Last updated: October 2, 2024
1. General Provisions
This personal data processing policy is compiled in accordance with the requirements of the Federal Law of July 27, 2006, No. 152-FZ "On Personal Data" (hereinafter - the Personal Data Law) and defines the procedure for processing personal data and measures to ensure the security of personal data taken by LLC "Cyberia" and/or its affiliates, including those in the same group as LLC "Cyberia" (hereinafter – Cyberia, Operator).
1.1. The Operator's primary goal and condition for carrying out its activities is the observance of human and civil rights and freedoms when processing their personal data, including the protection of the rights to privacy, personal and family secrets.
1.2. This Operator's policy regarding the processing of personal data (hereinafter - the Policy) applies to all information, including personal data in the sense of applicable legislation, which Cyberia can receive about you during your use of any websites (including the site https://cyberia-tech.ru), email, programs, products, and/or services of Cyberia, and other sites owned by Cyberia (hereinafter collectively - "Sites"), as well as during the execution by Cyberia / its affiliates of any agreements and contracts concluded with you.
2. Basic Terms Used in the Policy
2.1. Automated processing of personal data - processing of personal data using computer technology.
2.2. Blocking of personal data - temporary cessation of processing personal data (except for cases when processing is necessary for clarifying personal data).
2.3. Website - a set of graphical and information materials, as well as computer programs and databases ensuring their availability on the internet at the network address https://cyberia-tech.ru/.
2.4. Personal data information system - a set of personal data contained in databases and information technologies and technical means ensuring their processing.
2.5. Anonymization of personal data - actions as a result of which it is impossible to determine without using additional information the ownership of personal data to a specific User or another subject of personal data.
2.6. Processing of personal data - any action (operation) or a set of actions (operations) performed using automation tools or without using such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, destruction of personal data.
2.7. Operator - a government body, municipal body, legal or physical person, independently or jointly with other persons organizing and/or carrying out the processing of personal data, as well as determining the purposes of processing personal data, the composition of personal data to be processed, actions (operations) performed with personal data.
2.8. Personal data - any information relating directly or indirectly to a specific or identifiable User of the website https://cyberia-tech.ru/.
2.9. Personal data allowed by the subject of personal data for distribution - personal data, access to an unlimited number of persons to which is provided by the subject of personal data by giving consent to the processing of personal data allowed by the subject of personal data for distribution in the manner prescribed by the Personal Data Law (hereinafter - personal data allowed for distribution).
2.10. User - any visitor to the website https://cyberia-tech.ru/.
2.11. Provision of personal data - actions aimed at disclosing personal data to a certain person or a certain circle of persons.
2.12. Dissemination of personal data - any actions aimed at disclosing personal data to an unspecified circle of persons (transfer of personal data) or at familiarization with personal data of an unlimited circle of persons, including the disclosure of personal data in the mass media, placement in information and telecommunication networks, or providing access to personal data in any other way.
2.13. Cross-border transfer of personal data - transfer of personal data to the territory of a foreign state, to the authority of a foreign state, to a foreign individual or foreign legal entity.
2.14. Destruction of personal data - any actions as a result of which personal data are irretrievably destroyed with the impossibility of further recovery of the content of personal data in the personal data information system and/or material carriers of personal data are destroyed.
3. Basic Rights and Obligations of the Operator
3.1. The Operator has the right to:
Receive accurate information and/or documents containing personal data from the data subject;
In the event that the data subject withdraws consent for the processing of personal data or submits a request to cease the processing of personal data, the Operator is entitled to continue processing personal data without the data subject’s consent if there are grounds provided by the Personal Data Law;
Independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of the obligations stipulated by the Personal Data Law and the regulatory legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws;
Provide personal data of data subjects to third parties, if this is stipulated by current legislation (tax authorities, law enforcement agencies, other bodies) and this Policy.
3.2. The Operator is obligated to:
Provide the personal data subject, upon their request, with information related to the processing of their personal data;
Organize the processing of personal data in accordance with the procedure established by the current legislation of the Russian Federation;
Respond to inquiries and requests from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
Publish or otherwise provide unrestricted access to this Policy regarding the processing of personal data;
Take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, alteration, blocking, copying, provision, dissemination of personal data, as well as from other unlawful actions in relation to personal data;
Terminate the transfer (distribution, provision, access) of personal data, stop processing and destroy personal data in the manner and cases provided by the Personal Data Law;
Fulfill other obligations provided by the Personal Data Law.
4. Basic Rights and Obligations of Personal Data Subjects
4.1. Subjects of personal data have the right to:
Receive information regarding the processing of their personal data, except in cases provided by federal laws. Information is provided to the subject of personal data by the Operator in an accessible form, and it should not contain personal data related to other subjects of personal data, except when there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
Demand the Operator to clarify their personal data, block or destroy it if the personal data is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the declared purpose of processing, as well as to take measures provided by law to protect their rights;
Withdraw their consent to the processing of personal data, as well as to demand the termination of the processing of personal data;
Appeal in the authorized body for the protection of the rights of personal data subjects or in court the unlawful actions or inaction of the Operator when processing their personal data;
Exercise other rights provided by the legislation of the Russian Federation.
4.2. Subjects of personal data are obliged to:
Provide the Operator with accurate data about themselves;
Inform the Operator about the clarification (updating, modification) of their personal data.
4.3. Individuals who have provided the Operator with false information about themselves, or information about another subject of personal data without the latter's consent, are liable in accordance with the legislation of the Russian Federation.
5. Principles of Personal Data Processing
5.1. The processing of personal data is carried out on a lawful and fair basis.
5.2. The processing of personal data is limited to achieving specific, predetermined, and lawful purposes. Processing of personal data that is incompatible with the purposes of collecting personal data is not allowed.
5.3. Combining databases containing personal data processed for incompatible purposes is not allowed.
5.4. Only personal data that meets the purposes of their processing is subject to processing.
5.5. The content and volume of the processed personal data correspond to the declared purposes of processing. The processing of personal data in excess of the declared purposes of their processing is not allowed.
5.6. When processing personal data, the accuracy of personal data, their sufficiency, and, where necessary, relevance to the purposes of processing personal data are ensured. The Operator takes necessary measures or ensures their implementation to remove or clarify incomplete or inaccurate data.
5.7. The storage of personal data is carried out in a form that allows identifying the subject of personal data, no longer than required by the purposes of processing personal data, if the storage period of personal data is not established by federal law, a contract, the party of which, beneficiary, or guarantor is the subject of personal data. Processed personal data is destroyed or anonymized upon achieving the purposes of processing or in case of losing the necessity to achieve these goals, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing
Purpose of Processing
Personal Data
Legal Basis
Retention Period
Providing the User with access to services, information, and/or materials contained on the website
Cookie files;
IP addresses;
Other automatically collected data
Consent of the website visitor to data processing
Cookie files – in accordance with the Policy;
Other data – until the consent to data processing is withdrawn
Feedback form
Surname, first name, patronymic;
Email address;
Phone numbers;
Company affiliation (if applicable)
Consent of the website visitor to data processing
Until the consent to data processing is withdrawn
“Submit Resume” form
Assistance in employment or organizing other types of cooperation with a potential employer, providing information about new career opportunities, conducting initial interviews, providing services/performing work on the basis of a civil law contract, and also with the purpose of conducting activities by Cyberia related to personnel management and labor market analysis
Surname, first name, patronymic;
Gender;
Photograph;
Contact phone number;
Email address;
Date of birth;
Citizenship;
City and district of residence
Address of the personal Internet page on social networks;
Willingness to relocate and travel;
Marital status;
Work experience;
Education information;
Information about previous places of work;
Level of technical competencies;
Level of foreign language proficiency;
Salary expectations;
Other personal data that the candidate includes in their resume on their own;
Recommendations from previous places of work
Public offer, accepted by the candidate
Until the termination of the public offer or until the withdrawal of consent to data processing.
7. Recipients of Personal Data to Whom Cyberia May Transfer Candidate and Website Visitor Data
7.1. Cyberia Clients — potential employers, the Cyberia Group of persons (as defined by Article 9 of the Federal Law "On Protection of Competition" No. 135-FZ of 26.07.2006), with whom Cyberia has contractual relationships.
Purpose of the transfer: Execution of the public offer to provide services to candidates.
7.2. Companies of the Cyberia Group of Persons: LLC "Cyberia Labs" (127015, Moscow, internal territory of Municipal District Savelovsky, Butyrskaya St., Building 77).
Purpose of the transfer: Support of Cyberia's information systems.
8. Conditions for the Processing of Personal Data
8.1. The processing of personal data is carried out with the consent of the subject of personal data for the processing of his personal data.
8.2. The processing of personal data is necessary to achieve the goals set by an international treaty of the Russian Federation or by law, to perform the functions, powers, and duties imposed by the legislation of the Russian Federation on the operator.
8.3. The processing of personal data is necessary for the administration of justice, the execution of a judicial act, an act of another body or official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
8.4. The processing of personal data is necessary for the execution of a contract, of which the subject of personal data is a party, beneficiary, or guarantor, as well as for the conclusion of a contract at the initiative of the subject of personal data or a contract under which the subject of personal data will be a beneficiary or guarantor.
8.5. The processing of personal data is necessary for the exercise of the rights and legitimate interests of the operator or third parties or for achieving publicly significant goals provided that in doing so, the rights and freedoms of the subject of personal data are not violated.
8.6. The processing of personal data is carried out, access to which is provided by the subject of personal data or at his request (hereinafter - publicly available personal data).
8.7. The processing of personal data that are subject to publication or mandatory disclosure in accordance with federal law is carried out.
8.8. The processing of biometric personal data and special categories of personal data of site visitors related to racial, national origin, political opinions, religious or philosophical beliefs, intimate life is not carried out.
9. Procedure for Collection, Storage, Transfer, and Other Types of Personal Data Processing
The security of personal data processed by the Operator is ensured through the implementation of legal, organizational, and technical measures necessary to fully comply with the requirements of the current legislation on personal data protection.
9.1. The Operator ensures the security of personal data and takes all possible measures to prevent unauthorized access to personal data.
9.2. Personal data of the User will never, under any circumstances, be transferred to third parties, except in cases related to the execution of current legislation or if the personal data subject has given consent to the Operator to transfer data to a third party for the fulfillment of obligations under a civil law contract.
9.3. In case of inaccuracies in personal data, the User can update them independently by sending a notification to the Operator's email address legal@cyberia-tech.com with the subject line "Personal Data Update."
9.4. The processing period of personal data is determined by the achievement of the purposes for which the personal data were collected, unless another period is provided by the contract or current legislation.
The User may withdraw their consent to the processing of personal data at any time by sending a notification via email to the Operator's email address legal @cyberia-tech.com with the subject line "Withdrawal of Consent to Process Personal Data."
9.5. All information collected by third-party services, including payment systems, communication means, and other service providers, is stored and processed by these entities (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject and/or the user is responsible for familiarizing themselves with the mentioned documents in a timely manner. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this paragraph.
9.6. Prohibitions established by the personal data subject on the transfer (except for providing access), as well as on processing or conditions of processing (except for obtaining access) of personal data allowed for dissemination, do not apply in cases of processing personal data in state, public, and other public interests defined by the legislation of the Russian Federation.
9.7. The Operator ensures the confidentiality of personal data during processing.
9.8. The Operator stores personal data in a form that allows identifying the personal data subject, no longer than required by the purposes of processing personal data, if the storage period of personal data is not established by federal law, a contract, the party of which, beneficiary, or guarantor is the personal data subject.
9.9. Conditions for terminating the processing of personal data may include achieving the purposes of processing personal data, expiration of the personal data subject's consent, withdrawal of consent by the personal data subject, or a demand to stop processing personal data, as well as the identification of unlawful processing of personal data.
10. List of Actions Performed by the Operator with the Obtained Personal Data
10.1. The Operator carries out the collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
10.2. The Operator carries out automated processing of personal data with the receipt and/or transmission of the obtained information via information and telecommunication networks or without them.
11. Cross-Border Transfer of Personal Data
11.1. Before beginning the activity of cross-border transfer of personal data, the Operator is obliged to notify the authorized body for the protection of personal data subjects' rights about its intention to carry out the cross-border transfer of personal data (such notification is sent separately from the notification of the intention to process personal data).
11.2. Before submitting the aforementioned notification, the Operator is required to obtain the relevant information from the authorities of the foreign state, foreign individuals, and foreign legal entities to whom the cross-border transfer of personal data is planned.
12. Confidentiality of Personal Data
The Operator and other individuals who have gained access to personal data are obliged not to disclose personal data to third parties and not to distribute personal data without the consent of the personal data subject, unless otherwise provided by federal law.
13. Website Visit Analytics
13.1. Cookies are small files, usually consisting of letters and numbers, downloaded onto your device when visiting certain websites. They allow websites to recognize your device.
13.2. We aim to provide maximum comfort when using all the features of the websites. To ensure their correct operation, we process cookies, which help recognize you when visiting our sites, remember your preferences, and provide you with a personalized user experience.
13.3. Cookies are divided by their purpose into:
13.3.1. Necessary cookies, ensuring the basic functions of the website;
13.3.2. Statistical cookies, helping website owners understand visitor interactions;
13.3.3. Marketing cookies, used to track visitors across different websites to provide relevant advertising.
13.4. All three types of cookies are used on our sites. If you disagree with their processing, you can adjust the corresponding settings of your browser.
13.5. We use cookies and personal data collected using web analytics services only after obtaining your prior consent, provided through a cookie banner on the homepage of the site. These data do not include special categories or biometric data and are processed in an automated manner.
14. Final Provisions
14.1. The User may obtain any clarifications on issues concerning the processing of their personal data by contacting the Operator via email at legal@cyberia-tech.com.
14.2. This document will reflect any changes to the Operator's personal data processing policy. The policy is effective indefinitely until replaced by a new version.
14.3. The current version of the Policy is freely available on the Internet at https://almost-prod-only-en.esdl.ru/privacy-policy