Website Confidentiality Policy

01.10.2025

1. General Provisions

1.1. Protecting the confidential information you provide is a priority for Adviros LLC (hereinafter – Adviros). This Privacy Policy explains how Adviros collects, uses, and discloses to third parties the personal information you may provide when using the Adviros website adviros.ru, as well as when using the content, information, and services provided through the website.

1.2. This Adviros policy (hereinafter – the Policy) applies to all information that Adviros may obtain about users of the Site adviros.ru and applies only to the Site.

1.3. Use of the Site and its services constitutes the User's unconditional acceptance of this Policy and the terms of processing of their personal information set forth herein. If the User disagrees with these terms, the User must refrain from using the services.

1.4. If any provision of this Policy is unclear to you, you are obliged to contact Adviros in advance (via the contacts section or by email at compliance@mail.adviros.ru) for clarification, and only thereafter use the Site.

2. What Data We Collect on the Site adviros.ru and for What Purpose

2.1. While using the Site, you may provide Adviros with your personal data. Personal data is provided solely for the purpose of exchanging information with you, providing responses to your inquiries, granting access to certain specialized functions or areas of the Site, and receiving Adviros services, including those related to employment. Personal data is also used to facilitate your use of the Site and to help you use it more efficiently.

Information required for the provision of Services is marked accordingly (with an asterisk). If you decide not to provide any part of the required mandatory information necessary to complete a task, the specified service may not be provided to you.

2.2. Transfer of Your Personal Information to Third Parties – Adviros may transfer your personal information to third parties in accordance with the purposes set forth in Section 6 of the Policy:

  • Transfer of Personal Information to Affiliates and Potential Employers – Adviros may provide your personal information to its affiliates (ChAZ Adviros LLC, legal address: 127055, Moscow, Novoslobodskaya St., 41, floor 3, room I, office 11, INN: 7714364630; MPG IT Solutions LLC, legal address: 127055, Moscow, Novoslobodskaya St., 41, floor/room/office 3/I/30, INN: 7707449410) and potential employers for the purpose of your employment in the Russian Federation. If you do not wish to provide your personal information to affiliates of Adviros LLC, you may not use the Site.
  • For the purpose of technical support of the Site, Adviros may provide your personal information to Individual Entrepreneur Zverev Gleb Leonidovich, 413257, Saratov Region, Krasnokutsky District, Akhmat Village, Yubileynaya St., 18, INN 641700523225.
  • Law Enforcement and Disclosure of Information as Required by Law – Adviros may disclose your personal information to government authorities and institutions if they substantiate their legal authority to obtain such information, or on the basis of a subpoena, order, or request issued by a court or other person/authority with jurisdiction to obtain such information, as well as in other cases established by the applicable laws of the Russian Federation.

2.3. Location of Data Storage – Adviros will store and process your information in Moscow, Russia, or, from time to time, in other locations within the Russian Federation that Adviros deems necessary or convenient to provide you with services quickly and efficiently.

2.4. Adviros performs collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), blocking, deletion, and destruction of personal data.

Processing of personal data by automated means (in personal data information systems) and by non-automated means is carried out in compliance with the requirements of the legislation of the Russian Federation and the Company's regulations governing the processing and protection of personal data. When processing personal data by automated means, Adviros takes necessary measures to ensure the security of the personal data being processed. Processing of personal data by non-automated means, including storage of physical media containing personal data, is carried out in premises that ensure their safety, with the ability to determine storage locations for personal data in accordance with the procedure established by the legislation of the Russian Federation.

2.5. Non-Identifying Information – The Site adviros.ru, like many other websites, automatically collects certain non-identifying information about its users, such as: the date and time of access to the Site, the Internet address of the website from which you linked to our Site; the operating system used, sections visited, web pages visited and information viewed, as well as materials sent to or downloaded from this Site. Such non-identifying information is used to administer and improve the Site's functionality, as well as to collect statistical information.

Cookies – This Site uses cookies, a technology by which information is written to the user's computer, enabling the Site to recognize future visits from that computer. Cookies are intended to enhance the usability of the Site. For example, information provided through cookies is used to recognize you as a user who has previously visited the Site, to track your activity on the Site in order to better meet your needs. You may refuse some cookies, but this may negatively affect your use of the Site and your ability to access certain features. We additionally recommend reviewing the Cookie Policy posted on the Site.

Statistical Information – Adviros may use non-personal data to create summary reports on Site user statistics and Site usage, and then share these reports with others. The statistical data contained in such reports cannot be linked to a specific individual or personal information about individual users.

2.6. The Site does not control and is not responsible for third-party websites that the User may access via links available on the adviros.ru Site.

2.7. Adviros and other persons who gain access to personal data are obliged not to disclose personal data to third parties or distribute personal data without your consent, unless otherwise provided by federal law. Adviros takes the necessary measures to protect your personal data in accordance with Section 11 of this Policy.

3. Key Rights and Obligations of Adviros

3.1. Adviros has the right to:

  • obtain from you accurate information and/or documents containing personal data;
  • in the event that you withdraw your consent to the processing of personal data, or submit a request to cease processing of personal data, Adviros may continue processing personal data without your consent if there are grounds specified in the Personal Data Law;
  • independently determine the composition and list of measures necessary and sufficient to ensure compliance with the obligations set forth in the Personal Data Law and regulatory acts adopted thereunder, unless otherwise provided by the Personal Data Law or other federal laws.

3.2. Adviros is obliged to:

  • provide you with information regarding the processing of your personal data;
  • organize the processing of personal data in accordance with the procedure established by the applicable legislation of the Russian Federation;
  • respond to your inquiries and requests, as well as to inquiries from your representatives, in accordance with the requirements of the Personal Data Law;
  • notify the authorized body for the protection of the rights of personal data subjects, upon request from such body, of the necessary information within 10 days from the date of receipt of such request;
  • publish or otherwise provide unrestricted access to this Policy;
  • adopt legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, alteration, blocking, copying, provision, distribution, and from other unlawful actions with respect to personal data;
  • cease transfer (distribution, provision, access) of personal data, cease processing, and destroy personal data in accordance with the procedure and cases provided for by the Personal Data Law;
  • perform other duties provided for by the Personal Data Law.

4. Key Rights and Obligations of Site Users

4.1. You have the right to:

  • receive information regarding the processing of your personal data, except in cases provided for by federal laws. Information is provided to you in an accessible form and shall not contain personal data relating to other personal data subjects, unless there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
  • request that Adviros clarify your personal data, block or destroy it if the personal data is incomplete, outdated, inaccurate, unlawfully obtained, or is no longer necessary for the stated purpose of processing, as well as take measures provided by law to protect your rights;
  • withdraw your consent to the processing of personal data, and also request the cessation of processing of personal data;
  • appeal against unlawful actions or inaction of Adviros in connection with the processing of your personal data to the authorized body for the protection of the rights of personal data subjects or in court. In accordance with Article 23 of Federal Law No. 152-FZ "On Personal Data," the authorized body for the protection of the rights of personal data subjects in the Russian Federation is the federal executive authority responsible for control and supervision in the field of information technology and communications;
  • the right to protect your rights and legitimate interests, including compensation for losses and/or compensation for moral damage in court, and to exercise other rights provided for by the legislation of the Russian Federation.

4.2. You are obliged to:

  • provide Adviros with accurate data about yourself;
  • inform Adviros of any clarification (updating, modification) of your personal data.

4.3. Persons who provide Adviros with false information about themselves, or information about another personal data subject without the latter's consent, shall be 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 lawful and fair basis.

5.2. Personal data processing is limited to achieving specific, predetermined, and lawful purposes. Processing of personal data incompatible with the purposes of collecting personal data is not permitted.

5.3. The merging of databases containing personal data processed for incompatible purposes is not permitted.

5.4. Only personal data that meets the purposes of its processing is subject to processing.

5.5. The content and scope of the personal data processed correspond to the stated purposes of processing. The personal data processed shall not be excessive in relation to the stated purposes of its processing.

5.6. When processing personal data, the accuracy of personal data, its sufficiency, and, where necessary, its relevance to the purposes of personal data processing are ensured. Adviros takes necessary measures and/or ensures that they are taken to remove or clarify incomplete or inaccurate data.

5.7. Personal data is stored in a form that permits identification of the personal data subject for no longer than is required by the purposes of personal data processing, unless the storage period for personal data is established by federal law, or by a contract to which you are a party, beneficiary, or guarantor. Processed personal data is destroyed upon achievement of the processing purposes or in the event that the need to achieve these purposes is no longer necessary, unless otherwise provided by federal law.

5.8. Categories of Site Users (personal data subjects): employees of the Company, candidates (applicants), and Site visitors.

6. Purposes of Personal Data Processing

6.1. Purpose of Processing: Assistance in employment, training, and professional development

Site User Category: Candidate (applicant)

Personal Data: Last name, first name, patronymic, email address, phone numbers, as well as data provided by the personal data subject in the resume submitted to Adviros, including, but not limited to: date, month and year of birth, gender, citizenship, information on education and qualifications, details of the document confirming the right to reside in the territory of the Russian Federation (for foreign citizens), work permit details (for foreign citizens), information on previous places of work and employment history, information on foreign language proficiency, possession of a driver's license, possession of a car.

Legal Basis, Processing Period: Consent to the processing of personal data. Processing period is until the purpose of processing is achieved, and with respect to assistance in employment – within 180 days from the date of applying for a vacancy, as well as until withdrawal of consent or in accordance with clause 8.1.

Method and Types of Personal Data Processing: Mixed. Collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (provision, access), blocking, deletion, destruction of personal data.

Procedure for Destruction of Personal Data upon Achievement of Processing Purposes: Defined in clause 10.1 of this Policy.

6.2. Purpose of Processing: Receiving informational newsletters

Site User Category: Visitor

Personal Data: Email address, last name and first name, place of work, phone number.

Legal Basis, Processing Period: Consent to the processing of personal data. Processing period is until the purpose of processing is achieved or until withdrawal of consent, as well as in accordance with clause 8.1.

Method and Types of Personal Data Processing: Mixed. Collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (provision, access), blocking, deletion, destruction of personal data.

Procedure for Destruction of Personal Data upon Achievement of Processing Purposes: Defined in clause 10.1 of this Policy.

6.3. Purpose of Processing: Processing of the Data Subject's inquiries and communication with them

Site User Category: Visitor

Personal Data: Last name, first name, email address.

Legal Basis, Processing Period: Consent to the processing of personal data. Processing period is until the purpose of processing is achieved or until withdrawal of consent, as well as in accordance with clause 8.1.

Method and Types of Personal Data Processing: Mixed. Collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (provision, access), blocking, deletion, destruction of personal data.

Procedure for Destruction of Personal Data upon Achievement of Processing Purposes: Defined in clause 10.1 of this Policy.

6.4. Purpose of Processing: Registration for and participation in Adviros events

Site User Category: Visitor

Personal Data: Last name, first name, email address, phone numbers, place of work

Legal Basis, Processing Period: Consent to the processing of personal data. Processing period is until the purpose of processing is achieved or until withdrawal of consent, as well as in accordance with clause 8.1.

Method and Types of Personal Data Processing: Mixed. Collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (provision, access), blocking, deletion, destruction of personal data.

Procedure for Destruction of Personal Data upon Achievement of Processing Purposes: Defined in clause 10.1 of this Policy.

6.5. Purpose of Processing: Informing Site users about Adviros's activities

Site User Category: Company employees

Personal Data: Photograph, last name, first name, place of work, position, experience, education.

Legal Basis, Processing Period: Consent to the dissemination of personal data. Processing period is until termination of the employment contract or until withdrawal of consent, as well as in accordance with clause 8.1.

Method and Types of Personal Data Processing: Mixed. Collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (provision, access), blocking, deletion, destruction of personal data.

Procedure for Destruction of Personal Data upon Achievement of Processing Purposes: Defined in clause 10.1 of this Policy.

6.6. Purpose of Processing: Collection of statistical information about Site visitors

Site User Category: Visitors

Personal Data: Cookies; IP addresses; other automatically collected data, namely: page URL; referrer URL; page title; browser and its version; operating system and its version; device model; screen height and width; information on whether the visitor has cookies and JavaScript (ECMAScript) enabled; JavaScript events (recording visitor interactions with the site, including the use of JavaScript API methods on the site, such as form submission, page scrolling); time zone; browser language; screen color depth; width and height of the browser's client area; interests of site visitors; geographic data; page load parameters (e.g., time to render and server response time); data on pages viewed and visits, clicks on external links, file downloads, bounces, time spent on the site, and browsing depth.

Legal Basis, Processing Period: Consent to the processing of personal data. Processing period is until the purpose of processing is achieved or until withdrawal of consent, as well as in accordance with clause 8.1, with respect to cookies – in accordance with the Cookie Policy.

Method and Types of Personal Data Processing: Mixed. Collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (provision, access), blocking, deletion, destruction of personal data.

Procedure for Destruction of Personal Data upon Achievement of Processing Purposes: Defined in clause 10.1 of this Policy.

7. Conditions for Processing Personal Data

7.1. Personal data processing is carried out with your consent.

7.2. Personal data processing is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or law, to carry out functions, powers, and duties assigned to Adviros by the legislation of the Russian Federation.

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

7.4. Personal data processing is necessary for the performance of a contract to which you are a party, beneficiary, or guarantor, as well as for the conclusion of a contract at your initiative or a contract under which you will be a beneficiary or guarantor.

7.5. Personal data processing is necessary for the exercise of the rights and legitimate interests of Adviros or third parties, or for the achievement of socially significant purposes, provided that your rights and freedoms are not violated.

7.6. Processing of personal data is carried out to which access by an unlimited circle of persons is provided by you or at your request (hereinafter – publicly available personal data).

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

8. Periods for Processing and Storage of Personal Data

8.1. The periods for processing and storage of personal data for each purpose of personal data processing specified in Section 6 are established taking into account compliance with the requirements, including the conditions for processing personal data, determined by the legislation of the Russian Federation, and/or taking into account the provisions of the contract to which you are a party, beneficiary, or guarantor, this Policy, and/or your consent to the processing of personal data, whereby processing and storage of personal data are carried out no longer than required by the purposes of personal data processing, unless otherwise established by the legislation of the Russian Federation. The User may withdraw their consent at any time in accordance with clause 13 of this Policy.

8.2. The condition for termination of personal data processing may be the achievement of the purposes of personal data processing, expiration of your consent to the processing of personal data, withdrawal of consent or a request to cease processing of personal data, as well as the discovery of unlawful processing of personal data.

9. Cross-Border Transfer of Personal Data

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

9.2. Before submitting the aforementioned notification, Adviros is obliged to obtain relevant information from government authorities of foreign states, foreign individuals, and foreign legal entities to whom the cross-border transfer of personal data is planned.

10. Procedure for Destruction of Personal Data

10.1. Procedure for Destruction of Personal Data:

Destruction of personal data processed within the framework of the purposes specified in Section 6 is carried out in the following cases:

  • upon achievement of the purpose(s) of personal data processing or in the event that the need to achieve the purpose(s) of processing is no longer necessary, unless otherwise provided by law and other applicable regulatory legal acts of the Russian Federation;
  • upon discovery of unlawful processing of personal data;
  • upon withdrawal of consent to the processing of personal data, unless otherwise provided by law;
  • upon submission by you of a request to cease processing of personal data, unless otherwise provided by law.

Methods for destroying personal data are determined by Adviros depending on the methods of personal data processing. In the absence of legal grounds for processing personal data (conditions for processing personal data), Adviros destroys the personal data or ensures its destruction in accordance with the procedure established by law (if processing of personal data is carried out by a person acting on behalf of Adviros). Destruction is carried out by performing actions that make it impossible to restore the content of personal data in the personal data information system. Based on the results of the destruction, an act of destruction of personal data is drawn up, and an entry is made in the electronic event log of the personal data information system, in accordance with the requirements of the law and other regulatory acts of the Russian Federation.

11. Ensuring Adviros's Compliance with Personal Data Protection Obligations

11.1. The security of personal data processed by Adviros is ensured through the implementation of legal, organizational, and technical measures necessary to meet the requirements of federal legislation in the field of personal data protection.

To prevent unauthorized access to personal data, Adviros applies the following organizational and technical measures:

  • appointment of a person responsible for organizing the processing of personal data;
  • appointment of persons responsible for ensuring measures to preserve personal data and prevent unauthorized access to it;
  • appointment of a person responsible for ensuring the security of personal data in information systems;
  • restriction of the list of persons authorized to process personal data;
  • familiarization of data subjects with the requirements of federal legislation and Adviros's regulatory documents on the processing and protection of personal data;
  • organization of accounting, storage, and handling of media containing personal data;
  • identification of threats to the security of personal data during processing, and development of threat models based on them;
  • development of a personal data protection system based on the threat model;
  • testing the readiness and effectiveness of the use of information security tools;
  • segregation of user access to information resources and hardware/software for information processing;
  • registration and recording of actions of users of personal data information systems;
  • use of antivirus tools and personal data protection system recovery tools;
  • application, where necessary, of firewalls, intrusion detection systems, security analysis tools, and cryptographic information protection tools;
  • organization of access control to Adviros's premises, and security of premises with technical means for processing personal data.

12. Final Provisions

12.1. You may withdraw your consent to the processing of personal data, obtain any clarification regarding its processing, and correct any inaccuracies in your personal data by contacting us via email at compliance@mail.adviros.ru or using the feedback form in the "Contacts" section on the Site.

12.2. You may also submit any request in hard copy to any Adviros office in person or send it by mail via registered mail with return receipt requested. We will provide the requested information regarding the processing of your personal data within the time period established by law. You can find the addresses of Adviros offices on the Site in the "Contacts" section.

12.3. This Policy is valid indefinitely until replaced by a new version. The Policy may be amended from time to time to reflect possible changes in our processing processes. Therefore, when you use the Site, you should independently check the date of this Privacy Policy and review any changes that have been made since the last version.

The date of the last change and the current version are indicated at the beginning of the Policy.

The current version of the Policy is freely available on the Internet at adviros.ru.

12.4. Person responsible for data processing and protection: Director of Information Technology at Adviros LLC, A. Yudkin, address: 127055 Moscow, Novoslobodskaya St., 41. Phone: 8(495)9373435. Email: privacy@mail.adviros.ru.