Personal Data Privacy Policy

Moscow · 15 June 2026

This is a courtesy translation provided for convenience. The Russian version of this Policy is the legally binding one and prevails in case of any discrepancy.

1GENERAL PROVISIONS

1.1.This document (hereinafter — the Policy) defines the policy regarding the processing of personal data of users of the website of IT-Navigator LLC (hereinafter — the Operator) on the website in the information and telecommunications network Internet at the address: www.it-navigator.online (hereinafter — the Site).

1.2.This Policy has been developed on the basis of clause 2 of part 1 of Article 18.1 of Federal Law No. 152-FZ of 27.07.2006 "On Personal Data".

1.3.In pursuance of the requirements of part 2 of Article 18.1 of Federal Law No. 152-FZ of 27.07.2006 "On Personal Data", the Policy is published in open access in the information and telecommunications network Internet on the Operator's Site at the address: www.it-navigator.online.

1.4.This Policy applies solely to the Site. The Operator does not control and shall not be liable for third-party websites to which the User may navigate via links available on the Site.

1.5.The concepts contained in Article 3 of Federal Law No. 152-FZ of 27.07.2006 "On Personal Data" are used in this Policy with the same meaning.

1.6.The following terms are also used in this Policy: Processing of personal data — any action (operation) or set of actions (operations) performed with personal data with or without the use of automation tools. The processing of personal data includes, inter alia: collection; recording; systematization; accumulation; storage; clarification (updating, modification); extraction; use; transfer (dissemination, provision, access); depersonalization; blocking; deletion; destruction; Personal data operator (operator) — a person who, independently or jointly with other persons, organizes and (or) carries out the processing of personal data, and also determines the purposes of the processing of personal data, the composition of the personal data to be processed, and the actions (operations) performed with personal data; Personal data — any information relating to a directly or indirectly identified or identifiable natural person (data subject); User — any person who visits the Site and uses the information, materials and Services of the Site. A User of the Site is a data subject within the meaning of Federal Law No. 152-FZ of 27.07.2006 "On Personal Data". Site Services — interactive (dialogue) software components on the pages of the Site, used for integration with information systems and providing the users of the Site with certain capabilities for accessing information on the Site (hereinafter — the Services, the Site Services). Cookie file — a small text file stored on the User's computer or mobile device and used to save web page browsing settings. During the first visit to the Site, this file is downloaded by means of the browser. On the next visit to the Site from the same device, the browser may check for the presence of an associated cookie file (i.e. one containing the name of the Site) and use the data of that cookie file in order to send them back to the Site. This enables the Operator to determine whether the Site has previously been visited from this browser or not and, in certain cases, to modify the content displayed. Cookie files facilitate the use of the Site and make it possible to provide Users with suitable content. Cookie files are used for research and statistical purposes, in order to improve the Service provided by the Site. IP address — a unique identifier (address) of a device (computer or mobile device) connected to a local network or to the Internet.

1.7.Rights and obligations of the Operator.

1.7.1.The Operator shall be obliged:

1.7.2.The Operator shall have the right:

1.8.Rights and obligations of the User.

1.8.1.The User shall be obliged:

1.8.2.The User shall have the right to:

2PURPOSES OF THE PROCESSING OF PERSONAL DATA

2.1.The processing of personal data is limited to the achievement of specific, predetermined and lawful purposes. The personal data processed shall not be excessive in relation to the stated purposes of their processing. Only personal data that correspond to the purposes of their processing shall be subject to processing.

2.2.The Operator processes the User's personal data for the following purposes:

2.2.1.Identification of a User registered on the Site.

2.2.2.Informing about the operation of the Site (the Services), monitoring and improving the quality of the Services.

2.2.3.Providing the User with access to personalized resources of the Site.

2.2.4.Establishing communication with the User, including the sending of notifications and enquiries concerning the use of the Site, the provision of services and the performance of works, and the processing of enquiries and applications from the User.

2.2.5.Determining the User's location in order to ensure security and to prevent fraud involving the User's personal data on the Site.

2.2.6.Creating an account for the User.

2.2.7.Providing the User with effective customer and technical support in the event of problems relating to the use of the Site.

2.2.8.Sending advertising to the User with his prior consent.

3LEGAL GROUNDS FOR THE PROCESSING OF PERSONAL DATA

3.1.The legal grounds for the processing of personal data by the Operator are:

4SCOPE AND CATEGORIES OF THE PERSONAL DATA PROCESSED, CATEGORIES OF DATA SUBJECTS

4.1.The Operator may process the personal data of Users — visitors to the Operator's website.

4.2.The personal data processed by the Operator include:

4.3.Cookie files are divided into: those which are necessary for the use of the Site and its functions; and operational ones, which collect information about the use of the Site, for example about frequently visited pages. Such data may be used to optimize the Site and to simplify navigation. The information provided by such files does not make it possible to identify Users.

4.4.The Operator uses cookie files in order to collect and store fragments of data in small files on the hard disk of the User's computer or mobile device and to ensure maximum convenience of navigation taking into account the User's preferences. Such files do not store any Personal data, but are used by the Operator solely in order to identify the User's computer or mobile device and to collect navigation data (for example, the pages viewed on the Site, the User's IP address).

4.5.The use of cookie files enables the Operator to analyse traffic patterns on the Site, to enhance the convenience of navigation on the Site, to determine the User's geographical location, to save browser parameters for the automatic collection of Personal data, thereby simplifying the User's login procedure on the Site so as to offer useful links based on the pages most recently viewed, and to collect navigation statistics.

4.6.The Operator shall have the right to establish that the provision to Users of the possibility of using certain functions of the Site is permissible only on condition that the acceptance and receipt of cookie files has been permitted by the User.

4.7.The Operator protects the data that are automatically transmitted by the User in the course of viewing the information blocks of the Site and when visiting the pages of the Site, including the IP address, information from cookie files, information about the browser or other program which makes it possible to display and view advertising information, the time of access, the address of the page on which the information block is located, and the address of the previous page.

4.8.Information about Users' IP addresses is used by the Operator solely for the purpose of identifying and eliminating technical problems.

4.9.The Operator ensures that the content and scope of the personal data processed correspond to the stated purposes of processing provided for in Article 2 of the Policy.

4.10.The Operator does not process biometric personal data or special categories of personal data concerning racial or ethnic origin, political views, religious or philosophical beliefs or intimate life.

5PROCEDURE AND CONDITIONS FOR THE PROCESSING OF PERSONAL DATA

5.1.The processing of personal data by the Operator is carried out in accordance with the requirements of the legislation of the Russian Federation in the following ways:

5.2.The list of actions performed by the Operator with the User's personal data for the purposes provided for in clause 2.2 of the Policy: collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (dissemination, provision, access), depersonalization, blocking, deletion, destruction.

5.3.The processing of personal data is carried out by the Operator subject to obtaining the User's consent (hereinafter — the Consent), except in the cases established by the legislation of the Russian Federation in which the processing of personal data may be carried out without such Consent.

5.4.By providing the Operator with the information necessary for initiating further interaction, the User expresses his Consent to the use thereof in accordance with this Policy. The User takes the decision to provide his personal data and gives his Consent freely, of his own will and in his own interest.

5.5.The period of the processing of personal data is determined by the achievement of the purposes for which the personal data were collected, unless another period is provided for by a contract with the User or by the current legislation. A condition for the termination of the processing of personal data may be the achievement of the purposes of the processing of personal data or the loss of the need to achieve those purposes, the expiry of the Consent or the withdrawal of the Consent by the User, and also the detection of unlawful processing of personal data.

5.6.The Consent may be withdrawn in the following manner: by sending a written notice to the address: 125493, Moscow, ul. Smolnaya, 14, to IT-Navigator LLC, marked "withdrawal of consent to the processing of personal data".

5.7.The Operator carries out the dissemination of personal data permitted by the User for dissemination, that is to say, performs actions aimed at their disclosure to an indefinite circle of persons, in compliance with the requirements, prohibitions and conditions established by part 9 of Article 9 and Article 10.1 of Federal Law No. 152-FZ of 27.07.2006 "On Personal Data". The disclosure to third parties and the dissemination of personal data without the User's consent are not permitted, unless otherwise provided by federal law. Consent to the processing of personal data permitted by the User for dissemination is executed separately from the User's other consents to the processing of his personal data, taking into account the Requirements for the content of consent to the processing of personal data permitted by the data subject for dissemination, approved by Order of Roskomnadzor No. 18 of 24.02.2021.

5.8.In processing personal data, the Operator takes, or ensures the taking of, the necessary legal, organizational and technical measures to protect personal data against unlawful or accidental access thereto, destruction, modification, blocking, copying, provision and dissemination of personal data, as well as against other unlawful actions in respect of personal data.

5.9.Personal data are stored in a form which makes it possible to identify the User for a period no longer than required by the purposes of the processing of personal data, except in cases where the period of storage of personal data is established by federal law or by a contract to which the User is a party, beneficiary or guarantor.

5.10.In processing personal data, the Operator complies with the requirements of Article 18 of Federal Law No. 152-FZ of 27.07.2006 "On Personal Data".

5.11.In processing personal data, the Operator undertakes to observe the confidentiality of personal data.

5.12.The Operator does not carry out cross-border transfer of personal data.

5.13.In the event of unlawful or accidental transfer (provision, dissemination, access) of personal data, the Operator shall inform the User thereof within 5 (five) business days.

5.14.The Operator, jointly with the User, takes all necessary measures to prevent losses or other adverse consequences caused by the unlawful or accidental transfer (provision, dissemination, access) of the User's personal data.

6BLOCKING, CLARIFICATION AND DESTRUCTION OF PERSONAL DATA. RESPONSES TO USERS' REQUESTS FOR ACCESS TO PERSONAL DATA

6.1.In the event that unlawful processing of personal data is detected upon an application by the User (or his representative), the Operator shall block the unlawfully processed personal data relating to the User concerned from the moment of such application or of receipt of the said request of the User, for the period of the verification. In the event that inaccurate personal data are detected upon an application by the User or his representative, the Operator shall block the personal data relating to that User from the moment of such application, for the period of the verification, provided that the blocking of the personal data does not infringe the rights and legitimate interests of the User or of third parties.

6.2.In the event of confirmation of the fact that the personal data are inaccurate, the Operator shall, on the basis of the information submitted by the User (or his representative), clarify the personal data within seven business days from the date of submission of such information.

6.3.In the event that unlawful processing of personal data is detected, the Operator shall, within a period not exceeding three business days from the date of such detection, cease the unlawful processing of personal data, and if it is impossible to ensure the lawfulness of the processing of personal data, shall, within a period not exceeding ten business days from the date of detection of the unlawful processing of personal data, destroy such personal data.

6.4.In the event of the achievement of the purpose of the processing of personal data, the Operator shall destroy the personal data within a period not exceeding thirty days from the date of achievement of the purpose of the processing of personal data, unless otherwise provided by a contract to which the User is a party, beneficiary or guarantor.

6.5.In the event of the withdrawal by the User of consent to the processing of his personal data, and where the retention of the personal data is no longer required for the purposes of the processing of personal data, the Operator shall destroy the personal data within a period not exceeding thirty days from the date of receipt of the said withdrawal, unless otherwise provided by a contract to which the User is a party, beneficiary or guarantor.

6.6.Within a period not exceeding seven business days from the date of submission by the User (or his representative) of information confirming that such personal data have been unlawfully obtained or are not necessary for the stated purpose of processing, the Operator shall destroy such personal data.

6.7.The personal data processed shall be subject to destruction in the event of the loss of the need to achieve the purposes of processing, unless otherwise provided by federal law.

6.8.The Operator responds to requests and applications of the User (or his representative) concerning the processing of personal data carried out by it in the following manner: by email — to requests and applications sent to the address office@it-navigator.online, within 7 (seven) business days from the date of receipt of the request or application.

7LIABILITY OF THE PARTIES

7.1.The Operator shall be liable for violation of the requirements of Federal Law No. 152-FZ of 27.07.2006 "On Personal Data" in accordance with the legislation of the Russian Federation.

7.2.The User shall have the right to claim compensation for losses and (or) compensation for moral harm through the courts.

8SETTLEMENT OF DISPUTES

8.1.In the event of disputes and/or disagreements arising out of the relations between the User and the Operator, such matters shall be resolved in accordance with the current legislation of the Russian Federation.

8.2.The current legislation of the Russian Federation shall apply to the Policy and to the relations between the User and the Operator.

9FINAL PROVISIONS

9.1.The Operator shall have the right to make amendments to the Policy without the User's consent.

9.2.The new version of the Policy shall enter into force from the moment of its publication on the Site, unless otherwise provided by the new version of the Policy. The new version of the Policy shall apply to relations that arise after its entry into force.

9.3.All suggestions or questions regarding the Policy should be sent to the email address office@it-navigator.online.