Privacy Policy

This policy explains how SERM-UP may process the personal data of website users and people who contact the company through the available communication channels.

Important Information

The website currently does not use enquiry forms. Enquiries are received through Telegram, phone and email.

If new data-processing tools, website forms, analytics systems or other technologies are introduced, this policy must be reviewed and updated before or at the time those tools are activated.

1. General Provisions

This policy applies to the SERM-UP website and to communications initiated by a user through the contact details published on the website.

The purpose of the document is to provide open information about the possible processing of personal data.

2. Data Controller

Controller: Individual Entrepreneur Daniel Hereni Email: 2@serm-up.ru Phone: +7 977 789-53-95 Telegram: @sagdiv

3. Personal Data That May Be Processed

Depending on the communication channel and the information voluntarily provided by the user, SERM-UP may process:

• a name or form of address;
• a telephone number;
• an email address;
• a Telegram username;
• the content of an enquiry;
• information about a company, brand, executive or reputation issue included in the enquiry;
• website technical data if analytics services are connected;
• cookie and browser data if such technologies are used on the website.

SERM-UP receives data directly from the user, from the content of the enquiry and from website technical tools if they are active at the time of the visit.

4. Purposes of Processing

Personal data may be processed for the following purposes:

• receiving and reviewing an enquiry;
• contacting the user through the selected communication channel;
• preparing information or a proposal concerning SERM-UP services;
• taking steps before entering into a contract;
• performing contractual obligations;
• analysing and improving the website if analytics services are connected;
• complying with applicable legal obligations.

5. Grounds for Processing

Processing may be based on:

• the user's voluntary enquiry;
• the user's consent;
• the need to prepare a response or service proposal;
• pre-contractual steps requested by the user;
• performance of a contract;
• applicable legal obligations.

The precise legal basis should be confirmed by legal counsel in accordance with the applicable Russian legislation and the actual technical configuration of the website.

6. How and Where Data Is Processed

SERM-UP uses organisational and technical measures intended to restrict unauthorised access to information.

Personal data is used only to the extent reasonably required to review the enquiry, communicate with the user and perform agreed work.

The data may be stored in communication systems, email, working documents and other tools used by the controller or authorised contractors.

7. Third Parties and Technical Services

When a user communicates through Telegram, some data is processed through Telegram infrastructure under Telegram's own terms and policies.

If analytics services are connected, technical visit data may be processed by the relevant service providers.

Hosting providers and technical contractors may have access to data only to the extent necessary to operate and maintain the website or communication systems.

Data may also be shared when required by law or when necessary to perform an agreement with the user, subject to the applicable legal requirements.

8. Data Retention

Data is retained for the period necessary to:

• review the enquiry;
• prepare a response or proposal;
• perform agreed work;
• comply with contractual, accounting and legal obligations;
• resolve questions connected to the communication.

The actual retention period depends on the nature of the enquiry, the subsequent communication and applicable legal requirements.

9. User Rights

Subject to applicable law, a user may have the right to:

• receive information about the processing of personal data;
• request clarification or correction of inaccurate data;
• request blocking or deletion where the relevant legal grounds exist;
• withdraw consent;
• object to processing where permitted;
• contact the controller with questions or requests.

10. Withdrawal of Consent

A user may withdraw consent by sending a message to the controller by email or Telegram.

The request should identify the communication channel through which the data was originally provided and provide enough information for the controller to locate and process the request.

Withdrawal does not automatically affect processing already carried out on another lawful basis or data that must be retained under applicable law.

11. Cookies and Analytics

At the time reflected in the Russian source text, the website does not use enquiry forms.

If cookies, analytics, embedded services or advertising tools are used, the website should provide appropriate information and, where required, consent controls.

The published text must reflect the actual technologies used at the time of publication.

12. Security

SERM-UP takes reasonable organisational and technical measures intended to protect personal data against unauthorised access, alteration, disclosure, loss or destruction.

No online system can be guaranteed to be completely secure. Users should avoid sending unnecessary sensitive information before the communication and confidentiality format has been agreed.

13. Changes to This Policy

The policy may be updated when:

• website functionality changes;
• enquiry forms are introduced;
• analytics or other technical services are connected;
• communication processes change;
• legal requirements change.

The current version should be published on this page.

14. Contact Concerning Personal Data

Telegram: @sagdiv Email: 2@serm-up.ru Phone: +7 977 789-53-95