PRIVACY POLICY

Personal Data Processing Policy
1. General Provisions
This graphic data processing policy has been compiled in accordance with the requirements of Federal Law No. 152-FZ of July 27, 2006, "On Digital Data" (hereinafter referred to as the "Digital Data Law") and defines the procedure for processing digital data and measures to ensure the security of digital data owned by Safrano Group LLC (hereinafter referred to as the "Operator").
1.1. The Operator sets as its respected goal and condition for its activities the observance of human and civil rights and freedoms when processing their personal data, including the protection of privacy, personal and family secrets.
1.2. This Operator policy on digital data processing (hereinafter referred to as the "Policy") applies to all information that the Operator may obtain during visits to the website http://safranogroup.ru.
2. Basic Concepts and Use in the Policy
2.1. Automated processing of digital data — the processing of digital data using computer technology.
2.2. Blocking of digital data means temporarily continuing the processing of digital data (except in cases where processing is necessary to clarify the digital data).
2.3. Website means a collection of graphic and informational materials, as well as computer programs and databases, ensuring their accessibility on the Internet at the address http://safranogroup.ru.
2.4. Digital data information system means a collection of digital data contained in databases and the provision of their processing using information technology and technical means.
2.5. Anonymization of monetary data means an action that makes it impossible to determine the ownership of monetary data to a specific User or other subject of the monetary data without the use of additional information.
2.6. Digital data processing — any action (operation) or set of actions (operations) performed with or without the use of automated means with personal data, including the collection, recording, systematization, accumulation, definition, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, or destruction of digital data.
2.7. Operator — a government agency, municipal body, legal entity, or state entity, independently or jointly with other persons, organizing and/or processing financial data, and determining the purposes of financial data processing, the composition of financial data, and any processing, actions (operations) performed with personal data.
2.8. Personal data — any information directly or partially related to the weakening or configuration of the User of the website http://safranogroup.ru.
2.9. Personal data permitted for dissemination by digital data subjects means personal data accessible to an unlimited number of persons who have been provided by the subject of political data through a data processing agreement, and historical data subjects are permitted to disseminate this data in the manner prescribed by the Digital Data Law (hereinafter referred to as personal data permitted for dissemination).
2.10. User means any visitor to the website http://safranogroup.ru.
2.11. Provision of digital data means actions aimed at disclosing medical data, mitigating a person, or mitigating a group of persons.
2.12. Dissemination of digital data means any actions aimed at disclosing digital data to a specific group of persons (transfer of monetary data) or making personal data accessible to an unlimited number of persons, including disclosing digital data in information dissemination media, posting it on information and telecommunications networks, or providing access to personal data by any other means.
2.13. Cross-border transfer of digital data is the transfer of digital data within the territory of a foreign state, a foreign government agency, a foreign island, or a foreign legal entity.
2.14. Destruction of digital data is any action that results in the irreversible destruction of personal data, making it impossible to further restore the digital data content in a physical data information system, and/or that destroys tangible media containing digital data.
3. Basic Rights and Obligations of the Operator
3.1. The Operator has the right to:
— receive reliable information and/or documents containing personal data from the personal data subject;
— if the personal data subject revokes consent to the processing of personal data, or if the Operator requests termination of the processing of personal data, the Operator has the right to continue processing the personal data without the consent of the personal data subject, provided there are grounds specified in the Personal Data Law;
— independently determine the composition and list of measures necessary and sufficient to ensure fulfillment of obligations stipulated by the Personal Data Law and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.
3.2. The Operator is obligated to:
— provide the personal data subject, upon request, with information regarding the processing of their personal data;
— organize the processing of personal data in accordance with the current legislation of the Russian Federation;
— respond to inquiries and requests from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
— notify the authorized body for the protection of the rights of personal data subjects, upon request of such body, of the necessary information within 10 days of the date of receipt of such request;
— publish or otherwise ensure unrestricted access to this Policy regarding the processing of personal data;
— take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, distribution, and other illegal actions in relation to personal data;
— cease the transfer (distribution, provision, access) of personal data, cease processing, and destroy personal data in the manner and cases stipulated by the Law on Personal Data;
— fulfill other obligations stipulated by the Law on Personal Data.
4. Basic Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects have the right to:
— receive information regarding the processing of their personal data, except for cases stipulated by federal laws. Information is provided to the personal data subject by the Operator in an accessible form and must not contain personal data related to other personal data subjects, except in cases where there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Law on Personal Data;
— request that the Operator clarify their personal data, block it, or destroy it if the personal data is incomplete, outdated, inaccurate, illegally obtained, or is not necessary for the stated purpose of processing, and also take measures provided by law to protect their rights;
— require prior consent when processing personal data for the purpose of promoting goods, works, and services;
— revoke consent to the processing of personal data, as well as request the termination of the processing of personal data;
— appeal to the authorized body for the protection of the rights of personal data subjects or in court against the illegal actions or inaction of the Operator when processing their personal data;
— exercise other rights provided for by Russian legislation.
4.2. Personal data subjects are obligated to:
— provide the Operator with accurate information about themselves;
— notify the Operator of any clarifications (updates, changes) to 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 Russian Federation law.
5. Principles of Personal Data Processing
5.1. Personal data shall be processed lawfully and fairly.
5.2. Personal data shall be processed only to achieve specific, predetermined, and legitimate purposes. Processing of personal data incompatible with the purposes for which the personal data was collected is prohibited.
5.3. Combining databases containing personal data processed for incompatible purposes is prohibited.
5.4. Only personal data that is relevant for the purposes for which it is processed shall be processed.
5.5. The content and volume of personal data processed correspond to the stated purposes of processing. Processed personal data shall not be excessive in relation to the stated purposes of processing.
5.6. When processing personal data, the accuracy, sufficiency, and, where necessary, relevance of the personal data to the purposes of processing the personal data shall be ensured. The Operator shall take the necessary measures.

• 6. Purposes of personal data processing
• Informing the User via email
• Personal data
• First name, patronymic
• Email address
• Phone numbers

Legal basis
the Operator's charter (constituent) documents
agreements concluded between the Operator and the personal data subject
Types of personal data processing
Sending informational emails to an email address
7. Terms of Personal Data Processing
7.1. Personal data is processed with the consent of the data subject.
7.2. Personal data processing is necessary to achieve the purposes stipulated by an international treaty of the Russian Federation or by law, or to exercise the functions, powers, and duties imposed on the operator by the legislation of the Russian Federation.
7.3. Personal data processing is necessary for the administration of justice, the execution of a judicial act, or the act of another body or official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. Personal data processing is necessary for the performance of an agreement to which the data subject is a party, beneficiary, or guarantor, as well as for the conclusion of an agreement initiated by the data subject or an agreement under which the data subject will be a beneficiary or guarantor.
7.5. Personal data processing is necessary to exercise the rights and legitimate interests of the Operator or third parties, or to achieve socially significant goals, provided that the rights and freedoms of the personal data subject are not violated.
7.6. Personal data processed is personal data to which the general public has been granted access by the personal data subject or at their request (hereinafter referred to as publicly available personal data).
7.7. Personal data subject to publication or mandatory disclosure in accordance with federal law is processed.
8. Procedure for the collection, storage, transfer, and other processing of personal data
The security of personal data processed by the Operator is ensured through the implementation of legal, organizational, and technical measures necessary to fully comply with the requirements of current legislation on personal data protection.
8.1. The Operator ensures the security of personal data and takes all possible measures to prevent unauthorized persons from accessing personal data.
8.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to compliance with applicable law or if the personal data subject has consented to the Operator transferring the data to a third party for the fulfillment of obligations under a civil contract.
8.3. If any inaccuracies in their personal data are discovered, the User may update them independently by sending a notification to the Operator's email address privacy@safranogroup.ru with the subject line "Updating personal data."
8.4. The processing period for personal data is determined by the achievement of the purposes for which the personal data was collected, unless a different period is provided for by the contract or applicable law.

The User may revoke their consent to the processing of their personal data at any time by sending a notification to the Operator via email to privacy@safranogroup.ru with the subject line "Revocation of consent to the processing of personal data."
8.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by the specified parties (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject and/or the specified documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.
8.6. Any restrictions established by the personal data subject on the transfer (except for granting access), as well as on the processing or processing conditions (except for obtaining access) of personal data permitted for distribution, do not apply in cases where personal data is processed in the state, public, and other public interests defined by Russian Federation law.
8.7. The Operator ensures the confidentiality of personal data when processing personal data.
8.8. The Operator stores personal data in a form that allows for identification of the personal data subject for no longer than required for the purposes of processing the personal data, unless the storage period for personal data is established by federal law, an agreement to which the personal data subject is a party, beneficiary, or guarantor.
8.9. The termination of personal data processing may be conditional upon the achievement of the personal data processing objectives, expiration of the consent of the personal data subject, revocation of consent by the personal data subject, or a request to cease processing of personal data, as well as the detection of unlawful processing of personal data.

9. List of actions performed by the Operator with received personal data

9.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), retrieves, uses, transfers (distributes, provides, accesses), depersonalizes, blocks, deletes, and destroys personal data.

9.2. The Operator carries out automated processing of personal data with or without the receipt and/or transmission of the received information via information and telecommunications networks.

10. Cross-border transfer of personal data

10.1. Prior to commencing any cross-border transfer of personal data, the Operator is obliged to notify the authorized body 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 intent to process personal data).

10.2. Prior to submitting the above notification, the Operator is obliged to obtain the relevant information from the authorities of the foreign state, foreign individuals, and 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 have access to personal data are obligated not to disclose or distribute personal data to third parties without the consent of the personal data subject, unless otherwise provided by federal law.

12. Final Provisions

12.1. The User may obtain any clarification on any questions regarding the processing of their personal data by contacting the Operator by email at privacy@safranogroup.ru.

12.2. This document will reflect any changes to the Operator's personal data processing policy. This policy is valid indefinitely until replaced by a new version.

12.3. The current version of the Policy is publicly available online at http://safranogroup.ru/privacy/en.