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Consent to the processing of personal data permitted for dissemination

Consent under Article 10.1 of Law 152-FZ and Roskomnadzor Order No. 18, which the User gives when publishing a memory page or family website: list of data, conditions, prohibitions, and withdrawal procedure.

Revision of September 8, 2026, effective from the date of publication. Operator: Istoki LLC, INN 3666002895, OGRN 1033600016372.

Consent to the processing of personal data permitted by the personal data subject for dissemination

Drawn up in accordance with Article 10.1 of Federal Law No. 152-FZ of July 27, 2006 “On Personal Data” and Roskomnadzor Order No. 18 of February 24, 2021 “On Establishing Requirements for the Content of Consent to the Processing of Personal Data Permitted by the Personal Data Subject for Dissemination”.

1.This consent is given by the personal data subject separately from the consent to personal data processing and takes the form of the implied (conclusive) action “Publish” performed in the account with respect to a specific memory page or family website (Article 10.1(6) of Law 152-FZ); the Operator records the date, time and account from which the action was performed. Silence or inaction of the subject is not deemed consent (Article 10.1(8) of Law 152-FZ).

Operator detailsIstoki Limited Liability Company (Istoki LLC), INN 3666002895, OGRN 1033600016372, address: 394026, Russian Federation, Voronezh, ul. Solnechnaya, 33, office 155; email: support@central-archive.ru
Subject detailsThe User of the Aggregator platform account, identified by the email address of the account from which the “Publish” action was performed; surname, first name and patronymic — as stated in the “Personal details” section
Information resource on which the personal data is disseminatedthe website central-archive.ru: public memory pages at addresses of the form https://central-archive.ru/lk/#/memory/<address> and family websites at addresses assigned by the Service; QR codes leading to these pages
Purpose of processingpreserving and sharing family history at the subject's initiative: publishing a memory page about a person and a family website accessible via link and QR code to an unlimited number of persons

List of personal data and dissemination conditions

2.The subject permits the dissemination of the following categories of personal data (Article 10.1(9) of Law 152-FZ):

Personal data categoryListPermission to disseminate
General personal data of the subject and of persons included by the subject in the contentsurname, first name, patronymic (including maiden name); years (dates) and places of birth and death; places of residence; occupation; information on family relationships; biographical information set out in the text of the pageyes — to the extent included by the subject in the published page
Imagesphotographs and video recordings uploaded by the subject to the published content (Article 152.1 of the Civil Code of the Russian Federation)yes — to the extent included by the subject in the published page
Voice recordingsrecordings of interviews, stories, songsyes — to the extent included by the subject in the published page
Special categories of personal datareligion, ethnicity, health statusonly if the subject has included them in the text; otherwise — no
Contact, passport and payment details, email address, phone numberno — not published
Information contained in the research questionnaire, documents and correspondence that the subject has not included in the published pageno

3.By including information and images of third parties (relatives) in the published page, the subject confirms that they have obtained those persons' consent to the disclosure and use of their image and information (Articles 152.1 and 152.2 of the Civil Code of the Russian Federation), and, with respect to deceased persons, the consent of their children and surviving spouse or, in their absence, their parents (Article 152.1(1) of the Civil Code of the Russian Federation), or that they act as an heir, and assumes liability toward those persons.

Conditions and prohibitions, term

4.The subject establishes the following dissemination conditions: the personal data may be viewed by an unlimited number of persons who have received the link or scanned the QR code; the Operator does not list published pages in catalogs and does not deliberately submit them to search engines, but the pages may be indexed by search engines if external links to them exist.

5.Prohibitions and conditions established by the subject: third parties are prohibited from processing the disseminated personal data for purposes other than familiarization with the family history (including copying, commercial use, and inclusion in databases), except in cases provided for by law (Article 10.1(9) and (10) of Law 152-FZ). The subject may establish additional conditions and prohibitions and restrict the range of persons by sending a request to the Operator; the Operator ensures compliance with these conditions by publishing information about the conditions and prohibitions on the page within 3 business days of receiving the request (Article 10.1(10) of Law 152-FZ).

6.The Operator disseminates personal data only to the extent and on the conditions determined by the subject and may not transfer it to third parties for purposes not specified in this consent.

7.The consent is effective from the moment the “Publish” action is performed until it is withdrawn by the subject, the page is unpublished, or the account is deleted.

Withdrawal of consent and termination of dissemination

8.The subject may withdraw the consent at any time (Article 10.1(12) of Law 152-FZ) by performing the “Unpublish” action in the account (the page immediately ceases to be accessible via the link and QR code) or by sending a demand to terminate dissemination to support@central-archive.ru or to the Operator's postal address. The demand must contain the subject's surname, first name and patronymic, contact information, the list of personal data whose processing is to be terminated (the page address), and a signature (Article 10.1(14) of Law 152-FZ).

9.The Operator terminates the dissemination (transfer, provision, access) of the personal data within 3 business days of receiving the demand, or within the period specified in a court decision that has entered into legal force (Article 10.1(14) of Law 152-FZ). Withdrawal of the consent does not affect the lawfulness of dissemination carried out before the withdrawal.

10.A person whose personal data has been published on a page by another User may send the Operator a demand to terminate dissemination in the manner set out in paragraph 8; the Operator restricts access to the page pending clarification of the circumstances and notifies the User who published it.

Operator details
Limited Liability Company “Istoki” (Istoki LLC)
INN 3666002895 / KPP 366201001 · OGRN 1033600016372
Registered address: 33 Solnechnaya St., office 155, Voronezh, 394026, Russian Federation
Mailing address: 31a Solnechnaya St., office 14 (Solnechny Alliance Business Center), Voronezh, 394026
Account No. 40702810613000000191 with the Central Black Earth Bank of Sberbank PJSC, Voronezh, correspondent account 30101810600000000681, BIC 042007681
Phone: +7 (473) 239-55-56, 8 800 550-58-90 · Email: support@central-archive.ru
General Director Pavel Andreevich Ovchinnikov, acting under the Charter