1. General Provisions

This Personal Data Processing Policy has been developed 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 personal data processing and the measures implemented by Limited Liability Company “Taglex Group Holding” (hereinafter referred to as the “Operator”) to ensure the security of personal data.

1.1. The Operator considers compliance with the rights and freedoms of individuals and citizens in the processing of their personal data, including the protection of the right to privacy and personal and family confidentiality, to be a fundamental objective and a mandatory condition of its business activities.

1.2. This Policy of the Operator regarding personal data processing (hereinafter referred to as the “Policy”) applies to all information that the Operator may obtain about visitors of the website https://taglex.com.

2. Key Terms Used in the Policy

2.1. Automated personal data processing — processing of personal data using computer technologies.

2.2. Blocking of personal data — temporary suspension of personal data processing (except in cases where processing is required to clarify personal data).

2.3. Website — a set of graphical and informational materials, as well as software and databases ensuring their availability on the Internet at https://taglex.com.

2.4. Personal data information system — a set of personal data contained in databases, together with information technologies and technical means ensuring their processing.

2.5. Depersonalization of personal data — actions resulting in the impossibility of determining, without the use of additional information, whether personal data belong to a specific User or another personal data subject.

2.6. Personal data processing — any action (operation) or set of actions (operations) performed with or without automation tools on personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.

2.7. Operator — a state authority, municipal authority, legal entity, or individual that independently or jointly with others organizes and/or carries out personal data processing, and determines the purposes of personal data processing, the scope of personal data subject to processing, and the actions (operations) performed with personal data.

2.8. Personal data — any information directly or indirectly relating to an identified or identifiable User of the website https://taglex.com.

2.9. Personal data permitted by the data subject for distribution — personal data to which access has been granted to an unlimited number of persons by the personal data subject through consent to the processing of personal data permitted for distribution in accordance with the procedure established by the Personal Data Law (hereinafter referred to as “personal data permitted for distribution”).

2.10. User — any visitor of the website https://taglex.com.

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 providing access to personal data to an unlimited number of persons, including publication in mass media, placement in information and telecommunication networks, or granting access by any other means.

2.13. Cross-border transfer of personal data — transfer of personal data to the territory of a foreign state to a public 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 without the possibility of restoring the content of personal data in a personal data information system and/or destruction of physical media containing personal data.

3. Main Rights and Obligations of the Operator

3.1. The Operator has the right to:

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

— in the event that the personal data subject withdraws consent to the processing of personal data, or submits a request to terminate personal data processing, continue processing personal data without the consent of the personal data subject if there are grounds specified in the Personal Data Law;

— independently determine the composition and list of measures necessary and sufficient to ensure compliance with the obligations established by the Personal Data Law and regulatory legal acts adopted in accordance therewith, 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 concerning the processing of their personal data;

— organize personal data processing in accordance with the procedure established by the legislation of the Russian Federation;

— respond to requests and inquiries 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 the rights of personal data subjects, upon its request, with the necessary information within 10 days from the date of receipt of such request;

— publish or otherwise ensure unrestricted access to this Policy regarding personal data processing;

— implement legal, organizational, and technical measures to protect personal data against unlawful or accidental access, destruction, modification, blocking, copying, provision, distribution, and other unlawful actions with respect to personal data;

— terminate the transfer (distribution, provision, access) of personal data, cease processing, and destroy personal data in the cases and in accordance with the procedure established by the Personal Data Law;

— fulfill other obligations established by the Personal Data Law.

4. Main Rights and Obligations of Personal Data Subjects

4.1. Personal data subjects have the right to:

— obtain information concerning the processing of their personal data, except in cases предусмотренных федеральными законами. The information shall be provided by the Operator in an accessible form and must not contain personal data relating to other personal data subjects, except where there are lawful grounds for the disclosure of such personal data. The scope of information and the procedure for obtaining it are established by the Personal Data Law;

— require the Operator to clarify, block, or destroy their personal data if such personal data are incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, as well as to take measures provided by law to protect their rights;

— require prior consent for the processing of personal data for the purposes of promoting goods, works, or services on the market;

— withdraw consent to the processing of personal data and submit a request to terminate the processing of personal data;

— appeal unlawful actions or omissions of the Operator in the processing of their personal data to the authorized body for the protection of the rights of personal data subjects or in court;

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

4.2. Personal data subjects are obliged to:

— provide the Operator with accurate personal data concerning themselves;

— notify the Operator of any clarification (update or 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 shall bear liability in accordance with the legislation of the Russian Federation.

5. Principles of Personal Data Processing

5.1. Personal data processing shall be carried out on a lawful and fair basis.

5.2. Personal data processing shall be limited to the achievement of specific, predetermined, and lawful purposes. Processing of personal data incompatible with the purposes of personal data collection shall not be permitted.

5.3. The consolidation of databases containing personal data processed for purposes that are incompatible with each other shall not be permitted.

5.4. Only personal data that meet the purposes of their processing shall be subject to processing.

5.5. The content and scope of personal data processed shall correspond to the stated purposes of processing. Excessive personal data in relation to the stated purposes of processing shall not be permitted.

5.6. When processing personal data, the accuracy, sufficiency, and, where necessary, relevance of personal data in relation to the purposes of processing shall be ensured. The Operator shall take necessary measures and/or ensure their implementation to delete or clarify incomplete or inaccurate data.

5.7. Personal data shall be 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 the 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 shall be destroyed or depersonalized upon achievement of the processing purposes or in the event that the need to achieve such purposes ceases to exist, unless otherwise provided by federal law.

6. Purposes of Personal Data Processing

Purpose of processing: informing the User by sending electronic communications.

Personal data:

• Full name
• Email address
• Telephone numbers

Legal grounds:

• Federal Law No. 149-FZ dated July 27, 2006 “On Information, Information Technologies and Information Protection”

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 of Personal Data Processing

7.1. Personal data shall be processed with the consent of the personal data subject.

7.2. Personal data processing shall be permitted where necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, or for the exercise of functions, powers, and duties imposed on the Operator by the legislation of the Russian Federation.

7.3. Personal data processing shall be permitted where necessary for the administration of justice or for the execution of a judicial act, an act of another authority, or an official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.

7.4. Personal data processing shall be permitted where necessary for the performance of a contract to which the personal data subject is a party, beneficiary, or guarantor, as well as for the conclusion of 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. Personal data processing shall be permitted where necessary for the exercise of the rights and legitimate interests of the Operator or third parties or for the achievement of socially significant objectives, provided that the rights and freedoms of the personal data subject are not violated.

7.6. Processing of personal data made publicly available by the personal data subject or at their request (hereinafter referred to as publicly available personal data) shall be permitted.

7.7. Processing of personal data subject to publication or mandatory disclosure in accordance with federal law shall be permitted.

8. Procedure for Collection, Storage, Transfer, and Other Forms 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 applicable legislation in the field of personal data protection.

8.1. The Operator ensures the preservation of personal data and takes all reasonable measures to prevent unauthorized access to personal data.

8.2. Under no circumstances shall the User’s personal data be transferred to third parties, except in cases related to compliance with applicable legislation or where the personal data subject has granted consent to the Operator for the transfer of data to a third party for the performance of obligations under a civil law contract.

8.3. In the event inaccuracies in personal data are identified, the User may update such data independently by sending a notification to the Operator via email at info@taglex.com marked “Personal Data Update”.

8.4. The period of personal data processing shall be determined by the achievement of the purposes for which the personal data were collected, unless a different period is established by a contract or applicable legislation.

The User may withdraw consent to the processing of personal data at any time by sending a notification to the Operator via email at info@taglex.com marked “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, shall be stored and processed by such entities (Operators) in accordance with their respective User Agreements and Privacy Policies. The personal data subject shall independently review such documents. The Operator shall not be liable for the actions of third parties, including the service providers referred to in this clause.

8.6. Restrictions established by the personal data subject on the transfer (except for granting access), processing, or conditions of processing (except for obtaining access) of personal data permitted for distribution shall not apply in cases where personal data are processed in state, public, or other public interests defined 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 shall store 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 the retention period 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 termination of personal data processing may include achievement of the processing purposes, expiration of the consent period, withdrawal of consent by the personal data subject, submission of a request to terminate processing, or identification of unlawful processing of personal data.

9. List of Actions Performed by the Operator with 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 carries out automated processing of personal data with or without the receipt and/or transfer of information via information and telecommunication networks.

10. Cross-Border Transfer of Personal Data

10.1. Prior to commencing cross-border transfer of personal data, the Operator shall notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out such transfer (such notification shall be submitted separately from the notification of intent to process personal data).

10.2. Before submitting the above notification, the Operator shall obtain from foreign public authorities, foreign individuals, and foreign legal entities to whom cross-border transfer of personal data is planned the relevant information required by applicable legislation.

11. Confidentiality of Personal Data

The Operator and other persons granted access to personal data shall not 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 may obtain any clarifications regarding matters related to the processing of their personal data by contacting the Operator via email at info@taglex.com.

12.2. Any amendments to the personal data processing policy of the Operator shall be reflected in this document. This Policy shall remain effective indefinitely until replaced by a new version.

12.3. The current version of the Policy is publicly available on the Internet at: https://taglex.com/policy