Privacy Policy

Version dated: May 25, 2025

This personal data processing policy defines the procedure for processing personal data and measures to ensure the security of personal data taken by Dialog LLC, OGRN: 1107746822611, INN 7736622878, address: 108814, Vn.ter.g. Sosenskoye settlement, Kommunarka settlement, Bachurinskaya street, 13, floor 1, room 2 (hereinafter referred to as the Operator), in accordance with the requirements of Art. 18.1. Federal Law of July 27, 2006 No. 152-FZ “On Personal Data”.

1. The purpose of developing this Policy is to determine the categories of personal data processed by the Operator, as well as the basic principles that the Operator follows when processing personal data.

This policy regarding the processing of personal data (hereinafter referred to as the Policy) applies to information that the Operator receives about users of the website https://dialogist.ru/ and the Operator’s clients.

2. Definition of terms

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

“Blocking of personal data” — temporary cessation of processing of personal data (except for cases when processing is necessary to clarify personal data).

“Operator’s website” — https://dialogist.ru, (hereinafter — the Site).

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

“Depersonalization of personal data” — actions as a result of which it is impossible to determine, without the use of additional information, the ownership of personal data by a specific User or another subject of personal data.

“Personal data processing” — any action (operation) or set of actions (operations) performed with or without the use of automation tools with personal data, including: collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.

“Operator” — Dialog LLC, 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” — any information related directly or indirectly to a specific or determinable User of the Operator’s website.

“Personal data permitted for distribution by the personal data subject” — personal data, access to which is granted to an unlimited number of persons by the personal data subject by giving consent to the processing of personal data permitted by the personal data subject for distribution in the manner prescribed by the Law on Personal Data (hereinafter — personal data permitted for distribution).

“User” — any visitor to the Operator’s website.

“Client” — an individual with whom the Operator concludes or has concluded an agreement.

“Provision of personal data” — actions aimed at disclosing personal data to a specific person or a specific group of persons, including by filling out a personal data collection form on the Operator’s website.

“Consent to the processing of personal data” — actions confirming the consent of the personal data subject. Consent may be given in any form that allows confirmation of the fact of its receipt, including by putting a mark in the personal data collection forms on the Operator’s website.

“Dissemination of personal data” — any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or familiarizing an unlimited number of persons with personal data, including the publication of personal data in the media, posting in information and telecommunications networks or providing access to personal data in any other way.

“Cross-border transfer of personal data” — the transfer of personal data to the territory of a foreign state to a foreign government body, a foreign individual or a foreign legal entity.

“Destruction of personal data” — any actions as a result of which personal data are irrevocably destroyed with the impossibility of further restoration of the content of personal data in the personal data information system and (or) the destruction of tangible media of personal data.

3. Basic rights and obligations of the Operator

3.1. The Operator has the right to:

  • receive reliable information and/or documents containing personal data from the personal data subject;
  • if the personal data subject revokes consent to the processing of personal data, the Operator has the right to continue processing personal data without the consent of the personal data subject, provided that there are such grounds specified in the Personal Data Law;
  • independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of the obligations stipulated by the Personal Data Law and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.

3.2. The Operator is obliged to:

  • provide the personal data subject, at his request, with information concerning the processing of his personal data;
  • organize the processing of personal data in the manner established by the current legislation of the Russian Federation;
  • respond to requests and inquiries of personal data subjects and their legal 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 of this body, of the necessary information within the period established by the current legislation of the Russian Federation;
  • publish or otherwise provide unlimited access to this Policy regarding the processing of personal data;
  • take 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;
  • stop the transfer (distribution, provision, access) of personal data, stop processing and destroy personal data in the manner and cases stipulated by the Law on Personal Data;
  • fulfill other obligations stipulated by the Law on Personal Data.

4. Basic 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 for cases stipulated by federal laws. The information is provided to the personal data subject by the Operator in an accessible form, and it must not contain personal data related to other personal data subjects, except in cases where there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Law on Personal Data;
  • demand that the operator clarify his personal data, block or destroy it if the personal data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated purpose of processing, and also take measures provided by law to protect their rights;
  • put forward a condition of prior consent when processing personal data for the purpose of promoting goods, works and services on the market;
  • to revoke consent to the processing of personal data;
  • to exercise other rights provided for by the legislation of the Russian Federation.

4.2. Personal data subjects are obliged to:

  • provide the Operator with reliable data about themselves;
  • notify the Operator about clarification (update, change) of their personal data.

4.3. Persons who have provided the Operator with false information about themselves or information about another personal data subject without the latter’s consent shall be liable in accordance with Russian legislation.

5. List of User’s personal data processed by the Operator

5.1. The Operator processes User’s data that does not fall into the special category:

  • User’s last name, first name, patronymic;
  • User’s contact phone number;
  • Contact e-mail address (e-mail).

5.2. When using the Site Service, the User gives the Operator their consent to process personal data (specified in clause 5.1 of the Policy).

5.3. The Operator’s Site collects and processes anonymized data about visitors (including cookies) using Internet statistics services (Yandex-Metrica and others). Cookies are used in the manner and on the terms reflected in the Cookie Policy.

5.4. The above data are hereinafter referred to as Personal Data.

5.5. Subjects of personal data (Users, Clients) may refuse to provide their personal data. In this case, the Operator will not be able to implement the above-mentioned purposes for which the subject transfers their personal data.

5.6. The Operator does not process special categories of personal data. The processing of personal data permitted for distribution, from among the special categories of personal data specified in Part 1 of Article 10 of the Law on Personal Data, is permitted if the prohibitions and conditions stipulated by Article 10.1 of the Law on Personal Data are observed.

5.7. The transfer (distribution, provision, access) of personal data permitted for distribution by the subject of personal data must be terminated at any time at the request of the subject of personal data. The request must include the last name, first name, patronymic (if any), telephone number, email address or postal address of the subject of personal data, as well as a list of personal data whose processing is subject to termination. The personal data specified in this request may only be processed by the Operator to whom it is sent.

5.8. Consent to the processing of personal data permitted for distribution shall cease to be valid from the moment the Operator receives such a request.

6. Purposes of personal data processing

6.1. The User’s personal data are processed by the Operator for the following purposes:

  • Providing the User with access to services, information and/or materials contained on the Site;
  • Ordering/booking services by the User;
  • Establishing feedback with the User, including sending notifications, requests, confirmations regarding the use of the Site, booking and provision of services, processing orders (requests) and applications from the User;
  • Providing the User of the Site with customer and technical support in the event of problems related to the use of the Site;
  • Collecting and analyzing statistical information from the site.

6.2. The Operator has the right to send the User notifications about new products and services, special offers and various events. The User can always opt out of receiving informational messages by sending the Operator an email to e.panin@dialogist.ru with the subject line “Opt-out of notifications about new products and services and special offers”.

6.3. Anonymized data of Users collected using Internet statistics services are used to collect information about the actions of Users on the Site, improve the quality of the Site and its content.

7. Principles of personal data processing

7.1. Personal data shall be processed in accordance with the law and on a fair basis.

7.2. Personal data shall be processed only to achieve the objectives. Personal data shall not be processed in a manner that is incompatible with the purposes of collecting personal data.

7.3. Only personal data that meet the purposes of their processing shall be processed.

7.4. The content and volume of personal data processed shall correspond to the stated purposes of their processing. Excessive amounts of personal data processed in relation to the stated purposes of their processing shall not be allowed.

7.5. When processing personal data, the accuracy of personal data, their sufficiency, and, where necessary, relevance in relation to the purposes of personal data processing shall be ensured. The operator shall take the necessary measures and/or ensure their adoption to delete or clarify incomplete or inaccurate data.

7.6. Personal data shall be stored in a form that allows the subject of personal data to be identified, no longer than required by the purposes of processing personal data, unless the storage period for personal data is established by federal law, an agreement to which the subject of personal data is a party, beneficiary or guarantor. Processed personal data shall be destroyed or depersonalized upon achieving the purposes of processing or in the event of loss of the need to achieve these purposes, unless otherwise provided by federal law.

8. Legal grounds for processing personal data

8.1. The legal grounds for processing personal data by the Operator are:

  • coordination, conclusion, execution, modification or termination of agreements between the Operator and the User/Client;
  • federal laws, other regulatory legal acts in the field of personal data protection;
  • consent of Users to the processing of their personal data, to the processing of personal data permitted for distribution.

8.2. The Operator processes the User’s personal data only if they are filled in and/or sent by the User independently through special forms located on the Website or sent to the Operator by e-mail.

8.3. By filling in the relevant forms and/or sending their personal data to the Operator, the User expresses their consent to this Policy.

8.4. The Operator processes anonymized data about the User if this is permitted in the User’s browser settings (saving cookies and using JavaScript technology are enabled).

9. Use of metric programs

9.1. The Operator uses metric programs (for example, Yandex.Metrica) to collect information about the use of the Site, such as the frequency of visits to the Site by users, pages visited, and sites that users visited before going to this Site. Metric programs collect only the IP addresses assigned to you on the day of visiting this Site, but not the name or other identification information (anonymous data).

9.2. Metric programs place a permanent cookie in the User’s web browser to identify him/her as a unique user the next time he/she visits the Operator’s Site. This cookie cannot be used by anyone other than the relevant Metric service that placed the cookie. Information collected using the cookie is transmitted to and stored on the servers of the Metric service (for example, Yandex.Metrica).

9.3. The Operator uses information received through the Metric service only for the purpose of improving services on the Operator’s Site. The Operator does not combine information received through the Metric Services with the User’s personal information.

9.4. The Metric Services’ ability to use and transfer information about visits to this Site to third parties is limited by the Metric Services’ Privacy Policy. The User can disable their cookies in their browser (in the browser settings). However, this may affect the operation of some of the Site’s functions.

9.5. By using the Operator’s Site, the User agrees to the processing of data about them by the Metric Services in the manner and for the purposes specified above and in the text of this Privacy Policy.

10. Procedure, conditions and terms for processing personal data

10.1. The Operator processes personal data in the following ways:

  • Non-automated processing of personal data;

10.2. The list of actions performed by the operator with the User’s personal data: collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, distribution (including transfer), depersonalization, blocking, destruction/deletion, as well as any other actions in accordance with the current legislation of the Russian Federation.

10.3. Personal data is processed with the consent of the subject of personal data to the processing of his personal data.

10.4. The User makes a decision on the provision of his personal data and gives Consent freely, of his own free will and in his own interests.

10.5. Consent is given in any form that allows confirming the fact of its receipt. In cases provided for by the legislation of the Russian Federation, Consent is drawn up in writing.

10.6. The processing of personal data is necessary for the performance of an agreement to which the personal data subject is a party or a beneficiary, as well as for concluding an agreement on the initiative of the personal data subject or an agreement under which the personal data subject will be a beneficiary.

10.7. The 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 that the rights and freedoms of the personal data subject are not violated.

10.8. The security of personal data processed by the Operator is ensured by implementing legal, organizational and technical measures necessary to fully comply with the requirements of the current legislation in the field of personal data protection.

10.9. The Operator ensures the safety of personal data and takes all possible measures to prevent unauthorized persons from accessing personal data. When processing personal data, the Operator ensures the confidentiality of personal data.

10.10. The User agrees that the Operator has the right to transfer personal data to third parties, in particular, postal service organizations, telecommunications operators, solely for the purpose of fulfilling the User’s requests.

10.11. The User’s personal data may be transferred to authorized government bodies only on the grounds and in the manner established by applicable law.

10.12. The period for processing personal data is determined by the achievement of the purposes for which the personal data were collected, unless another period is provided for by the agreement or applicable law. The User may at any time revoke their consent to the processing of personal data by sending the Operator a notice via e-mail to the Operator’s e-mail address e.panin@dialogist.ru with the subject line “Revocation of consent to the processing of personal data”.

10.13. All information collected by third-party services, including payment systems, communication tools and other service providers, is stored and processed by the specified persons (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject is obliged to familiarize themselves with the specified documents in a timely manner. The operator shall not be liable for the actions of third parties, including the service providers specified in this paragraph.

10.14. The prohibitions established by the personal data subject on the transfer (except for providing access), as well as on the processing or conditions of processing (except for obtaining access) of personal data permitted for distribution, shall not apply in cases of processing personal data in state, public and other public interests determined by the legislation of the Russian Federation.

10.15. The operator stores personal data in a form that makes it possible to identify the personal data subject for no longer than required for the purposes of processing personal data, unless the storage period for personal data is established by federal law, an agreement to which the personal data subject is a party or beneficiary.

10.16. The condition for termination of personal data processing may be the achievement of the purposes of personal data processing, the expiration of the consent of the personal data subject or the withdrawal of consent by the personal data subject, as well as the detection of unlawful processing of personal data.

11. Cross-border transfer of personal data

Cross-border transfer of data is not carried out.

12. Confidentiality of personal data

The Operator and other persons who have gained access to personal data are obliged not to disclose to third parties or distribute personal data without the consent of the subject of personal data, unless otherwise provided by federal law.

13. Final provisions

If you have any questions, you can get any clarifications on the processing of your personal data by writing to the Operator by e-mail: e.panin@dialogist.ru.

The Operator has the right to make changes to this Policy without the consent of the User.

The new Privacy Policy comes into force from the moment it is posted on the Site, unless otherwise provided by the new version of the Privacy Policy.

The Policy is valid indefinitely until it is replaced by a new version and is posted on the Internet at: https://dialogist.ru/en/privacy-policy-2/. In the event that individual terms of the Policy become irrelevant, the Policy remains valid with respect to all other terms.