Data ProcessingPublished: May 5, 2025This document defines the policy of Individual Entrepreneur Sofya Fridonovna Anikanova (hereinafter referred to as the “Operator”) regarding the processing of personal data and measures to ensure the security of personal data on the Website:
https://tsa-transfer.com (hereinafter referred to as the “Policy”).
The Policy applies to all personal data that the Operator may receive from a personal data subject.
1. Terms and Definitions:Operator – Individual Entrepreneur Sofya Fridonovna Anikanova.
Website – located at:
https://tsa-transfer.comUser – a personal data subject.
Personal Data – any information relating directly or indirectly to an identified or identifiable User.
Processing – any action/operation or a set of actions/operations performed on Personal Data using automation tools or without using such tools.
- 2. General Provisions:General provisions:
2.1. This Policy defines the procedure by which the Operator processes Users’ personal data and ensures the security and confidentiality of such data.
2.2. The Policy specifies:
2.2.1. what personal data the Operator receives and how it is used;
2.2.2. the main rights of Users as personal data subjects;
2.2.3. the methods, сроки of processing and storage of personal data;
2.2.4. the procedure for the destruction of personal data.
2.3. The Operator processes Personal Data on the basis of:
2.3.1. the User’s consent by accepting the Offer published at:
https://tsa-transfer.com/publicoffer2.3.2. for the purpose of performance of a service agreement;
2.3.3. consent to marketing mailings provided by filling out the subscription form on the Website.
2.3.2. for the purpose of performing a service agreement;
2.3.3. consent to receive promotional mailings provided by filling out a subscription form on the Website.
3.Processing of Personal Data:
3.1. Types of Processing used by the Operator: collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (provision), blocking, deletion, destruction.
3.2. The User agrees to the Policy when submitting their Personal Data to the Operator, including at the moment of:
3.2.1. filling out forms on the Website;
3.2.2. contacting via the phone number specified on the Website;
3.2.3. contacting via email;
3.2.4. contacting via messengers, including through a Telegram bot or Telegram Web App;
3.2.5. visiting the Website;
3.2.6. filling out forms for surveys and questionnaires;
3.3.7. participating in contests and promotions.
3.3. The Personal Data processed by the Operator is not biometric and does not belong to special categories of Personal Data.
3.4. The Operator processes the following Personal Data:
Purpose | Personal Data | Category | Processing Period | Destruction Method |
Conclusion of a contract based on an offer* and fulfillment of contractual obligations | first name, last name; phone number; Telegram username; email address | general | until the purpose is achieved or consent is withdrawn | deletion from the Operator’s database |
Analysis of User behavior on the Website | date, time and number of visits, information about visited pages, transitions from other resources, selected pricing plans | general | until the purpose is achieved or consent is withdrawn | deletion from the Operator’s database |
Ensuring the operation of the Website | IP address, location data, cookie files, type of operating system, browser type, geographic location, Internet service provider | general | until the purpose is achieved or consent is withdrawn | deletion from the Operator’s database |
Conducting marketing mailings | first name, last name; phone number; Telegram username; email address first name, last name; phone number; Telegram username; email address | general | until the purpose is achieved or consent is withdrawn | deletion from the Operator’s database |
*offer
https://tsa-transfer.com/publicoffer 3.5. Methods by which the Operator collects Personal Data:
3.5.1. through Website forms completed by the User;
3.5.2. via email, messengers, and phone;
3.5.3. automatically using technologies, web protocols, and “cookie” files.
3.6. The Operator stores Personal Data:
3.6.1. exclusively on properly protected electronic media;
3.6.2. using databases located within the territory of the Russian Federation;
3.6.3. on the Website using automated processing, except where non-automated Processing is required to comply with the legislation of the Russian Federation;
3.6.4. for all purposes from the moment consent is given until the moment consent is withdrawn or for as long as required by the purposes of Processing.
4.Access to Personal Data:
4.1. The Operator provides access to Personal Data only to its authorized employees.
4.2. The Operator does not disclose or provide Users’ Personal Data to third parties without their consent, except in the following cases:
4.2.1. for the purpose of preventing and suppressing unlawful actions of the User and protecting the legitimate interests of the Operator and third parties, as well as in cases предусмотренных by the legislation of the Russian Federation;
4.2.2. upon a reasoned request of judicial authorities, state security bodies, the prosecutor’s office, the police, investigative authorities, and other bodies and organizations in cases established by regulatory legal acts binding for execution.
5.Transfer of Personal Data to Third Parties:
5.1. Subject to the User’s consent, the Operator has the right to transfer (provide) the User’s personal data to the following counterparties of the Operator (hereinafter referred to as Third Parties):
Name | Legal information | Purpose of transfer |
LLC “AmoCRM” | TIN 9709001353 OGRN 1177746497763 address: 115093, Moscow, Lyusinovskaya St., 38 | work with the client database |
LLC “Unisender Smart” | TIN 9731091240 OGRN 1227700213180 address: 127015, Moscow, Bolshaya Novodmitrovskaya St., 23 | email mailing service |
LLC “Yandex” | TIN 7736207543 OGRN 1027700229193 address: 119021, Moscow, Lev Tolstoy St., 16 | web analytics services, surveys |
LLC “Yandex.Cloud” | TIN 7704458262 OGRN 1187746678580 address: 119021, Moscow, Lev Tolstoy St., 16 | data storage |
5.2. The User has the right to prohibit the Operator from transferring their personal data to Third parties.
5.3. Transfer of personal data is terminated upon the User’s request. Such request must include: email address and a list of personal data to be stopped from processing.
6.Updating and destruction of Personal Data:
6.1. The Operator updates Personal Data if the fact of their inaccuracy is confirmed.
6.2. The Operator destroys Personal Data in the following cases:
6.2.1. if there is a threat to the security of the Website;
6.2.2. upon expiration of the storage period for Personal Data;
6.2.3. upon achievement of the purposes of Personal Data processing;
6.2.4. upon the User’s request.
6.3. The Operator deletes all information received from the User if the User withdraws their consent to Processing. From that moment, the right to use the Website shall be terminated.
7.Guarantees and rights of the User:
7.1. The User guarantees that:
7.1.1. the Personal Data provided is accurate, up-to-date, and does not violate the legislation of the Russian Federation;
7.1.2. if the provided Personal Data relates to a third party, the User has obtained the consent of such third party to transfer the Personal Data to the Operator for Processing.
7.2. The User has the following rights:
7.2.1. right of access — the User has the right to request a copy of the personal data held by the Operator;
7.2.2. right to rectification — the User has the right to request that the Operator correct inaccurate or incomplete personal data;
7.2.3. right to withdraw consent — the User has the right to withdraw their consent to data processing;
7.2.4. right to erasure — the User has the right to request deletion of personal data held by the Operator relating to the User, except in cases where the Operator is required to retain such data by law;
7.2.5. other rights provided for by the Federal Law “On Personal Data”.
8.Obligations of the Operator:
8.1. The Operator shall:
8.1.1. provide, upon the User’s request, information regarding Processing or a reasoned refusal;
8.1.2. take necessary and sufficient measures to comply with the obligations предусмотренных by the legislation of the Russian Federation;
8.1.3. upon the User’s request, update the processed Personal Data, block or delete it if it is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of Processing;
8.1.4. ensure the lawfulness of Processing. If it is not possible to ensure the lawfulness of Processing, the Operator shall, within a period not exceeding 10 business days from the date of detection of unlawful Processing, destroy or ensure the destruction of Personal Data;
8.1.5. within a period not exceeding 30 days from the date of receipt of the User’s withdrawal of consent, cease Processing and destroy Personal Data, if its retention is no longer required for the purposes of Processing. An exception applies where Processing may be continued in accordance with the legislation of the Russian Federation.
8.2. To protect Personal Data, the Operator uses necessary legal, organizational, and technical measures in accordance with the requirements of the Federal Law “On Personal Data”
9.Requests of the Personal Data Subject:
9.1. The User or their representative has the right to send a request to the Operator, including withdrawal of consent to Processing, in the form of an electronic document.
9.1.1. by email:
tsa-transfer@mail.ru9.1.2. via Telegram:
https://t.me/tsa_transfer9.2. A request for withdrawal of Consent must contain:
9.2.1. information confirming the User’s participation in relations with the Operator: email address, surname, first name;
9.2.2. details of the representative and confirmation of their authority (when submitted by a representative);
9.2.3. the signature of the User (or representative).
9.3. The Operator shall review the request and provide a response within 10 business days from the date of receipt.
9.4. All correspondence received by the Operator is considered information of restricted access and shall not be disclosed without the written consent of the User.
10.Final provisions:
10.1. This Policy applies exclusively to the Website, Telegram bot, or Telegram Web App of the Operator and does not apply to other internet resources.
10.2. This Policy applies to all Personal Data received by the Operator from Users.
10.3. The Operator shall not be liable for the actions of third parties who have gained access to the User’s Personal Data due to the User’s fault.
10.4. The Operator does not verify:
10.4.1. the legal capacity of the User;
10.4.2. the accuracy of the Personal Data provided by the User.
10.5. The Operator has the right to amend this Policy. The new version of the Policy shall come into force from the moment of its publication.
10.6. If the User continues to use the Website after the new version of the Policy comes into force, this shall mean that the User has agreed to the terms of the new version.
11. Operator details:Sofya Fridonovna Anikanova
OGRNIP 321070000003643
INN 071300930701
Email:
tsa-transfer@mail.ruPolicy URL:
https://tsa-transfer.com/policyData Controller:
Individual Entrepreneur Sofya Fridonovna Anikanova
OGRNIP: 321070000003643
INN: 071300930701
Email: tsa-transfer@mail.ru
This Policy is governed by the laws of the Russian Federation.