Personal Data Processing Policy of LLC "CONNECT TECH"
Publication date: April 14, 2026
1. General Provisions
1.1. This Personal Data Processing Policy (hereinafter — the "Policy") defines the purposes, general principles and procedure for processing personal data, as well as the personal data protection measures implemented by Limited Liability Company "CONNECT TECH" (OGRN 1267700113614, INN 9723271672, address: 141 Lyublinskaya St., premises 5, Lyublino municipal district, Moscow, 109382, email: [email protected]) (hereinafter — the "Operator").
1.2. The Policy is a publicly available document of the Operator and may be reviewed by any person. The Policy is permanently published at: https://ewento.ru/privacy.
1.3. The Policy has been developed in accordance with the Constitution of the Russian Federation, Federal Law No. 152-FZ of 27 July 2006 "On Personal Data", Federal Law No. 149-FZ of 27 July 2006 "On Information, Information Technologies and Information Protection", Russian Government Decree No. 1119 of 1 November 2012, Russian Government Decree No. 687 of 15 September 2008, FSTEC Order No. 21 of 18 February 2013, Roskomnadzor Order No. 179 of 28 October 2022, and other regulatory acts of the Russian Federation in the field of personal data.
2. Terms and Definitions
2.1. Personal data — any information relating directly or indirectly to an identified or identifiable individual (a personal data subject).
2.2. Operator — LLC "CONNECT TECH" (OGRN 1267700113614, INN 9723271672), a legal entity that, alone or jointly with others, organizes and carries out the processing of personal data, and determines the purposes of processing, the composition of the data to be processed, and the actions (operations) performed with personal data.
2.3. Personal data processing — any action (operation) or set of actions (operations) performed with or without the use of automation tools on personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, destruction of personal data.
2.4. Automated personal data processing — processing of personal data by means of computer equipment.
2.5. Dissemination of personal data — actions aimed at disclosing personal data to an indefinite range of persons.
2.6. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific range of persons.
2.7. Blocking of personal data — temporary suspension of the processing of personal data (except where processing is necessary to clarify the personal data).
2.8. Destruction of personal data — actions as a result of which it becomes impossible to restore the content of personal data in a personal data information system and/or which result in the destruction of the physical media of personal data.
2.9. Anonymization of personal data — actions that make it impossible to determine, without the use of additional information, which personal data relate to a specific subject.
2.10. Personal data information system (ISPDn) — a set of personal data contained in databases and the information technologies and technical means that ensure their processing.
2.11. Cross-border transfer of personal data — the transfer of personal data to the territory of a foreign state to a foreign state authority, a foreign individual, or a foreign legal entity.
2.12. User — a legally capable individual at least 18 years of age, a user of the Internet and/or information systems, who uses the Platform, the Mobile application, or the Operator's Website on the basis of the User Agreement.
2.13. Platform — the "Ewento" software complex owned by the Operator, including the Website (https://ewento.ru), the web application, the mobile application, and related services, intended for organizing and managing events, ensuring networking between participants, registration, publishing information about events, and other functions.
2.14. Organizer — a legal entity or individual (including an individual entrepreneur) that has entered into an agreement with the Operator for the use of the Platform to hold Events.
2.15. Event — a conference, seminar, master class, forum, exhibition, training, summit, networking meeting, or other event for which the Platform is used.
2.16. Cookies — small text files stored in the User's browser that contain technical or service information about visits to the Website, including IP address, device and operating system type, browser, unique device identifier, referrer URL, and session information.
Other terms are interpreted in accordance with the provisions of Federal Law No. 152-FZ of 27 July 2006 "On Personal Data".
3. 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 personal data subject;
- require the personal data subject to update the personal data provided in a timely manner;
- independently determine the composition and list of measures necessary and sufficient to ensure compliance with the Operator's obligations under Russian law;
- delegate the processing of personal data to third parties with the consent of the personal data subject on the basis of an agreement.
3.2. The Operator is obliged to:
- process personal data in the manner established by the applicable legislation of the Russian Federation;
- consider requests from a personal data subject (or their legal representative) and provide reasoned responses within the periods established by law;
- provide the personal data subject with information regarding the processing of their personal data and free access to such data;
- take the necessary legal, organizational, and technical measures to protect personal data against unauthorized or accidental access, destruction, modification, blocking, copying, provision, dissemination, and other unlawful acts;
- not disclose or distribute personal data to third parties without the subject's consent, unless otherwise provided by federal law;
- publish or otherwise ensure unrestricted access to this Policy;
- comply with the requirements of Russian law on personal data.
4. Rights of Personal Data Subjects
Personal data subjects have the right to:
- receive full information regarding the processing of their personal data and obtain free access to such data;
- request clarification of their personal data, its blocking or destruction if it is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the declared processing purpose;
- withdraw consent to the processing of personal data;
- appeal the actions or inaction of the Operator to the authorized body for the protection of the rights of personal data subjects (Roskomnadzor) or in court;
- appeal decisions made solely on the basis of automated processing of their personal data;
- require the Operator to cease processing personal data.
5. Categories of Subjects and Scope of Personal Data Processed
5.1. The Operator may process the personal data of the following categories of subjects:
- Platform Users (event participants);
- Event Organizers and their representatives;
- clients and counterparties of the Operator (individuals), and representatives and employees of clients and counterparties (legal entities);
- employees of the Operator and candidates for vacant positions.
5.2. Scope of personal data processed:
| Category of subjects | Scope of personal data |
|---|---|
| Platform Users (event participants) | Last name, first name, patronymic; email address; phone number; place of work and job title; profile photo; information about interests and skills (for networking); metric program data; cookies and session technical data; photo/video images (when using the relevant features) |
| Organizers and their representatives | Last name, first name, patronymic; email address; phone number; place of work and job title; organization details |
| Clients, counterparties and their representatives | Last name, first name, patronymic; email address; phone number; place of work and job title |
| Employees and candidates | Last name, first name, patronymic; date and place of birth; registration and residence address; phone number; email address; passport data; INN (tax ID); SNILS (social insurance number); education details; employment history; bank card/account details; other information required under labor legislation |
5.3. The Operator ensures that the content and scope of the personal data processed correspond to the stated purposes of processing and takes measures to eliminate excess data.
5.4. The Operator does not process special categories of personal data concerning race, ethnicity, political views, religious or philosophical beliefs, health status, or intimate life.
6. Purposes of Personal Data Processing
| Processing purpose | Subject category | Legal basis |
|---|---|---|
| Providing access to the Platform, ensuring its operation (identification, authorization, account security) | Users, Organizers | Subject's consent; performance of contract (User Agreement) |
| Ensuring networking between event participants (contact recommendations, profiling by interests and skills) | Users | Subject's consent; performance of contract |
| Registration for Events and provision of information about them | Users | Subject's consent; performance of contract |
| Providing the Operator's services to Organizers | Organizers and their representatives | Performance of contract |
| Handling of requests and inquiries | All categories | Subject's consent; legitimate interest of the Operator |
| Informing about the Operator's products and services, including marketing materials | Users, Organizers, clients | Subject's consent |
| Improving Platform quality, traffic analysis, content personalization | Users | Subject's consent (cookies) |
| Fulfillment of employment obligations, HR recordkeeping | Employees, candidates | Labor legislation; subject's consent |
7. Use of Cookies
7.1. To ensure the correct operation of the Website, traffic analysis and content personalization, the Operator uses cookies. Cookies automatically collect the following anonymized statistical data: type of action performed, date and time, page URL, referrer, IP address, User Agent, ClientID (browser identifier), screen resolution, and data on viewed sections and services.
7.2. Data collected via cookies does not belong to special categories or biometric personal data under Articles 10–11 of Federal Law No. 152-FZ and is processed in an automated manner.
7.3. The basis for processing is the User's consent, provided on the first visit to the Website (cookie banner). Users may manage cookies through their browser settings. Blocking cookies may render certain Website components unavailable.
7.4. The User consents to the transfer of data obtained through cookies to third parties, including web analytics systems (Yandex.Metrica and similar), for research and provision of services on behalf of the Operator.
8. Legal Basis for Processing
The legal bases for the Operator's processing of personal data are:
- the Constitution of the Russian Federation;
- the Civil Code of the Russian Federation;
- the Labor Code of the Russian Federation;
- the Tax Code of the Russian Federation;
- Federal Law No. 152-FZ of 27 July 2006 "On Personal Data";
- Federal Law No. 149-FZ of 27 July 2006 "On Information, Information Technologies and Information Protection";
- the Operator's incorporation documents;
- the User Agreement (public offer);
- agreements concluded between the Operator and personal data subjects;
- consent of personal data subjects to processing;
- other grounds where consent to processing is not required by law.
9. Procedure and Conditions for Processing
9.1. The Operator processes personal data in the following ways: without the use of automation tools; in information systems with or without transmission of information over information and telecommunication networks; mixed processing.
9.2. List of actions performed with personal data: collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (provision, access), anonymization, blocking, deletion, destruction.
9.3. Processing is carried out subject to the subject's consent, except in cases established by Russian law.
9.4. Consent is given in any form that allows its receipt to be confirmed. Platform Users give consent upon registration by ticking the corresponding box and/or accepting the User Agreement.
9.5. Consent is specific, informed, conscious, unambiguous, and remains in force from the moment it is given until it is withdrawn.
9.6. Consent may be withdrawn by sending a written application to the Operator's legal address (by Russian Post or in person) or to [email protected] with the subject line "Withdrawal of consent to personal data processing". To identify the subject, the application must include the data used at registration.
9.7. If consent is withdrawn, the Operator may continue processing personal data where grounds provided by law exist.
10. Transfer of Personal Data to Third Parties
10.1. The transfer of Users' personal data to Event Organizers is carried out within the framework of contractual relations with the Organizer for the purpose of providing Platform services and with the subject's consent, including consent expressed by accepting the User Agreement.
10.2. The Operator may delegate the processing of personal data to third parties (processors) on the basis of an agreement.
10.3. The Operator may transfer personal data to state and local government authorities in the cases and manner provided by Russian law.
11. Cross-Border Transfer of Personal Data
11.1. If, in the course of providing services, the need for cross-border transfer of personal data arises, the Operator complies with the requirements of Article 12 of Federal Law No. 152-FZ, including sending notice to Roskomnadzor prior to such transfer.
11.2. Cross-border transfer is carried out only to the territory of foreign states that provide adequate protection of the rights of personal data subjects, or with the subject's written consent.
12. Storage of Personal Data
12.1. Personal data is stored in a form that allows the subject to be identified for no longer than required by the processing purposes, unless a storage period is established by federal law or contract.
12.2. When storing personal data, the Operator uses databases located on the territory of the Russian Federation, in accordance with Part 5 of Article 18 of Federal Law No. 152-FZ.
12.3. Storage terminates upon the following events: withdrawal of consent by the subject; achievement of the processing purposes; loss of the need to achieve the processing purposes; liquidation of the Operator.
13. Personal Data Protection Measures
13.1. When processing personal data, the Operator ensures confidentiality and takes the necessary legal, organizational, and technical measures to protect personal data in accordance with Russian Government Decree No. 1119 of 1 November 2012 and FSTEC Order No. 21 of 18 February 2013.
13.2. The Operator ensures: appointment of a person responsible for organizing personal data processing; use of information protection tools that have passed the established conformity assessment procedure; detection of unauthorized access and response measures; recovery of data in case of damage or loss; monitoring of the security measures implemented.
14. Updating, Deletion, and Destruction of Personal Data
14.1. If unlawful processing or inaccuracy of personal data is detected, the Operator must block the data from the moment the subject's request is received or a corresponding inquiry is made.
14.2. If inaccuracy is confirmed, the Operator clarifies the data within seven working days and lifts the block.
14.3. If unlawful processing is detected, the Operator ceases it within no more than three working days. If lawfulness cannot be ensured, the Operator destroys the data within no more than ten working days.
14.4. Upon achievement of the processing purpose or withdrawal of consent, the Operator ceases processing and destroys the data within no more than thirty days, unless otherwise provided by contract or law.
14.5. If the subject requests cessation of processing, the Operator ceases processing within no more than ten working days from the date of receipt of the request (except in cases provided for in clauses 2–11 of Part 1 of Article 6, Part 2 of Article 10, and Part 2 of Article 11 of Law No. 152-FZ). The period may be extended by no more than five working days with reasoned notice to the subject.
14.6. The personal data subject has the right to receive information regarding the processing of their data. Such information is provided within ten working days of the request (the period may be extended by no more than five working days with reasoned notice).
15. Final Provisions
15.1. This Policy is an internal document of the Operator, publicly available, and published on the Website at: https://ewento.ru/privacy.
15.2. The Operator may unilaterally make changes to the Policy. A new version takes effect from the moment it is published on the Website, unless otherwise provided by the new version.
15.3. For all questions related to the processing of personal data, the subject may contact the Operator by email at [email protected] or at the legal address: 141 Lyublinskaya St., premises 5, Lyublino municipal district, Moscow, 109382, Russia.
© 2026 LLC "CONNECT TECH". All rights reserved.