Customer-data processing instructions and agreement

1. Subject, parties and duration

The user-controller instructs Russian individual entrepreneur Kirill Anatolyevich Losinsky for selected connections, message/file commands, events, working history and integration security during the contract and lawful wind-down. Subjects: lawful contacts, customers, prospects and staff; data: names, phones, IDs, messages, statuses, files and necessary authorization. Special categories, biometrics and children require a separate regime.

2. Instructions and lawfulness

Operations: receiving from connections, recording, storage, organization, retrieval, designated transmission, correction, restriction and deletion. Settings, commands and annexes document instructions, including recipients/transfers. The user ensures lawful purposes, contacts, advertising and authority to instruct; the Provider reports unlawful instructions and suspends them. Compelled disclosure is notified beforehand unless prohibited.

3. Security and subprocessors

Only confidentiality-bound persons with necessary access and proportionate security measures are admitted under applicable Russian Law 152-FZ Articles 18, 18.1, 19 and GDPR Article 32. Actual places, measures, periods, providers and access are identified before disclosure. No certification or encryption of every SDK is asserted.

Subprocessors need prior written specific/general authorization, applicable change notification and reasonable advance objection opportunity. Equivalent safeguards bind them; the Provider remains responsible to the required extent. The list is supplied before processing. Independent messenger platforms are assessed by actual role.

4. Assistance, transfers and verification

Considering processing nature, the Provider assists with subject rights, security, notifications, impact assessments and necessary consultations. Incidents are notified without undue delay with known categories/scale, consequences, measures and contact, with updates. Each party’s own duties and statutory periods remain.

Necessary information and proportionate checks, including user/authorized-auditor audits, are provided protecting others’ data; secrecy cannot prevent verification. International transfers need concrete grounds/safeguards. This is neither EU SCCs nor a Chinese standard contract; annexes, assessments, consent and representatives are arranged before use. Commands do not legalize prohibitions.

5. Ending and responsibility

At ending, data are returned or deleted at the controller’s choice with copies deleted, except legally required purpose-restricted storage. Processing without grounds ceases without needing a command; export may be requested beforehand. Completion is confirmed in an agreed verifiable way. The user answers for its grounds; the Provider for instructions and its own mandatory duties. Subject rights are not limited.

Provider details

Индивидуальный предприниматель Лосинский Кирилл Анатольевич
Russian tax ID (INN) 740415769736 · Sole trader registration (OGRNIP) 317745600124301
456234, г. Златоуст, кв-л Северо-Запад 2-й, 20-28
support@api-senden.ru · +7 (351) 367-22-52

Bank: Отделение № 8597 ПАО Сбербанк, г. Челябинск
Russian bank code (BIK) 047501602
Settlement account 40802810072000015606
Correspondent account 30101810700000000602
No Russian VAT charged under the Russian AUSN regime. Applicable foreign tax duties remain.