Personal Data Processing Policy

1. General Provisions
This Personal Data Processing Policy is prepared in accordance with the requirements of Federal Law No. 152-FZ "On Personal Data" dated July 27, 2006 (hereinafter referred to as the "Personal Data Law") and determines the procedure for processing personal data and measures to ensure the security of personal data undertaken by Status Management Group LLP (hereinafter referred to as the "Operator").

1.1. The Operator's most important goal and condition for its activities is to respect the rights and freedoms of individuals when processing their personal data, including the protection of privacy, personal and family secrets.
1.2. This Operator's policy regarding the processing of personal data (hereinafter referred to as the "Policy") applies to all information that the Operator may obtain about visitors to the website http://by-qazan.com.

2. Basic Concepts 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 personal data processing (except when processing is necessary to clarify personal data).
2.3. Website - a set of graphical and informational materials, as well as computer programs and databases ensuring their availability on the internet at the network address http://by-qazan.com.
2.4. Personal data information system - a set of personal data contained in databases and information technologies and technical means ensuring their processing.
2.5. Depersonalization of personal data - actions resulting in the impossibility to determine, without additional information, the belonging of personal data to a specific User or other subject of personal data.
2.6. Processing of personal data - any action (operation) or set of actions (operations) performed with or without automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
2.7. Operator - a state body, municipal body, legal or natural person independently or jointly with others organizing and/or processing personal data, as well as determining the purposes of personal data processing, the composition of personal data to be processed, 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 http://by-qazan.com.
2.9. Personal data permitted by the personal data subject for dissemination - personal data to which access by an unlimited number of persons has been provided by the personal data subject by giving consent to the processing of personal data permitted for dissemination in the manner prescribed by the Personal Data Law (hereinafter referred to as "personal data permitted for dissemination").
2.10. User - any visitor to the website http://by-qazan.com.
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 familiarizing an unlimited circle of persons with personal data, including publishing personal data 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 an authority of a foreign state, a foreign individual, or a foreign legal entity.
2.14. Destruction of personal data - any actions resulting in the irreversible destruction of personal data with the impossibility of further restoring the content of personal data in the personal data information system and/or destruction of material carriers of personal data.

3. Basic Rights and Obligations of the Operator
3.1. The Operator has the right to:
— Receive from the personal data subject reliable information and/or documents containing personal data;
— 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 the fulfillment of obligations under the Personal Data Law.
3.2. The Operator is obliged to:
— Provide the personal data subject with information regarding the processing of their personal data upon request;
— Organize the processing of personal data in accordance with current Russian legislation;
— Respond to appeals and requests from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
— Provide the authorized body for the protection of personal data subjects' rights with necessary information within 10 days of receiving such a request;
— Publish or otherwise ensure unlimited access to this Policy;
— Take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, dissemination, as well as from other unlawful actions;
— Cease the transfer (distribution, provision, access) of personal data, cease processing, and destroy personal data in the manner and cases provided by the Personal Data Law;
— Perform other duties 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;
— Require the Operator to clarify, block, or destroy their personal data if the data is incomplete, outdated, inaccurate, illegally obtained, or not necessary for the stated processing purpose;
— Withdraw consent to the processing of personal data;
— Appeal against the Operator's unlawful actions or inaction in court;
— Exercise other rights provided by Russian legislation.
4.2. Personal data subjects are obliged to:
— Provide the Operator with reliable information about themselves;
— Inform the Operator about the clarification (updating, modification) of their personal data.
4.3. Persons who provided the Operator with false information about themselves or information about another personal data subject without the latter's consent bear responsibility under Russian legislation.

5. Principles of Personal Data Processing
5.1. The processing of personal data is carried out on a lawful and fair basis.
5.2. The processing of personal data is limited to achieving specific, predetermined, and lawful purposes.
5.3. The combining of databases containing personal data processed for incompatible purposes is not allowed.
5.4. Only personal data that meets the purposes of their processing is subject to processing.
5.5. The content and volume of processed personal data correspond to the stated processing purposes.
5.6. The accuracy of personal data, their sufficiency, and relevance in relation to the processing purposes are ensured.
5.7. Personal data is stored in a form that allows identification of the personal data subject for no longer than required by the processing purposes.

6. Purposes of Personal Data Processing
Processing purposes: conclusion, execution, and termination of civil law contracts
Personal data: last name, first name, patronymic; email address; phone numbers
Legal grounds: Federal Law "On Information, Information Technologies and Information Protection" No. 149-FZ dated July 27, 2006
Types of personal data processing: Collection, recording, systematization, accumulation, storage, destruction, and depersonalization of personal data

7. Conditions of Personal Data Processing
7.1. Processing is carried out with the consent of the personal data subject.
7.2. Processing is necessary to achieve purposes provided by an international treaty or Russian law.
7.3. Processing is necessary for the administration of justice.
7.4. Processing is necessary for the performance of a contract where the personal data subject is a party.
7.5. Processing is necessary to exercise the legitimate interests of the Operator or third parties.
7.6. Processing of publicly available personal data is carried out.
7.7. Processing of personal data subject to publication or mandatory disclosure under federal law is carried out.

8. Procedure for Collection, Storage, Transfer, and Other Types of Personal Data Processing
The security of personal data processed by the Operator is ensured through legal, organizational, and technical measures necessary to fully comply with current personal data protection legislation.
8.1. The Operator ensures the security of personal data and takes all possible measures to prevent unauthorized access to personal data.
8.2. The User's personal data will never be transferred to third parties except in cases required by law or when the personal data subject has consented to the transfer.
8.3. If inaccuracies in personal data are identified, the User may update them independently by sending a notice to the Operator's email address info@by-qazan.com with the subject "Update of 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.
The User may at any time withdraw consent to the processing of personal data by sending a notice to the Operator's email address info@by-qazan.com with the subject "Withdrawal of consent to personal data processing".
8.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by these persons (Operators) in accordance with their User Agreement and Privacy Policy.
8.6. The Operator ensures the confidentiality of personal data during processing.
8.7. The Operator stores personal data in a form that allows identification of the personal data subject for no longer than required by the processing purposes.
8.8. The condition for termination of personal data processing may be the achievement of the processing purposes, expiration of the consent period, withdrawal of consent by the personal data subject, or identification 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, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
9.2. The Operator performs automated processing of personal data with or without receipt and/or transmission of the obtained information via information and telecommunication 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' rights of its intention to carry out cross-border transfer of personal data.
10.2. Before submitting the aforementioned notification, 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 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 can obtain any clarifications on questions regarding the processing of their personal data by contacting the Operator via email at info@by-qazan.com.
12.2. This document will reflect any changes to the Operator's personal data processing policy. The Policy is valid indefinitely until replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet at http://by-qazan.com/policy.