Personal Data Processing Instruction

This Personal Data Processing Instruction is an appendix to the Public Offer published at https://atsoffice.ru/en/terms and determines the terms of processing personal data that the Customer entrusts to Individual Entrepreneur Anton Antonovich Tsalov, TIN 301808511415, OGRNIP 321302500039682, in accordance with part 3 of Article 6 of Federal Law No. 152-FZ “On Personal Data” dated 27 July 2006. In this Instruction, the Customer is referred to as the “Operator”, and Individual Entrepreneur Anton Antonovich Tsalov as the “Contractor”. These designations are used within the meaning of this Instruction and may not coincide with the designations of the same persons in the Public Offer and the Privacy Policy.

This English version is provided for convenience. In case of any discrepancy between the Russian and English versions, the Russian version shall prevail.

1. General Provisions

1.1. This Instruction applies in cases where the Operator uploads to the ATS Office platform the personal data of third parties (including the contact data of representatives of external platforms) for the purposes of selecting platforms, conducting negotiations and supporting the placement of the Operator’s materials.

1.2. With respect to such personal data, the Operator is the operator that independently determines the purposes and composition of the data processed and the actions performed with it. The Contractor processes such data on behalf of the Operator and within the limits of this Instruction.

1.3. This Instruction does not change the status of the Contractor as the operator in respect of the personal data that the Contractor processes for its own purposes in accordance with the Privacy Policy published at https://atsoffice.ru/en/privacy.

1.4. Acceptance of the Public Offer means the Operator’s agreement to the terms of this Instruction.

2. Subject Matter of the Instruction

2.1. The Operator instructs, and the Contractor undertakes the obligation, to process personal data on behalf of and in the interests of the Operator in the scope, for the purposes and by the methods provided by this Instruction.

2.2. The Contractor processes personal data solely within the limits of the Operator’s instruction and does not independently determine the purposes of their processing.

2.3. The obligation to obtain and confirm the consent of personal data subjects to processing rests with the Operator.

3. List of Personal Data and Categories of Subjects

3.1. Within the framework of this Instruction, the following personal data of the persons whose information the Operator uploads to the platform may be processed:

• surname, name and patronymic, or a pseudonym or public name;
• email address, phone number, identifier in a messenger or social network;
• information about the external platform, position or role of the person;
• the content of correspondence and communications in the course of negotiations;
• other information that the Operator independently includes in the uploaded materials.

3.2. Categories of personal data subjects: representatives and owners of external platforms, administrators of channels and communities, and other persons with whom the Operator intends to interact using the platform.

3.3. The Contractor does not aim to process special categories of personal data or biometric personal data within the framework of this Instruction.

4. List of Actions and Methods of Processing

4.1. The Contractor has the right to perform the following actions with personal data: collection (receipt from the Operator), recording, systematization, accumulation, storage, clarification, retrieval, use, transfer within the limits of platform functions, blocking, deletion and destruction.

4.2. Processing is carried out both with and without the use of automation tools.

4.3. The Contractor does not transfer the personal data processed under this Instruction to third parties, except in the cases provided by the Operator’s instruction, the functions of the platform or the legislation of the Russian Federation.

5. Purposes of Processing

5.1. The processing of personal data under this Instruction is carried out for the purposes of selecting external platforms, preparing and conducting negotiations with their representatives, supporting the placement of the Operator’s materials and providing the Operator with the results of the platform’s work.

5.2. The Contractor does not use the personal data processed under this Instruction for its own purposes unrelated to the performance of the Operator’s instruction.

6. Obligations of the Contractor

6.1. The Contractor processes personal data only within the limits of the Operator’s instruction and in accordance with this Instruction.

6.2. The Contractor ensures the confidentiality of personal data and does not disclose it to third parties without the Operator’s instruction, except in the cases provided by the legislation of the Russian Federation.

6.3. The Contractor takes legal, organizational and technical measures to protect personal data in accordance with Articles 18.1 and 19 of the Federal Law “On Personal Data”, including access differentiation, secure connection, logging, backup and limitation of the scope of persons having access to the data.

6.4. The Contractor ensures the processing of personal data using databases located in the territory of the Russian Federation in the cases provided by the legislation of the Russian Federation.

6.5. The Contractor notifies the Operator of detected facts of unlawful access to personal data or of other incidents within a reasonable period and assists in eliminating their consequences.

6.6. Upon completion of the provision of services or at the Operator’s request, the Contractor stops processing and deletes or returns the personal data processed under this Instruction, unless otherwise provided by the legislation of the Russian Federation.

7. Obligations and Guarantees of the Operator

7.1. The Operator guarantees that there are legal grounds for transferring personal data to the platform and for its processing by the Contractor, including the consents of personal data subjects, if such consents are required by the legislation of the Russian Federation.

7.2. The Operator independently determines the purposes and composition of the data processed and is responsible for their lawfulness and accuracy.

7.3. The Operator ensures the informing of personal data subjects and the exercise of their rights provided by the legislation of the Russian Federation.

7.4. The Operator ensures the ability of a subject to refuse to receive further messages and does not use the platform for mailings that violate the requirements of the legislation of the Russian Federation.

8. Term and Termination

8.1. This Instruction is valid for the term of the agreement concluded under the terms of the Public Offer and terminates simultaneously with its termination.

8.2. Termination of the Instruction does not release the parties from performing the obligations that arose during its validity period, including the obligations to ensure the confidentiality and protection of personal data.

9. Liability of the Parties

9.1. Each party is liable for non-performance or improper performance of its obligations under this Instruction in accordance with the legislation of the Russian Federation.

9.2. The Contractor is not liable for the lawfulness and accuracy of the legal grounds and information provided by the Operator, nor for the Operator’s performance of the obligations of a personal data operator toward personal data subjects and the authorized body.

10. Final Provisions

10.1. This Instruction is an integral part of the Public Offer. In the part not regulated by this Instruction, the terms of the Public Offer and the Privacy Policy apply.

10.2. The Contractor has the right to amend this Instruction in the manner provided for amending the Public Offer. The current version is published at https://atsoffice.ru/en/data-processing-instruction.

11. Contractor Details

Individual Entrepreneur Anton Antonovich Tsalov
TIN 301808511415
OGRNIP 321302500039682
Location: Russian Federation, Moscow
Email: support@atsoffice.ru
Website: https://atsoffice.ru
Web application: https://app.atsoffice.ru