Personal Data Processing Consent
Version effective from [EFFECTIVE_DATE]
Working draft — requires legal review
This is a working draft of consent under Article 9 of Russian Federal Law 152-FZ. The Operator’s details and the list of actual operations and processors must be clarified by a lawyer and filled in at the [...] placeholders before publication.
I, the data subject (“Subject”), acting freely, of my own will and in my own interest, hereby give consent to [OPERATOR_NAME] (the “Operator”) to process my personal data on the terms below, in the manner prescribed by Federal Law No. 152-FZ of 27 July 2006 “On Personal Data”.
1. Operator information
Name: [OPERATOR_NAME].
PSRN/PSRNSP: [OPERATOR_OGRN]. TIN: [OPERATOR_INN].
Registered address: [OPERATOR_ADDRESS].
Personal-data email: [PRIVACY_EMAIL].
2. Information about the Subject
The Subject is an individual registering an Account on the Syucai Platform at [DOMAIN] or in the Platform’s mobile application, identified through their verified contact details (phone, email) and the associated Account records.
3. Categories of personal data covered by the consent
Surname, first name; contact phone; email; password (as a cryptographic hash); date and place of birth (for Syucai-methodology calculations); time zone; gender (self-identified, optional); profile picture; device identifiers and push tokens; IP address; payment identifiers (without full card numbers); history of bookings, messages, and video-consultation recordings; Master subscription and financial-transaction data; Master verification data within the scope set by the Operator’s internal procedures.
4. Processing purposes
Platform registration and authentication; performance of the Platform offer agreement (booking, conducting, and paying for Consultations, maintaining a Master’s CRM); communication with the Subject by email, SMS, push, messengers; account-security enforcement; compliance with the Operator’s statutory obligations; protection of the Operator’s and third parties’ rights and legitimate interests.
5. Personal-data operations
Collection, recording, systematisation, accumulation, storage, refinement (updating, modifying), retrieval, use, transfer (provision, access) to third-party processors acting on the Operator’s instruction, anonymisation, blocking, deletion, destruction of personal data, both with the use of automation (on Operator and engaged-processor servers) and without it.
6. Term of consent
The consent is in force from the moment of acceptance by the Subject within the Platform interface until the Subject’s Account is deleted or the consent is withdrawn in the manner set out below, subject to retention periods mandatory for the Operator under Russian legislation (tax and accounting records, access journals).
7. Transfer of personal data to third parties
The Subject consents to the transfer of personal data, to the extent required to achieve the processing purposes, to the processors engaged by the Operator: payment providers (CloudPayments, YooKassa), the video provider (LiveKit), the push provider (Expo / VK Push Service), the email provider ([EMAIL_PROVIDER]), the transcription provider ([TRANSCRIPTION_PROVIDER]), the hosting and monitoring provider ([HOSTING_PROVIDER]). A processing agreement with confidentiality terms is in place with each processor.
Cross-border data transfer is performed only on the grounds established by Article 12 of 152-FZ; the actual list of such cases — [CROSS_BORDER_DETAILS].
8. Consent withdrawal
The Subject may withdraw this consent at any time by: (a) deleting the Account through the Platform interface; (b) sending a written notice to the Operator’s address or to [PRIVACY_EMAIL] with identity confirmation.
Upon receipt of a withdrawal, the Operator ceases personal-data processing and destroys the data within a period not exceeding 30 business days, save where processing must continue by law.
9. Consent confirmation
Consent is confirmed by the Subject’s active action on the Platform: ticking the corresponding checkbox at registration and/or another action that clearly expresses the Subject’s will (clicking “Agree” or “Sign up” with an indication in the interface that this consent and the Privacy Policy are being accepted). The fact of acceptance is recorded by the Operator in system journals (date, time, IP address, Account identifier).
Consent-withdrawal and subject-right requests — [PRIVACY_EMAIL].
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