Personal Data Processing Policy
Policy of LLC «Company BW» on the Processing of Personal Data and Information on the Measures Implemented to Protect Personal Data on the website beawire.com
(edition dated 13 October 2025)
1. General provisions
1.1. Purpose of the document
This Policy on the processing of personal data (the “Policy”) sets out the purposes, scope, conditions and procedure for processing personal data when using the website beawire.com (the “Website”), as well as the measures for ensuring the security of personal data.
1.2. Scope of application
The Policy applies to all personal data processing operations carried out when visiting the Website, including the use of cookies and the Yandex.Metrica web analytics service. The Website contains no forms for direct data collection (registration, feedback, etc.); processing is performed automatically via cookies and the analytics counter.
1.3. Key terms
The terms used correspond to those in Federal Law No. 152-FZ of 27.07.2006 “On Personal Data”: personal data, processing, operator, data subject, disclosure, anonymisation, cross-border transfer, etc. For the purposes of the Policy, cookies are small data fragments placed in the user’s browser and read during subsequent visits.
1.3. Key terms
For the purposes of this Policy, the following key terms are used:
Confidentiality of personal data — a mandatory requirement for the operator or any person who has obtained access to personal data not to disclose such data to third parties or disseminate them without the data subject’s consent, unless otherwise provided by federal law.
Processing of personal data — any operation or set of operations performed with or without the use of automated means on personal data, including collection, recording, systematisation, accumulation, storage, clarification (updating, amendment), retrieval, use, transfer (dissemination, provision, access), anonymisation, blocking, deletion and destruction of personal data.
Operator — a state or municipal authority, legal or natural person which, independently or jointly with others, organises and/or carries out the processing of personal data, and determines the purposes of processing, the composition of personal data to be processed, and the actions (operations) performed on personal data.
Personal data — any information relating, directly or indirectly, to an identified or identifiable natural person (data subject).
Data subject — a natural person who is identified or can be identified by means of personal data.
Cross-border transfer of personal data — transfer of personal data to the territory of a foreign state, to an authority of a foreign state, a foreign natural person or a foreign legal person.
Company — Limited Liability Company «Company BW».
1.4. Approval and review
This Policy enters into force on the date of its approval and remains effective until amended or replaced by a new Policy approved by the Company. The Policy is subject to periodic review and is made publicly available on the Website. A new edition enters into force upon publication.
2. Purposes of collection and processing of personal data
To ensure compliance with Federal Law No. 152-FZ of 27.07.2006 “On Personal Data” and subordinate legislation, the Company, acting as a personal data operator with the corresponding rights and obligations, ensures that processing conforms to the requirements of the law of the Russian Federation and that an appropriate level of security is applied to personal data being processed. The Operator processes personal data lawfully and fairly, limiting processing to specific, pre-determined and lawful purposes; only those data, and only to the extent necessary to achieve such purposes, are processed.
2.1. List of purposes, categories of data and legal bases
Information on personal data processing on the Website is set out below.
|
No. |
Purpose of processing |
Categories and list of personal data |
Data subjects |
Legal basis |
Processing operations |
Processing and retention period |
Destruction procedure |
|
1 |
Profiling of visitors and compilation of traffic statistics to improve the Website’s content and stability |
Network identifiers (IP address, cookie ID, session parameters), browser and device information, page URLs, on-page events, session duration, high-level geolocation by IP |
Website visitors |
Data subject’s consent expressed via the cookie banner |
Collection, recording, systematisation, accumulation, storage, use, transfer (provision, access), anonymisation, deletion |
Until cookie expiry or deletion by the user; aggregated statistics — until the analytical purposes are achieved |
Deletion of cookies by the user; deletion/anonymisation of technical logs upon completion of purposes |
2.2. Cookies and Yandex.Metrica
The Website uses cookies, including those set by Yandex.Metrica, to distinguish sessions and produce aggregated reports. Users may delete or block cookies in their browser settings; some functionality may be limited as a result.
3. Legal bases for processing personal data
3.1. Processing on the Website is carried out on the basis of the data subject’s consent, expressed by continuing to use the Website after the cookie banner is displayed.
3.2. Statistical materials are subject to anonymisation measures.
3.3. If the user does not agree to processing, the user must cease using the Website and delete/block cookies in the browser settings.
4. Procedure and conditions for processing personal data
4.1. Methods of processing. Processing is carried out in a mixed manner (with and without the use of automated means) within the Operator’s information systems and/or by engaged processors acting on the Operator’s instructions.
4.2. Minimisation and accuracy. Only the data necessary for the purposes specified in Section 2 are processed; measures are taken to ensure data are up-to-date and not excessive.
4.3. Disclosure to third parties.
• Analytics provider — Yandex (Yandex.Metrica), which obtains access to the data captured by the analytics counter and processes them under its own terms and policies.
• The Operator’s infrastructure providers (hosting, CDN, etc.) — for Website hosting and server logging.
Disclosure is effected to the extent necessary to achieve the purposes of processing and subject to compliance with Federal Law No. 152-FZ “On Personal Data”.
4.4. Cross-border transfer. The processing and storage of personal data are carried out predominantly in the territory of the Russian Federation. Cross-border transfer is permitted in a limited scope and only insofar as necessary to achieve the purposes specified in Section 2, subject to compliance with Law No. 152-FZ and the existence of contractual safeguards on the part of recipients (confidentiality, security and processing strictly in accordance with the Operator’s documented instructions). Where transfers are made to states that do not ensure an adequate level of protection of data subjects’ rights, the legal basis shall be the user’s consent; at the same time, data minimisation and other protective measures are applied. The data subject may withdraw consent by ceasing to use the Website and/or blocking cookies in the browser settings.
4.5. Security measures. The Operator applies necessary and sufficient organisational and technical measures (including access segregation and accounting, encrypted communication channels, logging, software updates and restricting the circle of authorised persons) aimed at preventing unauthorised or accidental access, destruction, alteration, blocking, copying, provision or dissemination of personal data.
4.6. Retention periods. Personal data are retained no longer than is required for the purposes of processing; cookies — until they expire or are deleted by the user; aggregated statistical data — until the analytical purposes are achieved.
5. Handling requests from data subjects
5.1. A data subject may submit to the Operator a request for information on the processing of his/her personal data, a demand for rectification, blocking or destruction of personal data, as well as a withdrawal of consent.
5.2. A request shall be submitted in writing or electronically with the note “Request regarding personal data” and must allow the applicant to be identified in the analytics systems (for example, by providing a cookie ID/a screenshot of browser settings).
5.3. Operator’s contact details:
— info@beawire.com, telephone +7 (495) 281-67-68;
— postal address: Russia, 129085, Moscow, Prospekt Mira, 101, bldg. 1, office 700.
5.4. The response period is within 30 calendar days from the date of receipt of the request, unless other time limits are set by law. The response is provided in the same form as the request unless the applicant specifies otherwise.
6. Procedure for destruction of personal data
6.1. Personal data shall be destroyed (deleted/anonymised):
— upon achievement of the purposes of processing or when such purposes no longer exist;
— upon identification of unlawful processing where ensuring lawfulness is impossible;
— upon receipt of an instruction from the competent authority;
— upon withdrawal of consent where no other legal bases for processing exist;
— upon expiry of the periods provided in Section 2.
6.2. For cookies, destruction is effected by the user deleting cookies from the browser; for technical logs — by deletion/anonymisation pursuant to operational regulations. The fact of destruction is recorded by technical means (event logs and/or formal acts).
7. Final provisions
7.1. Other rights and obligations of the Operator as a personal data operator are determined on the basis of Federal Law No. 152-FZ “On Personal Data” and other legal acts of the Russian Federation.
7.2. Officers and employees of the Operator who are at fault for breaches of the requirements for processing and protecting personal data bear liability in accordance with the legislation of the Russian Federation.
7.3. The Policy may be amended. The current edition and the date of its entry into force are published on the Website.