1. Scope
1.1. These terms determine the procedure for submitting documents, photographs and other files (hereinafter the Materials) to Individual Entrepreneur Andrei Viktorovich Svirin, Taxpayer Identification Number (INN) 772872317733, Primary State Registration Number of the Individual Entrepreneur (OGRNIP) 322774600176722 (hereinafter the Controller), through the inquiry form on the website https://complex.spb.ru/ and in subsequent correspondence concerning that inquiry.
1.2. Mailing address: P.O. Box 15, Moscow, 117647. Email address for matters relating to Materials and personal data: privacy@complex.spb.ru.
1.3. INN — Taxpayer Identification Number; OGRNIP — Primary State Registration Number of the Individual Entrepreneur.
2. Sender's Representations
2.1. When submitting Materials, the sender confirms that they obtained them lawfully and have the necessary right or other lawful basis to submit them to the Controller and allow the Controller to review them for the purpose of considering the inquiry.
2.2. If the sender acts on behalf of another person, they confirm that they have the appropriate authority. If the Materials contain other persons' personal data, information protected by law or objects of intellectual property rights, the sender ensures that an applicable basis exists for their submission and use within the scope of the inquiry. Consents and permissions required by law must be obtained before submission.
2.3. Upon a justified request from the Controller, the sender provides information and documents confirming their authority and the legal basis for submission. Before sending, they remove or conceal information that is not necessary for considering the inquiry.
2.4. The sender is liable for breaches of their obligations and the accuracy of their representations within the limits established by the legislation of the Russian Federation. These terms do not impose unconditional liability on the sender for any and all actions of the Controller and do not relieve the Controller of its own statutory obligations and liability.
3. Permitted Use of Materials
3.1. Within the scope of the sender's rights, submitting Materials authorizes the Controller to receive, review, technically copy, store, analyze and use them exclusively to the extent necessary to consider the inquiry, clarify the circumstances, make a preliminary assessment and prepare a reply. Personal data is processed only where a separate basis provided for by law exists.
3.2. Submitting Materials does not constitute assignment of exclusive rights and does not authorize their publication, independent advertising use, inclusion in publicly accessible databases or transmission to analytics services. Disclosure to other persons is permitted only to the extent necessary where an applicable basis exists, including to the technical processors specified in the Policy or in cases provided for by law.
3.3. If a contract is concluded, use of the Materials to provide the service is determined by the contract and applicable legal bases. The initial inquiry does not in itself confer a right to use any information for any research.
3.4. The sender's confirmation does not constitute consent by all persons mentioned in the Materials. The Controller independently verifies whether there is a sufficient basis for processing. If a lack of basis or excessive information is identified, use is restricted; unlawfully processed data is blocked and deleted within the statutory periods.
4. Retention and Deletion
4.1. Materials relating to an enquiry that does not lead to a contract, including copies in email and other systems used, are retained for no more than 90 calendar days from the last substantive message concerning the enquiry. If there is no further correspondence, the period runs from receipt of the enquiry. The materials are deleted when the purpose has been achieved or the period expires, unless there is an independent lawful basis for retaining them.
4.2. Temporary uploaded files are used to generate an email with attachments; the handler does not create a permanent public archive of these attachments. Temporary uploads are cleared by the server environment after the request has been completed. Copies of attachments in delivered emails remain subject to the established retention periods and must be deleted from all mail systems used.
4.3. If a contract is concluded, the necessary Materials and prepared documents are processed on the basis of the contract and legislation. Retention periods for mandatory accounting documents and information necessary to protect rights are determined separately. The existence of such a basis does not authorize retention of excessive Materials.
4.4. The sender or personal data subject may contact the Controller using its contact details concerning deletion of Materials. The request is considered with verification of authority and applicable retention bases. Minimal information about acceptance of these terms may be retained within the limits and on the bases specified in the Personal Data Processing Policy, without file contents or filenames.
5. Acceptance of the Terms
5.1. When uploading files, the sender independently selects a separate, previously unselected checkbox confirming lawful acquisition of and the right to submit the Materials, next to a link to these terms, and clicks the button to submit the inquiry. The Controller records the fact of acceptance, the date, the submission page and the version of the terms.
5.2. This checkbox confirms the terms for submitting Materials and does not replace separate consent to the processing of personal data. If no files are submitted, the Materials checkbox is not required.