Privacy Policy on the Processing of Personal Information

Privacy Policy on the Processing of Personal Information

1. Introduction
   This Privacy Policy describes how Sole Proprietor Sergey Tereshkin (the “Operator”, “we”, “us”) collects, uses, discloses, and safeguards personal information in connection with the website sergeytereshkin.ru (the “Website”). This Policy is intended to comply with Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA) and, where applicable, substantially similar provincial private-sector privacy laws in Quebec, Alberta, and British Columbia.

By using the Website or otherwise providing personal information to us in the course of a commercial activity, you consent to the collection, use, and disclosure of your personal information as described in this Policy, subject to your rights to withdraw consent and other rights under applicable law.

1. Key Definitions
   2.1. “Personal information” means information about an identifiable individual, including information that can be used alone or in combination with other information to identify a person (e.g., email address, telephone number).
   2.2. “Processing” means any operation performed on personal information, including collection, recording, organization, storage, adaptation, retrieval, use, disclosure by transmission or otherwise making available, de-identification, blocking, deletion, and destruction.
   2.3. “Operator” means the organization that determines the purposes of and means for processing personal information. For this Policy, the Operator is Sole Proprietor Sergey Tereshkin.
   2.4. “Website” means the online resources and related software and databases made available at sergeytereshkin.ru.
   2.5. “Service providers” means third-party companies that process personal information on our behalf for purposes such as hosting, communications, security, analytics, support, and payments (if applicable).
   2.6. “De-identification” means processing personal information to irreversibly remove or reduce the possibility of identifying an individual without additional information.
   2.7. “Publicly available information” means personal information available from public sources as defined or permitted by applicable Canadian law.

2. Accountability and Contact
   We are responsible for personal information under our control and have designated a Privacy Officer who oversees compliance with this Policy.
   Privacy Officer: s.i.tereshkin@res-rs.ru

3. What We Collect
   We may collect the following personal information:

• Email address

• Telephone number
  We may also receive any information you choose to include in your communications to us.

1. Purposes of Collection and Use
   We collect and use personal information for the following purposes:

• To provide access to the Website, its services, information, and materials

• To respond to inquiries and support requests

• To manage communications, including service notices and transactional messages

• To comply with legal and regulatory obligations

• To protect the security and integrity of our Website and systems

We will not collect, use, or disclose personal information for purposes other than those identified above, except with your consent or as permitted or required by law. We do not use personal information for incompatible purposes.

1. Consent
   We obtain your consent for the collection, use, and disclosure of personal information, except where permitted or required by law without consent. Consent may be express or implied depending on the sensitivity of the information and the context. You may withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice. If you withdraw consent, we may continue to retain and use your information as permitted or required by law (e.g., for record-keeping, compliance, or to resolve disputes).
   To withdraw consent, email: s.i.tereshkin@res-rs.ru with the subject “Withdrawal of consent”.

2. Disclosure to Service Providers and Other Third Parties
   We may disclose personal information to:

• Service providers that process information on our behalf for the purposes described in this Policy (e.g., hosting, communications, support)

• Authorities, courts, or other parties where required or permitted by law (e.g., legal proceedings, lawful requests, enforcing our rights)
  We do not sell personal information. We require service providers to safeguard personal information and to use it only for the services they provide to us.

1. Cross-Border Transfers
   Personal information may be stored and processed outside your province or outside Canada (including in jurisdictions whose privacy laws may differ from those in Canada), and may be accessible to courts, law enforcement, and national security authorities in those jurisdictions. We use contractual and organizational measures to protect personal information when transferred across borders, and we assess privacy risks of such transfers as required by applicable law.

2. Safeguards
   We implement appropriate administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, use, disclosure, alteration, or destruction. These measures are proportionate to the sensitivity of the information.

3. Accuracy
   We take reasonable steps to ensure that personal information is accurate, complete, and up to date for the purposes for which it is to be used. You may request correction of your personal information if you believe it is inaccurate or incomplete.

4. Retention and Deletion
   We retain personal information only as long as necessary to fulfill the purposes identified in this Policy or as required or permitted by law. When personal information is no longer necessary, we will securely delete or de-identify it. You may request deletion of your personal information, and we will accommodate the request where required by law and where no legal obligation requires us to retain it.

5. Your Rights
   Subject to limited exceptions under applicable law, you have the right to:

• Access your personal information under our control and obtain information about how it has been used and disclosed

• Request correction of your personal information

• Withdraw consent to processing

• Challenge our compliance with applicable privacy laws

To exercise these rights, contact our Privacy Officer at s.i.tereshkin@res-rs.ru. We may take reasonable steps to verify your identity before responding.

1. CASL (Commercial Electronic Messages)
   We comply with Canada’s anti-spam requirements. We send commercial electronic messages (e.g., newsletters) only with the required consent or as otherwise permitted by law, and each message includes an unsubscribe mechanism. To unsubscribe, follow the instructions in the message or email s.i.tereshkin@res-rs.ru with the subject “Unsubscribe”.

2. Breach Reporting and Notification
   In the event of a breach of security safeguards that creates a real risk of significant harm, we will report the breach to the Office of the Privacy Commissioner of Canada and notify affected individuals as required by law. We maintain records of all such breaches as required.

3. Publicly Available Information
   We may process publicly available information as permitted by Canadian law (for example, public directories), and in a manner consistent with the purposes described in this Policy.

4. Children’s Privacy
   Our Website is intended for a general audience. We do not knowingly collect personal information from children under the age of majority in their province of residence without appropriate consent where required by law. If you believe a child has provided personal information, please contact us to request deletion.

5. Updates to This Policy
   We may update this Policy from time to time to reflect changes in our practices or legal requirements. The updated version will be effective when posted on the Website. Your continued use of the Website after an update constitutes acceptance of the revised Policy.

6. Questions and Complaints
   If you have questions, requests, or complaints about this Policy or our privacy practices, please contact our Privacy Officer at s.i.tereshkin@res-rs.ru. You may also file a complaint with the Office of the Privacy Commissioner of Canada, or with your provincial privacy regulator where applicable.