Personal Data Processing Policy

1. General provisions

This Personal Data Processing Policy (the “Policy”) is drawn up in accordance with Russian Federal Law No. 152-FZ “On Personal Data” of 27.07.2006 and defines how personal data is processed and protected by the operator.

Operator: Runway Internet Resheniya LLC (OOO «Ранвей Интернет Решения»). INN 7813298266, KPP 781301001, OGRN 1187847015454. Address: 197110, St. Petersburg, Konstantinovsky pr., 11, lit. A, office 1-N/83,84/307, Russia.

Personal data contact: a.matroxin@runway-agency.ru.

The Policy applies to personal data the operator receives from visitors of runwai.ru (the “Site”).

2. Data processed and data subjects

Data subjects: Site visitors who submit a request through the Site forms.

Data processed: name; a contact chosen by the visitor (phone number, e-mail address or messenger handle); company name, if provided; the text of the request.

Technical web-server data (IP address, request timestamp, user-agent) is processed in hosting logs solely to keep the Site operational and secure.

For visit statistics the Site uses the Yandex Metrica web analytics service (YANDEX LLC): cookies and depersonalized visit data are processed (pages viewed, referral source, device and browser type). This data does not identify the visitor; cookies can be disabled in browser settings.

No special categories of personal data and no biometric data are processed.

3. Purposes of processing

Reviewing and answering requests submitted through the Site forms; contacting the visitor by the means they specified; preparing proposals and pre-contract work at the visitor's request.

4. Legal grounds

The data subject's consent (clause 1, part 1, article 6 of 152-FZ) given by ticking the checkbox before submitting a form, and the actions required to conclude a contract at the subject's initiative (clause 5, part 1, article 6 of 152-FZ).

5. Processing terms

Processing is mixed (automated and manual) and confidential. No decisions producing legal consequences for the subject are made on the basis of solely automated processing.

Personal data is not transferred to third parties except as required by Russian law. No cross-border transfer takes place. Databases are located in the Russian Federation (part 5, article 18 of 152-FZ).

Retention: until the purposes are achieved or the consent is withdrawn, and no longer than three years after the subject's last request. After that the data is destroyed.

6. Data subject's rights

The subject may obtain information about the processing of their data; demand its correction, blocking or destruction; withdraw consent at any time; appeal the operator's actions to Roskomnadzor or in court.

To exercise these rights, send a request to a.matroxin@runway-agency.ru with the subject line “Personal data”. Withdrawal of consent stops the processing; the data is destroyed within 30 days unless the law requires otherwise.

7. Protection measures

The operator applies organizational and technical measures: restricted access to data, encrypted transfer channels (TLS), media control and internal personal-data regulations.

8. Final provisions

The operator may amend this Policy. The current revision is permanently available on the Site at runwai.ru/legal/.