Personal data processing and protection policy

This Personal data processing and protection policy (hereinafter referred to as the Policy) applies to all information which «Media GURU» LLC (ITN 7725710297, address 115280, Moscow, Leninskaya Sloboda St., 19c1) (hereinafter referred to as the “Personal Data Operator” or “Operator”) may receive about a user (hereinafter referred to as the User) and/or on the third party on behalf of and in the interests of which the user acts – during the use of website (the “Site”), its services and services.

This Policy is based on and in accordance with Art. 24 of the Constitution of the Russian Federation, Federal Law No. 152-FL of July 27, 2006 “On Personal Data” and other normative acts of the Russian Federation.

The policy applies to all personal data (subjects) which can be received by the Operator during its activities.

The Policy goal is to provide the persons who provide their personal data with the necessary information allowing to assess which personal data and for what purposes are processed by the Operator, what methods of ensuring their safety are being implemented.

The policy protects the rights and freedoms of subjects when processing their personal data while using automation tools or without using such tools, and also establishes the responsibility of persons having access to personal data for non-compliance with the requirements governing the personal data processing and protection.

The Site’s Users recognize their consent to their personal data processing in accordance with this Policy while using Operator’s services, informing the Operator of their personal data, including through the intermediation of third parties.

Consent to the personal data processing can be withdrawn by the subject of personal data. In the event of the subject’s withdrawal of personal data consent to the personal data processing, the Operator has the right to continue personal data processing without the consent of the subject of personal data in the presence of grounds specified by the current legislation.

1.1. Within the current Policy, the User’s personal information is understood as:

1.1.1. Personal information which is provided by the User about himself when registering (creating an account) or in during feedback forms and other Site Services using, including User’s personal data. The information required for the Services provision is marked in a special way. Other information is provided by the User at his discretion.

1.1.2. Other User’s information, which processing is necessary for the Site use purposes.

1.1.3. This Policy applies to the Site only. The site does not control and is not responsible for the sites of third parties to which the User can click by the links available on the Site.


2.1. The site collects and stores only the personal information which is necessary for the Site services provision, Site use and agreements and contracts execution between the User and the Operator, except for cases when the legislation provides for mandatory storage of personal information during the period specified by law.

2.2. The operator processes personal data for carrying out activities, implementing their legitimate interests and requirements. Personal data processing goals:

2.2.1. Identification of the User registered on the Site.

2.2.2. Providing the User with the access to the Site resources, signing an offer contract with the user.

2.2.3. Establishment of feedback from the User, including sending notifications, requests concerning the Site use, rendering services, processing User’s requests.

2.2.4. Confirmation of personal data authenticity and completeness provided by the User.

2.2.5. Account creation in order to use the Site personalized resources if the User expressed his intention to create an account.

2.2.6. Providing the Customer with effective client and technical support in the event of issues related to the Site use and the relevant agreement (contract) implementation between the User and the Operator.

2.2.7. Notification of the User on updating the information materials of the Site, sending notifications and requests related to the services provision after obtaining the User’s consent.


3.1. In respect of the User’s personal information, confidentiality is maintained, except for cases of voluntary provision by the user of information about himself for general access to an unlimited number of persons. In this case, the User agrees that a certain part of his personal information becomes publicly available.

3.2. The Operator has the right to transfer the User’s personal information to third parties in the following cases:

3.2.1. The user has consented to such actions.

3.2.2. The transfer is necessary for the User in order to use a certain service or for a contract-offer execution with the User;

3.2.3. The transfer is provided for by Russian or other applicable legislation within the procedure established by law.

3.2.4. In the event of the Site sale, the buyer receives all obligations to comply with the terms of this Policy applying to the personal information.

3.3. The User’s personal data processing is carried out without any time limit by any lawful means, including information systems of personal data using automation tools or without using such tools. Users personal data processing is carried out in accordance with the Federal Law of July 27, 2006 No. 152-FL “On Personal Data”

3.4. The operator guarantees organizational and technical measures to protect the User’s personal information from unauthorized or accidental access, destruction, modification, blocking, copying, distribution, as well as from other illegal actions of third parties.


4.1. The User is obliged to:

4.1.1. Provide information about the personal data necessary for the Site use.

4.1.2. Update, supplement the information provided on personal data in case of changing this information.

4.2. The operator is obliged:

4.2.1. Use the information received solely within the stated purposes.

4.2.2. To ensure the confidential information is not kept secret, not to disclose without the prior written User’s permission and also not to sell, exchange, publish or disclose other User’s personal data, except for provided in this Policy.

4.2.3. Take precautions to protect the User’s personal data privacy in accordance with the procedure normally used to protect this kind of information in the existing business.

4.2.4. To block personal data related to the relevant User from the moment of the User’s request or his legal representative or authorized body for protection of the rights of subjects of personal data for the verification period in case of revealing unreliable personal data or illegal actions.


5.1. The Operator’s activity in the processing of personal data in information systems is based on the principles of protecting the confidentiality of information received.

5.2. The personal data safety when processing them in the information systems of the Operator is provided by means of an information security system which includes: organizational measures with application of the restriction of physical access to premises, application of software and technical protection measures.

5.3. Exchange of personal data when processing them in information systems is carried out through communication channels, protected by technical means of information protection.

5.4. When processing personal data in the Organization’s information systems, there are ensured:

– carrying out activities aimed at preventing unauthorized access to personal data and (or) transferring them to persons who do not have the right to access such information;
– timely detection of unauthorized access to personal data;
– Preventing the impact on the technical means of automated processing of personal data, in which result their functioning may be disrupted;
– the opportunity of immediate restoration of personal data, modified and destroyed due to unauthorized access;
– constant monitoring of the personal data protection level.


6.1. Personal data processing terms are determined on the basis of processing purposes in the information systems of the Operator, in accordance with the term of the contract, agreements with the subject of personal data, the limitation period, as well as other requirements of legislation and regulatory documents of the Operator.


7.1. In accordance with this Policy, the User when registering on the Site gives his consent to his personal data processing to the Operator and confirms that he acts by his own will and in his interest by giving such consent.

7.2. The consent shall extend to the following User’s information: first name, last name, middle name, telephone number, e-mail any other information regarding his identity.

7.3. Consent to the personal data processing is given by the User in order to:

• Use the Site in the within the services provided on the Site (by the Site), including for commercial purposes by signing a relevant offer contract with the Operator;
• conducting polls as well as marketing, statistical and other research;
• informing about new services or products of the Site and/or partners.

7.4. Consent is presented for the implementation of any actions with respect to the Personal Data required in order to achieve the above objectives, including without limitation: collection, systematization, accumulation, storage, clarification (updating, modification), use, distribution (including transfer), depersonalization, blocking, destruction, as well as the implementation of any other actions with personal data in accordance with applicable law.

7.5. Personal data processing is carried out by the Operator in the following ways:

• personal data processing while using automation tools;
• personal data processing without automation (manual processing) use.

When processing personal data, the operator is not limited in the application of the methods for processing them.

7.6. The User hereby acknowledges that the Operator has the right to provide third parties with my personal data if:

• The user provides his/her express consent to the transfer of his/her personal data to third parties;
• The disclosure of the User’s personal data is necessary to provide him with the Site’s services and/or to process his personal data. In the event that the Operator transfers the User’s personal data to third parties, the Operator requires third parties to respect the confidentiality of the User’s personal data.

7.7. This consent is given before the expiration of the storage of the relevant information or documents containing the above information, determined in accordance with the current legislation of the Russian Federation, after which it can be withdrawn by sending me a written notice to the Operator not less than 1 (one) month prior to the consent withdrawal.

7.8. Except for the cases provided by the current legislation of the Russian Federation and this Policy, the Operator shall not, without the express consent of the User, sell the User’s personal data to third parties, or exchange personal data of the User with third parties.


8.1. The Operator has the right to make changes to this Policy without the User’s consent.

8.2. The Policy’s new version shall come into force from the moment of its posting on the Site, unless otherwise provided by the new Policy’s edition.

8.3. The current Policy’s version is posted on the page at:


9.1. All suggestions, questions and notifications about this Policy should be report to the Operator’s address

«Media GURU» LLC:
ITN 7725710297/IEC 772501001
PSRN 1107746998325
Legal address: Leninskaya Sloboda St., Moscow, 115280, Moscow, Russia