PERSONAL DATA PROCESSING POLICY

St. Petersburg

July 01, 2024

This Personal Data Processing Policy (hereinafter referred to as the "Policy") is developed in accordance with Federal Law No. 152-FZ dated July 27, 2006, "On Personal Data" (hereinafter referred to as the "Law No. 152-FZ"), and defines the procedure and conditions for processing personal data by the Contractor, acting as a personal data operator.

1. Basic Concepts

1.1. Personal data refers to any information related to a directly or indirectly identified or identifiable individual (subject of personal data).

1.2. Personal data processing refers to any action (operation) or set of actions (operations) performed using automation tools or without such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (update, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.

1.3. The Contractor (Operator) is Maria Sergeevna Kravchenko, a Russian citizen (TIN 519048377107), who independently or jointly with other persons organizes and (or) carries out the processing of personal data, as well as determines the purposes of personal data processing, the composition of personal data to be processed, and the actions (operations) performed with personal data.

1.4. The Customer (Subject of Personal Data) is an individual or legal entity (representative) who has provided their personal data to the Contractor for the purpose of concluding and executing a contract for the provision of design services (public offer).

1.5. The Website is an Internet website owned by the Contractor that is used for informing about activities and providing services.

2. Purposes of Personal Data Processing

2.1. The Contractor processes the Customer's personal data for the following purposes:

* Conclusion, execution, modification, and termination of civil law contracts (in accordance with the Public Offer).

* Identification of the Customer.

* Interaction with the Customer (including the sending of notifications, requests, and information related to the provision of services).

* Sending commercial and informational messages (if consent is granted).

* Compliance with the requirements of the legislation of the Russian Federation.

3. Legal Basis for Personal Data Processing

3.1. Personal data processing is carried out on the following legal grounds:

* Part 5, Article 6 of Federal Law No. 152-FZ: processing is necessary for the execution of a contract in which the subject of personal data is a party, a beneficiary, or a guarantor, as well as for the conclusion of a contract at the initiative of the subject of personal data.

* The subject of personal data has consented to the processing of their personal data (for purposes that are not directly related to the execution of the contract, such as sending advertisements).

4. Composition of the processed personal data

4.1. Depending on the purpose of processing, the Contractor may request and process the following data:

* For individuals: last name, first name, patronymic; contact information (email address, phone number, messenger accounts); details of the payment document.

* For representatives of legal entities: last name, first name, patronymic; position; contact information (work email address, phone number).

* Other data necessary for the provision of a specific service, provided by the Customer voluntarily during the correspondence.

5. Procedure and conditions for processing personal data

5.1. Personal data processing is carried out in accordance with the principles and rules established by Federal Law No. 152-FZ.

5.2. Personal data processing is carried out in a mixed manner (using automation tools and without their use).

5.3. The Contractor ensures the confidentiality of personal data and takes all necessary measures to protect it from unauthorized access, destruction, modification, blocking, and dissemination.

5.4. The period of personal data processing is limited to the duration of the Agreement and the reporting retention period established by the legislation of the Russian Federation, or until the subject of personal data revokes their consent (if the processing is based on consent).

5.5. Personal data is transferred to third parties only in cases provided for by the legislation of the Russian Federation, or with the consent of the subject of personal data. The Contractor may transfer data to authorized persons (such as payment systems) solely for the purpose of executing the Agreement.

6. Rights of the subject of personal data

6.1. The Customer, as a subject of personal data, has the right to:

* Access to their personal data.

* Clarify, block, or destroy their personal data if it is incomplete, outdated, inaccurate, illegally obtained, or not necessary for the stated purpose of processing.

* Revoke their consent to the processing of personal data.

* To protect their rights and legitimate interests, including judicial protection.

* To appeal against the Operator's actions or inaction to the authorized body for the protection of personal data subjects' rights.

7. Final Provisions

7.1. This Policy is a public document and is posted on the Contractor's Website.

7.2. The Contractor reserves the right to make changes to this Policy. The new version of the Policy becomes effective as soon as it is posted on the Website, unless otherwise specified.