• General terms

This Personal data processing policy (hereinafter referred to as – “Policy”) is the fundamental internal document of TEAMIDEA GROUP LLC (hereinafter referred to as “TeamIdea” and/or “Company”), which regulates the processing of personal data. This Policy defines the basic principles, purposes, conditions and methods of personal data processing, the list of subjects and personal data processed in TeamIdea, TeamIdea functions in the processing of personal data, the rights of personal data subjects, as well as the requirements for personal data protection implemented in TeamIdea.

This Policy has been developed on the basis of the Constitution of the Russian Federation, the Labor Code of the Russian Federation, Federal Law No. 152-FZ of July 27, 2006 “On Personal Data” and other regulatory legal acts of the Russian Federation in the field of personal data.

• Terms and definitions.

For the purposes of this Policy, the following terms and definitions are used:“Personal data” means any information relating to a directly or indirectly identified or identifiable individual “Personal data operator” (hereinafter referred to as the “Operator”) means state authority, municipal authority, legal entity or individual person, independently or jointly with other persons organizing and (or) carrying out the processing of personal data, as well as determining the purposes of processing personal data, the composition of personal data, subject to processing, actions (operations) performed with personal data.

“Personal data processing” means any action (operation) or a set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modifying), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data“Provision of personal data” means actions aimed at disclosure of personal data to a certain person or a certain circle of persons.

“Dissemination of personal data” means actions aimed at disclosure of personal data to a certain person or a certain circle of persons.

“User" means a person who has access to the site, services via the Internet and uses the site, services.

“Automated personal data processing” means processing of personal data using computer technology.

“Destruction of personal data” means actions as a result of which it becomes impossible to restore the content of personal data in the information system of personal data and/or as a result of which the material carriers of personal data are destroyed.

“Personal data information system” means a set of personal data contained in databases and information technologies and technical means that ensure their processing.

“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 individual person or a foreign legal entity.

• Principles and purposes of personal data processing.

The Company processes personal data of the Company’s employees and other personal data subjects who are not in an employment relationship with the Company.

The personal data processing in the Company is carried out taking into account the need to ensure the protection of the rights and freedoms of the Company’s employees and other subjects of personal data, including the protection of the right to privacy, personal and family secrets, based on the following principles:
The personal data processing is carried out in the Company on a legal and fair basis
The personal data processing is limited to the achievement of specific, predetermined and legitimate purposesIt is not allowed to process the personal data incompatible with the purposes of personal data collection.
It is not allowed to combine databases containing personal data, the processing of which is carried out for purposes that are incompatible with each other.
Only personal data that meet the purposes of their processing are subject to processing.
The content and scope of the processed personal data correspond to the stated purposes of processing. Redundancy of the processed personal data in relation to the stated purposes of their processing is not allowedWhen processing personal data, the accuracy of personal data, their sufficiency, and, if necessary, their relevance in relation to the purposes personal data processing, are ensured. The Company takes the necessary measures to delete or clarify incomplete or inaccurate personal dataStorage of personal data is carried out in a form that allows determining the subject of personal data, no longer than the purposes of personal data processing require if the period of storage of personal data is not under federal law, an agreement to which the subject of personal data is a party, beneficiary or guarantorThe processed personal data is destroyed or depersonalized upon achievement of the processing purposes or in case of loss of the need to achieve these purposes, unless otherwise under federal law.


Personal data is processed by the Company for the purposes of:
Ensuring compliance with the Constitution of the Russian Federation, legislative and other regulatory legal acts of the Russian Federation, local regulations of the CompanyPerforming the functions, powers and obligations assigned by the legislation of the Russian Federation to the Company, including the provision of personal data to state authorities, the Pension Fund of the Russian Federation, the Social Insurance Fund of the Russian Federation, the Federal Compulsory Medical Insurance Fund, as well as other state authoritiesRegulation of labor relations with the Company’s employees (assistance in employment, training and promotion, ensuring personal safety, monitoring the quantity and quality of work performed, ensuring the safety of property).

Providing the Company’s employees with additional guarantees and compensations, including voluntary medical insurance, medical care and other types of social securityProtection of life, health or other vital interests of personal data subjectsPreparation, conclusion, execution and termination of contracts with counterpartiesExecution of judicial acts, acts of other authorities or officials subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedingsFor other legitimate purposes.

• List of subjects whose personal data is processed by the Company

The Company processes personal data of the following categories of subjects:Candidates for vacant positions of the CompanyThe Company’s employees, relatives of the Company’s employees, within the limits determined by the legislation of the Russian Federation, if information about them is given by the employeeIndividuals with whom the Company enters into independent contractor agreementRepresentatives of legal entities – counterparties of the CompanyCounterparties of the Company – individual entrepreneursUsers of the services and the website owned by the Company: http://www.teamidea.ru/en/

Other subjects of personal data.

• List of personal data processed by the Company

The list of personal data processed by the Company is determined in accordance with the legislation of the Russian Federation and local regulations of the Company, taking into account the purposes of processing personal data specified in Section 4 of this Policy, and includes data obtained during the implementation of labor and civil law relations, as well as in the selection of candidates for vacant positions of the CompanyProcessing of special categories of personal data concerning race, nationality, political views, religious or philosophical beliefs, intimate life is not carried out in the Company.

• List of actions with personal data and methods of their processing.

The Company collects, records, systematizes, accumulates, stores, clarifies (updates, modifies), extracts, uses, transfers (distribution, provision, access), depersonalizes, blocks, deletes and destroys personal data. The processing of personal data in the Company is carried out in the following ways:Non-automated personal data processingAutomated personal data processing with or without transmission of the received information via information and telecommunication networksMixed personal data processing7Terms of personal data processingThe personal data processing in the Company is carried out with the consent of the personal data subject to the processing of his personal data, unless otherwise under the legislation of the Russian Federation in the field of personal dataThe Company does not disclose or distribute personal data to third parties without the consent of the personal data subject, unless otherwise under federal law.

• Functions of the Company in the personal data processing

Company when processing personal data:Takes measures necessary and sufficient to ensure compliance with the requirements of the legislation of the Russian Federation and local regulations of the Company in the field of personal dataTakes 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 dataAppoints a person responsible for organizing the personal data processing in the CompanyIssues local regulations that determine the policy and issues of processing and protecting personal data in the CompanyFamiliarizes the Company’s employees directly engaged in the personal data processing with the provisions of the legislation of the Russian Federation and local regulations of the Company in the field of personal data, including the requirements for the protection of personal data, and training of these employees.

Publishes or otherwise provides unrestricted access to this PolicyInforms the personal data subjects or their representatives in accordance with the established procedure about the availability of personal data related to the relevant subjects, provides an opportunity to get acquainted with these personal data when applying and (or) receiving requests from the specified personal data subjects or their representatives, unless otherwise under the legislation of the Russian Federation FederationsTerminates processing and destroys personal data in cases under the legislation of the Russian Federation in the field of personal dataPerforms other actions under the legislation of the Russian Federation in the field of personal data.

• Rights of personal data subjects

Personal data subjects have the right toReceive full information about their personal data processed by the CompanyDemand clarification of their personal data, their blocking or destruction if the personal data is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processingDemand the adoption of measures under law to protect their rightsGet access to their personal data with the right to receive a copy of any record containing their personal data, except as otherwise under federal lawWithdraw consent to the personal data processingAppeal against the actions or inaction of the Company to the authorized authority for the protection of the rights of personal data subjects or in courtConduct other rights under the legislation of the Russian Federation.

• Company responsibilities

The Company is obliged:
To provide the personal data subject, upon his request, with information concerning his personal data processing, or legally provide a refusal within thirty days from the receipt date of the request of the personal data subject or his representative.
To explain to the personal data subject, the legal consequences of refusing to provide his personal data, if the provision of personal data is mandatory in accordance with federal law.
To take the necessary 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.
To publish on the Internet and provide unrestricted access using the Internet to the document defining its policy regarding the personal data processing, to information about the implemented requirements for the personal data protectionTo block illegally processed personal data related to the personal data subject.
To clarify the personal data of the subjects.
To terminate illegal personal data processing in case of detection of illegal personal data processing carried out by the Company.
To terminate the personal data processing and destroy personal data upon achievement of the purpose of personal data processing, unless otherwise under the agreement to which the personal data subject is a party, beneficiary or guarantor, if the purpose of personal data processing is achieved.
To terminate personal data processing and destroy personal data if the personal data subject withdraws consent to the personal data processing, if the Company does not have the right to process personal data without the consent of the personal data subject.
To perform other obligations under the legislation of the Russian Federation.

The Company’s employees are obliged:

To get acquainted with the Policy and internal documents regulating the personal data processing, and comply with the requirements of these documentsTo process personal data only within performing their work dutiesNot to disclose personal data, access to which was obtained within performing their work dutiesTo inform the employer about the facts of disclosure (destruction, distortion) of personal data.

• Measures taken by the Company to ensure the fulfillment of the operator’s obligations in the personal data processingThe following measures are taken to ensure that the Company fulfills the operator’s obligations under the legislation of the Russian Federation in the field of personal data:

Appointment of a person responsible for organizing the personal data processing in the CompanyAdoption of local regulations and other documents in the field of processing and protection of personal dataConduction of training and methodological work with the Company’s employees responsible for organizing the personal data processingObtaining consents of personal data subjects to the processing of their personal data, except as otherwise under the legislation of the Russian FederationSeparation of personal data processed without the use of automation tools from other information, in particular by fixing them on separate material carriers of personal data, in special sectionsEnsuring separate storage of personal data and their material carriers, the processing of which is carried out for different purposes and which contain different categories of personal dataStorage of material carriers of personal data in compliance with the conditions that ensure the personal data safety and exclude unauthorized access to themImplementation of internal control over the compliance of the personal data processing with the Federal Law “On Personal Data” and the regulatory legal acts adopted in accordance with it, the requirements for the personal data protection, this Policy, local regulations of the CompanyOther measures under the legislation of the Russian Federation in the field of personal date.

• Timeframes for personal data processing

Timeframes of personal data processing (storage) are determined based on the purposes of personal data processing, in accordance with the contract validity period with the personal data subject, the requirements of federal laws, the basic rules for the operation of organizations archives, the statute of limitationsPersonal data whose processing (storage) period has expired must be destroyed, unless otherwise under federal law. Storage of personal data after the termination of their processing is allowed only after their depersonalization

• Final provisions

This Policy may be revised in any of the following cases:When changing the legislation of the Russian Federation in the field of personal data processing and protectionIn cases of receipt of instructions from the competent state authorities to eliminate inconsistencies affecting the scope of the PolicyBy decision of the Company’s managementWhen changing the purposes of personal data processingWhen changing the organizational structure, the structure of information and/or telecommunication systems (or introducing new ones)When applying new technologies for processing and protecting personal data (including transmission, storage).

If there is a need to change the process of personal data processing related to the Company’s activities.

In case of non-compliance with the provisions of this Policy, the Company and its employees are liable in accordance with the current legislation of the Russian Federation.

1. This Policy and the relations between the personal data subjects and the Company arising in connection with the application of this Policy are the subject to the law of the Russian Federation

1. General Provisions
This Personal Data Processing Policy (hereinafter — the "Policy") is the foundational internal document of Limited Liability Company "KIT" (hereinafter — "YWIS" and/or the "Company"), governing matters related to the processing of personal data.
This Policy defines the core principles, purposes, conditions, and methods of personal data processing, the categories of data subjects and personal data processed by YWIS, the functions of YWIS in the processing of personal data, the rights of data subjects, and the personal data protection requirements implemented by YWIS.
This Policy has been developed in accordance with the Constitution of the Russian Federation, the Labour Code of the Russian Federation, Federal Law No. 152-FZ dated 27.07.2006 "On Personal Data", and other regulatory legal acts of the Russian Federation in the field of personal data.
2. Key Terms and Definitions
For the purposes of this Policy, the following key terms and definitions apply:
"Personal Data" — any information relating directly or indirectly to an identified or identifiable individual.
"Personal Data Operator" (hereinafter — the "Operator") — a state authority, municipal authority, legal entity, or individual that independently or jointly with other persons organises and/or carries out the processing of personal data, and determines the purposes of personal data processing, the categories of personal data to be processed, and the actions (operations) to be performed with personal data.
"Processing of Personal Data" — any action (operation) or set of actions (operations) performed with or without the use of automated means in relation to personal data, including collection, recording, organisation, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (dissemination, provision, access), depersonalisation, blocking, deletion, and destruction of personal data.
"Provision of Personal Data" — actions aimed at disclosing personal data to a specific person or a defined group of persons.
"Dissemination of Personal Data" — actions aimed at disclosing personal data to an indefinite group of persons.
"User" — an individual who has access to the website and services via the Internet and uses such website and services.
"Automated Processing of Personal Data" — processing of personal data by means of computer technology.
"Destruction of Personal Data" — actions as a result of which it becomes impossible to restore the content of personal data in a personal data information system, and/or as a result of which physical media containing personal data are destroyed.
"Personal Data Information System" — a set of personal data contained in databases together with the information technologies and technical means that ensure their processing.
"Cross-border Transfer of Personal Data" — the transfer of personal data to the territory of a foreign state, to a foreign state authority, a foreign individual, or a foreign legal entity.
3. Principles and Purposes of Personal Data Processing
The Company processes personal data of its employees and other data subjects who are not in an employment relationship with the Company.
Personal data processing within the Company is carried out with due regard to the need to protect the rights and freedoms of the Company's employees and other data subjects, including the right to privacy, personal and family confidentiality, on the basis of the following principles:

• Personal data processing within the Company is carried out on a lawful and fair basis.
• Personal data processing is limited to achieving specific, predetermined, and lawful purposes.
• Processing of personal data incompatible with the purposes for which such data was collected is not permitted.
• The merging of databases containing personal data processed for mutually incompatible purposes is not permitted.
• Only personal data that is relevant to the purposes of its processing shall be processed.
• The content and volume of personal data processed shall correspond to the stated processing purposes. Excessive processing of personal data beyond the stated purposes is not permitted.
• During processing, the accuracy, sufficiency, and, where necessary, relevance of personal data in relation to the processing purposes shall be ensured. The Company takes the necessary measures to delete or correct incomplete or inaccurate personal data.
• Personal data shall be stored in a form that allows identification of the data subject for no longer than required by the purposes of processing, unless the retention period is established by federal law or by a contract to which the data subject is a party, beneficiary, or guarantor.
• Processed personal data shall be destroyed or depersonalised upon achieving the processing purposes or upon the loss of necessity to achieve such purposes, unless otherwise provided for by federal law.

Personal data is processed within the Company for the following purposes:

• Ensuring compliance with the Constitution of the Russian Federation, legislative and other regulatory legal acts of the Russian Federation, and the Company's internal regulations.
• Exercising the functions, powers, and obligations imposed on the Company by the legislation of the Russian Federation, including the submission of personal data to state authorities, the Pension Fund of the Russian Federation, the Social Insurance Fund of the Russian Federation, the Federal Compulsory Medical Insurance Fund, and other state bodies.
• Regulating employment relationships with the Company's employees (facilitating employment, training and career advancement, ensuring personal safety, monitoring the quantity and quality of work performed, and safeguarding property).
• Providing the Company's employees with additional guarantees and benefits, including voluntary medical insurance, healthcare, and other forms of social support.
• Protecting the life, health, or other vital interests of data subjects.
• Preparing, concluding, executing, and terminating contracts with counterparties.
• Enforcing judicial acts and acts of other authorities or officials subject to enforcement in accordance with the legislation of the Russian Federation on enforcement proceedings.
• Other lawful purposes.

4. Categories of Data Subjects Whose Personal Data Is Processed by the Company
The Company processes personal data of the following categories of data subjects:

• Candidates for vacant positions within the Company.
• Employees of the Company and their family members, to the extent permitted by the legislation of the Russian Federation, where such information is provided by the employee.
• Individuals with whom the Company enters into civil law contracts.
• Representatives of legal entities that are counterparties of the Company.
• Counterparties of the Company that are individual entrepreneurs.
• Users of the services and website owned by the Company: https://ywis.consulting/
• Other data subjects.

5. Categories of Personal Data Processed by the Company
The categories of personal data processed by the Company are determined in accordance with the legislation of the Russian Federation and the Company's internal regulations, taking into account the processing purposes set out in Section 4 of this Policy, and include data obtained in the course of employment and civil law relationships, as well as in the process of selecting candidates for vacant positions within the Company.
The Company does not process special categories of personal data relating to racial or ethnic origin, political opinions, religious or philosophical beliefs, or intimate life.
6. Personal Data Processing Actions and Methods
The Company carries out collection, recording, organisation, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (dissemination, provision, access), depersonalisation, blocking, deletion, and destruction of personal data.
Personal data processing within the Company is carried out by the following methods:

• Non-automated processing of personal data.
• Automated processing of personal data, with or without transmission of the resulting information via information and telecommunication networks.
• Mixed processing of personal data.

7. Conditions for Personal Data Processing
Personal data processing within the Company is carried out with the consent of the data subject, unless otherwise provided for by the legislation of the Russian Federation in the field of personal data.
Without the consent of the data subject, the Company shall not disclose personal data to third parties or disseminate such data, unless otherwise provided for by federal law.
8. The Company's Functions in Personal Data Processing
In the course of processing personal data, the Company shall:

• Take measures necessary and sufficient to ensure compliance with the requirements of the legislation of the Russian Federation and the Company's internal regulations in the field of personal data.
• Take legal, organisational, and technical measures to protect personal data against unlawful or accidental access, destruction, modification, blocking, copying, provision, dissemination, and other unlawful actions.
• Appoint a person responsible for organising personal data processing within the Company.
• Issue internal regulations defining the policy and procedures for personal data processing and protection within the Company.
• Familiarise employees of the Company who directly process personal data with the provisions of the legislation of the Russian Federation and the Company's internal regulations in the field of personal data, including personal data protection requirements, and provide training to such employees.
• Publish or otherwise ensure unrestricted access to this Policy.
• Notify data subjects or their representatives, in the prescribed manner, of the existence of personal data relating to the relevant subjects, and provide the opportunity to review such data upon request, unless otherwise established by the legislation of the Russian Federation.
• Cease processing and destroy personal data in cases provided for by the legislation of the Russian Federation in the field of personal data.
• Perform other actions provided for by the legislation of the Russian Federation in the field of personal data.

9. Rights of Data Subjects
Data subjects shall have the right to:

• Receive complete information about their personal data processed by the Company.
• Request the correction, blocking, or destruction of their personal data where such data is incomplete, outdated, inaccurate, unlawfully obtained, or no longer necessary for the stated processing purpose.
• Demand that legally prescribed measures be taken to protect their rights.
• Access their personal data, including the right to receive a copy of any record containing their personal data, except in cases provided for by federal law.
• Withdraw consent to the processing of personal data.
• Appeal the actions or inaction of the Company to the authorised body for the protection of data subjects' rights or through judicial proceedings.
• Exercise other rights provided for by the legislation of the Russian Federation.

10. Obligations of the Company
The Company shall be obliged to:

• Provide the data subject, upon request, with information relating to the processing of their personal data, or lawfully refuse to do so, within thirty days from the date of receipt of the request from the data subject or their representative.
• Explain to the data subject the legal consequences of refusing to provide their personal data, where such provision is mandatory under federal law.
• Take necessary legal, organisational, and technical measures to protect personal data against unlawful or accidental access, destruction, modification, blocking, copying, provision, dissemination, and other unlawful actions.
• Publish on the Internet and ensure unrestricted online access to a document defining its personal data processing policy and information on the implemented personal data protection requirements.
• Block unlawfully processed personal data relating to the data subject.
• Clarify the personal data of data subjects.
• Cease unlawful processing of personal data upon detection of such unlawful processing.
• Cease processing and destroy personal data upon achievement of the processing purpose, unless otherwise provided for by a contract to which the data subject is a party, beneficiary, or guarantor.
• Cease processing and destroy personal data in the event of withdrawal of the data subject's consent, where the Company is not entitled to process personal data without such consent.
• Fulfil other obligations provided for by the legislation of the Russian Federation.

Employees of the Company shall be obliged to:

• Familiarise themselves with this Policy and internal documents governing the personal data processing procedure, and comply with the requirements of such documents.
• Process personal data solely within the scope of their job duties.
• Not disclose personal data accessed in the course of performing their employment duties.
• Notify the employer of any instances of disclosure, destruction, or distortion of personal data.

11. Measures Taken by the Company to Fulfil Its Obligations as an Operator in Personal Data Processing
To ensure that the Company fulfils its obligations as an Operator under the legislation of the Russian Federation in the field of personal data, the following measures are taken:

• Appointment of a person responsible for organising personal data processing within the Company.
• Adoption of internal regulations and other documents in the field of personal data processing and protection.
• Organisation of training and methodological work with Company employees responsible for organising personal data processing.
• Obtaining data subjects' consent to the processing of their personal data, except in cases provided for by the legislation of the Russian Federation.
• Segregation of personal data processed without automated means from other information, in particular by recording it on separate physical media or in dedicated sections.
• Ensuring separate storage of personal data and their physical media where processing is carried out for different purposes or involves different categories of personal data.
• Storing physical media containing personal data under conditions that ensure data preservation and prevent unauthorised access.
• Conducting internal audits of personal data processing compliance with Federal Law "On Personal Data", related regulatory acts, personal data protection requirements, this Policy, and the Company's internal regulations.
• Other measures provided for by the legislation of the Russian Federation in the field of personal data.

12. Personal Data Processing Periods
The periods for processing (retention) of personal data are determined based on the purposes of processing, in accordance with the term of the contract with the data subject, the requirements of federal laws, the standard rules for organisational record keeping, and applicable limitation periods.
Personal data whose processing (retention) period has expired must be destroyed, unless otherwise provided for by federal law. Retention of personal data after the cessation of processing is permitted only after its depersonalisation.
13. Final Provisions
This Policy may be revised in any of the following cases:

• Changes to the legislation of the Russian Federation in the field of personal data processing and protection.
• Receipt of orders from competent state authorities to remedy non-conformities within the scope of this Policy.
• A decision by the Company's management.
• Changes to the purposes of personal data processing.
• Changes to the organisational structure or to information and/or telecommunication systems (or the introduction of new ones).
• The adoption of new technologies for personal data processing and protection (including transmission and storage).
• The emergence of a need to modify the personal data processing procedure in connection with the Company's activities.

In the event of non-compliance with the provisions of this Policy, the Company and its employees shall bear liability in accordance with the applicable legislation of the Russian Federation.
This Policy and the relations between data subjects and the Company arising in connection with the application of this Policy shall be governed by the law of the Russian Federation.

In accordance with the requirements of Article 9 of Federal Law No. 152-FZ dated 27.07.2006 "On Personal Data", I hereby freely, of my own will and in my own interest, provide my personal data and give consent to their processing by LLC "KIT", located at: Russian Federation, 117105, Moscow, Varshavskoye Shosse, Building 26, Floor 4, Premises 38, Office 411 (hereinafter — YWIS), including through the use of the website https://ywis.consulting/.
This Consent is granted for the performance of the actions listed in Clause 3 of Article 3 of Federal Law No. 152-FZ dated 27.07.2006 "On Personal Data", namely: collection, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, and transfer (provision, access), whether performed with or without the use of automated means.
This Consent to the Processing of Personal Data is specific, informed, and conscious, given to YWIS without any reservations or limitations.
List of personal data subject to processing:

• last name, first name, patronymic;
• date of birth;
• place of birth;
• registered address;
• identity document details;
• phone number;
• email address;
• job title.

Consent to the processing of personal data is provided for the purposes of promoting goods, works, and services in the market, obtaining information about services rendered by YWIS, including for the purpose of receiving responses to inquiries submitted by website users through electronic feedback forms on the YWIS website, via social media, email, and telephone.
This Consent shall remain in force until:

• the purposes of personal data processing have been achieved;
• the data subject withdraws consent to the processing of personal data;
• the expiration of the storage period;
• the liquidation of the company.

Consent may be withdrawn at any time upon written request by the personal data subject.

This Cookie Policy (hereinafter — the "Policy") describes the types of cookies, the purposes of their use, how the Company processes data collected during the use of the Website https://ywis.consulting/ by Visitors, and the ways in which cookie processing may be declined.
1. Terms and Definitions
The following terms are used in this Policy:
Company — LLC "KIT", located at: Russian Federation, 117105, Moscow, Varshavskoye Shosse, Building 26, Floor 4, Premises 38, Office 411.
Website Visitor (Visitor) — any individual who visits and uses the Website.
Website — a set of software and hardware tools for electronic computers that enable the publication of information and data for public access, united by a common purpose, through technical means used for communication between computers on the Internet. The Website is available on the Internet at: https://ywis.consulting/.
Yandex — Limited Liability Company "YANDEX", LLC "YANDEX", OGRN 1027700229193, 119021, Moscow, Lva Tolstogo St., 16.
Cookies — small pieces of data that the Website requests from the browser used on the Visitor's computer or mobile device. Cookies reflect the Visitor's preferences or actions on the Website, as well as information about their device, and the date and time of the session. Cookies are stored locally on the Visitor's computer or mobile device. The Visitor may delete stored cookies through the settings of the relevant browser.
2. General Provisions
2.1. Upon the first visit to the Website using a new browser or in private browsing mode, a banner is displayed notifying the Visitor of cookie collection and requesting the Visitor's consent to the processing of their cookies.
2.2. By clicking the consent button (e.g., "Accept", "OK", or any other button serving the same purpose) or by continuing to use the Website, the Visitor grants consent to the processing of their cookies and confirms acceptance of the provisions of this Policy. Continued use of the Website means that the Visitor has followed any link posted on the Website, clicked any button on the Website, or viewed content on any page of the Website.
2.3. The Visitor may opt out of cookies through their browser settings (see the "Help" section of the relevant browser for guidance). In such case, the Website will only use cookies that are strictly necessary for its operation and the services it provides; however, opting out may result in the Website functioning incorrectly.
2.4. This Policy applies solely to the Website. The Company does not control and is not responsible for third-party websites that the Visitor may access via links available on the Website.
3. Data Processing on the Website
3.1. The Website uses the Yandex.Metrica web analytics service, provided by Yandex under the following terms:
3.1.1. The Yandex.Metrica web analytics service uses cookies.
3.1.2. Information about the Visitor's use of the Website, collected via cookies, is transmitted to Yandex and stored on Yandex servers located in the Russian Federation. Yandex processes the received information to evaluate the Visitor's use of the Website and to generate Website activity reports.
3.1.3. Yandex processes the received information in accordance with:

• the Cookie Policy available at: https://yandex.ru/legal/cookies_policy;
• the Terms of Use of the Yandex.Metrica service available at: https://yandex.ru/legal/metrica_termsofuse;
• the Privacy Policy available at: https://yandex.ru/legal/confidential.

By continuing to use the Website, the Visitor agrees to the processing of their data by Yandex in the manner and for the purposes set out in Section 3.1 of this Policy.
4. Types of Cookies Used by the Company
4.1. Session Cookies These cookies exist only in temporary memory for the duration of the Visitor's session on the Website. Browsers typically delete session cookies after the Visitor closes the browser window. Session cookies allow the Website to remember the Visitor's choices made on previous pages of the Website, avoiding the need to re-enter information.
4.2. Persistent Cookies Cookies that are stored on the Visitor's computer and are not deleted when the browser is closed. Persistent cookies may retain user preferences for the Website, allowing those preferences to be applied in future browsing sessions. Such cookies help identify the Visitor as a unique user of the Website and, upon return, help recall information about the Visitor and their previous actions.
4.3. Statistical Cookies These cookies contain information about how the Visitor uses the Website — for example, which pages are visited and which links are followed. The primary purpose of such cookies is to improve Website functionality.
4.4. Strictly Necessary Cookies The minimum set of cookies required for the correct operation of the Website.
5. Purposes of Cookie Use and Visitor Data Processing
5.1. Cookies are used to ensure the correct operation of the Website and to improve its performance and usability.
5.2. Information about the Visitor's interaction with the Website is processed for the purposes of:

• improving the functionality and stability of the Website;
• analysing traffic and understanding how Visitors use the Website;
• adapting displayed content and settings to the Visitor's preferences;
• enhancing the quality of information, services, and materials provided.

6. Cookie Management
The Visitor may manage the use of cookies through their browser settings, including the ability to block or delete them. Please note that disabling certain types of cookies may affect the correct operation of the Website and restrict access to some features.
7. Additional Terms
7.1. The Company reserves the right to amend this Policy.
7.2. A new version of the Policy shall take effect from the date of its publication on the Website, unless otherwise specified in the new version.
7.3. The current version of this Policy is available on the Internet at: https://teamidea.ru.