General
The website owner and personal-data operator is SealSoft LLC (ООО «СеалСофт»), INN 7713506917, OGRN 1037739855669, KPP 771701001, address: 129226, Moscow, Wilhelm Pieck St., 4A, 36, Russia. This Policy applies to the presentation-request form, related correspondence, data-subject requests and the technical operation of aikantorovich.ru. Personal-data contact: integrator@crystalfund.ru.
Individuals and data
Data subjects are website visitors and representatives of organisations submitting an enquiry. The operator processes only information necessary for the stated purposes.
- name; organisation; telephone; business email; and challenge comment, to the extent provided by the visitor;
- enquiry topic, page address and source, language, submission date and time, and consent version;
- IP address, session identifier, CSRF token and technical HTTP request parameters required to operate and protect the form.
Purposes and legal grounds
Form data is processed under separate consent to answer the enquiry, send the requested presentation and arrange a possible next contact about that enquiry. If communications progress to entering into or performing a contract, the relevant contractual and statutory grounds apply. Technical data is used to operate the website, protect the form and prevent abuse in pursuit of the operator's rights and legitimate interests, provided data-subject rights and freedoms are not infringed. Processing required by law is limited to the legally required scope.
Operations and methods
The operator may collect, record, organise, accumulate, store, update, retrieve, use, disclose to parties processing data on the operator's instructions, restrict, delete and destroy data by automated and non-automated means. The operator does not make decisions producing legal effects solely through automated processing, does not profile visitors and does not disseminate form data to an unlimited audience.
Recipients and processors
The enquiry is delivered to integrator@crystalfund.ru. If the operator appoints another party for hosting, mail delivery, backup or website protection, that party acts only under contract and the operator's instructions and must comply with confidentiality, localisation and security requirements. Current information about that party and its instructions is provided to a data subject as required by law.
Localisation and international transfers
When collecting personal data of Russian citizens online, the operator ensures recording, organisation, accumulation, storage, update and retrieval using databases located in the Russian Federation. An international transfer does not begin unless the separate Roskomnadzor notification procedure, foreign-recipient assessment, lawful-ground requirements and a corresponding Policy update have been completed where such transfer is required.
Retention and destruction
Enquiry data and related correspondence are retained until the response and initial discussion are complete, but no longer than 90 calendar days from submission. If a separate contractual or statutory ground arises during that period, the data moves to that process and its retention rules. Once the purpose is achieved or consent is withdrawn, the data is destroyed within 30 calendar days unless another lawful ground requires continued processing. If destruction cannot be completed within that period, the data is restricted and destroyed within six months unless law sets another period. The technical session lasts until the browser is closed; the related CSRF token lasts no longer than two hours.
Rights and response periods
A data subject may obtain information about processing, demand correction, restriction, cessation or destruction, and withdraw consent. Information on whether and how data is processed is provided within ten business days; this period may be extended by no more than five business days with a reasoned notice. Verified inaccurate data is corrected, and unlawfully obtained or unnecessary data is destroyed, within no more than seven business days. A cessation request is completed within ten business days, subject to a reasoned extension of no more than five business days, unless another lawful ground applies.
Withdrawal, requests and complaints
Requests should be sent to integrator@crystalfund.ru under the Data-subject request procedure. Withdrawal does not affect prior lawful processing. Where another lawful ground applies, the operator may continue only within that ground's scope. A data subject may complain about the operator's action or inaction to Roskomnadzor or a court.
Minors and sensitive data
The form is intended for adult representatives of organisations. It should not be used to submit minors' data, special-category data, health or intimate-life information, political, religious or philosophical beliefs, or biometric data. If the operator receives such information without a purpose and lawful ground, processing will be restricted and the data destroyed in accordance with the applicable procedure.
Security and Roskomnadzor notification
The operator applies necessary legal, organisational and technical safeguards, limits access, maintains confidentiality, protects sessions and channels, detects incidents and organises recovery. The operator fulfils its Roskomnadzor notification obligation before processing begins through the live form and keeps the notification information current. If an incident results in a violation of data-subject rights, the operator notifies Roskomnadzor within the statutory periods.
Policy changes
The current version is available on this page. Changes to purposes, data, recipients, periods, database locations, international transfers or analytics are published before the new processing begins and, where required, reflected in the Roskomnadzor notification and renewed consent.