1. GENERAL PROVISIONS
1.1. This Privacy & Personal Data Processing Policy (hereinafter — the “Policy”) is issued by Individual Entrepreneur Andrey Khodakov (Tax ID: 519053147204, hereinafter — the “Operator”) and describes how we collect, use, store, and protect personal data in accordance with applicable international privacy regulations, including the GDPR and other global data protection standards.
1.2. This Policy applies to all users (“Users”) of the website https://the-strategium.com
(hereinafter — the “Website”) within the Operator’s consulting and related business activities.
2. KEY TERMS
Personal Data — any information relating to an identified or identifiable individual.
Processing of Personal Data — any operation performed on personal data, including collection, storage, use, transfer, or deletion.
Operator / Controller — Individual Entrepreneur Andrey Khodakov, who independently determines the purposes and means of processing personal data.
3. TYPES OF PERSONAL DATA WE PROCESS
3.1. We may process the following categories of personal data provided by Users:

• Full name
• Contact details (phone number, email address)
• Professional information (job title, place of work)
• Any other data voluntarily submitted by the User (e.g., during form submissions)

3.2. The Website may also collect anonymized technical data using cookies and analytics services, including IP address, device information, browser type, and interaction logs.
4. PURPOSES OF DATA PROCESSING
4.1. We process personal data for the following purposes:

• To enter into and execute consulting service agreements
• To provide information about our services (with the User’s consent where required)
• To improve the quality, functionality, and user experience of the Website
• To respond to inquiries and provide customer support
• To conduct analytics and internal reporting

5. LEGAL BASIS FOR PROCESSING
5.1. We process personal data on one or more of the following legal grounds:

• User consent (e.g., when submitting forms or subscribing to updates)
• Performance of a contract or steps prior to entering into a contract
• Legitimate interests (e.g., improving services, preventing fraud)
• Compliance with applicable law

6. DATA PROCESSING AND SECURITY MEASURES
6.1. The Operator implements administrative, technical, and organizational measures to ensure the protection and confidentiality of personal data against unauthorized access, alteration, disclosure, or destruction.
6.2. Personal data may be transferred to third parties only when required by law or when such transfer is necessary to fulfill contractual obligations (e.g., use of third-party service providers acting under confidentiality obligations).
6.3. Cross-border transfers of data outside the User’s jurisdiction — where applicable — are carried out in compliance with international legal requirements, including GDPR-compliant safeguards (e.g., Standard Contractual Clauses).
7. USER RIGHTS
7.1. Users have the following rights regarding their personal data:

• Right to access — obtain a copy of their personal data.
• Right to rectification — request correction of inaccurate or incomplete data.
• Right to withdraw consent at any time (where processing is based on consent).
• Right to deletion (“right to be forgotten”) — request removal of personal data when legally applicable.
• Right to restrict processing under certain conditions.
• Right to data portability — receive data in a structured, machine-readable format.
• Right to object — challenge processing based on legitimate interests or direct marketing.

To exercise any of these rights, Users may contact us directly.
8. CONTACT INFORMATION
For any questions or requests related to personal data processing, please contact us at:
Email: strategium.info@inbox.ru
9. FINAL PROVISIONS
9.1. This Policy is effective indefinitely until replaced by a new version.
9.2. The most up-to-date version of this Policy is published on the Website at:
https://the-strategium.com/privacy-policy_en
Last updated: July 1, 2025