# 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 dated July 27, 2006 "On Personal Data" (hereinafter referred to as the Personal Data Law) and defines the procedure for processing personal data and measures to ensure the security of personal data taken by LLC "Spatial Systems" (hereinafter referred to as the Operator).

1.1. The Operator considers the observance of human and civil rights and freedoms when processing their personal data, including the protection of the rights to privacy, personal and family secrets, as its most important goal and condition for carrying out its activities.
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 https://spatialsystems.ru.

## 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 processing of personal data (except in cases 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 that ensure their availability on the Internet at the network address https://spatialsystems.ru.
2.4. Personal data information system - a set of personal data contained in databases and ensuring their processing information technologies and technical means.
2.5. Depersonalization of personal data - actions as a result of which it is impossible to determine, without the use of 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 the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
2.7. Operator - a state body, municipal body, legal entity or individual, independently or jointly with other persons organizing and/or carrying out the processing of personal data, as well as determining the purposes of processing personal data, 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 https://spatialsystems.ru.
2.9. Personal data permitted by the subject of personal data for dissemination - personal data, access to which is provided to an unlimited number of persons by the subject of personal data by giving consent to the processing of personal data permitted by the subject of personal data 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 https://spatialsystems.ru.
2.11. Provision of personal data - actions aimed at disclosing personal data to a certain person or a certain 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 with personal data of an unlimited number of persons, including the publication of personal data in the 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 as a result of which personal data are destroyed irrevocably with the impossibility of further restoration of the content of personal data in the personal data information system and/or material carriers of personal data are destroyed.

## 3. Basic Rights and Obligations of the Operator

3.1. The Operator has the right:

- Receive from the subject of personal data reliable information and/or documents containing personal data;
- In case the subject of personal data withdraws consent to the processing of personal data, as well as, sends an appeal with a request to terminate the processing of personal data, the Operator has the right to continue processing personal data without the consent of the subject of personal data 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 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:

- Provide the subject of personal data, upon his request, with information regarding the processing of his personal data;
- Organize the processing of personal data in the manner 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 Personal Data Law;
- Report to the authorized body for the protection of the rights of personal data subjects, upon the request of this body, the necessary information within 10 days from the date of receipt of such request;
- Publish or otherwise provide 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 in relation to personal data;
- Cease the transfer (distribution, provision, access) of personal data, stop processing and destroy personal data in the manner and cases provided for by the Personal Data Law;
- Perform other duties provided for by the Personal Data Law.

## 4. Basic Rights and Obligations of Personal Data Subjects

4.1. Personal data subjects have the right:

- Receive information regarding the processing of his personal data, except in cases provided for by federal laws. The information is provided to the personal data subject by the Operator in an accessible form, and it should not contain personal data relating to other personal data subjects, except in cases where there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it is established by the Personal Data Law;
- Require the operator to clarify his personal data, block or destroy them if the personal data are incomplete, outdated, inaccurate, illegally obtained or are not necessary for the stated purpose of processing, as well as take legal measures to protect their rights;
- Put forward a condition of prior consent when processing personal data for the purpose of promoting goods, works, services on the market;
- To withdraw consent to the processing of personal data, as well as, to send a request to terminate the processing of personal data;
- Appeal to the authorized body for the protection of the rights of personal data subjects or in court against unlawful actions or inaction of the Operator when processing his personal data;
- To exercise other rights provided for by the legislation of the Russian Federation.

4.2. Personal data subjects are obliged:

- Provide the Operator with reliable data about themselves;
- Inform the Operator about the clarification (update, change) 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 consent of the latter, are liable in accordance with the legislation of the Russian Federation.

## 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 the achievement of specific, predetermined and lawful purposes. Processing of personal data that is incompatible with the purposes of collecting personal data is not allowed.
5.3. It is not allowed to combine databases containing personal data, the processing of which is carried out for purposes that are incompatible with each other.
5.4. Only personal data that meet the purposes of their processing are subject to processing.
5.5. The content and volume of the processed personal data correspond to the stated purposes of processing. Redundancy of the processed personal data in relation to the stated purposes of their processing is not allowed.
5.6. When processing personal data, the accuracy of personal data, their sufficiency, and, if necessary, relevance in relation to the purposes of processing personal data are ensured. The Operator takes the necessary measures and/or ensures their adoption to delete or clarify incomplete or inaccurate data.
5.7. The storage of personal data is carried out in a form that allows identifying the subject of personal data, no longer than required by the purposes of processing personal data, if the storage period for personal data is not established by federal law, an agreement to which the subject of personal data is a party, beneficiary or guarantor. Processed personal data are destroyed or depersonalized upon achievement of the processing purposes or in case of loss of the need to achieve these purposes, unless otherwise provided by federal law.

## 6. Purposes of Personal Data Processing

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

Personal data

- email address
- name

Legal grounds

- Federal Law "On Information, Information Technologies and Information Protection" dated July 27, 2006 N 149-FZ

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 Personal Data Processing

7.1. The processing of personal data is carried out with the consent of the personal data subject to the processing of his personal data.
7.2. The processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or law, for the implementation of the functions, powers and duties imposed by the legislation of the Russian Federation on the operator.
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 a contract to which the personal data subject is a party or beneficiary or guarantor, as well as for the conclusion of a contract on the initiative of the personal data subject or a contract under which the personal data subject will be the beneficiary or guarantor.
7.5. The processing of personal data is necessary for the exercise of the rights and legitimate interests of the operator or third parties or for the achievement of socially significant goals, provided that the rights and freedoms of the personal data subject are not violated.
7.6. The processing of personal data is carried out, access to which is provided to an unlimited number of persons by the personal data subject or at his request (hereinafter referred to as publicly available personal data).
7.7. The processing of personal data subject to publication or mandatory disclosure in accordance with 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 the implementation of legal, organizational and technical measures necessary to fully comply with the requirements of the current legislation in the field of personal data protection.

8.1. The Operator ensures the safety 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 the implementation of current legislation or in the case that the personal data subject has given consent to the Operator to transfer data to a third party to fulfill obligations under a civil law contract.
8.3. In case of inaccuracies in personal data, the User can update them independently by sending a notification to the Operator to the email address info@spatialsystems.ru with the note "Updating personal data".
8.4. The term for processing personal data is determined by the achievement of the purposes for which the personal data were collected, unless another term is provided for by the contract or current legislation.
The User can at any time withdraw his consent to the processing of personal data by sending a notification to the Operator via email to the Operator's email address info@spatialsystems.ru with the note "Withdrawal of consent to the processing of personal data".
8.5. All information that is collected by third-party services, including payment systems, communication means and other service providers, is stored and processed by the specified persons (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject and/or with the specified documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.
8.6. The prohibitions established by the personal data subject on the transfer (except for providing access), as well as on the processing or conditions of processing (except for obtaining access) of personal data permitted for dissemination, do not apply in cases of processing personal data in state, public and other public interests determined by the legislation of the Russian Federation.
8.7. The Operator, when processing personal data, ensures the confidentiality of personal data.
8.8. The Operator stores personal data in a form that allows identifying the subject of personal data, no longer than required by the purposes of processing personal data, if the storage period for personal data is not established by federal law, an agreement to which the subject of personal data is a party, beneficiary or guarantor.
8.9. The condition for terminating the processing of personal data may be the achievement of the purposes of processing personal data, the expiration of the consent of the personal data subject, the withdrawal of consent by the personal data subject or a requirement to terminate the processing of personal data, as well as the identification of unlawful processing of personal data.

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

9.1. The Operator carries out collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, 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 received information via information and telecommunication networks or without it.

## 10. Cross-Border Transfer of Personal Data

10.1. The Operator, before starting activities on the cross-border transfer of personal data, is obliged to notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out cross-border transfer of personal data (such notification is sent separately from the notification of the intention to carry out personal data processing).
10.2. The Operator, before submitting the above notification, is obliged to obtain relevant information from the authorities of a foreign state, foreign individuals, 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 and not to distribute personal data without the consent of the personal data subject, unless otherwise provided by federal law.

## 12. Final Provisions

12.1. The User can receive any clarifications on issues of interest regarding the processing of his personal data by contacting the Operator via email info@spatialsystems.ru.
12.2. This document will reflect any changes to the personal data processing policy by the Operator. The Policy is valid indefinitely until it is replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet at https://spatialsystems.ru/privacy/.