Privacy policy

Approved

By order of AVS LLC dated __________ No. __________

Privacy policy

of the website of AVS LLC

This Privacy Policy for personal data (the “Privacy Policy”) is prepared in accordance with paragraph 2, part 1, Article 18.1 of Federal Law No. 152-FZ of 27.07.2006 “On Personal Data” and is an integral part of the public offer (Terms of use) on the Internet at: .______________________________ (state domain) (the “Site”), and the personal data policy published on the Site at: …..

Site services are interactive (dialogue) software components on Site pages used to integrate with information systems and that give users certain access to information on the Site, namely: ________________________________________________ (to be completed by the initiator) (the “Services”, “Site Services”).

Use of the Site’s services means unconditional acceptance of this Privacy Policy and the personal information processing terms contained herein; if you do not agree, you must not use the services.

1. GENERAL PROVISIONS

1.1. A “User” of the Site is a person (visitor) who is registered on the Site and uses the services, products and services offered on the Site, or a person who uses them without registration where technically possible.

1.2. A “Visitor” of the Site is a person who uses (views) the Site without registration and who does not obtain useful functions from the services, products and services offered on the Site.

1.3. For the purposes of this Policy, a User’s/Visitor’s “personal information” means:

1.3.1. Information that the User provides about themselves when registering (creating an account) or when using the Services, including personal data. Information required to provide the Services is marked accordingly.

1.3.2. Data automatically sent to the Site’s services when they are used by software on the User’s/Visitor’s device, including the IP address, cookies, the User’s/Visitor’s browser (or other program used to access the services), technical characteristics of hardware and software, date and time of access, requested page addresses and other similar information.

1.3.3. This Privacy Policy applies only to the Site at .______________________. The Site at .______________________ does not control and is not responsible for third-party sites that the User/Visitor may access via links on the Site at .______________________.

2. PURPOSES OF PROCESSING USERS’ PERSONAL INFORMATION

2.1. The Site collects and stores only such personal information as is necessary to provide the services or perform agreements and contracts with the User, except where the law requires storage for a specific period.

Upon receiving notice from a User of withdrawal of consent to personal data processing, the Site will stop processing within no more than 10 business days of receipt.

Withdrawal of consent to personal data processing may be sent to the e-mail: __________________ or in writing to the location of the Operator (Site Administration — AVS LLC): 109387, Moscow, Lyublino municipal district, Lyublinskaya St., 42, premises 39/11/3.

2.2. The User’s personal information is processed for the following purposes:

2.2.1. To identify a User registered on the Site, for ___________________________.

2.2.2. To give the User access to personalized areas of the Site.

2.2.3. To contact the User, including sending notices and requests about use of the Site, provision of services, and handling the User’s requests and applications.

2.2.4. To determine the User’s location for security and fraud prevention.

2.2.5. To verify the accuracy and completeness of personal data provided by the User.

2.2.6. To create an account for ________________________, if the User has consented to account creation.

2.2.7. To notify the User about _______________________.

2.2.8. To provide effective customer and technical support if problems arise in using the Site.

2.2.9. To carry out marketing activities with the User’s consent.

2.2.10. ______________________________________________________.

(list other purposes depending on your activities and the purpose of the site)

3. CONDITIONS OF PROCESSING USERS’ PERSONAL INFORMATION

AND ITS DISCLOSURE TO THIRD PARTIES

3.1. The Site stores personal information in accordance with internal rules of the relevant services.

3.2. The User’s personal information remains confidential, except when the User voluntarily discloses it for unrestricted public access. When using some services, the User agrees that a certain part of their information may be publicly available.

3.3. The Site may transfer the User’s personal information to third parties in the following cases:

3.3.1. The User has consented to such transfer.

3.3.2. Transfer is necessary for the User to use a specific service or to perform a specific agreement or contract with the User.

3.3.4. Transfer is required by Russian or other applicable law under the applicable procedure.

3.3.5. In a transfer of rights to the Site, the acquirer assumes all duties to comply with this Policy in respect of the personal data received.

3.4. Processing of the User’s/Visitor’s personal data is carried out in line with the consents they have given, by means including: collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, destruction, including in personal data information systems, with or without automation. Processing complies with Federal Law No. 152-FZ of 27.07.2006 “On Personal Data”.

3.5. If personal data is lost or disclosed, the Site Administration will inform the User.

3.6. The Site Administration takes necessary organizational and technical measures to protect personal information against unlawful or accidental access, destruction, alteration, blocking, copying, distribution, and other unlawful actions by third parties.

3.7. To protect personal data when it is processed, the following legal, organizational and technical measures are applied against unauthorized, unlawful or accidental access, destruction, alteration, blocking, copying, distribution, and other unlawful actions, including:

3.7.1. Development and maintenance of local internal policies of the Operator on personal data processing and security, and procedures to detect and prevent violations of Russian personal data law and remedy the consequences.

3.7.2. Periodic internal control and, where applicable, control by third parties (external audit) of compliance with the law and internal policies of the Operator.

3.7.3. Assessment of harm that may be caused to data subjects in case of violations of the law on personal data.

3.7.4. Training of the Operator’s employees who process personal data on Russian law and the Operator’s local policies on processing and security of personal data.

3.7.5. Identification of threats to the security of personal data in personal data information systems.

3.7.6. Organizational and technical measures to ensure security in personal data information systems, as required for protection of personal data.

3.7.7. Detection of unauthorized access and remedial action.

3.7.8. Restoration of personal data modified or destroyed due to unauthorized access.

3.7.9. Rules of access to personal data in information systems, and logging and recording of all actions with personal data in those systems.

3.7.10. Monitoring of measures to ensure security and the protection level of personal data information systems.

3.8. The Site Administration, together with the User, takes all reasonable steps to prevent loss or other adverse consequences of loss or disclosure of the User’s personal data.

4. OBLIGATIONS OF THE PARTIES

4.1. The User must:

4.1.1. Provide the personal data information necessary to use the Site.

4.1.2. Update the personal data information if it changes.

4.2. The Site Administration must:

4.2.1. Use the information received only for the purposes set out in this Privacy Policy.

4.2.2. Keep confidential information secret, not disclose it without prior written permission of the User, and not sell, exchange, publish or otherwise disclose the User’s personal data, except as provided in this Policy.

4.2.3. Consider applications from a data subject (or legal representative) on processing and give reasoned responses.

4.2.4. Give the data subject (or legal representative) free access to their personal data.

4.2.5. Block the User’s personal data from the time of a request or application by the User, legal representative or competent authority, for the period of review if the data is inaccurate or processing is unlawful.

5. LIABILITY

5.1. The Site Administration is liable to the User for damage caused by unlawful use of personal data, in accordance with the laws of the Russian Federation.

5.2. The Site Administration is not liable for loss of confidential information if the information:

5.2.1. Became public before the loss or disclosure.

5.2.2. Was received from a third party before the Site Administration received it.

5.2.3. Was disclosed with the User’s consent.

6. DISPUTE RESOLUTION

6.1. All disputes under this Policy are resolved by negotiations in accordance with applicable law, and if no settlement is reached, in court at the place of the Site Administration — AVS LLC (TIN 9723255222, OGRN 1257700280727).

6.2. A party may go to court only after sending a written claim with an inventory of enclosures and notice of delivery, and not receiving a response (or a refusal) within 30 calendar days from the date the claim was sent.

6.3. This Privacy Policy and the relations between the User/Visitor and the Site Administration are governed by the laws of the Russian Federation.

7. ADDITIONAL PROVISIONS

7.1. The Site Administration may change this Privacy Policy without the User’s/Visitor’s consent.

7.2. The new Privacy Policy takes effect from publication on the Site unless the new version provides otherwise.

7.3. Suggestions or questions on this Policy should be sent to __________________________.

7.4. The current Privacy Policy is published at: .___________________________.