Personal Data Processing Policy
Last Updated: April 15, 2026
1. General Provisions
This Personal Data Processing Policy (hereinafter referred to as the "Policy") defines the procedure for processing personal data and the measures to ensure the security of personal data undertaken by Technologic LLC (hereinafter referred to as the "Operator").
1.1. The Operator’s primary goal and condition for carrying out its activities is to uphold the rights and freedoms of individuals and citizens when processing their personal data, including the protection of the rights to privacy, personal, and family secrets.
1.2. This Policy of the Operator regarding the processing of personal data applies to all information that the Operator may obtain about visitors to the website at https://skyward.cc.
1.3. Technologic LLC is the legal owner of the Skyward trademark ("Skyward"). This Policy applies to the website operated under this trademark at https://skyward.cc.
2. Basic Terms Used in the Policy
2.1. Automated processing of personal data – processing of personal data using computer technology.
2.2. Blocking of personal data – temporary cessation of processing of personal data (except where processing is necessary to clarify personal data).
2.3. Website – a collection of graphic and informational materials, as well as computer programs and databases, ensuring their availability on the internet at the network address https://skyward.cc.
2.4. Personal data information system – a collection of personal data contained in databases, along with information technologies and technical means ensuring their processing.
2.5. Depersonalization of personal data – actions as a result of which it becomes impossible to determine the ownership of personal data to a specific User or other personal data subject without the use of additional information.
2.6. Processing of personal data – any action (operation) or set of actions (operations) performed using automation means or without such means with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), retrieval, 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, organizing and/or carrying out the processing of personal data independently or jointly with other persons, as well as determining the purposes of processing personal data, the composition of personal data to be processed, and the actions (operations) performed with personal data.
2.8. Personal data – any information relating directly or indirectly to a specific or identifiable User of the website https://skyward.cc.
2.9. Personal data authorized for dissemination by the personal data subject – personal data to which access by an unrestricted circle of persons has been granted by the personal data subject by giving consent to the processing of personal data authorized for dissemination by the personal data subject in the legally prescribed manner (hereinafter referred to as "personal data authorized for dissemination").
2.10. User – any visitor to the website https://skyward.cc.
2.11. Provision of personal data – actions aimed at disclosing personal data to a specific person or a specific circle of persons.
2.12. Distribution of personal data – any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or at making personal data available to an unlimited circle of persons, including publication of personal data in the mass media, placement in information and telecommunication networks, or providing access to personal data in any other way.
2.13. Cross-border transfer of personal data – transfer of personal data to the territory of a foreign state to a foreign state authority, a foreign individual, or a foreign legal entity.
2.14. Destruction of personal data – any actions as a result of which personal data are permanently destroyed with no possibility of further restoration of the content of personal data in the personal data information system and/or the physical media of personal data are destroyed.
3. Core Rights and Obligations of the Operator
3.1. The Operator has the right to:
3.2. The Operator is obliged to:
4. Core Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects have the right to:
4.2. Personal data subjects are obliged to:
4.3. Persons who provide the Operator with inaccurate information about themselves or information about another personal data subject without the latter's consent shall be liable in accordance with applicable law.
5. Principles of Personal Data Processing
5.1. Processing of personal data is carried out on a lawful and fair basis.
5.2. Processing of personal data is limited to achieving specific, predetermined, and lawful purposes. Processing of personal data incompatible with the purposes of collecting personal data is not permitted.
5.3. Combining databases containing personal data processed for mutually incompatible purposes is not permitted.
5.4. Only personal data that meets the purposes of their processing are subject to processing.
5.5. The content and scope of the processed personal data correspond to the stated purposes of processing. Redundancy of processed personal data relative to the stated purposes of their processing is not permitted.
5.6. When processing personal data, the accuracy, sufficiency, and, where necessary, relevance of personal data in relation to the purposes of processing personal data are ensured. The Operator takes necessary measures and/or ensures that they are taken to remove or clarify incomplete or inaccurate data.
5.7. Personal data is stored in a form that permits identification of the personal data subject for no longer than required by the purposes of processing personal data, unless the storage period for personal data is established by law or a contract to which the personal data subject is a party, beneficiary, or guarantor. Processed personal data is destroyed or depersonalized upon achievement of the processing purposes or in the event that the necessity for achieving these purposes is lost, unless otherwise provided by law.
6. Purposes of Personal Data Processing
7. Conditions for Processing Personal Data
7.1. Processing of personal data is carried out with the consent of the personal data subject to the processing of their personal data.
7.2. Processing of personal data is necessary to achieve the purposes provided for by an international treaty or by law, or to carry out functions, powers, and duties imposed on the Operator by law.
7.3. Processing of personal data is necessary for the administration of justice, enforcement of a judicial act, an act of another body or official subject to enforcement in accordance with applicable law.
7.4. Processing of personal data is necessary for the performance of a contract to which the personal data subject is a party, beneficiary, or guarantor, as well as for concluding a contract at the initiative of the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor.
7.5. Processing of personal data is necessary for the exercise of the rights and legitimate interests of the Operator or third parties, or for achieving socially significant goals, provided that the rights and freedoms of the personal data subject are not violated.
7.6. Processing of personal data to which access by an unrestricted circle of persons is granted by the personal data subject or at their request (hereinafter referred to as "publicly available personal data") is carried out.
7.7. Processing of personal data subject to publication or mandatory disclosure in accordance with law is carried out.
8. Procedure for Collection, Storage, Transfer, and Other Types of Processing of Personal Data
The security of personal data processed by the Operator is ensured by implementing legal, organizational, and technical measures necessary to fully comply with the requirements of applicable legislation in the field of personal data protection.
8.1. The Operator ensures the integrity of personal data and takes all possible measures to prevent access to personal data by unauthorized persons.
8.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to the execution of applicable law or where the personal data subject has given consent to the Operator to transfer data to a third party for the performance of obligations under a civil law contract.
8.3. If inaccuracies in personal data are identified, the User may update them independently by sending a notification to the Operator’s email address info@skyward.cc marked "Personal Data Update."
8.4. The period for processing personal data is determined by the achievement of the purposes for which the personal data were collected, unless a different period is provided for by contract or applicable law. The User may withdraw their consent to the processing of personal data at any time by sending a notification to the Operator via email at info@skyward.cc marked "Withdrawal of Consent to Personal Data Processing."
8.5. All information collected by third-party services, including payment systems, communication means, and other service providers, is stored and processed by such persons (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject should review these documents. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this clause.
8.6. Prohibitions established by the personal data subject on the transfer (except for granting access), as well as on the processing or conditions of processing (except for obtaining access) of personal data authorized for dissemination, shall not apply in cases of processing of personal data in state, public, or other public interests determined by applicable law.
8.7. The Operator ensures the confidentiality of personal data when processing them.
8.8. The Operator stores personal data in a form that permits identification of the personal data subject for no longer than required by the purposes of processing personal data, unless the storage period for personal data is established by law or a contract to which the personal data subject is a party, beneficiary, or guarantor.
8.9. The cessation of personal data processing may result from achieving the purposes of processing personal data, expiry of the consent period by the personal data subject, withdrawal of consent by the personal data subject or a request to cease processing personal data, as well as the discovery of unlawful processing of personal data.
9. List of Actions Performed by the Operator with Obtained Personal Data
9.1. The Operator carries out the collection, recording, systematization, accumulation, storage, clarification (updating, changing), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
9.2. The Operator carries out automated processing of personal data, with or without the receipt and/or transmission of the information obtained via information and telecommunication networks.
10. Cross-Border Transfer of Personal Data
10.1. Prior to commencing activities involving the cross-border transfer of personal data, the Operator is obliged to notify the competent authority for the protection of the rights of personal data subjects of its intention to carry out the cross-border transfer of personal data (such notification is sent separately from the notification of intention to process personal data), if required by applicable law.
10.2. Before submitting the aforementioned notification (where required), the Operator is obliged to obtain relevant information from the foreign state authorities, foreign individuals, or foreign legal entities to whom the cross-border transfer of personal data is planned.
11. Confidentiality of Personal Data
The Operator and other persons who obtain access to personal data are obliged not to disclose personal data to third parties or distribute personal data without the consent of the personal data subject, unless otherwise provided by applicable law.
12. Final Provisions
12.1. The User may obtain any clarifications on questions of interest regarding the processing of their personal data by contacting the Operator via email at info@skyward.cc.
12.2. Operator Contact Information:
Technologick LLC (owner of the Skyward trademark)
Email: info@skyward.cc.
Phone: +7 (930) 270-2754
12.3. Any changes to the Operator's personal data processing policy will be reflected in this document. The Policy is valid indefinitely until replaced by a new version.
12.4. The current version of the Policy is freely available on the internet at https://skyward.cc/privacy (or relevant path).
Last Updated: April 15, 2026
1. General Provisions
This Personal Data Processing Policy (hereinafter referred to as the "Policy") defines the procedure for processing personal data and the measures to ensure the security of personal data undertaken by Technologic LLC (hereinafter referred to as the "Operator").
1.1. The Operator’s primary goal and condition for carrying out its activities is to uphold the rights and freedoms of individuals and citizens when processing their personal data, including the protection of the rights to privacy, personal, and family secrets.
1.2. This Policy of the Operator regarding the processing of personal data applies to all information that the Operator may obtain about visitors to the website at https://skyward.cc.
1.3. Technologic LLC is the legal owner of the Skyward trademark ("Skyward"). This Policy applies to the website operated under this trademark at https://skyward.cc.
2. Basic Terms Used in the Policy
2.1. Automated processing of personal data – processing of personal data using computer technology.
2.2. Blocking of personal data – temporary cessation of processing of personal data (except where processing is necessary to clarify personal data).
2.3. Website – a collection of graphic and informational materials, as well as computer programs and databases, ensuring their availability on the internet at the network address https://skyward.cc.
2.4. Personal data information system – a collection of personal data contained in databases, along with information technologies and technical means ensuring their processing.
2.5. Depersonalization of personal data – actions as a result of which it becomes impossible to determine the ownership of personal data to a specific User or other personal data subject without the use of additional information.
2.6. Processing of personal data – any action (operation) or set of actions (operations) performed using automation means or without such means with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), retrieval, 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, organizing and/or carrying out the processing of personal data independently or jointly with other persons, as well as determining the purposes of processing personal data, the composition of personal data to be processed, and the actions (operations) performed with personal data.
2.8. Personal data – any information relating directly or indirectly to a specific or identifiable User of the website https://skyward.cc.
2.9. Personal data authorized for dissemination by the personal data subject – personal data to which access by an unrestricted circle of persons has been granted by the personal data subject by giving consent to the processing of personal data authorized for dissemination by the personal data subject in the legally prescribed manner (hereinafter referred to as "personal data authorized for dissemination").
2.10. User – any visitor to the website https://skyward.cc.
2.11. Provision of personal data – actions aimed at disclosing personal data to a specific person or a specific circle of persons.
2.12. Distribution of personal data – any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or at making personal data available to an unlimited circle of persons, including publication of personal data in the mass media, placement in information and telecommunication networks, or providing access to personal data in any other way.
2.13. Cross-border transfer of personal data – transfer of personal data to the territory of a foreign state to a foreign state authority, a foreign individual, or a foreign legal entity.
2.14. Destruction of personal data – any actions as a result of which personal data are permanently destroyed with no possibility of further restoration of the content of personal data in the personal data information system and/or the physical media of personal data are destroyed.
3. Core Rights and Obligations of the Operator
3.1. The Operator has the right to:
- receive from the personal data subject accurate information and/or documents containing personal data;
- if the personal data subject withdraws consent to the processing of personal data, or sends a request demanding the cessation of processing of personal data, the Operator has the right to continue processing personal data without the consent of the personal data subject if there are legal grounds for doing so;
- independently determine the composition and list of measures necessary and sufficient to ensure compliance with the obligations stipulated by applicable law, unless otherwise provided by law.
3.2. The Operator is obliged to:
- provide the personal data subject, upon their request, with information regarding the processing of their personal data;
- organize the processing of personal data in accordance with the procedure established by applicable legislation;
- respond to requests and inquiries from personal data subjects and their legal representatives in accordance with legal requirements;
- notify the competent authority for the protection of the rights of personal data subjects, upon request from that authority, of the necessary information within the legally prescribed time limit;
- publish or otherwise provide unrestricted access to this Policy regarding the processing of personal data;
- adopt legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, alteration, blocking, copying, provision, distribution, as well as from other unlawful actions with respect to personal data;
- cease the transfer (distribution, provision, access) of personal data, cease processing and destroy personal data in the manner and cases provided for by applicable law;
- perform other duties stipulated by applicable law.
4. Core Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects have the right to:
- receive information concerning the processing of their personal data, except in cases provided for by law. Such information is provided by the Operator to the personal data subject in an accessible form and must not contain personal data relating to other personal data subjects, except where there are legal grounds for disclosing such personal data;
- request that the Operator clarify, block, or destroy their personal data if the personal data are incomplete, outdated, inaccurate, unlawfully obtained, or are not necessary for the stated purpose of processing, as well as take legally prescribed measures to protect their rights;
- impose a condition of prior consent when processing personal data for the purpose of marketing goods, works, and services;
- withdraw consent to the processing of personal data, as well as submit a request demanding the cessation of processing of personal data;
- appeal against the unlawful actions or inaction of the Operator in processing their personal data to the competent authority or in court;
- exercise other rights provided for by applicable law.
4.2. Personal data subjects are obliged to:
- provide the Operator with accurate data about themselves;
- inform the Operator of any clarification (updating, change) of their personal data.
4.3. Persons who provide the Operator with inaccurate information about themselves or information about another personal data subject without the latter's consent shall be liable in accordance with applicable law.
5. Principles of Personal Data Processing
5.1. Processing of personal data is carried out on a lawful and fair basis.
5.2. Processing of personal data is limited to achieving specific, predetermined, and lawful purposes. Processing of personal data incompatible with the purposes of collecting personal data is not permitted.
5.3. Combining databases containing personal data processed for mutually incompatible purposes is not permitted.
5.4. Only personal data that meets the purposes of their processing are subject to processing.
5.5. The content and scope of the processed personal data correspond to the stated purposes of processing. Redundancy of processed personal data relative to the stated purposes of their processing is not permitted.
5.6. When processing personal data, the accuracy, sufficiency, and, where necessary, relevance of personal data in relation to the purposes of processing personal data are ensured. The Operator takes necessary measures and/or ensures that they are taken to remove or clarify incomplete or inaccurate data.
5.7. Personal data is stored in a form that permits identification of the personal data subject for no longer than required by the purposes of processing personal data, unless the storage period for personal data is established by law or a contract to which the personal data subject is a party, beneficiary, or guarantor. Processed personal data is destroyed or depersonalized upon achievement of the processing purposes or in the event that the necessity for achieving these purposes is lost, unless otherwise provided by law.
6. Purposes of Personal Data Processing
Purpose of Processing | Informing the User via email |
Personal Data | Last name, first name Email address |
Legal Grounds | Operator's constituent (founding) documents |
Types of Processing | Collection, recording, systematization, accumulation, storage, destruction, and depersonalization of personal data Sending informational emails to the email address |
7. Conditions for Processing Personal Data
7.1. Processing of personal data is carried out with the consent of the personal data subject to the processing of their personal data.
7.2. Processing of personal data is necessary to achieve the purposes provided for by an international treaty or by law, or to carry out functions, powers, and duties imposed on the Operator by law.
7.3. Processing of personal data is necessary for the administration of justice, enforcement of a judicial act, an act of another body or official subject to enforcement in accordance with applicable law.
7.4. Processing of personal data is necessary for the performance of a contract to which the personal data subject is a party, beneficiary, or guarantor, as well as for concluding a contract at the initiative of the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor.
7.5. Processing of personal data is necessary for the exercise of the rights and legitimate interests of the Operator or third parties, or for achieving socially significant goals, provided that the rights and freedoms of the personal data subject are not violated.
7.6. Processing of personal data to which access by an unrestricted circle of persons is granted by the personal data subject or at their request (hereinafter referred to as "publicly available personal data") is carried out.
7.7. Processing of personal data subject to publication or mandatory disclosure in accordance with law is carried out.
8. Procedure for Collection, Storage, Transfer, and Other Types of Processing of Personal Data
The security of personal data processed by the Operator is ensured by implementing legal, organizational, and technical measures necessary to fully comply with the requirements of applicable legislation in the field of personal data protection.
8.1. The Operator ensures the integrity of personal data and takes all possible measures to prevent access to personal data by unauthorized persons.
8.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to the execution of applicable law or where the personal data subject has given consent to the Operator to transfer data to a third party for the performance of obligations under a civil law contract.
8.3. If inaccuracies in personal data are identified, the User may update them independently by sending a notification to the Operator’s email address info@skyward.cc marked "Personal Data Update."
8.4. The period for processing personal data is determined by the achievement of the purposes for which the personal data were collected, unless a different period is provided for by contract or applicable law. The User may withdraw their consent to the processing of personal data at any time by sending a notification to the Operator via email at info@skyward.cc marked "Withdrawal of Consent to Personal Data Processing."
8.5. All information collected by third-party services, including payment systems, communication means, and other service providers, is stored and processed by such persons (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject should review these documents. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this clause.
8.6. Prohibitions established by the personal data subject on the transfer (except for granting access), as well as on the processing or conditions of processing (except for obtaining access) of personal data authorized for dissemination, shall not apply in cases of processing of personal data in state, public, or other public interests determined by applicable law.
8.7. The Operator ensures the confidentiality of personal data when processing them.
8.8. The Operator stores personal data in a form that permits identification of the personal data subject for no longer than required by the purposes of processing personal data, unless the storage period for personal data is established by law or a contract to which the personal data subject is a party, beneficiary, or guarantor.
8.9. The cessation of personal data processing may result from achieving the purposes of processing personal data, expiry of the consent period by the personal data subject, withdrawal of consent by the personal data subject or a request to cease processing personal data, as well as the discovery of unlawful processing of personal data.
9. List of Actions Performed by the Operator with Obtained Personal Data
9.1. The Operator carries out the collection, recording, systematization, accumulation, storage, clarification (updating, changing), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
9.2. The Operator carries out automated processing of personal data, with or without the receipt and/or transmission of the information obtained via information and telecommunication networks.
10. Cross-Border Transfer of Personal Data
10.1. Prior to commencing activities involving the cross-border transfer of personal data, the Operator is obliged to notify the competent authority for the protection of the rights of personal data subjects of its intention to carry out the cross-border transfer of personal data (such notification is sent separately from the notification of intention to process personal data), if required by applicable law.
10.2. Before submitting the aforementioned notification (where required), the Operator is obliged to obtain relevant information from the foreign state authorities, foreign individuals, or foreign legal entities to whom the cross-border transfer of personal data is planned.
11. Confidentiality of Personal Data
The Operator and other persons who obtain access to personal data are obliged not to disclose personal data to third parties or distribute personal data without the consent of the personal data subject, unless otherwise provided by applicable law.
12. Final Provisions
12.1. The User may obtain any clarifications on questions of interest regarding the processing of their personal data by contacting the Operator via email at info@skyward.cc.
12.2. Operator Contact Information:
Technologick LLC (owner of the Skyward trademark)
Email: info@skyward.cc.
Phone: +7 (930) 270-2754
12.3. Any changes to the Operator's personal data processing policy will be reflected in this document. The Policy is valid indefinitely until replaced by a new version.
12.4. The current version of the Policy is freely available on the internet at https://skyward.cc/privacy (or relevant path).