the Policy) applies to all information which the Operator can receive about any visitors of the https://softwarecats.dev/ website.

2. General Definitions
2.1. Automated Personal Data Processing—processing of personal data with the means of computer technologies.

2.2. Blocking of Personal Data—a temporary suspension of personal data processing (unless the processing is required for personal data rectification).

2.3. Website—a set of graphic and information materials, as well as computer programs and databases, which ensure their availability on the Internet at the web address https://softwarecats.dev/.

2.4. Personal Data Information System—a collection of personal data in databases, as well as information technologies and hardware, which ensure the said personal data processing.

2.5. Anonymization of Personal Data—actions which make the subject of personal data unidentifiable without the use of additional information.

2.6. Processing of Personal Data—any action (operation) or set of actions (operations) performed with personal data with or without automation tools, including collection, recording, organization, accumulation, storage, rectification (updating, changing), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, or destruction of personal data.

2.7. Operator—a state, municipal, legal body or individual that independently or jointly processes personal data and/or organizes their processing, as well as determines the purpose of personal data processing, the composition of personal data to be processed, and actions (operations) performed with personal data.

2.8. Personal Data—any information directly or indirectly related to a specific or identifiable user of the https://softwarecats.dev/ website.

2.9. Personal Data Permitted for Distribution by their Subject—personal data which the subject allowed to be publicly disclosed by giving their consent to processing of the said personal data as set forth in the Law on Personal Data (hereinafter—Personal Data Permitted for Distribution).

2.10. User—any visitor of the https://softwarecats.dev/ website.

2.11. Provision of Personal Data—actions aimed at disclosing personal data to a certain person or a certain number of persons.

2.12. Distribution of Personal Data—any actions aimed at public disclosure of personal data (transfer of personal data) or at allowing an unlimited number of persons to familiarize themselves with personal data, including the publication of personal data in media, information and telecommunication networks, or providing access to personal data in any other way.

2.13. Cross-Border Transfer of Personal Data—an act of transferring personal data to the territory of a foreign state, to an authority of a foreign state, to a foreign individual, or to a foreign legal entity.

2.14. Destruction of Personal Data—any actions, which result in permanent destruction of personal data with no possibility of their further restoration in personal data information system and/or the destruction of physical personal data storage.

3. General Rights and Obligations of the Operator
3.1. The Operator has the following rights:
– receive reliable information and/or documents containing personal data from the subject of personal data;
– if the subject of personal data withdraws their consent to processing of personal data, the Operator has the right to continue processing of the said personal data without the consent of the subject if eligible according to the Law on Personal Data; and
– independently determine the measures, which are necessary and sufficient to ensure the fulfillment of obligations set forth in the Law on Personal Data and corresponding regulatory acts, unless the Law on Personal Data or other federal laws specify otherwise.

3.2. The Operator has the following obligations:
– provide the subject of personal data with information regarding the processing of their personal data upon their request;
– organize the processing of personal data in the manner provisioned by the applicable laws of the Russian Federation;
– respond to requests and inquiries from subjects of personal data and their legal representatives in accordance with the requirements of the Law on Personal Data;
– provide all necessary information to the privacy authority upon request within 30 days from receiving the said request;
– publish or otherwise provide unrestricted access to this Personal Data Processing Policy;
– take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, or distribution, as well as from other illegal actions related to personal data;
– stop the transfer (distribution, provision, access) and processing of personal data and destroy them according to the procedures and conditions set forth in the Law on Personal Data; and
– fulfill other obligations set forth in the Law on Personal Data.

4. General Rights and Obligations of the Subject of Personal Data
4.1. The subject of personal data have the following rights:
– receive information regarding the processing of their personal data, except for the cases specified by federal laws. The information should be provided by the Operator in an accessible form and should not contain personal data of other subjects, except for the cases when the disclosure of personal data is legally eligible. The list of data and the procedures to receive them are set forth in the Law on Personal Data;
– request the Operator to update, block, or destroy their personal data in case the personal data are incomplete, outdated, inaccurate, illegally obtained, or are not required for the stated processing purpose, and also to take measures for protecting their rights in accordance with the law;
– demand that the processing of personal data for promotion of goods and services on the market is performed only upon their consent;
– withdraw their consent to processing of personal data;
– appeal to a privacy authority or in court against illegal actions or inaction of the Operator during the processing of their personal data; and
– exercise other rights provided by the laws of the Russian Federation.

4.2. The subject of personal data has the following obligations:
– provide the Operator with reliable information; and
– inform the Operator about changes or updates to their personal data.

4.3. The individuals who provide the Operator with false information about themselves or with personal data of other subjects without their consent will be held accountable in accordance with the laws of the Russian Federation.

5. The Operator has the rights to process the following personal data:

5.1. Full name.

5.2. Email address.

5.3. Phone numbers.

5.4. CV.

5.5. The website also collects and processes anonymized data about its visitors (including cookies) with the help of Internet statistics services (Yandex Metrica, Google Analytics, etc.).

5.6. In this Policy, the data listed above are hereinafter referred to as the Personal Data.

5.7. The Operator does not process personal data from special categories related to race, nationality, political views, religious or philosophical beliefs, or intimate life.

5.8. Processing of the personal data permitted for distribution from the special categories, which are specified in Part 1 of Article 10 of the Law on Personal Data, is permitted only if all the restrictions and conditions listed in the Article 10.1 of the Law on Personal Data are met.

5.9. The user's consent to processing of the personal data permitted for distribution should be obtained separately from other consents to processing of their personal data. All the conditions (including the conditions of Article 10.1 of the Law on Personal Data) should be met. Requirements for the content of such a consent are established by the privacy authority.

5.9.1 The user’s consent to processing of their personal data permitted for distribution should be given directly to the Operator.

5.9.2 The Operator should publish all information about conditions and restrictions of processing of the personal data permitted for public distribution no later than within 3 (three) business days upon receiving the specified consent from the user.

5.9.3 Transfer (distribution, provision, access) of the personal data permitted for distribution by the subject of personal data should be stopped upon request of the subject. The request should include the full name of the subject, their contact information (phone number, email address or postal address), as well as the list of personal data, which processing should be terminated. The personal data specified in such a request can only be processed by the Operator to which it was sent.

5.9.4 The consent to processing of the personal data permitted for distribution remains effective until the Operator receives the request specified in clause 5.9.3 of this Personal Data Policy.

6. Principles of Personal Data Processing
6.1. Personal Data are processed on a legal and fair basis.

6.2. Processing of personal data is limited to fulfilling the specific, pre-defined, and legal purposes. Processing of personal data that is incompatible with the purposes of personal data collection is not permitted.

6.3. It is forbidden to merge databases, if they contain personal data processed for incompatible purposes.

6.4. If personal data are not required for the purposes of processing, they should not be processed.

6.5. The content and volume of the processed personal data should correspond to the stated purposes of processing. Redundancy of the processed personal data in relation to the stated purposes of their processing is not permitted.

6.6. Personal data processing should ensure the data accuracy, sufficiency, and, in corresponding cases, relevance to the purposes of processing. The Operator should take necessary measures to delete or rectify incomplete or inaccurate data and/or should ensure that such measures are taken.

6.7. Personal data should be stored in a form, which allows identification of their subject, and no longer than it is required for the processing purposes, unless the storage period is established by federal laws or a contract with the subject of personal data as a party, beneficiary, or guarantor. Upon fulfilling the processing purposes or if their fulfillment is no longer required, the processed personal data are destroyed or anonymized, unless its otherwise provided by federal laws.

7. Purposes of Personal Data Processing
7.1. User's personal data are processed for the following purposes:
– inform the user by emails;
– sign, execute, and terminate civil contracts; and
– provide the user with access to services, information, and/or materials contained on the https://softwarecats.dev/ website.

7.2. The Operator also has the right to send notifications to the user about new products and services, special offers, and various events. The user can opt out from receiving information messages at any moment by sending an email with the subject “Opt out from receiving notifications about new products, services, and special offers” to hello@softwarecats.dev.

7.3. Anonymized data of users that are collected using Internet statistics services are used to collect information about users‘ actions on the website and to improve the quality of the website and its content.

8. Legal Basis for Personal Data Processing
8.1. The Operator processes personal data on the following legal basis:
– Federal Law No. 149-FZ "On Information, Information Technologies, and Information Protection" dated July 27, 2006;
– the Operator’s statutory documents;
– contracts between the Operator and the subjects of personal data;
– federal laws and other regulations related to personal data protection; and
– users’ consents to processing of their personal data and the personal data permitted for distribution.

8.2. The Operator should only process user’s personal data if they are provided and/or sent by the user through special forms on the https://softwarecats.dev/ website or sent to the Operator via email. By filling out the corresponding forms and/or sending their personal data to the Operator, the user agrees to the terms of the Policy.

8.3. The Operator processes anonymized data of the user only if it is allowed in the user's browser settings (use of cookies and the JavaScript technology is enabled).

8.4. The subject of personal data makes an independent decision to provide their personal data and gives consent freely, of their own free will, and in their own interests.

9. Conditions of Personal Data Processing
9.1. Personal data are processed upon consent of the subject of the personal data.

9.2. Processing of personal data is required to achieve the goals of an international contract of the Russian Federation or laws, to perform functions and fulfill duties and responsibilities assigned to the Operator by the laws of the Russian Federation.

9.3. Processing of personal data is required for administration of justice, execution of a court order or an act of another body or official that are subject to execution in accordance with the laws of the Russian Federation on enforcement proceedings.

9.4. Processing of personal data is required for execution of a contract with the subject of personal data as a party, beneficiary, or guarantor, as well as to sign a contract at the discretion of the subject of personal data or a contract under which the subject of personal data is a beneficiary or guarantor.

9.5. Processing of personal data is required to exercise the rights and legal interests of the Operator or third parties, or to achieve socially significant goals, provided that the rights and freedoms of the subject of personal data are not violated.

9.6. Processed are the personal data, to which public access is provided by the subject of the personal data or by their request (hereinafter referred to as the Publicly Available Personal Data).

9.7. Processed are the personal data, which are subject to publication or mandatory disclosure according to federal laws.

10. The Procedure for Collecting, Storing, Transferring, and Other Types of Personal Data Processing
The security of personal data processed by the Operator should be ensured by implementing legal, organizational, and technical measures, which are required for full compliance with the requirements of the applicable personal data protection laws.

10.1. The Operator should ensure the safety of personal data and take all possible measures to prevent unauthorized access to them.

10.2. The user's personal data should never, under no circumstances, be transferred to third parties, unless required to comply with applicable laws or when the subject of personal data gives the Operator their consent to transfer data to a third party in order to fulfill obligations under a civil contract.

10.3. In case of discrepancies in their personal data, the user can update them independently by sending a notification with the subject “Personal Data Update” to the Operator's email address: hello@softwarecats.dev.

10.4. The period for personal data processing is determined by fulfillment of the purposes, for which the personal data were collected, unless another period is specified in a contract or applicable laws.
The user may withdraw their consent to processing of personal data at any time by sending a notification with the subject “Withdrawal of Consent to Processing of Personal Data” to the Operator's email address: hello@softwarecats.dev.

10.5. All information collected by third-party services, such as payment systems, communication systems, and other service providers, is stored and processed by those parties (Operators) in accordance with their own User Agreements and Privacy Policies. The subject of personal data and/or the user should familiarize themselves with the aforementioned documents in a timely manner. The Operator is not responsible for actions of any third parties, including the service providers specified in this clause.

10.6. Restrictions on transfer (except for granting access) and processing of the personal data permitted for distribution or conditions of their processing (except for gaining access) that are set by the subject of the personal data do not apply to processing of personal data in state and other public interests determined by the laws of the Russian Federation.

10.7. The Operator should ensure confidentiality of the personal data they process.

10.8. The Operator should store personal data in a form, which allows identification of their subject, and no longer than it is required for the processing purposes, unless the storage period is established by federal laws or a contract with the subject of personal data as a party, beneficiary, or guarantor.

10.9. Processing of personal data may be terminated if the purposes of the processing are fulfilled, the consent of the subject of the personal data is expired or withdrawn, or the processing is found to be illegal.

11. The List of Operations with Collected Personal Data
11.1. The Operator can collect, record, organize, accumulate, store, rectify (update, change), extract, use, transfer (distribute, provide, access), anonymize, block, delete, and destroy personal data.

11.2. The Operator automatically processes personal data with or without receiving and/or transmitting the received information via information and telecommunications networks.

12. Cross-Border Transfer of Personal Data
12.1. Prior to initiating a cross-border transfer of personal data, the Operator should ensure that the foreign state, to which territory they intend to transfer the personal data, provides reliable protection of rights for subjects of personal data.

12.2. Cross-border transfer of personal data to the territory of foreign states, which do not meet the above requirements, can only be performed upon written consent of the subject of personal data to the cross-border transfer of their personal data and/or in case of execution of a contract with the subject as a party.

13. Confidentiality of Personal Data
The Operator and other parties with access to personal data should not disclose the personal data to third parties or distribute them without the consent of the subject of personal data, unless it is otherwise required by federal laws.

14. Final Provisions
14.1. The user can contact the Operator via email hello@softwarecats.dev to receive clarifications and/or answers to any questions regarding the processing of their personal data.

14.2. This document should reflect all changes to the Operator’s Personal Data Processing Policy. The Policy remains effective for an indefinite term until replaced by a new version.

14.3. The current version of the Policy is available freely on the Internet at https://softwarecats.dev/policy.