1. General Provisions

This personal data processing policy is compiled in accordance with the requirements of the Federal Law of 27.07.2006 No. 152-FZ "On Personal Data" (hereinafter - the Personal Data Law) and defines the procedure for processing personal data and measures to ensure the security of personal data taken by LLC "REFORMA" (hereinafter - the Operator).

1.1. The Operator sets its most important goal and condition for the implementation of its activities the observance of human and civil rights and freedoms when processing their personal data, including the protection of rights to privacy, personal and family secrets.

1.2. This Operator's policy regarding personal data processing (hereinafter - the Policy) applies to all information that the Operator can obtain about visitors to the website https://tapki.com.

2. Key Concepts Used in the Policy

2.1. Automated processing of personal data - processing of personal data using computer technology.

2.2. Blocking of personal data - temporary cessation of processing of personal data (except in cases where processing is necessary to clarify personal data).

2.3. Website - a collection of graphical and information materials, as well as computer programs and databases ensuring their availability on the internet at a network address https://tapki.com.

2.4. Information system of personal data - a set of personal data contained in databases, and information technologies and technical means ensuring their processing.

2.5. Anonymization of personal data - actions as a result of which it is impossible to determine without using additional information the belonging of personal data to a specific User or another subject of personal data.

2.6. Processing of personal data - any action (operation) or a set of actions (operations) performed using automation tools or without using such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.

2.7. Operator - a state body, municipal body, legal entity or individual, independently or together with other persons organizing and (or) processing personal data, as well as determining the purposes of processing personal data, the composition of personal data to be processed, actions (operations) performed with personal data.

2.8. Personal data - any information related directly or indirectly to a specific or identifiable User of the website https://tapki.com.

2.9. Personal data permitted for distribution by the subject of personal data - personal data, access to an unlimited number of persons to which is provided by the subject of personal data by giving consent to the processing of personal data allowed for distribution in the manner prescribed by the Law on Personal Data (hereinafter - personal data allowed for distribution).

2.10. User - any visitor to the website .

2.11. Provision of personal data - actions aimed at disclosure of personal data to a certain person or a certain circle of persons.

2.12. Dissemination of personal data - any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or at acquainting the personal data with an unlimited circle of persons, including disclosing personal data in the media, placement in information and telecommunication networks, or providing access to personal data in any other way.

2.13. Cross-border transfer of personal data - the transfer of personal data to the territory of a foreign state to the authority of a foreign state, foreign individual or foreign legal entity.

2.14. Destruction of personal data - any actions as a result of which personal data is destroyed irreversibly with the impossibility of further restoration of the content of personal data in the information system of personal data and (or) as a result of which material carriers of personal data are destroyed.

3. Basic Rights and Obligations of the Operator

3.1. The Operator has the right to:
— receive reliable information and/or documents containing personal data from the subject of personal data;
— in case of withdrawal of consent to the processing of personal data by the subject of personal data, as well as the direction of the appeal with the requirement to stop processing personal data, the Operator is entitled to continue processing personal data without the consent of the subject of personal data if there are grounds specified in the Law on Personal Data;
— independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations provided by the Law on Personal Data and the regulatory legal acts adopted in accordance with it, unless otherwise provided by the Law on Personal Data or other federal laws.

3.2. The Operator is obliged to:
— provide the subject of personal data at his request with information concerning the processing of his personal data;
— organize the processing of personal data in the manner prescribed by the current legislation of the Russian Federation;
— respond to appeals and requests of subjects of personal data and their legal representatives in accordance with the requirements of the Law on Personal Data;
— report to the authorized body for the protection of the rights of subjects of personal data at the request of this body the necessary information within 10 days from the date of receipt of such request;
— publish or otherwise provide unrestricted access to this Policy regarding the processing of personal data;
— take legal, organizational and technical measures to protect personal data from unauthorized or accidental access to them, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other illegal actions in relation to personal data;
— stop the transfer (distribution, provision, access) of personal data, stop processing and destroy personal data in the manner and cases provided by the Law on Personal Data;
— perform other duties provided by the Law on Personal Data.

4. Basic Rights and Obligations of Personal Data Subjects

4.1. Subjects of personal data have the right to:
— receive information concerning the processing of his personal data, except in cases provided by federal laws. Information is provided to the subject of personal data by the Operator in an accessible form, and it should not contain personal data related to other subjects of personal data, except in cases where there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it is established by the Law on Personal Data;
— demand from the operator clarification of his personal data, their blocking or destruction if personal data are incomplete, outdated, inaccurate, illegally obtained, or are not necessary for the stated purpose of processing, as well as take measures provided by law to protect their rights;
— set a condition of prior consent when processing personal data for the purpose of promoting goods, works, and services on the market;
— to withdraw consent to the processing of personal data, as well as to direct the requirement to stop processing personal data;
— appeal against the illegal actions or inaction of the Operator when processing his personal data to the authorized body for the protection of the rights of subjects of personal data or in court;
— to exercise other rights provided by the legislation of the Russian Federation.

4.2. Subjects of personal data are obliged to:
— provide the Operator with accurate data about themselves;
— inform the Operator about the clarification (update, change) of their personal data.

4.3. Individuals who have provided the Operator with false information about themselves, or information about another subject of personal data without the consent of the latter, are liable in accordance with the legislation of the Russian Federation.

5. Principles of Personal Data Processing

5.1. Personal data processing is carried out on a legal and fair basis.

5.2. The processing of personal data is limited to achieving specific, predefined, and lawful purposes. Processing of personal data incompatible with the purposes of collecting personal data is not allowed.

5.3. The merging of databases containing personal data being processed for purposes incompatible with each other is not allowed.

5.4. Only personal data that meets the purposes of their processing are subject to processing.

5.5. The content and volume of processed personal data correspond to the declared purposes of processing. The processing of personal data that is excessive in relation to the stated purposes of their processing is not allowed.

5.6. When processing personal data, the accuracy of personal data, their sufficiency, and, if necessary, relevance to the purposes of personal data processing are ensured. The operator takes necessary measures and/or ensures their adoption for the removal or clarification of incomplete or inaccurate data.

5.7. The storage of personal data is carried out in a form that allows determining the subject of personal data, no longer than required by the purposes of personal data processing if the period of personal data storage is not established by federal law, contract, a party of which, beneficiary or guarantor under which is the subject of personal data. Processed personal data is destroyed or depersonalized upon reaching the goals of processing or in case of loss of the need to achieve these goals, unless otherwise provided by federal law.

6. Purposes of Personal Data Processing

6.1. Purpose of processing: providing the User with access to services, information and/or materials contained on the website

6.2. Personal data: email address

6.3. Legal basis: Federal Law "On Information, Information Technologies, and Protection of Information" of 27.07.2006 N 149-FZ

6.4. Types of personal data processing: Sending informational letters to the email address

7. Conditions for Processing Personal Data

7.1. The processing of personal data is carried out with the consent of the subject of personal data to the processing of his personal data.

7.2. The processing of personal data is necessary for achieving the purposes provided by an international treaty of the Russian Federation or the law, for the exercise of the functions, powers, and duties imposed by the legislation of the Russian Federation on the operator.

7.3. The processing of personal data is necessary for the administration of justice, execution of a judicial act, an act of another body or official to be executed in accordance with the legislation of the Russian Federation on enforcement proceedings.

7.4. The processing of personal data is necessary for the execution of a contract, a party of which, beneficiary or guarantor under which is the subject of personal data, as well as for the conclusion of a contract on the initiative of the subject of personal data or a contract under which the subject of personal data will be the beneficiary or guarantor.

7.5. The processing of personal data is necessary for the exercise of the rights and legitimate interests of the operator or third parties or for the achievement of socially significant objectives provided that this does not violate the rights and freedoms of the subject of personal data.

7.6. The processing of personal data to which access by an unlimited number of persons is provided by the subject of personal data or at his request (hereinafter - publicly available personal data) is carried out.

7.7. The processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.

8. Order of collection, storage, transfer, and other types of personal data processing

The security of personal data processed by the Operator is ensured through the implementation of legal, organizational, and technical measures necessary to fully comply with the requirements of the current legislation in the field of personal data protection.

8.1. The Operator ensures the safety of personal data and takes all possible measures to exclude access to personal data by unauthorized persons.

8.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to the enforcement of current legislation or if the subject of personal data has consented to the Operator transferring the data to a third party for the fulfillment of obligations under a civil law contract.

8.3. In the event of inaccuracies in personal data, the User can update them independently by sending a notification to the Operator's email address info@tapki.com with the note "Personal data update".

8.4. The period of personal data processing is determined by the achievement of the purposes for which the personal data were collected unless a different period is stipulated by the contract or current legislation.

The User may at any time revoke their consent to the processing of personal data by sending a notification via email to the Operator's email address info@tapki.com with the note "Revocation of consent to the processing of personal data".

8.5. All information collected by third-party services, including payment systems, communication means, and other service providers, is stored and processed by the said persons (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data is acquainted with/and or with these documents. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this clause.

8.6. The restrictions on the transfer (other than providing access), as well as on the processing or conditions of processing (other than obtaining access) of personal data allowed for distribution, set by the subject of personal data, do not apply in cases of personal data processing in state, public, and other public interests defined by the legislation of the Russian Federation.

8.7. The Operator ensures the confidentiality of personal data during processing.

8.8. The Operator stores personal data in a form that allows the identification of the subject of personal data no longer than is required by the purposes of personal data processing, unless the storage period of personal data is established by federal law, a contract, the party to which, beneficiary, or guarantor of which is the subject of personal data.

8.9. The condition for the termination of personal data processing may be the achievement of the purposes of personal data processing, the expiration of the subject's consent to the processing of personal data, the revocation of consent by the subject of personal data, or a requirement to cease processing personal data, as well as the detection of unlawful processing of personal data.

9. List of actions performed by the Operator with the obtained personal data

9.1. The Operator carries out the collection, recording, systematization, accumulation, storage, clarification (updating, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.

9.2. The Operator carries out automated processing of personal data with the receipt and/or transfer of the obtained information via information and telecommunication networks or without it.

10. Cross-border transfer of personal data

10.1. Before starting activities related to the cross-border transfer of personal data, the Operator is obliged to notify the authorized body for the protection of the rights of personal data subjects about its intention to carry out the cross-border transfer of personal data (such notification is sent separately from the notification of the intention to process personal data).

10.2. Before submitting the above-mentioned notification, the Operator must obtain the relevant information from the authorities of the foreign state, foreign individuals, and foreign legal entities to whom it is planned to transfer personal data.

11. Confidentiality of Personal Data

The Operator and other persons who have gained access to personal data must not disclose or distribute personal data to third parties without the consent of the personal data subject, unless otherwise provided by federal law.

12. Final Provisions

12.1. The User may obtain any clarifications on issues concerning the processing of his personal data by contacting the Operator via email at info@tapki.com.

12.2. Any changes to the Operator's personal data processing policy will be reflected in this document. The policy is effective indefinitely until it is replaced with a new version.

12.3. The current version of the Policy is freely available on the Internet at https://tapki.com/en/privacy.