1. General Provisions
This personal data processing policy has been drawn up in accordance with the requirements of Federal Law No. 152-FZ dated July 27, 2006 “On Personal Data” (hereinafter referred to as the “Personal Data Law”) and defines the procedure for processing personal data and the measures to ensure the security of personal data.
1.1. The Operator considers the observance of human and civil rights and freedoms in the processing of personal data—including the protection of the right to privacy, personal and family confidentiality—to be a fundamental goal and a condition for carrying out its activities.
1.2. This Operator’s personal data processing policy (hereinafter referred to as the “Policy”) applies to all information that the Operator may obtain about visitors of the website https://optimist.expert/ .
2. Key Terms 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 termination of the processing of personal data (except where processing is necessary to verify or update personal data).
2.3. Website — a set of graphical and informational materials, as well as computer programs and databases, providing access to such materials on the Internet at https://optimist.expert/ .
2.4. Personal data information system — a set of personal data contained in databases and the information technologies and technical means that enable their processing.
2.5. Depersonalization (anonymization) of personal data — actions that make it impossible, without additional information, to determine which specific User (or other personal data subject) the personal data relates to.
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, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
2.7. Operator — a state authority, municipal authority, legal entity or individual who independently or jointly with other persons organizes and/or carries out the processing of personal data and determines the purposes of personal data processing, the composition of personal data to be processed, and the actions (operations) performed with personal data.
2.8. Personal data — any information relating directly or indirectly to a specific or identifiable User of the website https://optimist.expert/ .
2.9. Personal data permitted by the data subject for distribution — personal data for which the data subject has granted consent for processing and for making available to an unlimited number of persons, in the manner provided by the Personal Data Law (hereinafter referred to as “personal data permitted for distribution”).
2.10. User — any visitor of the website https://optimist.expert/ .
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or to a specific circle of persons.
2.12. Distribution of personal data — any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or at making personal data available to an unlimited number of persons, including publication in mass media, placement in information and telecommunication networks, or providing access to personal data by any other means.
2.13. Cross-border transfer of personal data — transfer of personal data to the territory of a foreign state to a foreign state authority, a foreign individual, or a foreign legal entity.
2.14. Destruction of personal data — any actions resulting in the irreversible destruction of personal data, making it impossible to restore the content of personal data in the personal data information system and/or resulting in the destruction of physical media containing personal data.
3. Main Rights and Obligations of the Operator
3.1. The Operator has the right to:
receive from the personal data subject reliable information and/or documents containing personal data.
in the event the personal data subject withdraws consent to the processing of personal data or submits a request to terminate the processing of personal data, continue processing personal data without the subject’s consent if there are grounds provided by the Personal Data Law.
independently determine the composition and list of measures necessary and sufficient to ensure compliance with obligations under the Personal Data Law and related regulations, unless otherwise provided by the Personal Data Law or other federal laws.
3.2. The Operator is obliged to:
provide the personal data subject, upon request, information regarding the processing of their personal data.
organize the processing of personal data in accordance with the applicable legislation of the Russian Federation.
respond to requests and inquiries from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law.
provide the authorized body for the protection of personal data subjects’ rights, upon request, the necessary information within 10 days from the date of receiving such request.
publish or otherwise ensure unrestricted access to this Policy.
take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision, distribution, and from other unlawful actions in relation to personal data.
terminate the transfer (distribution, provision, access) of personal data, terminate processing, and destroy personal data in the manner and cases provided by the Personal Data Law.
fulfill other obligations provided by the Personal Data Law.
4. Main Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects have the right to:
receive information regarding the processing of their personal data, except in cases provided by federal laws. The information is provided by the Operator in an accessible form and must not include personal data relating to other personal data subjects, except where there are lawful grounds for disclosure of such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law.
require the Operator to correct, block, or destroy their personal data if the personal data is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, and to 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.
withdraw consent to the processing of personal data and submit a requirement to terminate the processing of personal data.
appeal unlawful actions or inaction of the Operator in the processing of personal data to the authorized body for the protection of personal data subjects’ rights or to a court.
exercise other rights provided by the legislation of the Russian Federation.
4.2. Personal data subjects are obliged to:
provide the Operator with accurate data about themselves.
inform the Operator about changes (updating, modification) of their personal data.
4.3. Persons who provided the Operator with inaccurate information about themselves, or information about another personal data subject without the latter’s consent, are liable in accordance with the legislation of the Russian Federation.
5. Principles of Personal Data Processing
5.1. Personal data is processed on a lawful and fair basis.
5.2. Processing of personal data is limited to achieving specific, pre-determined, and lawful purposes. Processing of personal data that is incompatible with the purposes of collection is not allowed.
5.3. Combining databases containing personal data where processing is carried out for purposes incompatible with each other is not allowed.
5.4. Only personal data that meets the purposes of processing is subject to processing.
5.5. The content and scope of processed personal data correspond to the stated purposes of processing. Excessive processing of personal data in relation to the stated purposes is not allowed.
5.6. When processing personal data, accuracy, sufficiency, and, where necessary, relevance of personal data to the purposes of processing are ensured. The Operator takes necessary measures and/or ensures their implementation to delete or correct incomplete or inaccurate data.
5.7. Personal data is stored in a form allowing identification of the personal data subject no longer than required by the purposes of processing, unless the storage period is established by federal law or by a contract to which the subject is a party, beneficiary, or guarantor. Processed personal data is destroyed or depersonalized upon achieving the purposes of processing or in case the need to achieve such purposes is lost, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing
Purpose of processing
- informing the User by sending emails
Personal data
email address
first and last name
Legal grounds
- the Operator’s charter (founding) documents
Types of personal data processing
collection, recording, systematization, accumulation, storage, destruction, and depersonalization of personal data
sending informational emails to the email address.
7. Conditions for Personal Data Processing
7.1. Personal data is processed with the consent of the personal data subject to the processing of their personal data.
7.2. Processing of personal data is necessary to achieve purposes provided by an international treaty of the Russian Federation or by law, to perform functions, powers, and obligations assigned to the Operator by the legislation of the Russian Federation.
7.3. Processing of personal data is necessary for the administration of justice, execution of a judicial act, or an act of another authority or official subject to enforcement under the legislation of the Russian Federation on enforcement proceedings.
7.4. Processing of personal data is necessary for the performance of a contract to which the personal data subject is a party, beneficiary, or guarantor, as well as for concluding a contract at the initiative of the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor.
7.5. Processing of personal data is necessary to exercise the rights and legitimate interests of the Operator or third parties or to achieve socially significant goals, provided this does not violate the rights and freedoms of the personal data subject.
7.6. Personal data is processed that is made publicly accessible by the personal data subject or at the personal data subject’s request (hereinafter referred to as “publicly accessible personal data”).
7.7. Personal data is processed that is subject to publication or mandatory disclosure under federal law.
8. Procedure for 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 applicable legislation in the field of personal data protection.
8.1. The Operator ensures the safety of personal data and takes all possible measures to prevent 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 compliance with applicable law or if the personal data subject has given consent to the Operator to transfer data to a third party for the performance of obligations under a civil law contract.
8.3. If inaccuracies are found in personal data, the User may update it independently by sending a notice to the Operator at 
with the subject line “Updating personal data”.
8.4. The period of processing personal data is determined by achievement of the purposes for which the personal data was collected, unless a different period is provided by a contract or applicable law. The User may withdraw consent to processing at any time by sending a notice to the Operator by email to with the subject line “Withdrawal of consent to personal data processing”.
8.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by such persons (Operators) in accordance with their user agreements and privacy policies. The personal data subject and/or User should familiarize themselves with these documents. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this clause.
8.6. Restrictions established by the personal data subject on the transfer (except for granting access), as well as on processing or conditions of processing (except for obtaining access) of personal data permitted for distribution, do not apply in cases of processing personal data in state, public, and other public interests as defined by the legislation of the Russian Federation.
8.7. The Operator ensures confidentiality of personal data when processing personal data.
8.8. The Operator stores personal data in a form allowing identification of the personal data subject no longer than required by the purposes of processing, unless the storage period is established by federal law or by a contract to which the subject is a party, beneficiary, or guarantor.
8.9. A condition for termination of personal data processing may be achievement of the purposes of processing, expiration of consent, withdrawal of consent by the personal data subject, or a requirement to terminate processing, as well as identification of unlawful processing.
9. List of Actions Performed by the Operator with Received Personal Data
9.1. The Operator carries out: collection, recording, systematization, accumulation, storage, correction (updating, modification), 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 receipt and/or transfer of received information via information and telecommunication networks or without such networks.
10. Cross-Border Transfer of Personal Data
10.1. Before starting activities related to the cross-border transfer of personal data, the Operator must notify the authorized body for the protection of personal data subjects’ rights of its intention to carry out such transfer (such notification is sent separately from the notification of intention to process personal data).
10.2. Before submitting the above notification, the Operator must obtain from the authorities of the foreign state, foreign individuals, and foreign legal entities to which cross-border transfer is planned, the relevant information.
11. Confidentiality of Personal Data
The Operator and other persons who have access to personal data are obliged not to disclose to third parties or distribute personal data without the consent of the personal data subject, unless otherwise provided by federal law.
12. Final Provisions
12.1. The User may receive any clarifications on issues related to the processing of their personal data by contacting the Operator via email: .
12.2. Any changes to the Operator’s personal data processing policy will be reflected in this document. The Policy remains effective indefinitely until it is replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet at: https://optimist.expert/privacy/ .