Privacy Policy

1. General Provisions

This Policy describes the procedure for processing and protecting personal data that you provide when using the site and when applying for services.

Personal data operator: Alexander Narizhny (hereinafter — the "Operator").

The policy is drawn up taking into account the requirements of:

• RF: Federal Law No. 152-FZ "On Personal Data".
• RK: Law of the Republic of Kazakhstan "On Personal Data and Their Protection" (21.05.2013 No. 94-V).

2. What data is processed

The Operator can process only the data that you provide voluntarily, including:

• name (full name/how you introduced yourself);
• contact details (phone, e-mail, messenger);
• message content/description of the request and context;
• technical data necessary for the operation of the site (IP address, browser/device information, cookies) — only if it is used on the site.

The Operator does not request or process special categories of personal data (about health, political views, etc.), unless you send them yourself in a message. Please do not transmit such information unnecessarily.

3. Purposes of processing

Personal data is processed for:

• feedback on your request;
• preliminary assessment of the possibility of cooperation;
• coordination of terms and execution of agreements/contract;
• ensuring the operation of the site and security (if relevant technical logs are available);
• compliance with the requirements of applicable law (if there is an obligation to store individual data/documents).

4. Legal grounds for processing

The Operator processes data based on:

• your consent (for example, when sending a form/message);
• necessity for concluding and/or executing a contract, if you enter into a working relationship;
• legal obligations of the Operator under applicable law (in necessary cases).

5. Conditions for transfer to third parties

The Operator does not sell or disclose your data to third parties without grounds.

Transfer is possible only in the amount necessary for the purposes of processing, for example:

• to providers of hosting, mail, messengers, recording/payment services (if used) — as processors on behalf, subject to confidentiality obligations;
• upon a legal request from authorized bodies — in cases and in the manner prescribed by law.

6. Cross-border transfer

If services whose servers are located outside the RF or RK are used for the operation of the site/communications, cross-border data transfer is possible. In this case, the Operator ensures transfer within the framework of applicable requirements and uses only those channels/providers that provide a reasonable level of data protection.

7. Storage periods

Data is stored no longer than necessary to achieve the purposes of processing or until the withdrawal of consent, unless otherwise required by law.

Correspondence and requests can be stored for a reasonable period for the history of interaction and protection of the rights and legitimate interests of the parties.

8. Confidentiality of work interactions

The content of work sessions and discussions is confidential by default. In coaching formats, the Operator additionally relies on ICF ethical standards: confidentiality, respect for the client's context and clear agreements. NDA can be signed upon request.

9. Protection measures

The Operator applies reasonable organizational and technical measures to protect personal data from unauthorized access, modification, disclosure or destruction (access control, restriction of the circle of persons, basic protection of infrastructure and communication channels).

10. Rights of the personal data subject

You have the right to:

• request information about the processing of your data;
• demand clarification, blocking or deletion of data (if this does not contradict the law);
• withdraw consent to processing;
• appeal against the actions/inaction of the Operator to the authorized bodies for the protection of personal data in the RF/RK.

11. Contacts

Send requests for personal data (access, correction, deletion, withdrawal of consent) through the communication channel specified on the website in the contacts/application section.