Privacy Policy on Personal Data Processing

1. General Provisions
This personal data processing policy is compiled in accordance with the requirements of Federal Law No. 152-FZ of 27.07.2006 “On Personal Data” (hereinafter, the “Personal Data Law”) and defines the procedure for processing personal data and the measures taken by Individual Entrepreneur Evgeny Sergeevich Larin (hereinafter, the “Operator”) to ensure the security of personal data.
1.1. The Operator’s foremost objective and condition for conducting its activities is to respect 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 Privacy Policy of the Operator regarding personal data processing (hereinafter, the “Policy”) applies to all information that the Operator may obtain regarding visitors to the website https://llp.group.

2. Key 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 suspension of personal data processing (except where processing is necessary to clarify personal data).
2.3. Website — a set of graphic and informational materials, as well as computer programs and databases, ensuring their availability on the Internet at https://llp.group.
2.4. Personal data information system — a set of personal data contained in databases and the information technologies and technical means that ensure their processing.
2.5. Depersonalization of personal data — actions that make it impossible, without the use of additional information, to determine that personal data belongs to a specific User or other personal data subject.
2.6. Processing of personal data — any action (operation) or set of actions (operations), performed with or without the use of automation tools, involving personal data, including collection, recording, systematization, accumulation, storage, updating (modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
2.7. Operator — a state body, municipal body, legal or natural person that, independently or jointly with others, organizes and/or carries out the processing of personal data, and determines the purposes of processing, 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://llp.group.
2.9. Personal data permitted by the personal data subject for dissemination — personal data to which an unlimited number of persons has been granted access by the personal data subject by giving consent to the processing of personal data permitted by the personal data subject for dissemination in the manner provided by the Personal Data Law (hereinafter, “personal data permitted for dissemination”).
2.10. User — any visitor of the website https://llp.group.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific circle of persons.
2.12. Dissemination of personal data — any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or at familiarizing an unlimited circle of persons with personal data, including publication in mass media, posting 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 that result in the irreversible destruction of personal data with no possibility of further restoration of the content of personal data in the personal data information system and/or the destruction of the physical media containing personal data.

3. Basic 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;
— in the event the personal data subject withdraws consent to the processing of personal data or submits a request to cease processing, continue processing personal data without the subject’s consent if there are grounds specified in the Personal Data Law;
— independently determine the composition and list of measures necessary and sufficient to ensure fulfillment of the obligations provided by the Personal Data Law and regulatory legal acts adopted pursuant thereto, unless otherwise provided by the Personal Data Law or other federal laws.
3.2. The Operator is obliged to:
— provide the personal data subject, upon request, with information regarding the processing of his/her personal data;
— organize the processing of personal data in the manner established by the current legislation of the Russian Federation;
— respond to communications and requests from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
— provide, upon request, necessary information to the authorized body for the protection of personal data subjects within 10 days from the date of receipt of such request;
— publish or otherwise ensure unrestricted access to this Policy regarding personal data processing;
— take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, alteration, blocking, copying, provision, dissemination, as well as from other unlawful actions with respect to personal data;
— cease the transfer (dissemination, provision, access), cease processing, and destroy personal data in the manner and cases provided by the Personal Data Law;
— fulfill other obligations provided 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 by federal laws. 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, unless there are lawful grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
— require the Operator to clarify their personal data, block or destroy it if the personal data is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, as well as take legal measures to protect their rights;
— stipulate prior consent as a condition for processing personal data for the purpose of marketing goods, works, and services;
— withdraw consent to the processing of personal data and submit a demand to cease the processing of personal data;
— appeal unlawful actions or omissions of the Operator in processing their personal data to the authorized body for the protection of personal data subjects or in court;
— exercise other rights provided by the legislation of the Russian Federation.
4.2. Personal data subjects are obliged to:
— provide the Operator with accurate data about themselves;
— inform the Operator of clarification (updating, modification) of their personal data.
4.3. Persons who have provided the Operator with inaccurate information about themselves or information about another personal data subject without the latter’s consent bear liability in accordance with the legislation of the Russian Federation.

5. Principles of Personal Data Processing
5.1. Personal data is processed on a lawful and fair basis.
5.2. Personal data processing is limited to achieving specific, predetermined, and lawful purposes. Processing of personal data incompatible with the purposes of collecting personal data is not allowed.
5.3. Combining databases containing personal data that are processed for purposes incompatible with each other is not allowed.
5.4. Only personal data that meet the purposes of their processing are subject to processing.
5.5. The content and scope of processed personal data correspond to the stated purposes of processing. Excessive processing of personal data in relation to the stated purposes is not permitted.
5.6. When processing personal data, the accuracy of personal data, their sufficiency, and, where necessary, their relevance to the purposes of personal data processing are ensured. The Operator takes necessary measures and/or ensures that incomplete or inaccurate data are removed or clarified.
5.7. Personal data is stored in a form that allows identification of the personal data subject for no longer than required by the purposes of personal data processing, unless a personal data retention period is established by federal law or by 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 when there is no longer a need to achieve these purposes, unless otherwise provided by federal law.

6. Purposes of Personal Data Processing
Purpose of processing: to provide the User with access to the services, information, and/or materials contained on the website.
Personal data: surname, first name, patronymic; email address; phone numbers.
Legal grounds: the Operator’s constituent (founding) documents.
Types of personal data 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. Personal data is processed with the consent of the personal data subject to the processing of his/her personal data.
7.2. Processing is necessary to achieve the objectives provided for by an international treaty of the Russian Federation or by law, and to perform the functions, powers, and duties imposed on the Operator by the legislation of the Russian Federation.
7.3. Processing is necessary for the administration of justice, execution of a judicial act, or an act of another body or official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. Processing is necessary for the performance of a contract to which the personal data subject is a party, beneficiary, or guarantor, as well as for entering into 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 is necessary to exercise the rights and legitimate interests of the Operator or third parties or to achieve socially significant goals, provided that this does not violate the rights and freedoms of the personal data subject.
7.6. Processing is carried out for personal data to which access is provided by the personal data subject to an unlimited number of persons or at the subject’s request (hereinafter, “publicly available personal data”).
7.7. Processing is carried out for personal data subject to publication or mandatory disclosure in accordance with federal law.

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 through 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 safekeeping of personal data and takes all possible measures to exclude 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 compliance with applicable law or where the personal data subject has given the Operator consent to transfer the 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 notice to the Operator at the Operator’s email address e.larin@llp.group with the note “Update of personal data.”
8.4. The period of personal data processing is determined by the achievement of the purposes for which the personal data was collected, unless another period is provided by contract or applicable law. The User may withdraw his/her consent to the processing of personal data at any time by sending a notice to the Operator via email at e.larin@llp.group with the note “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 parties (Operators) in accordance with their User Agreements and Privacy Policies. The personal data subject shall familiarize him/herself with the said documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.
8.6. Restrictions established by the personal data subject on transfer (other than granting access), as well as on processing or conditions of processing (other than access) of personal data permitted for dissemination, do not apply in cases of processing personal data in state, public, and other public interests as determined by the legislation of the Russian Federation.
8.7. When processing personal data, the Operator ensures the confidentiality of personal data.
8.8. The Operator stores personal data in a form that allows identification of the personal data subject for no longer than required by the purposes of personal data processing, unless a different storage period for personal data is established by federal law or by a contract to which the personal data subject is a party, beneficiary, or guarantor.
8.9. Grounds for terminating the processing of personal data may include the achievement of the purposes of personal data processing, expiration of the personal data subject’s consent, withdrawal of consent by the personal data subject, a demand to cease processing, or the discovery of unlawful processing of personal data.

9. List of Actions Performed by the Operator with Received Personal Data
9.1. The Operator performs collection, recording, systematization, accumulation, storage, updating (modification), retrieval, use, transfer (dissemination, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
9.2. The Operator carries out automated processing of personal data with the receipt and/or transfer of the obtained information via information and telecommunication networks or without such networks.

10. Cross-Border Transfer of Personal Data
10.1. Before commencing cross-border transfer of personal data, the Operator must notify the authorized body for the protection of personal data subjects of its intention to carry out cross-border transfer of personal data (such notice is sent separately from the notice of intent to process personal data).
10.2. Prior to submitting the above notice, the Operator must obtain 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 gained access to personal data are obliged not to disclose to third parties or disseminate personal data without the consent of the personal data subject, unless otherwise provided by federal law.

12. Final Provisions
12.1. The User may obtain any clarifications on matters concerning the processing of his/her personal data by contacting the Operator via email at e.larin@llp.group.
12.2. Any changes to the Operator’s personal data processing policy will be reflected in this document. The Policy is of indefinite duration until replaced by a new version.
12.3. The current version of the Policy is publicly available on the Internet at https://llp.group/en/policy.