This is a courtesy translation. The legally binding document is the Russian version published at spgsales.ru/soglasie/. Consent is given under Russian law, and in the event of any discrepancy between the two texts, the Russian version prevails. Section numbering is identical in both versions.
This consent to the processing of personal data (hereinafter — the "Consent") is executed as a separate document in accordance with Article 9 of Federal Law No. 152-FZ of 27 July 2006 "On Personal Data". The requirement to execute consent separately from other documents signed or confirmed by the data subject has been in force since 1 September 2025 (Federal Law No. 156-FZ of 24 June 2025).
I, the data subject, acting freely, of my own will and in my own interest, give Individual Entrepreneur Nune Ashotovna Oganyan (TIN 682710537390, ОГРНИП 324774600810801, address: 5A bldg. 1, Polyany St., Moscow; hereinafter — the "Operator") my specific, informed, conscious and unambiguous consent to the processing of my personal data on the terms set out below.
1. The data subject. The surname, first name and patronymic (if any) and the contact details of the data subject are provided by the data subject when giving this Consent — when completing a feedback form on the website spgsales.ru.
2. The Operator obtaining the consent. Individual Entrepreneur Nune Ashotovna Oganyan, TIN 682710537390, ОГРНИП 324774600810801, address: 5A bldg. 1, Polyany St., Moscow. Contact for data subject requests: info@spgsales.ru, +7 (993) 246-36-15.
3. Purpose(s) of processing the personal data.
- Receiving, registering and reviewing enquiries submitted through the forms of the website spgsales.ru.
- Preparing and concluding a service contract at the initiative of the data subject, and contacting the data subject regarding their enquiry.
- Reviewing an application for a vacancy with the Operator — if the enquiry is submitted through the job application form.
- Measuring website traffic by means of web analytics — only where I have given separate consent to the use of analytics cookies.
Processing is carried out solely for the purposes stated.
4. List of personal data to which consent is given.
| What I fill in | Personal data |
|---|---|
| Callback, consultation, project brief, quiz | name; telephone number; email address; the content of the enquiry and my answers to the questions in the form |
| Job application | name; telephone number; email address; the information I have stated in the attached CV |
| Technical information | anonymised device and network address identifier; the address of the page from which the enquiry was sent; date and time of the enquiry |
The list is limited to the data necessary to achieve the purposes set out in clause 3 (the data minimisation principle). Special categories of personal data and biometric personal data are not processed.
The network address and the device identifier are stored solely in anonymised form — by irreversible transformation using a secret key; the original values are not stored. The page address is stored without query parameters.
5. Operations performed on the personal data and methods of processing. Collection, recording, systematisation, accumulation, storage, updating, retrieval, use, transfer (provision of, and access to, the data) to the persons listed in clause 6, anonymisation, blocking, deletion and destruction. Processing is automated, with transfer over the Internet. The database into which the personal data of citizens of the Russian Federation is entered is located in the territory of the Russian Federation — in data centres at 74 km MKAD, bldg. 3, Khimki, Moscow Region and at 42 bldg. 5, Volgogradsky Prospekt, Moscow.
6. Persons processing the data on the Operator's instructions, and recipients of the personal data.
6.1. Processing on the Operator's instructions (Part 3, Article 6 of Federal Law No. 152-FZ) has been entrusted to:
- Individual Entrepreneur Evgeniy Samuelovich Boateng, TIN 774319428786, ОГРНИП 318774600624112, address: 71 Smolnaya St., Moscow — receipt of enquiries from the website forms, their storage and transfer to the Operator, delivery of email notifications, and recording of enquiries in the customer relationship management system.
6.2. Persons engaged for processing with the Operator's consent:
- LLC "Hosting-Technologies", TIN 7721833428, address: 2/1 bldg. 2, 1st Frezernaya St., Moscow 109202 — hosting of the website technical facilities, receipt and storage of enquiries (data centre);
- LLC "ADMINVPS", TIN 7708257630, address: 19 Leninskaya Sloboda St., Moscow 115280 — hosting of the mail server through which notifications of enquiries are delivered (data centre);
- JSC "amoCRM", TIN 7709477879, address: 38 Lyusinovskaya St., Moscow 115093 — recording of enquiries in the customer relationship management system;
- LLC "Yandex", TIN 7736207543, address: 16 Lva Tolstogo St., Moscow 119021 — protection of forms against automated submissions; web analytics where I have consented to analytics cookies.
6.3. The persons listed process the data under a contract with the Operator, in compliance with the requirements of Federal Law No. 152-FZ and with an obligation to maintain confidentiality. All of these persons are located in the territory of the Russian Federation. The personal data is not transferred to any other person except in the cases provided for by law.
7. Period for which the consent is valid, and the conditions for its termination. This Consent is valid for 3 (three) years from the date of my last enquiry and, in any event, until I withdraw it. Once the purposes of processing have been achieved, the period has expired or the consent has been withdrawn, the personal data is subject to destruction unless there are other lawful grounds for processing it.
8. Procedure for withdrawing consent. I may withdraw this Consent at any time by sending the Operator a written request using the contact details given in clause 2 — in particular, by email to info@spgsales.ru. Upon receiving the withdrawal, the Operator ceases processing the personal data and destroys it within the period established by law, except where processing may continue on the grounds provided for by Part 2 of Article 9 and by Articles 6, 10 and 11 of Federal Law No. 152-FZ.
9. Dissemination and cross-border transfer. Dissemination of the personal data, that is, its disclosure to an indefinite group of persons, is not carried out. Cross-border transfer of the personal data is not carried out.
10. Rights of the data subject and procedure for appeal. In giving this Consent, I retain the right to: obtain information about the processing of my personal data to the extent provided for by Part 7 of Article 14 of Federal Law No. 152-FZ; obtain access to my personal data; demand that it be updated, blocked or destroyed if it is incomplete, out of date, inaccurate, unlawfully obtained or not necessary for the stated purpose; and withdraw this Consent. Requests are to be sent to info@spgsales.ru; the Operator responds within 10 working days of receiving the request. The Operator's acts may be appealed against to Roskomnadzor — the authority competent for the protection of the rights of data subjects — or through the courts.
11. Informational and promotional messages. Consent to receive informational and promotional messages is given by a separate tick box in the form, is voluntary, and is not a condition for the review of an enquiry or for the provision of services. Declining such messages does not affect the review of an enquiry.
12. Confirmation. I confirm that I have read the Operator's Privacy Policy on the processing of personal data, that my rights as a data subject — including the right to withdraw consent — have been explained to me, and that this consent is given by me voluntarily.
13. How consent is given and recorded. When completing a form on the website, consent is given by an affirmative action — ticking the box next to the link to this Consent and to the Privacy Policy. The box is not pre-ticked: it is ticked by the data subject. The fact that consent was given, its date and time, and the revision of this document are recorded in the Operator's information system. Such a record is proper confirmation that consent was obtained in a form allowing the fact of its receipt to be confirmed (Part 1, Article 9 of Federal Law No. 152-FZ).
Registration number in the register of personal data operators: 77-25-309337 of 20 June 2025. The entry can be verified in the Roskomnadzor register (pd.rkn.gov.ru/operators-registry/operators-list/) by TIN 682710537390.
Revision of 4 August 2026.