Personal data processing policy

1. General Provisions

1.1 This personal data processing policy is formulated in accordance with the provisions of Federal Law No. 152-FZ, dated 27.07.2006, known as the "On Personal Data" law (hereinafter referred to as the Personal Data Law). It outlines the procedures for personal data processing and the measures implemented by "Avelan" LLC (OGRN 1097746049455), referred to henceforth as the Operator.

1.2 The Operator's primary goal and commitment in its activities are to uphold human and civil rights and freedoms during the processing of personal data. This includes safeguarding the rights to privacy, personal, and family confidentiality.

1.3 This Policy, governing the processing of personal data by the Operator (hereinafter referred to as the Policy), applies to all information collected by the Operator from visitors to the website https://avelan.ru.

2. Basic Concepts Used in the Policy

2.1 Automated Processing of Personal Data - Refers to the processing of personal data using computer equipment.

2.2 Blocking Personal Data - Temporary cessation of personal data processing, except in cases where processing is necessary to clarify personal data.

2.3 Website - Comprises a collection of graphic and informational materials, along with computer programs and databases, ensuring their accessibility on the Internet at the network address https://avelan.ru.

2.4 Personal Data Information System - Encompasses a collection of personal data stored in databases, along with information technologies and technical means facilitating their processing.

2.5 Personal Data Depersonalization - Denotes actions resulting in the inability to determine, without additional information, whether personal data belong to a specific User or other subject of personal data.

2.6 Processing of Personal Data - Refers to any action (operation) or set of actions (operations) carried out with or without the use of automation means involving personal data. These actions include but are not limited to collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.

2.7 Operator - Designates a state authority, municipal authority, legal entity, or individual, acting independently or in collaboration with others, responsible for organizing and/or conducting the processing of personal data. Additionally, the Operator determines the purposes of personal data processing, the scope of personal data subject to processing, and the actions (operations) performed with personal data.

2.8 Personal Data - Encompasses any information directly or indirectly related to a specific or identifiable User of the https://avelan.ru website.

2.9 Personal Data Authorized by the Data Subject for Dissemination - Refers to personal data for which the data subject has granted access to an unlimited number of individuals by consenting to the processing of personal data in a manner prescribed by the Personal Data Law. These are henceforth referred to as personal data authorized for dissemination.

2.10 User - Denotes any individual visiting the website https://avelan.ru.

2.11 Provision of Personal Data - Refers to actions aimed at disclosing personal data to a specific individual or a specific group of individuals.

2.12 Dissemination of Personal Data - Encompasses any actions aimed at disclosing personal data to an indefinite number of individuals (personal data transfer) or making personal data accessible to an unlimited number of individuals. This includes the disclosure of personal data in mass media, posting in information and telecommunication networks, or providing access to personal data through any other means.

2.13 Cross-Border Transfer of Personal Data - Involves the transfer of personal data to the territory of a foreign country, including to foreign government authorities, foreign individuals, or foreign legal entities.

2.14 Destruction of Personal Data - Entails any actions resulting in the irreversible destruction of personal data, rendering the content of personal data in the personal data information system and/or material carriers of personal data irrecoverable.

3. Basic Rights and Obligations of the Operator

3.1 The Operator has the following rights:

— To receive reliable information and/or documents containing personal data from the data subject.

— In cases where the data subject revokes their consent to the processing of personal data or submits a request to cease processing, the Operator reserves the right to continue processing personal data without the consent of the data subject if grounds specified in the Personal Data Law exist.

— To independently determine the composition and list of measures necessary and sufficient to fulfill 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 data subject, upon their request, with information regarding the processing of their personal data.

— Organize the processing of personal data in accordance with the procedures established by the current legislation of the Russian Federation.

— Respond to appeals and requests from personal data subjects and their legal representatives in accordance with the requirements of the Law on Personal Data.

— Report to the authorized body for the protection of the rights of personal data subjects, upon request, with the necessary information within 10 days from the date of receiving such a request.

— Publish or provide unrestricted access to this Policy on personal data processing.

— Implement legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision, dissemination, and other unlawful actions.

— Cease the transfer (dissemination, provision, access), processing, and destroy personal data in the manner and cases stipulated by the Personal Data Law.

— Fulfill other obligations stipulated by the Personal Data Law.

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 in cases provided for by federal laws. The Operator must provide this information to the data subject in an accessible form and it must not contain personal data relating to other subjects of personal data unless there are legal grounds for such disclosure. The list of information and the procedure for obtaining it are established by the Law on Personal Data.

— Demand from the Operator clarification of their personal data, as well as request the blocking or deletion of it if the personal data is incomplete, outdated, inaccurate, unlawfully obtained, or no longer necessary for the stated purpose of processing. Personal data subjects also have the right to take legal measures to protect their rights.

— Impose a condition of prior consent when processing personal data for the marketing of goods, works, and services.

— Withdraw consent for the processing of personal data, as well as submit a request to cease the processing of personal data.

— Appeal to the authorized body for the protection of the rights of personal data subjects or to court against unlawful acts or omissions of the Operator in the processing of their personal data.

— Exercise other rights provided for by the legislation of the Russian Federation.

4.2 Personal data subjects are obligated to:

— Provide the Operator with accurate and reliable data about themselves.

— Notify the Operator of any changes or updates to their personal data.

4.3 Individuals who provide the Operator with false information about themselves or information about another subject of personal data without the latter's consent shall be liable in accordance with the legislation of the Russian Federation..

5. Principles of Personal Data Processing

5.1 Personal data processing is conducted on a lawful and fair basis.

5.2 Personal data processing is limited to achieving specific, predetermined, and legitimate purposes. Processing personal data incompatible with the purposes of data collection is prohibited.

5.3 Merging databases containing personal data processed for incompatible purposes is prohibited.

5.4 Only personal data that aligns with the purposes of processing shall be processed.

5.5 The content and scope of processed personal data must correspond to the stated purposes of processing. Redundancy of processed personal data in relation to the stated purposes is prohibited.

5.6 During personal data processing, the accuracy, sufficiency, and, when necessary, relevance of personal data to the processing purposes shall be ensured. The Operator shall take necessary measures and/or ensure their adoption to delete or clarify incomplete or inaccurate data.

5.7 Storage of personal data is conducted in a format that allows for the identification of the data subject and for no longer than required by the purposes of personal data processing, unless the period of storage is established by federal law, contract, or a party to which, beneficiary, or guarantor of which is the data subject. Processed personal data shall be destroyed or depersonalized upon the achievement of the processing purposes or when there is no longer a need to achieve these purposes, unless otherwise stipulated by federal law.

6. Purposes of Personal Data Processing

6.1 The purpose of processing personal data is the conclusion, execution, and termination of civil law contracts in accordance with the Federal Law "On Information, Information Technologies, and Information Protection" of July 27, 2006, No. 149-FZ, and subsequent regulations.

6.2 The personal data processed include:

— Surname, first name, patronymic.

— Email address.

— Contact phone number.

7. Conditions of Personal Data Processing

7.1 Personal data processing is carried out with the consent of the data subject to the processing of their personal data.

7.2 Personal data processing is necessary to achieve purposes provided for by international treaties of the Russian Federation or by law, to fulfill the functions, powers, and obligations imposed on the operator by the legislation of the Russian Federation.

7.3 Personal data processing is necessary for the administration of justice, execution of a judicial act, or an act of another body or official subject to enforcement in accordance with the legislation of the Russian Federation on enforcement proceedings.

7.4 Personal data processing is necessary for the execution of an agreement to which the data subject is a party or a beneficiary or guarantor, as well as for the initiation of an agreement 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 for the exercise of the rights and legitimate interests of the operator or third parties, or for the achievement of socially important purposes, provided that the rights and freedoms of the data subject are not violated.

7.6 Personal data processing is carried out for publicly available personal data, where access is granted by the data subject or at their request.

7.7 Processing of personal data subject to publication or mandatory disclosure in accordance with federal law.

8. Procedure for Collection, Storage, Transfer, and Other Types of Personal Data Processing

8.1 The security of personal data processed by the Operator is ensured by implementing legal, organizational, and technical measures necessary for full compliance with the requirements of applicable legislation in the field of personal data protection.

8.2 The Operator shall ensure the safety of personal data and take all possible measures to prevent unauthorized access to personal data.

8.3 The User's personal data will never, under any circumstances, be transferred to third parties, except in cases required by current legislation or if the data subject has provided consent to the Operator to transfer the data to a third party for fulfilling obligations under a civil law contract.

8.4 If any inaccuracies in the personal data are detected, the User may independently update them by sending a notice to the Operator at the Operator's email address info@avelan.ru with the subject line "Personal Data Update."

8.5 The duration of personal data processing is determined by the achievement of the purposes for which the personal data were collected, unless another duration is specified by the contract or applicable law.

The User may withdraw their consent to the processing of personal data at any time by sending a notice to the Operator via email to info@avelan.ru with the subject line "Withdrawal of consent to the processing of personal data."

8.6 All information collected by third-party services, such as payment systems, communication tools, and other service providers, is stored and processed by these entities (Operators) in accordance with their respective User Agreements and Privacy Policies. The Personal Data Subject agrees to these terms by using the aforementioned services and/or by accepting their documents. The Operator holds no responsibility for the actions of third parties, including the service providers specified in this paragraph.

8.7 Prohibitions established by the personal data subject regarding the transfer (except for granting access), as well as processing or conditions of processing (except for receiving access) of personal data authorized for dissemination, do not apply in cases of personal data processing for state, public, and other public interests as defined by the legislation of the Russian Federation.

8.8 The Operator ensures confidentiality of personal data during processing.

8.9 The Operator shall store personal data in a form that allows identification of the data subject for no longer than necessary for the purposes of personal data processing, unless the period of personal data storage is established by federal law, a contract to which the data subject is a party, beneficiary, or guarantor.

8.10 The termination of personal data processing may occur upon achieving the purposes of personal data processing, expiration of the data subject's consent, withdrawal of consent by the data subject, or a request to terminate personal data processing. Additionally, the termination may occur upon detection of unlawful processing of personal data.

9. List of Actions Performed by the Operator with Received Personal Data

9.1 The Operator shall collect, record, systematize, accumulate, store, clarify (update, change), extract, use, transfer (disseminate, provide, access), depersonalize, block, delete, and destroy personal data.

9.2 The Operator performs automated processing of personal data, with or without receiving and/or transmitting the received information via information and telecommunication networks.

10. Transborder Transfer of Personal Data

10.1 Prior to initiating transborder transfer of personal data, the Operator shall notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out such transfer (this notification shall be sent separately from the notification of intention to process personal data).

10.2 Before submitting the aforementioned notification, the Operator shall be obligated to obtain relevant information from foreign authorities, individuals, or legal entities to whom the transborder transfer of personal data is planned.

11. Confidentiality of Personal Data

11.1 The Operator and any other individuals with access to personal data are obligated not to disclose or disseminate personal data to third parties without the consent of the data subject, unless otherwise provided by federal law.

12. Final Provisions

12.1 Users may obtain any clarifications on matters regarding the processing of their personal data by contacting the Operator via email at info@avelan.ru.

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

12.3 The current version of the Policy is readily available on the Internet at https://avelan.ru/policy.