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Personal Data Processing Policy

Effective date: June 22, 2026. Last updated: June 22, 2026.

This Policy defines the procedure for processing and protecting personal data of website users and clients of the Adler Funeral Agency. The document has been developed in accordance with the Constitution of the Russian Federation, Federal Law No. 152-FZ of July 27, 2006 «On Personal Data», and other regulatory acts of the Russian Federation.

1. General provisions

1.1. This Policy applies to all personal data that the Operator may receive from the user when using the website, filling out contact forms, making phone inquiries, entering into a funeral services agreement, or visiting the office in person.

1.2. Use of the website constitutes the user's acknowledgment of this Policy. Submitting a request through website forms or otherwise providing data to the Operator is deemed consent to personal data processing within the scope and purposes specified in the Policy.

1.3. The Operator does not verify the accuracy of personal data provided by the user and assumes that the user provides current and accurate information.

2. Personal data operator

2.1. The personal data operator is IE Sekent Andrey Eduardovich (hereinafter — the «Operator», the «Agency»).

2.2. TIN: 231705757734. OGRNIP: 324237500156670.

2.3. Correspondence address: 354057, Krasnodar Krai, Sochi, Dagomyskaya ul. (Dagomyskaya St.), 60, office 41.

2.4. Office address: 354340, Adler, ul. Kirova (Kirova St.), 50/4.

2.5. Contact phone: +7 918 306-40-43, +7 989 165-41-55. Email: a.sekent@yandex.ru.

3. Categories of personal data processed

3.1. The Operator may process the following categories of personal data:

  • surname, first name, patronymic;
  • phone number;
  • email address;
  • residential address or service call location;
  • information required for arranging funeral services and documents (including data about the deceased — to the extent provided by law);
  • information about ordered services and inquiry history;
  • technical data: IP address, browser type, cookie data, information about visited website pages.

3.2. The Operator does not process special categories of personal data (racial origin, political views, health status, etc.), except when such information is required for document processing as required by law and is provided voluntarily by the user.

4. Purposes of personal data processing

4.1. Personal data is processed for the following purposes:

  • contacting the user and processing requests for funeral services;
  • conclusion and performance of a funeral services agreement;
  • processing documents required for organizing funerals, cremation, transport, and other funeral events;
  • informing about order status and coordinating service details;
  • compliance with requirements of Russian Federation legislation;
  • improving website performance, analyzing traffic and user experience;
  • protecting the rights and legitimate interests of the Operator and third parties.

5. Legal grounds for processing

5.1. Personal data processing is carried out on the basis of:

  • consent of the personal data subject (Art. 6, 9 of Federal Law No. 152-FZ);
  • necessity for performance of a contract to which the data subject is a party (para. 5, part 1, Art. 6 of Federal Law No. 152-FZ);
  • necessity to comply with obligations of the Operator established by law (para. 2, part 1, Art. 6 of Federal Law No. 152-FZ);
  • legitimate interests of the Operator subject to respect for the data subject's rights (para. 7, part 1, Art. 6 of Federal Law No. 152-FZ).

6. Methods, terms, and conditions of processing

6.1. Personal data processing is carried out using automation tools and without them (mixed processing).

6.2. Actions with personal data: collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (provision, access), depersonalization, blocking, deletion, destruction.

6.3. The retention period for personal data is determined by processing purposes, contract term, and legal requirements. Data received through website forms that did not result in a contract is stored for no more than 1 (one) year from the date of the last inquiry, unless another period is established by law.

6.4. Upon achievement of processing purposes or withdrawal of consent, personal data is subject to destruction or depersonalization, unless otherwise provided by law.

7. Transfer of personal data to third parties

7.1. The Operator may transfer personal data to third parties only when necessary to provide funeral services and perform the contract, including:

  • government authorities (registry office, medical institutions, social protection agencies) — for document processing;
  • cemeteries, crematoria, morgues — for organizing burial or cremation;
  • carriers — for organizing transport;
  • banks — for processing payments;
  • hosting providers and communication services — to ensure website operation and communications.

7.2. Data transfer is carried out under agreements in compliance with Federal Law No. 152-FZ requirements. The Operator does not sell or transfer personal data for marketing purposes without separate user consent.

8. Cookies and analytics

8.1. The website uses cookies — small text files stored on the user's device. Cookies are used to ensure proper website operation, remember consent to data processing, and analyze traffic.

8.2. The user may disable cookies in browser settings. In that case, some website features may not work correctly.

8.3. By continuing to use the website and clicking «Accept» in the cookie notice, the user agrees to cookie use in accordance with this Policy.

9. Rights of the personal data subject

9.1. The personal data subject has the right to:

  • receive information about processing of their personal data;
  • request clarification, blocking, or destruction of data if it is incomplete, outdated, inaccurate, or processed unlawfully;
  • withdraw consent to personal data processing;
  • appeal actions or inaction of the Operator to Roskomnadzor or court;
  • protection of their rights and legitimate interests, including compensation for damages and moral harm.

9.2. To exercise your rights, send a request to a.sekent@yandex.ru or to the postal address 354057, Krasnodar Krai, Sochi, Dagomyskaya ul. (Dagomyskaya St.), 60, office 41 indicating your full name and the nature of the request. The Operator will review the request within no more than 30 (thirty) days from the date of receipt.

10. Personal data protection measures

10.1. The Operator takes necessary legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision, distribution, and other unlawful actions.

10.2. Such measures include: restricting access to personal data, using secure communication channels, backup copying, training employees on personal data processing rules.

11. Processing of minors' data

11.1. The website and Agency services are not intended for independent use by persons under 18 years of age. Personal data of minors is processed only with participation of their legal representatives.

12. Policy changes

12.1. The Operator may amend this Policy. The current version is posted on this page with the update date indicated.

12.2. A new edition of the Policy takes effect upon publication on the website, unless otherwise provided by the new edition.

13. Contact information

13.1. For questions regarding personal data processing, contact:

— phone: +7 918 306-40-43, +7 989 165-41-55;

— email: a.sekent@yandex.ru;

— address: 354340, Adler, ul. Kirova (Kirova St.), 50/4.

13.2. The authorized body for protection of personal data subjects' rights is the Federal Service for Supervision of Communications, Information Technology and Mass Media (Roskomnadzor), website: https://rkn.gov.ru.

Have questions?

Contact us by phone +7 918 306-40-43 or email a.sekent@yandex.ru.

+7 918 306-40-43