PERSONAL DATA PROCESSING POLICY

OGRNIP 316290100080284
TIN 290503811819
Sole Proprietor: Maryukhin R.A.

1. General Provisions
1.1. This document (hereinafter – the "Policy") establishes the policy of Sole Proprietor Radislav Alexandrovich Maryukhin (hereinafter – the "Operator") regarding the processing and protection of personal data of users of the Websites and Mobile Application (as defined below), and contains information about the Operator's implemented requirements for the protection of such data, including their confidentiality. This Policy complies with the following legal acts:
  • Federal Law "On Personal Data" No. 152-FZ dated July 27, 2006;
  • Government Resolution No. 687 dated September 15, 2008;
  • Government Resolution No. 1119 dated July 6, 2008;
  • FSTEC Order dated February 18, 2013;
  • Other legal acts of the Russian Federation on data protection.

2. Terms and Definitions
  • Websites – https://wikium.ru/, https://maxmentality.ru/, https://clubskills.ru/, http://get.skilljoy.ru/, http://skilljoy.ru/ — proprietary platforms owned by the Operator.
  • Mobile Application – “Automated Cognitive Training System ‘Wikium’” for iOS.
  • User – any person accessing the Websites or Mobile Application.
  • Personal Data (PD) – any information relating to an identified or identifiable individual.
  • Processing of PD – any operation involving PD, including collection, storage, use, dissemination, etc.
  • Automated Processing – using IT tools for PD.
  • Dissemination / Provision – transfer of PD to defined or undefined persons.
  • PD System (ISPD) – information systems managing PD.
  • Blocking / Destruction of PD – temporary or permanent cessation of processing.
  • Cross-Border Transfer – transfer of PD abroad.
  • Cookies / IP Address – data and identifiers associated with user web access.
Operator Address: 165650, Arkhangelsk Region, Koryazhma, ul. A.G. Gleikha, d.16a, kv.11

3. Personal Data Processing
3.1. General Principles:
  • Lawfulness and fairness;
  • Goal-specific processing only;
  • Database segregation by purpose;
  • Data relevance, accuracy, and proportionality;
  • Destruction/Anonymization upon goal fulfillment.
3.2. Processing Legal Grounds:
  • With user consent;
  • When required by law or public interest;
  • For contract execution or protection of life and health;
  • For Operator’s or third-party legal interests.
3.3. Purposes:
  • Execution of license/user agreements;
  • Identification and communication;
  • Service provision, technical support;
  • Marketing and service improvement;
  • Preventing technical issues.
3.4. Data Subjects:
  • Website/Mobile App users;
  • Individuals in contractual relationships with Operator;
  • Affiliated persons and legal representatives.
3.5. Processing Tools:
  • Both automated and manual systems.
3.6. Data Types:
  • Full name, email, phone, address, IP, cookies;
  • Personal identifiers, feedback content;
  • No special category or biometric data is processed.

4. Storage and Transfer
4.1. PD may be stored electronically or on paper.
4.2. Storage is organized securely (locked cabinets or systems).
4.3. Cross-border and third-party transfer is only permitted with user consent or under law.
4.4. Operator may delegate processing under contract while remaining responsible.

5. Security Measures
5.1. Organizational and technical safeguards are implemented.
5.2. Appointed data protection officer.
5.3. Legal documents and policies are in place.
5.4. Physical and system security protocols (access logs, encryption, threat monitoring).

6. Data Subject Rights
6.1. Subjects may request:
  • Confirmation of PD processing;
  • Processing purposes, legal grounds, and methods;
  • Information on data recipients;
  • Duration and scope of processing;
  • Transborder data flow info.
6.2. Subjects may demand rectification, blocking, or destruction of incomplete or unlawfully obtained PD.
6.3. Subjects may submit requests or complaints via info@maryukhin.ru.

7. Final Provisions
7.1. This Policy is a public and official document.
7.2. It may be amended without notice; latest version is posted on the Websites.
7.3. Contact for inquiries: info@maryukhin.ru.
7.4. Current versions available at: