Personal Data Processing Policy of Logicode Limited Liability Company

This personal data processing policy has been drawn up in accordance with the requirements of Federal Law No. 152-FZ "On Personal Data" dated 27.07.2006 (hereinafter — the Personal Data Law) and defines the procedure for processing personal data and the measures taken by Logicode LLC (hereinafter — the Operator) to ensure the security of personal data.

1.1. The Operator considers respect for human and civil rights and freedoms in the processing of personal data, including protection of the right to privacy, personal and family secrets, to be its most important goal and a condition for carrying out its activities.

1.2. This policy of the Operator regarding the processing of personal data (hereinafter — the Policy) applies to all information that the Operator may obtain about visitors to the website https://logicode.pro/.

2.1. Automated processing of personal data — processing of personal data by means of computer technology.

2.2. Blocking of personal data — temporary suspension of the processing of personal data (except where processing is necessary to clarify personal data).

2.3. Website — a set of graphic and information materials, as well as computer programs and databases, ensuring their availability on the Internet at the network address https://logicode.pro/.

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. De-identification of personal data — actions as a result of which it becomes impossible, without the use of additional information, to determine that personal data belongs 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 the use of automation tools on personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), de-identification, blocking, deletion, and destruction of personal data.

2.7. Operator — a state authority, municipal authority, legal entity, or individual that independently or jointly with other persons organizes and/or carries out the processing of personal data, and determines the purposes of processing personal data, 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://logicode.pro/.

2.9. Personal data permitted by the subject of personal data for distribution — personal data to which access by an unlimited number of persons is granted by the subject of personal data by giving consent to the processing of personal data permitted for distribution in the manner prescribed by the Personal Data Law (hereinafter — personal data permitted for distribution).

2.10. User — any visitor to the website https://logicode.pro/.

2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific group of persons.

2.12. Distribution of personal data — any actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or at familiarizing an unlimited number of persons with personal data, including publication of personal data in the media, posting on information and telecommunications networks, or providing access to personal data in any other way.

2.13. Cross-border transfer of personal data — the 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 as a result of which personal data is irrevocably destroyed, making it impossible to further restore the content of personal data in the personal data information system, and/or the physical media containing personal data are destroyed.

3.1. The Operator has the right to:

— receive from the subject of personal data reliable information and/or documents containing personal data;

— if the subject of personal data withdraws consent to the processing of personal data, or submits a request to cease processing of personal data, continue processing personal data without the consent of the subject of personal data where grounds specified in the Personal Data Law exist;

— independently determine the composition and list of measures necessary and sufficient to ensure compliance with the obligations provided for 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 obliged to:

— provide the subject of personal data, at their request, with information relating to the processing of their personal data;

— organize the processing of personal data in the manner established by the current legislation of the Russian Federation;

— respond to inquiries and requests from subjects of personal data and their legal representatives in accordance with the requirements of the Personal Data Law;

— report to the authorized body for the protection of the rights of subjects of personal data, at that body's request, the necessary information within 10 days from 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 of personal data, as well as from other unlawful actions with respect to personal data;

— cease the transfer (distribution, provision, access) of personal data, cease processing, and destroy personal data in the manner and in the cases provided for by the Personal Data Law;

— fulfill other obligations provided for by the Personal Data Law.

4.1. Subjects of personal data have the right to:

— receive information relating to the processing of their personal data, except in cases provided for by federal laws. Information is provided to the subject of personal data by the Operator in an accessible form, and must not contain personal data relating to other subjects of personal data, except where there are legal 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 it, or destroy it if the personal data is incomplete, outdated, inaccurate, unlawfully obtained, or is not necessary for the stated purpose of processing, and to take measures provided for by law to protect their rights;

— set a condition of prior consent when processing personal data for the purposes of promoting goods, works, and services on the market;

— withdraw consent to 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 subjects of personal data, or in court, against unlawful actions or inaction of the Operator in the processing of their personal data;

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

4.2. Subjects of personal data are obliged to:

— provide the Operator with reliable data about themselves;

— inform the Operator of any clarification (updating, modification) of their personal data.

4.3. Persons who have provided the Operator with unreliable information about themselves, or information about another subject of personal data without the latter's consent, shall bear liability in accordance with the legislation of the Russian Federation.

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. Processing of personal data that is incompatible with the purposes of its collection is not permitted.

5.3. The combining of databases containing personal data processed for purposes incompatible with one another is not permitted.

5.4. Only personal data that meets the purposes of its processing is subject to processing.

5.5. The content and volume of personal data processed correspond to the stated purposes of processing. Excessive processing of personal data in relation to the stated purposes of its processing is not permitted.

5.6. When processing personal data, the accuracy of the personal data and its sufficiency are ensured, and where necessary, its relevance to the purposes of processing. The Operator takes the necessary measures and/or ensures that they are taken to delete or clarify incomplete or inaccurate data.

5.7. Personal data is stored in a form that allows the subject of personal data to be identified for no longer than is required by the purposes of processing personal data, unless the storage period for personal data is established by federal law, an agreement to which the subject of personal data is a party, beneficiary, or guarantor. Processed personal data is destroyed or de-identified upon achievement of the purposes of processing or in the event that the need to achieve those purposes is no longer relevant, unless otherwise provided for by federal law.

Purpose of processing

providing the User with access to services, information, and/or materials contained on the website

Personal data

— last name, first name, patronymic

— email address

— phone numbers

Legal grounds

— the Operator's founding (constituent) documents

— agreements concluded between the Operator and the subject of personal data

Types of processing of personal data

— collection, recording, systematization, accumulation, storage, destruction, and de-identification of personal data

— sending informational emails to the email address

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

7.2. The processing of personal data is necessary to achieve purposes provided for by an international treaty of the Russian Federation or by law, for the exercise of functions, powers, and duties assigned to the Operator by the legislation of the Russian Federation.

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

7.4. The processing of personal data is necessary for the performance of an agreement to which the subject of personal data is a party, beneficiary, or guarantor, as well as for concluding an agreement at the initiative of the subject of personal data, or an agreement under which the subject of personal data will be a beneficiary or guarantor.

7.5. The processing of personal data is necessary to exercise the rights and legitimate interests of the Operator or third parties, or to achieve socially significant purposes, provided that the rights and freedoms of the subject of personal data are not violated.

7.6. Processing is carried out of personal data to which access by an unlimited number of persons has been granted by the subject of personal data or at their request (hereinafter — publicly available personal data).

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

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 applicable legislation in the field of personal data protection.

8.1. The Operator ensures the safety of personal data and takes all possible measures to prevent 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 legislation, or where the subject of personal data has given the Operator consent to transfer data to a third party for the fulfillment of obligations under a civil law agreement.

8.3. If inaccuracies in personal data are identified, the User may update them independently by sending the Operator a notice to the Operator's email address 1@logicode.pro marked "Updating personal data."

8.4. The period for processing 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 an agreement or applicable legislation.

The User may withdraw their consent to the processing of personal data at any time by sending the Operator a notice via email to the Operator's email address 1@logicode.pro marked "Withdrawal 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 these entities (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data is responsible for reviewing these documents themselves. The Operator is not responsible for the actions of third parties, including the service providers referred to in this clause.

8.6. Restrictions established by the subject of personal data on the transfer (other than the provision of access), as well as on the processing or conditions of processing (other than 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 the legislation of the Russian Federation.

8.7. The Operator ensures the confidentiality of personal data when processing it.

8.8. The Operator stores personal data in a form that allows the subject of personal data to be identified for no longer than is required by the purposes of processing personal data, unless the storage period for personal data is established by federal law, an agreement to which the subject of personal data is a party, beneficiary, or guarantor.

8.9. The processing of personal data may be terminated upon achievement of the purposes of processing, expiration of the subject's consent, withdrawal of consent by the subject, a request to cease processing, or the identification of unlawful processing of personal data.

9.1. The Operator carries out the collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), de-identification, blocking, deletion, and destruction of personal data.

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

10.1. Prior to commencing cross-border transfer of personal data, the Operator is obliged to notify the authorized body for the protection of the rights of subjects of personal data 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 is obliged to obtain relevant information from the authorities of the foreign state, foreign individuals, or foreign legal entities to which the cross-border transfer of personal data is planned.

The Operator and other persons who have gained access to personal data are obliged not to disclose it to third parties and not to distribute personal data without the consent of the subject of personal data, unless otherwise provided for by federal law.

12.1. The User may obtain any clarifications on matters of interest relating to the processing of their personal data by contacting the Operator via email at 1@logicode.pro.

12.2. Any changes to the Operator's personal data processing policy will be reflected in this document. 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 https://logicode.pro/privacy.