1. General provisions
This personal data processing policy has been compiled in accordance with the requirements of Federal Law No. 152-FZ dated 27.07.2006 "On Personal Data" (hereinafter referred to as the Personal Data Law) and defines the procedure for processing personal data and measures to ensure the security of personal data taken by Ivan Mikhailov (hereinafter referred to as the Operator).
1.1. The Operator sets as its most important goal and condition for the implementation of its activities the observance of human and civil rights and freedoms when processing his personal data, including the protection of the rights to privacy, personal and family secrets.
1.2. This Operator's policy regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator can receive about visitors to the https://pci.7sec.com website.
2. Basic concepts used in the Policy
2.1. Automated personal data processing is the processing of personal data using computer technology.
2.2. Blocking of personal data is the temporary termination of the processing of personal data (except in cases where the processing is necessary to clarify personal data).
2.3. Website is a collection of graphic and informational materials, as well as computer programs and databases that ensure their availability on the Internet at the network address https://pci.7sec.com.
2.4. Personal data information system is a set of personal data contained in databases and information technologies and technical means that ensure their processing.
2.5. Depersonalization of personal data — actions as a result of which it is impossible to determine without using additional information whether personal data belongs to a specific User or another personal data subject.
2.6. Personal data processing is any action (operation) or set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
2.7. Operator — a state body, municipal body, legal entity or individual who independently or jointly with other persons organize and/or process personal data, as well as determine the purposes of personal data processing, the composition of personal data to be processed, actions (operations) performed with personal data.
2.8. Personal Data — any information related directly or indirectly to a specific or identifiable User of the https://pci.7sec.com website.
2.9. Personal data authorized by the personal data subject for dissemination is personal data to which an unlimited number of persons have access by the personal data subject by giving consent to the processing of personal data authorized by the personal data subject for dissemination in accordance with the procedure provided for by the Personal Data Act (hereinafter referred to as personal data authorized for Dissemination).
2.10. User — any visitor to the https://pci.7sec.com website.
2.11. Provision of personal data — actions aimed at disclosing personal data to a certain person or a certain circle of persons.
2.12. Dissemination of personal data — any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or at familiarizing with personal data of an unlimited number of persons, including the publication of personal data in the media, posting in information and telecommunications networks or providing access to personal data in any other way.
2.13. Cross—border transfer of personal data is the transfer of personal data to the territory of a foreign state to an authority of a foreign state, a foreign individual or a foreign legal entity.
2.14. Destruction of personal data — any actions as a result of which personal data is permanently destroyed with the impossibility of further restoration of the content of personal data in the personal data information system and/or the material carriers of personal data are destroyed.
3. Basic rights and obligations of the Operator
3.1. The Operator has the right to:
— receive reliable information and/or documents containing personal data from the personal data subject;
— if the personal data subject withdraws consent to the processing of personal data, as well as sending a request to terminate the processing of personal data, the Operator has the right to continue processing personal data without the consent of the personal data subject, provided there are grounds specified in the Law on Personal Data;
— independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations stipulated by the Law on Personal Data and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Law on Personal Data or other federal laws.
3.2. The Operator is obliged to:
— to provide the personal data subject, upon his request, with information regarding the processing of his personal data;
— organize the processing of personal data in accordance with the procedure established by the current legislation of the Russian Federation;
— respond to requests and requests from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Act;
— to provide the necessary information to the authorized body for the protection of the rights of personal data subjects at the request of this body within 10 days from the date of receipt of such request.;
— to publish or otherwise provide unrestricted access to this Personal Data Processing Policy;
— take legal, organizational and technical measures to protect personal data from unlawful or accidental access to them, destruction, modification, blocking, copying, provision, dissemination of personal data, as well as from other unlawful actions in relation to personal data;
— stop transmitting (distributing, providing, accessing) personal data, stop processing and destroy personal data in accordance with the procedure and cases provided for by the Law on Personal Data;
— perform other duties provided for by the Law on Personal Data.
4. Basic rights and obligations of personal data subjects
4.1. Subjects of personal data have the right to:
— receive information regarding the processing of his personal data, except in cases provided for by federal laws. The information is provided to the personal data subject by the Operator in an accessible form, and it should not contain personal data related to other personal data subjects, except in cases where there are legitimate grounds for the disclosure of such personal data. The list of information and the procedure for obtaining it are established by the Law on Personal Data;
— require the operator to clarify his personal data, block or destroy them if the personal data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated purpose of processing, as well as take legally prescribed measures to protect their rights.;
— to put forward a condition of prior consent when processing personal data in order to promote goods, works and services on the market;
— to revoke consent to the processing of personal data, as well as to send a request to terminate the processing of personal data;
— to appeal to the authorized body for the protection of the rights of personal data subjects or in court against unlawful actions or omissions of the Operator during the processing of his personal data;
— to exercise other rights provided for by the legislation of the Russian Federation.
4.2. Subjects of personal data are obliged to:
— provide the Operator with reliable information about themselves;
— inform the Operator about the clarification (updating, modification) of their personal data.
4.3. Persons who have provided the Operator with false information about themselves or information about another personal data subject without the latter's consent are liable in accordance with the legislation of the Russian Federation.
5. Principles of personal data processing
5.1. Personal data is processed on a lawful and fair basis.
5.2. The processing of personal data is limited to the achievement of specific, predetermined and legitimate purposes. Processing of personal data incompatible with the purposes of personal data collection is not allowed.
5.3. It is not allowed to combine databases containing personal data, the processing of which is carried out for purposes incompatible with each other.
5.4. Processing is subject only to personal data that meet the purposes of their processing.
5.5. The content and volume of personal data processed correspond to the stated purposes of processing. Redundancy of the processed personal data in relation to the stated purposes of their processing is not allowed.
5.6. When processing personal data, the accuracy of personal data, its sufficiency, and, if necessary, its relevance to the purposes of personal data processing are ensured. The Operator takes the necessary measures and/or ensures that they are taken to delete or clarify incomplete or inaccurate data.

Effective date: 20 April 2026
Last updated: 20 April 2026

1. Controller Information
This Privacy Policy explains how 7Security EOOD ("we", "us", "our") processes personal data in accordance with the General Data Protection Regulation (GDPR).
Data Controller:
7Security EOOD
47A Cherni Vrah Blvd., 5th floor,
Sofia, 1407, Bulgaria
Email: contact@7sec.com

2. Personal data we collect data you provide:

• Full name
• Email address
• Phone number
• Company name / job title
• Any information submitted via forms or scheduling tools

2.2 Data collected automatically:

• IP address
• Browser type and device information
• Approximate location
• Website usage data (pages visited, time on site)
• Cookies and tracking technologies

3. Purpose of Processing
We process your personal data for the following purposes:

• Responding to inquiries and providing services
• Scheduling meetings and consultations
• Managing business relationships
• Sending marketing communications (subject to your consent)
• Improving website performance and analytics
• Ensuring security and preventing fraud
• Complying with legal obligations

4. Legal Basis for Processing (GDPR)
We rely on the following legal bases:

• Consent (Art. 6(1)(a)) – for marketing communications and non-essential cookies
• Contract performance (Art. 6(1)(b)) – to provide requested services or consultations
• Legal obligation (Art. 6(1)(c))
• Legitimate interests (Art. 6(1)(f)) – improving our services, analyzing website usage, ensuring business development, and maintaining security, provided that such interests are not overridden by your rights and freedoms

5. Cookies and Tracking
We use cookies and similar technologies for:

• Essential cookies – required for website functionality
• Analytics cookies – to understand how users interact with the website
• Marketing cookies – for advertising and retargeting

Cookies may be stored for varying durations, up to a maximum of 24 months.
You can manage your cookie preferences through our cookie banner or browser settings.

6. Data Sharing
We may share personal data with:

• Service providers and partners
• Analytics and advertising platforms
• Legal authorities where required by law

All third parties process personal data under contractual obligations and appropriate safeguards.

7. Third-Party Services
We use the following third-party services:

• Google Ads (Google Ireland Ltd.) – advertising and conversion tracking
• LinkedIn Ads (LinkedIn Ireland Unlimited Company) – B2B marketing and retargeting
• Calendly (Calendly LLC) – meeting scheduling
• NetHunt CRM – customer relationship management
• Zapier – data automation and integrations

These providers may process personal data on our behalf in accordance with Data Processing Agreements.

8. International Data Transfers
Some of our service providers may process data outside the European Economic Area (EEA). In such cases, we ensure appropriate safeguards, including:

• Standard Contractual Clauses (SCCs)
• Transfers to countries with adequacy decisions

9. Data Retention
We retain personal data as follows:

• Contact requests: up to 12 months
• Client data: for the duration of the contract + 5 years
• Marketing data: until consent is withdrawn
• Analytics and cookies data: up to 24 months

10. Your Rights Under GDPR
You have the right to:

• Access your personal data (Art. 15)
• Rectify inaccurate data (Art. 16)
• Erase your data (Art. 17)
• Restrict processing (Art. 18)
• Data portability (Art. 20)
• Object to processing (Art. 21)
• Withdraw consent at any time

To exercise your rights, contact: contact@7sec.com
You also have the right to lodge a complaint with a supervisory authority in your country of residence.

11. Data Protection Officer
We have not appointed a Data Protection Officer, as it is not required under Article 37 GDPR.

12. Automated Decision-Making
We do not use automated decision-making or profiling that produces legal or similarly significant effects.

13. Data Security
We implement appropriate technical and organizational measures, including:

• SSL encryption
• Secure infrastructure
• Access control and internal policies

14. Changes to This Policy
We may update this Privacy Policy from time to time. The latest version will always be available on this page.

15. Contact
For any questions regarding this Privacy Policy:
📧 Email: contact@7sec.com
📍 Address: 7Security EOOD
47A Cherni Vrah Blvd., 5th floor,
Sofia, 1407, Bulgaria