Personal Data Processing Policy

1. General Provisions

This Personal Data Processing Policy (hereinafter — 'Policy') defines the procedure for processing and protecting personal data of users of the website https://websailors.ru.

The Policy is developed in accordance with Federal Law No. 152-FZ of 27.07.2006 'On Personal Data' and other regulatory legal acts of the Russian Federation.

2. Personal Data Operator

3. Principles of Personal Data Processing

Personal data processing is carried out based on the following principles:

• Lawfulness and fairness of processing
• Compliance of processing purposes with declared purposes
• Compliance of volume and nature of processed data with declared purposes
• Inadmissibility of combining databases created for incompatible purposes
• Data storage no longer than required by processing purposes
• Data destruction or anonymization upon achieving processing purposes

Within this Policy, 'user personal data' means: personal data that the user provides about themselves independently on the Website or during interaction, as well as contractual relations. Such information includes: last name, first name, patronymic, email address, contact phone.

Personal data provided by the user is considered unreliable and may be blocked until the user or their legal representative provides consent to the processing of the user's personal data in any additionally specified form besides that provided on the Website.

4. Categories of Processed Personal Data

Automatically Collected Data:

• IP address
• Browser and device information
• Data about visited pages and actions taken
• Visit date and time
• Cookie files
• Website referral source

5. Data Not Subject to Processing

The Operator does not process special categories of personal data relating to race or ethnic origin, political views, religious or philosophical beliefs, health status, intimate life.

6. Purposes of Personal Data Processing

The Company processes only those personal data necessary for providing and improving the quality of Services.

The Company may use user personal information for the following purposes:

• Identifying the party in the context of providing the Service
• Providing the user with personalized Services
• Improving quality of Services and developing new ones
• Carrying out and/or performing functions, powers and duties imposed by the legislation of the Russian Federation

7. Legal Grounds for Processing

Personal data processing is carried out on the following legal grounds:

• Consent of the personal data subject (Art. 6 Part 1 Item 1 of Law 152-FZ)
• Legitimate interests of the operator (Art. 6 Part 1 Item 7 of Law 152-FZ)

8. Transfer of Data to Third Parties

Personal data may be transferred to third parties in the following cases:

• With user consent
• As required by Russian Federation legislation

When transferring data, the Operator requires third parties to maintain confidentiality and ensure data protection.

9. Localization of Personal Data

In accordance with the requirements of Part 5 of Article 18 of Federal Law No. 152-FZ of 27.07.2006 'On Personal Data', when collecting personal data, including via the Internet, the Operator ensures recording, systematization, accumulation, storage, clarification (updating, modifying), extraction of personal data of citizens of the Russian Federation using databases located on the territory of the Russian Federation.

10. Protection of Personal Data

The Company takes necessary and sufficient organizational and technical measures to protect user personal data from unauthorized or accidental access, destruction, modification, blocking, copying, distribution, as well as other unlawful actions with personal data of third parties.

Organizational measures:

• Restricted access to personal data
• Appointment of data processing officers
• Employee training in data handling rules

11. Rights and Obligations of the Personal Data Subject

The User is responsible for providing accurate information, as well as updating the provided data in case of any changes.

The User may at any time change (update, supplement) the personal information provided by them or part of it, as well as parameters of its confidentiality by contacting the Company. The User may request clarification, blocking or destruction of data.

The User has the right to receive information regarding the processing of their personal data and has the right at any time to withdraw consent to personal data processing by sending a written notice to the email address: denis.benyaminov@gmail.com with the note 'withdrawal of consent to personal data processing'.

The User may appeal the Operator's actions to Roskomnadzor or court.

According to this Policy, the Operator may require confirmation of the User's identity by requesting such confirmation in any form not contrary to law.

12. Data Retention Period

Personal data is stored for the period necessary to achieve processing purposes.

13. Changes to the Policy

The Operator has the right to make changes to this Policy.