Personal Data Processing Policy

Date of publication and entry into force: May 11, 2023.

1 General provisions

This Policy on Personal Data Processing is prepared in accordance with the requirements of the Federal Law “On Personal Data” dated 27.07.2006 № 152-FZ and determines the rules of personal data processing and measures to ensure the security of personal data carried out by Key Staff Consulting Company LCC (hereinafter – the Operator). The use of any Operator website, program, product or service implies the User’s consent to the terms of this Policy, which may be amended or supplemented by the terms for specific Operator websites, programs, products and services.

1.1. The main goal and condition of the Operator’s activity is to respect the rights and freedoms of people and citizens when processing their personal data, including the right to privacy, personal and family secrets.

1.2. The present policy of the Operator on the processing of personal data (hereinafter – the Policy) applies to all information that the Operator may obtain about the visitors of the website.

2 Basic terms used in the Policy

2.1. Automated processing of personal data – processing of personal data by means of computer equipment.

2.2. Blocking of personal data – is temporary cessation of processing of personal data (except if the processing is necessary for clarification of personal data).

2.3. Website – is a set of graphic and informational materials, as well as computer programs and databases, ensuring their availability on the Internet at the network address

2.4. Personal data information system – a set of personal data contained in databases of personal data, and information technology and technical means ensuring their processing.

2.5. De-identification of personal data – actions as a result of which it is impossible to determine, without using additional information, which personal data belongs to a particular user or other subject of personal data.

2.6. Processing of personal data – any action (operation) or set of actions (operations) performed with or without the use of automated means with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.

2.7. Operator – a state body, local authority, legal entity or natural person who, independently or jointly with others, organizes and (or) carries out processing of personal data, as well as determines the purpose of personal data processing, the composition of personal data to be processed, the operations performed with personal data.

2.8. Personal data – any information directly or indirectly related to a particular or identifiable user of the website.

2.9. User means any visitor to the website.

2.10. Disclosure of personal data – actions aimed at disclosure of personal data to a certain person or a certain circle of people.

2.11. Dissemination of personal data – any action aimed at disclosure of personal data to an unspecified number of persons (transfer of personal data) or making personal data known to the public, including publication of personal data in the media, placement in information and telecommunication networks or providing access to personal data in any other way.

2.12. Cross-border transfer of personal data – transfer of personal data to the territory of a foreign state to a foreign state authority, a foreign natural person or a foreign legal entity.

2.13. Destruction of personal data – any action as a result of which personal data are irretrievably destroyed with the impossibility of further restoration of the content of personal data in the information system of personal data and (or) destroyed material media of personal data.Visit our partners,shoes – leaders in fashionable footwear!

3 The Operator may process the following personal data of the User

3.1. Name, first name, patronymic.

3.2. Telephone numbers.

3.3. The Site also collects and processes anonymous data of visitors (including cookies) using Internet statistical services (Yandex Metrika and Google Analytics, etc.).

3.4. The above-mentioned data are hereinafter in the text of this Policy combined with the general concept of personal data.

4. Purposes of personal data processing

4.1. The purpose of processing the User’s personal data is the conclusion, execution and termination of civil law contracts; providing the User with access to the services, information and/or materials contained on the website, clarification of order details.

4.2. The Operator also has the right to send the User information about new products and services, special offers and various events. The User may refuse to receive such information at any time by sending an e-mail to the Operator at with the note “Refuse notifications about new products and services and special offers”.

4.3. The anonymous data of the users collected with the help of Internet statistical services are used to collect information about the users’ actions on the website, to improve the quality of the website and its content.

5 Legal basis for processing personal data

5.1. The Operator processes the User’s personal data only if the User independently fills in and/or sends them through the special forms available on the website By filling in the relevant forms and/or sending personal data to the Operator, the User expresses his or her agreement with this Policy.

5.2. The Operator processes the anonymous data of the User if the settings of the User’s browser allow it (the saving of “cookie” files and the use of JavaScript technology are enabled).

6 Procedures for collecting, storing, transferring and other processing of personal data

6.1. The safety of personal data processed by the Operator is ensured by the implementation of legal, organizational and technical measures necessary to fully comply with the requirements of applicable legislation in the field of personal data protection.

6.2. The Operator provides security of personal data and takes all possible measures to exclude access to personal data by unauthorized persons.

6.3. The User’s personal data will never, under any circumstances, be transferred to third parties, except in cases related to the execution of current legislation.

6.4. If the User finds any inaccuracies in his/her personal data, he/she may update them by sending a message to the Operator’s e-mail address with the subject “Updating of personal data”.

6.5. The period of processing personal data is unlimited. The User may withdraw his/her consent to the processing of personal data at any time by sending a message to the Operator’s e-mail address with the note “Withdrawal of consent to the processing of personal data”.

7 Transborder transfer of personal data

7.1. Prior to the international transfer of personal data, the Operator is obliged to ensure that the foreign country, to the territory of which the transfer of personal data is to be carried out, provides reliable protection of the rights of the subjects of personal data.

7.2. Transborder transfer of personal data to the territory of foreign countries that do not meet the above requirements may be carried out only if there is a written consent of the data subject to the transborder transfer of his/her personal data and/or to the performance of the contract to which the data subject is a party.

8 Final provisions

8.1. The User may obtain clarification of any questions concerning the processing of his/her personal data by contacting the Operator by e-mail at

8.2. This document will reflect any changes in the Operator’s personal data processing policy. The policy is valid indefinitely until it is replaced by a new version.

8.3. The current version of the Policy is freely available on the Internet at