Wi-Fi SYSTEM Privacy Policy Regarding Personal Data Processing
1. General Provisions
This Personal Data Processing Policy is prepared in accordance with the requirements of the Federal Law No. 152-FZ dated 27.07.2006 “On Personal Data” (hereinafter referred to as the “Personal Data Law”) and defines the procedure for processing personal data and the measures taken by LLC “Integra”, Tax ID (INN) 2801214008, Tax Registration Reason Code (KPP) 280101001 (hereinafter referred to as the “Operator”) to ensure the security of personal data.
Address: 675000, Blagoveshchensk, Pionerskaya St., 14, Apt. 29.
1.1. The Operator’s primary goal and essential condition for carrying out its activities is to respect and protect the rights and freedoms of individuals when processing their personal data, including the protection of rights to privacy, personal and family confidentiality.
1.2. This Operator’s Policy regarding personal data processing (hereinafter — the “Policy”) applies to all information that the Operator may obtain about visitors to the website https://wifi-sys.com/ .
2. Key Terms Used in the Policy
2.1. Automated personal data processing — processing of personal data using computer-based technologies.
2.2. Blocking of personal data — temporary suspension of personal data processing (except where processing is necessary to verify the data).
2.3. Website — a collection of graphical and informational materials, as well as computer programs and databases, ensuring their accessibility on the Internet at the domain address https://wifi-sys.com/ .
2.4. Personal data information system — a set of personal data contained in databases, together with the information technologies and technical means used to process them.
2.5. Depersonalization of personal data — actions resulting in personal data being rendered irreversibly unidentifiable with a specific User or other data subject without the use of additional information.
2.6. Processing of personal data — any action (operation) or set of actions (operations) performed using or without automated means on personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transmission (distribution, provision, access), depersonalization, blocking, deletion, or destruction of personal data.
2.7. Operator — a state or municipal authority, legal entity, or individual who independently or jointly with others organizes and/or carries out personal data processing, and determines the purposes of processing, the composition of personal data to be processed, and the actions (operations) performed on personal data.
2.8. Personal data — any information relating directly or indirectly to an identified or identifiable User of the website https://wifi-sys.com/ .
2.9. Personal data authorized by the data subject for dissemination — personal data for which the data subject has granted open, unrestricted access by giving consent to the processing of such data in the manner prescribed by the Personal Data Law (hereinafter — “personal data authorized for dissemination”).
2.10. User — any visitor to the website https://wifi-sys.com/ .
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific individual or a specified group of individuals.
2.12. Dissemination of personal data — any actions aimed at disclosing personal data to an indefinite number of persons (data transfer), or enabling access to personal data by an unlimited audience—e.g., publication in mass media, placement in information and telecommunications networks, or granting access via other means.
2.13. Cross-border transfer of personal data — transfer of personal data to the territory of a foreign state to a foreign government authority, foreign individual, or foreign legal entity.
2.14. Destruction of personal data — any actions resulting in the irreversible and complete destruction of personal data, making it impossible to restore them in the personal data information system and/or eliminating physical data carriers.
3. Operator’s Main Rights and Obligations
3.1. The Operator has the right to:
— obtain accurate information and/or documents containing personal data from the data subject;
— continue processing personal data without the data subject’s consent in cases of withdrawal of consent or submission of a request to cease processing, provided grounds exist as stipulated in the Personal Data Law;
— independently determine the scope and list of measures necessary and sufficient for fulfilling its obligations under the Personal Data Law and associated regulatory legal acts, unless otherwise specified by the Personal Data Law or other federal laws.
3.2. The Operator is obligated to:
— provide the data subject, upon request, with information regarding the processing of their personal data;
— organize personal data processing in accordance with the current legislation of the Russian Federation;
— respond to inquiries and requests from data subjects and their lawful representatives in compliance with the Personal Data Law;
— provide the authorized body for personal data protection, upon its request, with the required information within 10 days of receiving such a request;
— publish or otherwise provide unrestricted access to this Policy on personal data processing;
— implement legal, organizational, and technical measures to protect personal data against unlawful or accidental access, destruction, modification, blocking, copying, provision, dissemination, or other unlawful actions;
— cease dissemination (distribution, provision, access), processing, and destroy personal data in the manner and cases stipulated by the Personal Data Law;
— fulfill other obligations prescribed by the Personal Data Law.
4. Data Subjects’ Rights and Obligations
4.1. Data subjects have the right to:
— receive information about the processing of their personal data, except where restricted by federal law. Information shall be provided by the Operator in an accessible form and shall not include personal data of other data subjects unless lawful grounds exist for disclosure. The scope of information and procedure for obtaining it are defined by the Personal Data Law;
— request the Operator to correct, block, or delete their personal data if such data are incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the stated processing purpose, and to take lawful measures to protect their rights;
— require prior consent for the processing of personal data for marketing purposes (promotion of goods, works, or services);
— withdraw consent to personal data processing and submit a request to terminate such processing;
— appeal unlawful actions or inaction of the Operator in personal data processing to the authorized body for personal data protection or via judicial proceedings;
— exercise other rights granted under the legislation of the Russian Federation.
4.2. Data subjects are obligated to:
— provide the Operator with accurate personal data;
— notify the Operator of any updates (corrections, changes) to their personal data.
4.3. Individuals who provide the Operator with inaccurate information about themselves or about another data subject without the latter’s consent bear liability in accordance with Russian legislation.
5. Principles of Personal Data Processing
5.1. Personal data processing shall be lawful and fair.
5.2. Processing shall be limited to specific, pre-defined, and lawful purposes. Processing incompatible with the purposes of data collection is prohibited.
5.3. Merging databases containing personal data processed for incompatible purposes is prohibited.
5.4. Only personal data necessary to fulfill processing goals shall be processed.
5.5. The content and volume of processed personal data shall correspond to the declared purposes. Processing of excessive personal data relative to the purposes is prohibited.
5.6. Personal data accuracy, sufficiency, and relevance (where necessary) to the processing purposes shall be ensured. The Operator shall take—or ensure the taking of—necessary measures to correct or remove incomplete or inaccurate data.
5.7. Personal data shall be stored in a form allowing identification of the data subject only for as long as required by the processing purposes, unless a longer retention period is stipulated by federal law, contract (to which the data subject is a party, beneficiary, or guarantor). Personal data shall be destroyed or depersonalized upon achievement of processing purposes—or if such purposes are no longer relevant—unless otherwise provided by federal law.
6. Purposes of Personal Data Processing
| Purpose of Processing | providing the User with access to services, information and/or materials available on the website; informing the User via email notifications |
| Personal Data | email address; phone numbers; full name (surname, first name, patronymic) |
| Legal Basis | contracts concluded between the Operator and the data subject; Federal Law No. 149-FZ “On Information, Information Technologies and Information Protection” dated 27.07.2006 |
| Types of Personal Data Processing | Collection, recording, systematization, accumulation, storage, destruction, and depersonalization of personal data; sending informational emails to the email address |
7. Conditions for Personal Data Processing
7.1. Personal data processing is carried out with the data subject’s consent.
7.2. Processing is necessary to achieve goals stipulated by an international treaty of the Russian Federation or by law, or to fulfill functions, powers, and duties imposed on the Operator by Russian legislation.
7.3. Processing is necessary for administration of justice, enforcement of court decisions or acts of other authorities/officials subject to execution under Russian enforcement legislation.
7.4. Processing is necessary to perform a contract to which the data subject is a party, beneficiary, or guarantor—or to conclude a contract at the data subject’s initiative, or in cases where the data subject will be a beneficiary or guarantor.
7.5. Processing is necessary to protect the Operator’s or third parties’ rights and legitimate interests—or to achieve public interest goals—provided that the data subject’s rights and freedoms are not violated.
7.6. Processing concerns personal data made publicly accessible by the data subject or at their request (hereinafter — publicly accessible personal data).
7.7. Processing concerns personal data subject to publication or mandatory disclosure under federal law.
8. Procedure for Collection, Storage, Transfer, and Other Types of Personal Data Processing
The security of personal data processed by the Operator is ensured through legal, organizational, and technical measures required by applicable personal data protection legislation.
8.1. The Operator ensures the confidentiality of personal data and takes all feasible measures to prevent unauthorized access.
8.2. The User’s personal data shall never be transferred to third parties, except (a) where required by law, or (b) if the data subject has explicitly consented to such transfer for the performance of obligations under a civil-law contract.
8.3. If inaccuracies in personal data are identified, the User may independently update them by sending a notification to the Operator’s email address with the subject line “Update of Personal Data”.
8.4. The duration of personal data processing is determined by the purposes for which the data were collected, unless otherwise specified by contract or law.
The User may withdraw consent to personal data processing at any time by sending a notification via email to with the subject line “Withdrawal of Consent to Personal Data Processing”.
8.5. Information collected by third-party services (e.g., payment systems, communication services, other providers) is stored and processed by such entities in accordance with their own Terms of Use and Privacy Policies. The Operator is not liable for the actions of such third parties.
8.6. Restrictions imposed by the data subject on transfer (except access provision), processing, or processing conditions (except access granting) for personal data authorized for dissemination do not apply when processing is carried out in state, public, or other legitimate public interests as defined by Russian legislation.
8.7. The Operator ensures the confidentiality of personal data during processing.
8.8. The Operator stores personal data in an identifiable form only as long as required to fulfill processing purposes, unless a longer retention period is stipulated by federal law, or by a contract to which the data subject is a party, beneficiary, or guarantor.
8.9. Grounds for termination of processing include: achievement of processing purposes; expiration of consent validity; withdrawal of consent or submission of a termination request; or detection of unlawful data processing.
9. List of Actions Performed by the Operator on Personal Data
9.1. The Operator carries out: collection, recording, systematization, accumulation, storage, updating (modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
9.2. The Operator performs automated processing of personal data with or without transmission of the resulting information via information and telecommunications networks.
10. Cross-Border Transfer of Personal Data
10.1. Before initiating cross-border personal data transfers, the Operator must notify the authorized personal data protection authority of its intent to carry out such transfers (this notification is submitted separately from the notification of intent to process personal data).
10.2. Prior to such notification, the Operator must obtain relevant information from foreign government authorities, foreign individuals, or foreign legal entities that are intended recipients of the transferred data.
11. Confidentiality of Personal Data
The Operator and any other persons granted access to personal data are prohibited from disclosing or disseminating such data to third parties without the data subject’s consent, unless otherwise required by federal law.
12. Final Provisions
12.1. Users may request clarifications on any issues concerning the processing of their personal data by contacting the Operator at .
12.2. Any amendments to this Policy will be reflected herein. The Policy remains in effect indefinitely until superseded by a new version.
12.3. The current version of the Policy is freely available online at: https://wifi-sys.com//privacy-policy .