Alexey Poltaratskiy’s Personal Data Processing Policy
This policy applies to personal data processed by individual entrepreneur Alexey Poltaratskiy in connection with Leadership Atlas agreements. The English text is provided for reference alongside the Russian policy.
Licensor and contact
Individual Entrepreneur Alexey Poltaratskiy (Russian registration number 324774600030121) acts as controller where he determines the purposes and scope of processing. For privacy enquiries, email jpoltaratskaya@gmail.com.
Purposes and categories of data
For enquiries, contract preparation and performance, and access and support under an agreement, the Licensor may process names, work contact details, organisations, positions or roles, and information from correspondence. The information comes from the person who makes the enquiry or the organisation they represent. Its scope depends on the purpose for which it is needed.
Lawful grounds, processing and retention
Processing is governed by Russian Federal Law No. 152-FZ and other applicable rules. Depending on the purpose, the basis may be a legal obligation, conclusion or performance of a contract where applicable, legitimate interests that respect the data subject’s rights, or consent where required. The Licensor may collect, record, store, use, update and delete data. Data are retained for as long as necessary for the purpose, subject to mandatory retention periods, and then destroyed or anonymised as required by law.
Data uploaded by a licensee
If the agreement provides for processing of data uploaded by the licensee on its instructions, the licensee determines the purposes of that processing. The Licensor acts within those documented instructions. They define the data, permitted operations, safeguards and how processing ends. Contact the licensee as controller about the processing of those data.
Confidentiality and security
The Licensor maintains confidentiality and takes organisational and technical measures required by applicable law. Access is limited to what is needed for the relevant task. Data may be transferred where there is a lawful basis and applicable safeguards and transfer requirements are met.
Rights and enquiries
Data subjects may request information about processing, ask for correction, restriction or deletion where the law provides for it, withdraw consent where processing relies on it, and complain about a controller’s actions. Send your request to jpoltaratskaya@gmail.com and indicate that it is addressed to Individual Entrepreneur Alexey Poltaratskiy.