Personal Data Processing Policy

PERSONAL DATA PROCESSING POLICY for users of the smyslit.com website (SMYSLIT / content factory for business / Content Operations Platform) Revision date: 02.10.2026 Nizhny Novgorod 1. GENERAL PROVISIONS 1.1. This Personal Data Processing Policy (hereinafter — the Policy) defines the procedure and conditions for the processing of personal data by the Operator, measures to protect personal data, and the rights of personal data subjects. 1.2. The personal data operator: full name: DAYNET LLC; INN (tax ID): 5249129298; OGRN (state registration No.): 1135249004956; registered address: 603006, Nizhny Novgorod Region, Nizhny Novgorod, 110 Belinskogo St., office P43/8; email for personal data inquiries: info@daynet.pro; phone: +7 831 228-22-00; website: https://smyslit.com (hereinafter — the Site). 1.3. The Policy has been developed in accordance with the Constitution of the Russian Federation, Federal Law No. 152-FZ of 27.07.2006 "On Personal Data" (hereinafter — 152-FZ), Federal Law No. 149-FZ of 27.07.2006 "On Information, Information Technologies, and Data Protection", and other normative legal acts of the Russian Federation. 1.4. By using the Site, the personal data subject confirms that they have read this Policy. Consent to personal data processing is executed separately in the cases provided for by 152-FZ and this Policy. 1.5. The Policy is a publicly available document and shall be published on the Internet at: https://smyslit.com/privacy. 2. TERMS 2.1. Personal data — any information relating directly or indirectly to an identified or identifiable natural person (personal data subject). 2.2. Personal data processing — any action (operation) or set of actions performed on personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (provision, access), depersonalization, blocking, deletion, destruction. 2.3. Operator — DAYNET LLC, which independently or jointly with other persons organizes and (or) carries out the processing of personal data. 2.4. User — a natural person using the Site, including a representative of a legal entity acting on its behalf. 3. PURPOSES OF PERSONAL DATA PROCESSING The Operator processes personal data for the following purposes: 3.1. processing requests submitted through the forms on the Site and contacting the User via the specified contacts; 3.2. concluding, performing, and terminating service agreements (pilot, production cycle, implementation and support of the SMYSLIT content system); 3.3. preparing commercial proposals, calculations, and demonstration materials at the User's request; 3.4. handling the User's requests, claims, and inquiries, including personal data subject requests; 3.5. ensuring the information security of the Site, preventing fraud and abuse; 3.6. analyzing depersonalized Site usage statistics (where corresponding cookies/metrics and legal grounds exist); 3.7. sending informational and promotional materials — only with the subject's separate consent (Art. 18 of the Federal Law "On Advertising"); 3.8. fulfilling obligations imposed on the Operator by the legislation of the Russian Federation. 4. CATEGORIES OF SUBJECTS AND COMPOSITION OF PERSONAL DATA 4.1. Categories of subjects: Site users; representatives of counterparties; other persons who have sent an inquiry to the Operator. 4.2. Composition of the processed data (depending on the usage scenario): — name (contact person); — company name; — phone number (if provided); — email address; — the content of the request or inquiry, including information about the company's tasks, if the User provided it voluntarily; — technical data: IP address, cookies and similar identifier data, browser and device information, date and time of access; — payment data and transaction identifiers (upon conclusion of a contract — to the extent necessary for settlements, subject to payment providers' requirements). 4.3. The Operator does not intentionally process special categories of personal data (Art. 10 of 152-FZ) or biometric personal data (Art. 11 of 152-FZ), except where the User has voluntarily included such data in an inquiry. The User must not submit excessive special categories of data. 5. LEGAL GROUNDS FOR PROCESSING 5.1. the consent of the personal data subject (Art. 6 par. 1 cl. 1, Art. 9 of 152-FZ); 5.2. the necessity of processing for the performance of a contract to which the subject is a party, or for concluding a contract at the subject's initiative (Art. 6 par. 1 cl. 5 of 152-FZ); 5.3. necessity for fulfilling the Operator's obligations established by the legislation of the Russian Federation (Art. 6 par. 1 cl. 2 of 152-FZ); 5.4. other grounds provided for by Art. 6 of 152-FZ, where applicable. 6. PROCEDURE AND CONDITIONS OF PROCESSING. OPERATIONS ON DATA 6.1. Processing is carried out both with and without the use of automation tools. 6.2. The Operator performs the following operations: collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (provision, access), blocking, deletion, destruction. 6.3. Transfer of personal data to third parties is permitted: — to persons engaged by the Operator to support the operation of the Site and the services (hosting, email delivery, payment services, infrastructure), under agreements providing for confidentiality and data protection; — to state authorities — in the cases and manner established by the legislation of the Russian Federation; — to other persons — with the subject's consent or where another legal ground exists. 6.4. The Operator ensures the recording, systematization, accumulation, storage, clarification, and retrieval of personal data of citizens of the Russian Federation using databases located in the Russian Federation (Art. 18 par. 5 of 152-FZ). 6.5. Cross-border transfer of personal data is carried out where legal grounds exist and in compliance with Art. 12 of 152-FZ. The list of foreign states / recipients (if any) is specified by the Operator in an annex to the Policy or in the current version of the Policy after such transfer begins. 7. RETENTION PERIODS 7.1. Personal data is stored no longer than the processing purposes require, unless a different period is established by federal law or contract. 7.2. Request and correspondence data is stored for the duration of negotiations and contract performance; if no contract is concluded — for no more than 3 (three) years from the date of the last inquiry, unless a different period is required by law. 7.3. Data of subjects' inquiries is stored for 3 (three) years from the date the inquiry is closed, unless a different period is established by law. 7.4. Security logs are stored for at least 12 (twelve) months, unless a different period is established by information security requirements and legislation. 7.5. Upon achieving the processing purposes or upon withdrawal of consent (where processing is based on consent and no other grounds exist), personal data is destroyed or depersonalized within 30 (thirty) days, unless otherwise provided by law. 8. PERSONAL DATA PROTECTION MEASURES 8.1. The Operator takes the legal, organizational, and technical measures necessary to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision, distribution, and other unlawful actions, including: — restricting employee and contractor access; — recording and monitoring operations on personal data; — using information security tools, antivirus protection, and backups; — using secure transmission channels (HTTPS); — regularly reviewing whether the protection measures are up to date. 9. RIGHTS OF THE PERSONAL DATA SUBJECT 9.1. The subject has the right to: — receive information about the processing of their personal data; — demand the clarification, blocking, or destruction of personal data if it is incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the stated purpose; — withdraw consent to personal data processing; — appeal the Operator's actions or inaction to the authorized body for the protection of personal data subjects' rights (Roskomnadzor) or to a court; — exercise other rights provided for by 152-FZ. 9.2. To exercise their rights, the subject sends a request to info@daynet.pro with the subject line "Personal data subject request", followed by identity verification by a method sufficient for identification. 9.3. The Operator reviews the inquiry and sends a response within the time limits established by Art. 20 of 152-FZ (as a rule, within 10 business days of receiving the request, with a possible extension in the cases provided for by law). 10. COOKIES AND SIMILAR TECHNOLOGIES 10.1. The Site uses cookies and similar technologies. For details, see the Cookie Policy published at https://smyslit.com/cookie. 11. RECOMMENDATION TECHNOLOGIES 11.1. Where recommendation technologies are used on the Site and in SMYSLIT services, information about them is published at https://smyslit.com/recommendations in accordance with Art. 10.2-2 of Federal Law No. 149-FZ. 12. UPDATING AND AMENDMENT OF THE POLICY 12.1. The Operator may update the Policy. The new version takes effect from the moment it is published on the Site, unless otherwise provided by the new version. The revision date is indicated at the beginning of the document. 13. OPERATOR CONTACTS DAYNET LLC INN 5249129298, OGRN 1135249004956 603006, Nizhny Novgorod Region, Nizhny Novgorod, 110 Belinskogo St., office P43/8 Email: info@daynet.pro Phone: +7 831 228-22-00