Licensor’s Personal Data Processing Policy
This policy applies to Leadership Atlas licensing, user access and support. The English text is provided for reference alongside the Russian policy.
Licensor and contact
Individual Entrepreneur Julia Poltaratskaya (Russian registration number 320774600193041) acts as a controller for personal data she processes to conclude and perform a licence agreement, administer access and communicate with the licensee’s representatives. For privacy enquiries, email jpoltaratskaya@gmail.com.
Data about the licensee’s representatives
For licensing and orders, account administration, onboarding, support and account security, the Licensor processes names, work emails, organisations, job or account roles, account activity and information supplied in enquiries. The information comes from the licensee, the representative or use of the Service. The scope is limited to what is necessary for the relevant purpose.
Lawful grounds, processing and retention
The basis depends on the purpose and applicable law. It may include legal obligations, the conclusion or performance of a contract where applicable, legitimate interests that respect data subjects’ rights, or consent where required. The Licensor collects, records, stores, uses, updates and deletes data with or without automation. Data are retained for as long as necessary for the purpose or for a period required by law or contract, then deleted or anonymised as applicable.
Data uploaded by a licensee
The licensee is the controller for the personal data of assessed individuals it uploads. The Licensor processes those data on the licensee’s documented instructions. The same applies to representative data submitted as part of the licensee’s materials under those instructions. The licence agreement and data processing terms determine purposes, categories, location, safeguards, retention, and return or deletion. Contact the licensee about data it controls. The Licensor forwards relevant enquiries to the licensee as set out in the agreement.
Access and security
The Licensor limits access to authorised roles and tasks and applies measures for user identification, access controls and activity oversight. Any processors receive only the information needed for their assigned work, subject to applicable confidentiality, security, localisation and transfer requirements.
Rights and enquiries
You can ask for information about processing, request correction, restriction or deletion where provided by law, withdraw consent where it is the basis for processing, and complain to the relevant authority. Email jpoltaratskaya@gmail.com with the account, organisation or situation your request relates to. If identity verification is required, the Licensor will explain how to provide the necessary information securely.