PRIVACY POLICY
for personal data of users of https://itexia.ru/
ITEXIA JSC
Version of 12 October 2026
1. General provisions
1.1. This Privacy Policy for personal data of website users (the “Policy”) has been prepared to meet Article 18.1 of Federal Law No. 152-FZ of 27 July 2006 “On Personal Data” (the “Personal Data Law”) and other regulatory acts of the Russian Federation on the protection and processing of personal data.
1.2. Joint-Stock Company ITEXIA (ITEXIA JSC), INN 2310238590, OGRN 1242300056910, registered address: 350000, Krasnodar Krai, Krasnodar Urban District, Krasnodar, 41 Ordzhonikidze St. (the “Operator”), protects the personal data it processes from unauthorised access and disclosure, unlawful use or loss, in accordance with the laws of the Russian Federation.
1.3. The Policy is a publicly available document and applies to the website on the Internet at https://itexia.ru/ (the “Website”).
1.4. The Policy does not apply to third-party websites and services that the User may reach through links placed on the Website.
1.5. The Policy sets general requirements and rules, binding on the Operator’s employees involved in personal data processing, for working with information that contains personal data of data subjects who use the Website.
1.6. The Policy does not cover the security of personal data that constitutes a state secret of the Russian Federation.
1.7. Terms contained in Article 3 of the Personal Data Law are used in this Policy with the meanings given in that Federal Law.
1.8. This Policy also uses the following terms:
Data subject, User/Visitor of the website — an individual who visits the Website and/or uses the information, materials, forms and services published on it.
Website — the software, information and technical means that provide access to the Operator’s information over the Internet at https://itexia.ru/.
Confidentiality of personal data — the duty of the Operator, or of another person who has gained access to personal data, not to disclose it to third parties and not to distribute personal data without the data subject’s consent or another lawful basis.
Director — the sole executive body of the Operator.
1.9. Main rights and duties of the Operator.
1.9.1. The Operator has the right to:
independently determine the set and list of measures necessary and sufficient to perform the duties provided for by the personal data laws of the Russian Federation;
entrust the processing of personal data to other persons in compliance with the laws of the Russian Federation;
obtain from the User reliable information and documents containing personal data that are necessary for the purposes set out in this Policy;
if the User withdraws consent to processing, or demands that processing stop, continue processing without the User’s consent where the law provides a basis to do so;
exercise other rights provided for by the laws of the Russian Federation.
1.9.2. The Operator shall:
organise the processing of personal data in accordance with the laws of the Russian Federation;
process personal data only for the lawful purposes defined in this Policy;
provide the User, at the User’s request, with information about the processing of the User’s personal data;
respond to enquiries and requests from Users and their representatives within the time limits set by law;
notify the authority authorised to protect the rights of data subjects of the required information in the cases and within the time limits set by law;
take the necessary legal, organisational and technical measures to protect personal data;
stop processing and transfer, and destroy personal data, in the cases provided for by the laws of the Russian Federation;
perform other duties provided for by the personal data laws of the Russian Federation.
1.10. Main rights and duties of the User.
1.10.1. The User has the right to:
receive information about the processing of the User’s personal data;
demand that personal data be updated, blocked or destroyed if it is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing;
withdraw consent to the processing of personal data;
demand that processing of personal data stop in the cases provided for by law;
challenge the Operator’s actions or failure to act before the authority authorised to protect the rights of data subjects, or in court;
exercise other rights provided for by the laws of the Russian Federation.
1.10.2. The User shall:
provide the Operator with accurate personal data;
promptly report changes to the personal data provided, where that is necessary for the purposes of processing.
1.11. Liability for breach of the laws of the Russian Federation on the processing and protection of personal data is determined in accordance with the laws of the Russian Federation.
2. Purposes and legal bases of personal data processing
2.1. Processing of personal data is limited to the achievement of specific, pre-defined and lawful purposes. Processing of personal data that is incompatible with the purposes for which it was collected is not allowed.
2.2. The Operator processes only the personal data that is necessary to achieve the relevant purposes of processing.
2.3. The Operator may process personal data for the following purposes:
contacting the User;
handling requests and enquiries sent through the Website;
providing consultations on the Operator’s services;
providing customer and technical support;
preparing commercial proposals;
preparing, concluding, performing and terminating civil-law contracts;
providing services to develop, support, technically audit and improve websites and other information systems;
promoting the Operator’s goods, works and services;
sending informational and advertising messages where the User has given the relevant consent;
collecting and analysing statistical data on how the Website works, in order to improve its functionality, content, usability and security;
keeping the Website working and secure;
performing the Operator’s duties under the laws of the Russian Federation.
2.4. Personal data is processed in accordance with, in particular, the following regulatory acts:
the Constitution of the Russian Federation;
the Civil Code of the Russian Federation;
Law of the Russian Federation No. 2300-I of 7 February 1992 “On Protection of Consumer Rights”;
Federal Law No. 149-FZ of 27 July 2006 “On Information, Information Technologies and Protection of Information”;
Federal Law No. 152-FZ of 27 July 2006 “On Personal Data”;
Federal Law No. 38-FZ of 13 March 2006 “On Advertising”;
Decree of the Government of the Russian Federation No. 1119 of 1 November 2012;
Order of the FSTEC of Russia No. 21 of 18 February 2013;
other regulatory acts of the Russian Federation applicable to the Operator’s activities.
2.5. The legal bases for processing personal data are:
the data subject’s consent;
the need to process data in order to enter into a contract at the initiative of the data subject, or to perform a contract to which the data subject is a party or a beneficiary;
the need to process data in order to perform the Operator’s duties under the laws of the Russian Federation;
the need to process data in order to exercise the rights and legitimate interests of the Operator or third parties, provided that the rights and freedoms of the data subject are not infringed;
other bases provided for by the laws of the Russian Federation.
3. Scope and categories of personal data processed
3.1. The content and scope of the personal data processed correspond to the stated purposes of processing and must not be excessive in relation to those purposes.
3.2. The Operator may process the following personal data of Users, clients, potential clients, counterparties and representatives of counterparties:
surname, first name and patronymic;
phone number;
email address;
organisation name;
job title;
INN of the organisation or individual entrepreneur;
information contained in the User’s requests and enquiries;
information needed to prepare, conclude and perform a contract;
technical information about interaction with the Website;
IP address;
information from cookie files;
information about the browser, operating system and device;
date and time of the visit;
addresses of pages visited;
the source of the visit;
other technical data sent automatically when the Website is used.
3.3. The Operator does not intentionally process special categories of personal data concerning racial or ethnic origin, political views, religious or philosophical beliefs, health or intimate life.
3.4. The Operator does not process biometric personal data for the purpose of identifying the data subject, unless the law and a separate lawful basis expressly provide for such processing.
3.5. Personal data is mainly received directly from the User, or is sent automatically by technical means when the Website is used.
4. Procedure and conditions of personal data processing
4.1. The Operator processes personal data with automation, without automation, and also by mixed means.
4.2. The Operator may carry out the following actions with personal data:
collection;
recording;
systematisation;
accumulation;
storage;
updating (refreshing, changing);
retrieval;
use;
transfer (provision, access) in the cases provided for by law;
blocking;
deletion;
destruction.
4.3. Personal data is processed with the data subject’s consent, or where another legal basis is provided for by the laws of the Russian Federation.
4.4. Access to personal data is given only to employees and other authorised persons of the Operator who need that access to perform their job or contractual duties.
4.5. The Operator does not distribute personal data to an indefinite number of persons without a separate consent of the data subject, unless a federal law expressly provides otherwise. Where personal data must be distributed, the Operator obtains a separate consent to the processing of personal data that the data subject has permitted to be distributed, in accordance with Article 10.1 of Federal Law No. 152-FZ.
4.6. Personal data is transferred to state bodies and other authorised organisations in the cases and in the manner provided for by the laws of the Russian Federation.
4.7. The Operator takes the necessary legal, organisational and technical measures to protect personal data from unlawful or accidental access, destruction, alteration, blocking, copying, provision, distribution and other unlawful actions.
4.7.1. To keep personal data secure, the Operator in particular:
identifies threats to the security of personal data;
applies the necessary organisational and technical protection measures;
adopts local regulations on the processing and protection of personal data;
appoints a person responsible for organising the processing of personal data, in the cases provided for by law;
restricts access to personal data;
monitors the protection measures taken;
takes measures to detect and prevent unauthorised access;
ensures that personal data can be restored in the cases provided for;
trains employees who are allowed to process personal data;
takes other measures provided for by law.
4.8. Personal data is stored in a form that makes it possible to identify the data subject for no longer than the purposes of processing require, unless a different storage period is set by federal law or by a contract.
4.9. The processing period is determined by the achievement of the purposes of processing, the expiry of the consent, or the occurrence of another ground for stopping processing that is provided for by law.
4.10. If a data subject demands that processing of personal data stop, the Operator stops that processing within the time limits set by the laws of the Russian Federation, except where the Operator is entitled to continue processing without the data subject’s consent.
4.11. When collecting personal data of citizens of the Russian Federation over the Internet, the Operator records, systematises, accumulates, stores, updates and retrieves personal data using databases located in the Russian Federation, except for the exceptions provided for by law.
4.12. The Operator ensures the confidentiality and security of personal data in accordance with the laws of the Russian Federation.
4.13. The User may refuse advertising and informational mailings by using the unsubscribe function or by sending the relevant request to info@itexia.ru.
4.14. The Operator does not transfer personal data across borders.
4.15. Use of analytics tools and cookies
4.15.1. To analyse how Users behave on the Website, to improve the quality of its operation and content, and to analyse the effectiveness of advertising materials, the Website uses analytics tools (web analytics services). When the Website is used, information sent by the User’s browser may be processed automatically, including the IP address, cookie data, browser information, technical characteristics of hardware and software, the date and time of access, the addresses of requested pages, the source of the visit and other similar technical information.
4.15.2. The Website uses the following analytics tools:
Yandex Metrica, provided by Yandex LLC;
Top.Mail.Ru, provided by VK LLC;
Roistat, provided by Business Analytics LLC.
4.15.3. Information received through analytics tools is used by the Operator to analyse Website traffic, Users’ actions, the effectiveness of individual pages and advertising materials, to find technical problems and to improve the Website’s functionality.
4.15.4. The User may restrict or prohibit the use of cookies in the browser settings.
4.15.5. Restricting or disabling cookies may cause individual Website functions to work incorrectly.
4.16. Transfer of personal data and entrusting processing to third parties
4.16.1. In order to keep the Website and the Operator’s business running, personal data may be transferred, or its processing entrusted, to the following persons:
Limited Liability Company “Yandex”, INN: 7736207543. Address: 119021, Moscow, 16 Leo Tolstoy St. Purpose: collection and analysis of statistical data to improve the operation of the Operator’s Website.
Limited Liability Company “VK”, INN: 7743001840. Address: 125167, Moscow, 39 Leningradsky Prospekt, building 79. Purpose: collection and analysis of statistical data to improve the operation of the Operator’s Website.
Limited Liability Company “1C-Bitrix”, INN: 7717586110. Address: 109544, Moscow, 2 Entuziastov Blvd., 13th floor, rooms 8–19. Purpose: operation of the information systems used by the Operator, interaction with Users, and promotion of the Operator’s goods, works and services.
Limited Liability Company “Business Analytics”, INN: 7709973919. Address: 109004, Moscow, Tagansky inner-city municipal district, 23A Alexander Solzhenitsyn St., building 1, premises III, room 1. Purpose: collection and analysis of statistical data, analysis of advertising effectiveness, and improvement of the operation of the Operator’s Website.
4.16.2. Personal data is transferred to those persons, and processing is entrusted to them, only to the extent necessary for the relevant purpose of processing and where a legal basis provided for by law exists.
4.17. Persons who process Users’ personal data on the Operator’s instructions shall follow the principles and rules of personal data processing, ensure the confidentiality and security of personal data, and meet the other requirements of the laws of the Russian Federation.
5. Updating, correction, blocking and destruction of personal data
5.1. Providing information to the data subject
5.1.1. The User may contact the Operator to obtain information about the processing of the User’s personal data.
5.1.2. Information is provided to the data subject or the data subject’s representative within the time limits and in the manner set by Federal Law No. 152-FZ.
5.1.3. The data subject’s right of access to personal data may be restricted in the cases provided for by the laws of the Russian Federation.
5.2. Updating and correction of personal data
5.2.1. If inaccurate personal data is found, the Operator blocks it for the period of verification, in the cases and in the manner provided for by law.
5.2.2. If the inaccuracy is confirmed, the Operator corrects the personal data on the basis of information and documents provided by the data subject, the data subject’s representative or an authorised body, within the time limits set by law.
5.3. Stopping unlawful processing
5.3.1. If unlawful processing of personal data is found, the Operator blocks the relevant personal data for the period of verification.
5.3.2. If the unlawfulness of processing is confirmed, the Operator stops that processing within the time limits set by Federal Law No. 152-FZ. If the processing cannot be made lawful, the relevant personal data is destroyed within the time limits set by law.
5.4. Withdrawal of consent and a demand to stop processing
5.4.1. The User may withdraw a consent to personal data processing that was given earlier, or send a demand to stop the processing of personal data, to info@itexia.ru. The request must contain information that allows the Operator to identify the applicant and to determine which personal data the demand concerns.
5.4.2. Withdrawal of consent does not prevent further processing of personal data where such processing is permitted by the laws of the Russian Federation without the data subject’s consent.
5.5. Destruction of personal data
5.5.1. Personal data is destroyed when a ground provided for by law arises, including:
when the purposes of processing are achieved, or the need to achieve them ceases;
when unlawful processing is found, if it cannot be made lawful;
when consent is withdrawn, if there is no other lawful basis for continuing processing;
when a lawful demand from the data subject to stop processing is received;
when the established storage periods expire.
5.5.2. Personal data is destroyed by means that make it impossible to restore the content of the personal data, unless the law provides otherwise.
5.5.3. The fact of destruction of personal data is recorded in the manner established by the laws of the Russian Federation and by the Operator’s local documents.
6. Final provisions
6.1. This Policy was approved and takes effect on 12 October 2026 for an indefinite period, until a new version is approved and published.
6.2. The Operator may amend this Policy because the laws of the Russian Federation change, because the information systems or personal-data processing technologies in use change, because the Operator’s activities change, or for other valid reasons. A new version of the Policy takes effect when it is published on the Website, unless the new version sets a different date.
6.3. Information about the Operator:
Enquiries about the processing and protection of personal data, withdrawals of consent and demands to stop the processing of personal data may be sent to: info@itexia.ru