Consent to the processing of personal data
Draft. The document is drafted in compliance with the requirements of Russian legislation and is subject to final legal review and approval prior to publication.
The legally binding version is the Russian edition of the document: Russian version. The translation is provided for convenience only and has no independent legal force.
This Consent to the processing of personal data (hereinafter — the "Consent") is given in accordance with Article 9 of the Federal Law No. 152-FZ dated July 27, 2006 "On Personal Data" (hereinafter — "152-FZ"). The Consent is provided by the subject of personal data freely, by their own will and in their own interest when submitting a request via feedback forms or the cost calculator on the lumux.ru website. Checking the corresponding field (checkbox) and submitting the request mean that the subject has read the terms of this Consent and the Privacy Policy and accepts them.
1. Personal Data Subject
The personal data subject (hereinafter referred to as the "Subject") is an individual who independently fills out and submits a request via feedback forms or the cost calculator on the lumux.ru website, providing their personal data.
By providing this Consent, the Subject confirms that they are acting on their own behalf, the data they have provided is accurate and relates to them personally, and in the case of providing data of third parties — that they have obtained their consent for such transfer and processing.
2. Personal Data Operator
The operator processing the Subject's personal data is:
- Individual Entrepreneur Pavel Yuryevich Kolomin
- INN: 971508170490
- OGRNIP: 318774600058786
- Legal address: [legal address to be confirmed]
- Phone: +7 925 525-55-66
- Email: hello@lumux.ru
- Telegram: t.me/lumux_smart
- Website: lumux.ru
The operator provides turnkey smart home system design, installation, and configuration services (lighting, climate control, security, multiroom audio) in Moscow and the Moscow region.
3. List of Personal Data
The Subject consents to the processing of the following personal data provided by them via feedback forms and the cost calculator:
- last name;
- name;
- contact phone number.
The email address is not requested or collected through website forms. The operator does not process special categories of personal data or biometric personal data.
Information about technical data (cookies, IP address, Yandex.Metrica web analytics service data) is processed under the terms described in the Privacy Policy. The IP address is used transiently — to protect against automated requests and limit request frequency — and is not saved as part of the request.
4. List of Actions with Personal Data and Processing Methods
The Subject consents to the Operator performing the following actions with the personal data specified in Section 3 of this Consent:
- collection;
- recording;
- systematization;
- accumulation;
- storage;
- clarification (update, modification);
- use;
- transfer (provision, access) — to the operator of the Bitrix24 cloud CRM system, located on the territory of the Russian Federation, for the purpose of recording and processing the request;
- deletion.
Processing of personal data is carried out using automation tools and without the use of such tools (mixed processing). The primary recording and storage of the Subject's personal data (last name, first name, contact phone number) are carried out in an information base located on the territory of the Russian Federation (Bitrix24), which ensures compliance with the requirements of Part 5, Article 18 of Federal Law No. 152-FZ (Federal Law No. 242-FZ).
On the website's technical infrastructure, the Subject's direct identifiers (last name, first name, contact phone number) are not stored — only anonymized request data is placed there: form type, calculation parameters, estimated amount, consent version, and consent timestamp. Cross-border transfer of personal data is not carried out.
5. Purposes of Personal Data Processing
The Subject's personal data is processed by the Operator solely for the following purposes:
- processing and support of the request submitted by the Data Subject on the website;
- conducting consultations on the Operator's services;
- calculating the estimated cost of services based on the parameters specified by the Subject;
- contacting the Subject via their chosen channel (phone call or messenger — Telegram, WhatsApp, or Max — depending on the specified preferred communication channel) to clarify the details of the request and coordinate further interaction.
Communication via messengers is initiated by the Subject and through the channel chosen by them; the Operator's response is sent manually. The website does not automatically transfer the Subject's personal data to messengers.
6. Legal Basis for Processing
The legal grounds for processing personal data are:
- Consent of the Data Subject to the processing of his/her personal data (clause 1, part 1, Article 6 of Federal Law No. 152-FZ);
- the necessity of performing actions preceding the conclusion of a contract or the performance of a service contract, of which the Data Subject is a party (clause 5, part 1, Article 6 of Federal Law No. 152-FZ).
7. No advertising mailings
This Consent does not apply to the processing of personal data for the purpose of promoting services on the market through direct contact with the Data Subject via communication channels (advertising mailings). The Operator does not request consent for receiving advertisements and informational mailings and does not send them to the Data Subject.
If the Operator intends to conduct promotional mailings in the future, separate voluntary consent from the Data Subject will be requested, which can be withdrawn at any time.
8. Validity Period of Consent and Procedure for Its Withdrawal
This Consent is effective from the moment it is provided (submission of the request) until the processing purposes specified in Section 5 are achieved, or until the Consent is withdrawn by the Data Subject, whichever occurs first. Upon achieving the processing purposes or upon expiration of the storage period, the personal data shall be deleted or anonymized.
Consent may be revoked by the Data Subject at any time. To revoke Consent, the Data Subject shall send a written statement in free form to the Operator by one of the following methods:
- by email: hello@lumux.ru;
- by phone: +7 925 525-55-66.
In the event of withdrawal of Consent, the Operator shall cease processing the Subject's personal data and ensure its deletion within a period not exceeding 30 (thirty) days from the date of receipt of the withdrawal, except for cases where processing must be continued in accordance with the legislation of the Russian Federation or for the performance of a concluded contract.
9. Rights of the Personal Data Subject
The Subject has the right to exercise the rights provided for in Article 14 of Federal Law No. 152-FZ, including:
- receive information regarding the processing of his/her personal data;
- request clarification, blocking, or destruction of their personal data if it is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing;
- revoke this Consent in the manner provided for in Section 8.
Inquiries regarding the exercise of rights should be sent to the Operator at the email address hello@lumux.ru or by phone at +7 925 525-55-66. A detailed description of the Data Subject's rights and the procedure for their exercise is provided in the Privacy Policy.
10. Consent text in website forms
When submitting a request via feedback forms or the cost calculator, the Subject confirms their consent by checking the corresponding box. The box is unchecked by default; consent is given by the Subject's active action.
Next to the consent field, the following text is placed: "By clicking the button, I give consent to the processing of personal data and accept the Privacy Policy".
Without the consent checkbox checked, the request cannot be sent and will not be processed.