Personal Data Processing Policy

Website ooofferly.com (the “Website”)

This is an English translation provided for convenience. The legally binding version is the Russian one (Политика обработки персональных данных); in case of any discrepancy, the Russian text prevails. Processing is governed by the law of the Russian Federation.

1. General provisions

1.1. This Personal Data Processing Policy (the “Policy”) is drawn up in accordance with Federal Law No. 152-FZ of 27.07.2006 “On Personal Data” and defines how the Operator processes personal data and the measures taken to ensure their security.

1.2. Operator: Alisa Kostolomova, self-employed (professional income tax payer), TIN (INN) 772589042300, Moscow, Russia. Contact for requests: hi@ooofferly.com.

1.3. The Operator processes users' personal data in connection with the use of the Website and the provision of the services described in the Public Offer.

1.4. By using the Website and/or submitting data through its forms, the User consents to the processing of their personal data under this Policy.

2. What data is processed

2.1. The Operator processes the following data:

• Contact data that the User provides voluntarily (e.g. an e-mail address when contacting us);
• The contents of uploaded documents (a CV and accompanying text) that the User uploads to obtain the service, which may contain personal data (name, contact details, information about experience and education);
• Technical data automatically obtained when using the Website (e.g. interface language settings, de-identified technical session information).

2.2. The Operator does not request special categories of personal data and asks the User not to include them in uploaded documents.

3. Purposes of processing

• providing the service — automated CV analysis and preparation of a rewritten CV and a cover letter;
• accepting and confirming payment;
• communicating with the User in response to their requests;
• fulfilling obligations provided for by the law of the Russian Federation.

4. Legal grounds

4.1. Processing is carried out on the basis of: the User's consent to the processing of personal data; the necessity of performing the contract (the Public Offer) to which the User is a party; the requirements of applicable Russian law.

5. Procedure and conditions of processing

5.1. Personal data is processed using automation.

5.2. The contents of uploaded documents are processed in memory to generate the result of the service and are not stored by the Operator on a permanent basis after the service is provided. The result is provided to the User to download themselves and is not archived by the Operator.

5.3. To provide the service, certain data may be transferred to the Operator's providers solely to the extent necessary to perform the contract:

• to the payment service provider — to accept and confirm payment;
• to the automated text-processing (AI) service provider — to analyse the CV and generate the result.

5.4. Cross-border transfer. When the automated processing provider is used, data may be processed on servers located outside the Russian Federation. By using the Website, the User confirms their consent to such transfer to the extent necessary to provide the service.

5.5. The Operator does not transfer personal data to third parties for purposes other than those specified in this Policy, except as provided by Russian law.

6. Processing and storage periods

6.1. The contents of uploaded documents are not stored by the Operator after the service is provided.

6.2. Contact data is processed until the purposes of processing are achieved or until the User withdraws consent.

7. Cookies and local storage

7.1. The Website may use technical cookies and browser local storage (e.g. to remember the chosen interface language). This data is not used to identify the User as an individual.

8. Rights of the data subject

8.1. The User has the right to: obtain information about the processing of their personal data; request the clarification, blocking or deletion of data if it is incomplete, outdated, inaccurate or processed in breach of the law; withdraw consent to processing.

8.2. To exercise these rights, the User sends a request to: hi@ooofferly.com. The Operator considers the request within the periods established by Russian law.

9. Data protection

9.1. The Operator takes reasonable and sufficient legal, organisational and technical measures to protect personal data against unlawful access, destruction, alteration, blocking, copying and distribution.

10. Changes to the Policy

10.1. The Operator may amend this Policy. The current version is published on the Website at ooofferly.com. Continued use of the Website after changes means acceptance of the updated Policy.

11. Operator's details