Policy regarding the processing of personal data

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 determines the procedure for processing personal data and measures taken by A4 Real Estate (hereinafter referred to as the "Operator") to ensure the security of personal data.
1.1. The Operator considers the observance of human and citizen rights and freedoms in processing their personal data, including the protection of privacy, personal and family secrets, to be a key goal and prerequisite for its activities.
1.2. This Operator Policy on personal data processing (hereinafter referred to as the "Policy") applies to all information that the Operator may receive about visitors to the website https://a4.estate.

2. Terms Used in the Policy
2.1. Automated processing of personal data: Processing of personal data using computer technologies.
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 collection of graphic and informational materials, as well as software and databases, accessible via the internet at https://a4.estate.
2.4. Personal Data Information System: A set of personal data contained in databases and ensuring their processing via information technologies and technical means.
2.5. Anonymization of personal data: Actions that make it impossible to determine without additional information the identity of personal data related to a specific User or other subject of personal data.
2.6. Processing of personal data: Any action (operation) or a set of actions (operations) performed on personal data with or without the use of automation tools, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
2.7. Operator: A state or municipal body, a legal entity, or an individual that independently or together with others organizes and/or performs the processing of personal data, determines the purposes of personal data processing, the composition of personal data subject to processing, and the actions (operations) performed with the personal data.
2.8. Personal data: Any information directly or indirectly related to an identified or identifiable User of the website https://a4.estate.
2.9. Personal data authorized for distribution: Personal data to which an unlimited number of persons have access, as provided by the personal data subject through consent for processing under the terms defined by the Personal Data Law (hereinafter referred to as "Personal Data Authorized for Distribution").
2.10. User: Any visitor to the website https://a4.estate.
2.11. Provision of personal data: Actions aimed at disclosing personal data to a specific person or a specific group of people.
2.12. Distribution of personal data: Any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or granting access to personal data to an unlimited number of persons, including publicizing personal data in media, posting in information and telecommunication networks, or granting 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, a foreign authority, a foreign natural person, or a foreign legal entity.
2.14. Destruction of personal data: Any actions resulting in the irretrievable destruction of personal data, making it impossible to restore the content of personal data in the personal data information system and/or leading to the destruction of the physical media on which personal data is stored.

3. Rights and Responsibilities of the Operator
3.1. The Operator has the right to:

• Obtain accurate information and/or documents containing personal data from the personal data subject.
• Continue processing personal data without the consent of the personal data subject in cases specified in the Personal Data Law.
• Independently determine the composition and list of measures necessary and sufficient to ensure compliance with the Personal Data Law, except as otherwise provided by federal laws.

3.2. The Operator is obliged to:

• Provide the personal data subject with information regarding the processing of their personal data upon request.
• Organize the processing of personal data as per Russian legislation.
• Respond to inquiries and requests from personal data subjects and their legal representatives as required by the Personal Data Law.
• Notify the authorized body for the protection of personal data subjects of necessary information upon request within 10 days.
• Publish or otherwise ensure unrestricted access to this Policy.
• Take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, alteration, blocking, copying, provision, dissemination, and other unlawful actions.
• Cease the transfer of personal data and destroy personal data under the terms specified in the Personal Data Law.

4. Rights and Responsibilities of Personal Data Subjects
4.1. Personal data subjects have the right to:

• Obtain information on the processing of their personal data, except as otherwise stipulated by federal laws.
• Demand that the Operator update, block, or destroy their personal data if it is incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for processing purposes.
• Revoke consent for personal data processing and demand the termination of personal data processing.
• Complain to the authorized body or court about unlawful actions or inactions of the Operator during personal data processing.

4.2. Personal data subjects are required to:

• Provide accurate personal data to the Operator.
• Inform the Operator about the clarification (updating, modification) of their personal data.

5. Principles of Personal Data Processing
5.1. Processing of personal data is carried out on a lawful and fair basis.
5.2. Processing of personal data is limited to achieving specific, predetermined, and lawful purposes. Processing of personal data incompatible with the purposes of data collection is not allowed.
5.3. It is prohibited to combine databases containing personal data if the processing purposes are incompatible.
5.4. Only personal data that is relevant to the stated purposes of processing is subject to processing.
5.5. The content and scope of personal data processed must correspond to the stated purposes of processing. Processing of excessive personal data beyond the stated purposes is not allowed.
5.6. Accuracy, adequacy, and, where necessary, relevance of personal data in relation to the purposes of processing are ensured during data processing. The Operator takes necessary measures to delete or clarify incomplete or inaccurate data.
5.7. Personal data is stored in a form that allows the identification of the personal data subject for no longer than required by the purposes of processing, unless otherwise specified by federal law or a contract to which the personal data subject is a party, beneficiary, or guarantor. Processed personal data is destroyed or anonymized upon achieving the purposes of processing or if there is no longer a need to achieve those purposes, unless otherwise stipulated by federal law.

6. Purposes of Personal Data ProcessingPurpose of Processing
Informing the User via email communications.
Personal Data Processed

• Surname, first name, patronymic.
• Email address.
• Phone numbers.

Legal Grounds for Processing

• Founding (charter) documents of the Operator.

Types of Personal Data Processing

• Collection, recording, systematization, accumulation, storage, destruction, and anonymization of personal data.
• Sending informational emails to the provided email addresses.

7. Conditions for Processing Personal Data7.1. Consent of the Subject
The processing of personal data is carried out with the consent of the personal data subject.
7.2. Legal Requirements
The processing of personal data is necessary to achieve the objectives provided for by an international treaty of the Russian Federation or a law, or to perform functions, powers, and obligations imposed on the Operator by the legislation of the Russian Federation.
7.3. Judicial or Legal Obligations
The processing of personal data is necessary for the administration of justice, enforcement of a judicial act, or an act of another authority or official subject to execution under the legislation of the Russian Federation on enforcement proceedings.
7.4. Contractual Obligations
The processing of personal data is necessary for the performance of a contract to which the personal data subject is a party, a beneficiary, or a 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. Legitimate Interests
The processing of personal data is necessary to protect the rights and legitimate interests of the Operator or third parties or to achieve socially significant goals, provided that this does not violate the rights and freedoms of the personal data subject.
7.6. Publicly Available Personal Data
The processing of personal data is carried out when the personal data has been made publicly accessible by the personal data subject or at their request.
7.7. Mandatory Disclosure
The processing of personal data is carried out when it is subject to publication or mandatory disclosure under federal law.

8. Procedure for Collecting, Storing, Transferring, 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 current legislation on personal data protection.
8.1. Protection of Personal Data
The Operator ensures the security of personal data and takes all possible measures to exclude unauthorized access to personal data.
8.2. Transfer of Personal Data
The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to compliance with applicable law or if the personal data subject has given consent to the Operator for the transfer of data to a third party to fulfill obligations under a civil contract.
8.3. Updating Personal Data
If inaccuracies in personal data are identified, the User may update them independently by sending a notification to the Operator's email address at office@a4.estate with the subject line "Updating Personal Data."
8.4. Duration of Personal Data Processing
The duration of personal data processing is determined by achieving the purposes for which the personal data was collected unless a different period is specified by a contract or applicable law.
The User may withdraw consent to the processing of personal data at any time by sending a notification to the Operator via email at office@a4.estate with the subject line "Withdrawal of Consent for Personal Data Processing."
8.5. Data Collection by Third-Party Services
All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by these entities in accordance with their User Agreement and Privacy Policy. The Operator is not responsible for the actions of third parties, including the aforementioned service providers.
8.6. Exceptions for Public Interest
Restrictions imposed by the personal data subject on the transfer, processing, or conditions of processing personal data permitted for distribution do not apply in cases of processing personal data for public, governmental, or other interests as defined by the legislation of the Russian Federation.
8.7. Confidentiality of Personal Data
The Operator ensures the confidentiality of personal data during processing.
8.8. Storage Duration
The Operator stores personal data in a form that allows identification of the personal data subject no longer than required by the purposes of processing unless a different storage period is established by federal law or a contract involving the personal data subject.
8.9. Termination of Processing
Conditions for terminating personal data processing include achieving the purposes of processing, expiration of the data subject's consent, withdrawal of consent by the data subject, a demand for termination of processing, or the detection of unlawful processing of personal data.
9. List of Actions Performed by the Operator with Received Personal Data9.1. Types of Actions
The Operator performs the following actions with personal data:

• Collection.
• Recording.
• Systematization.
• Accumulation.
• Storage.
• Updating (clarification, modification).
• Retrieval.
• Use.
• Transfer (distribution, provision, access).
• Anonymization.
• Blocking.
• Deletion.
• Destruction.

9.2. Automated Processing
The Operator carries out automated processing of personal data, which may include the receipt and/or transfer of obtained information through telecommunications networks or without their use.

10. Cross-Border Transfer of Personal Data10.1. Notification of Regulatory Authorities
Before initiating activities involving the cross-border transfer of personal data, the Operator must notify the authorized body for the protection of personal data subjects' rights about its intention to carry out such transfers. This notification is submitted separately from the notification of intent to process personal data.
10.2. Verification of Recipients
Prior to submitting the aforementioned notification, the Operator is required to obtain relevant information from the foreign government authorities, foreign individuals, or foreign legal entities to whom the cross-border transfer of personal data is planned.
11. Confidentiality of Personal Data
The Operator and other parties who have access to personal data are obligated not to disclose or distribute personal data to third parties without the consent of the personal data subject, except as provided by federal law.
12. Final Provisions12.1. User Inquiries
Users can obtain any clarification regarding the processing of their personal data by contacting the Operator via email at office@a4.estate.
12.2. Policy Updates
This document will reflect any changes to the Operator's personal data processing policy. The Policy remains in effect indefinitely until replaced with a new version.
12.3. Availability of the Current Version
The current version of the Policy is freely available on the Internet at https://a4.estate/privacy.