APPROVED
Self-employed person Olga Alekseevna Shorokhova
INN: 271203917394
October 19, 2026
PERSONAL DATA PROCESSING POLICY
1. General Provisions
1.1. This Personal Data Processing Policy (hereinafter, the "Policy") has been developed in accordance with the Constitution of the Russian Federation; Federal Law No. 152-FZ of July 27, 2006 "On Personal Data"; Federal Law No. 422-FZ of November 27, 2018 "On Conducting an Experiment to Establish a Special Tax Regime 'Tax on Professional Income'"; and other regulatory legal acts of the Russian Federation.
1.2. The personal data operator is an individual applying the special tax regime "Tax on Professional Income" (a self-employed person), Olga Alekseevna Shorokhova, INN 271203917394 (hereinafter, the "Operator").
1.3. The Policy defines the procedure for processing personal data and the measures to ensure its security taken by the Operator in the course of providing psychological counseling services using the "Psychonavigator Tarot" method.
2. Basic Concepts Used in the Policy•       Personal data means any information relating directly or indirectly to an identified or identifiable User (the personal data subject).
•       Processing of personal data means any action (operation) or set of actions performed with personal data, whether or not by automated means, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (dissemination, provision, access), depersonalization, blocking, deletion and destruction.
•       User means any person who has visited the Operator's website and/or has submitted a request to receive a service.
3. Purposes and Legal Grounds for Processing Personal Data3.1. The Operator processes the User's personal data for the following purposes:
•       identifying the User in order to provide the service;
•       establishing feedback, and sending notifications and commercial proposals (service prices);
•       entering into and performing an agreement for the provision of services (acceptance of the public offer);
•       sending the finished result of the consultation (the image of the card spread layout and a written response);
•       sending informational and advertising messages (subject to separate consent).
3.2. The legal grounds for processing are Article 6 of Federal Law No. 152-FZ (performance of an agreement to which the User is a party) and the User's consent to the processing of special categories of personal data (information on intimate life, psychological state and philosophical beliefs), as provided for by Article 10 of Federal Law No. 152-FZ.
4. Scope and Categories of Personal Data Processed4.1. To achieve the purposes specified in clause 3.1, the Operator processes the following data:
•       surname, first name and patronymic (if any);
•       e-mail address;
•       telephone number (if any);
•       the text of the question formulated by the User in the request form;
•       the content of the checklist completed by the User (including information about psychological state, personal experiences and life events);
•       data on the Tarot arcanum (card) selected;
•       technical data (IP address, cookie data, browser information), which is collected automatically when the website is visited.
4.2. The Operator does not process biometric data or special categories of data relating to racial or national origin, political views, or religious or philosophical beliefs, except where the User independently and voluntarily states such data in the text of their question or checklist.
5. Procedure and Conditions for Processing Personal Data5.1. Stages of processing within the "Psychonavigator Tarot" service:
•       Stage 1: The User completes a request form on the website, providing an e-mail address, a name and the text of the question. The data is delivered to the Operator's e-mail.
•       Stage 2: The Operator informs the User of the cost of the service in a reply e-mail. The User makes a 100% prepayment (through the Faster Payments System (SBP), by bank transfer, or by other methods permitted for self-employed persons).
•       Stage 3: The Operator sends the User an image of the Tarot card spread layout.
•       Stage 4: The User selects a card, completes the checklist and sends it to the Operator. At this stage, the Operator gains access to special categories of personal data (psychological state).
•       Stage 5: Based on the checklist, the Operator finalizes the response and sends the User the finished result of the consultation.
•       Stage 6: The service is deemed completed.
5.2. Data is processed by a mixed method: with the use of automation tools (the website, e-mail, messengers) and without the use of automation tools (in the case of offline counseling).
5.3. The Operator does not transfer personal data to third parties, except in cases provided for by the legislation of the Russian Federation, or where a mailing service is used to send e-mails (in which case a confidentiality agreement is concluded with that service).
5.4. The Operator stores data on the territory of the Russian Federation (on a personal secured computer, in cloud storage with servers located in the Russian Federation, or in secure e-mail services).
6. Terms of Processing and Storage of Personal Data6.1. The User's personal data is stored for 3 (three) years from the completion of the service, to enable the resolution of claims and disputes and to confirm the fact that the service was provided to the tax authorities (the Federal Tax Service of Russia).
6.2. Upon expiry of the storage period, or upon receipt of a request to withdraw consent (unless this contradicts clause 6.1), personal data is destroyed by permanent and irreversible deletion from electronic media.
7. Rights of the Personal Data Subject7.1. The User has the right to:
•       obtain information concerning the processing of their personal data;
•       require the Operator to clarify their personal data, or to block or destroy it, if the data is incomplete, outdated, inaccurate, unlawfully obtained or not necessary for the stated purpose of processing;
•       withdraw consent to the processing of personal data;
•       appeal against the actions or inaction of the Operator to the competent authority (Roskomnadzor, the Federal Service for Supervision of Communications, Information Technology and Mass Media) or in court.
7.2. To exercise their rights, the User sends a request to the Operator's e-mail address:
psy-navigator@olgashorohova.ru
8. Measures for the Protection of Personal Data8.1. The Operator takes the necessary legal, organizational and technical measures to protect personal data against unlawful access, destruction, modification, blocking, copying and dissemination, including:
•       use of licensed anti-virus software;
•       use of strong passwords and two-factor authentication for access to e-mail;
•       storage of devices in places that exclude access by unauthorized persons.
9. Final Provisions9.1. This Policy is a publicly available document and is posted at:
http://psy-navigator-taro.ru/
9.2. The Operator may amend the Policy unilaterally. The new version takes effect from the moment it is posted on the website.
Operator's Contact Details:
Self-employed person Olga Alekseevna Shorokhova
INN: 271203917394
E-mail: psy-navigator@olgashorohova.ru