Personal Data Processing Policy

This Personal Data Processing Policy (the “Policy”) has been prepared in accordance with Federal Law of the Russian Federation No. 152-FZ “On Personal Data” of 27 July 2006 (the “Personal Data Law”) and sets out how personal data is processed and protected by [Operator name] (the “Operator”).

The Policy applies to personal data the Operator receives from visitors of the website [Website address] (the “Website”), including through the forms on the Website: the project inquiry, the project builder questionnaire, the one-to-one work request, the AI production request and the product launch notification request.

The Operator processes personal data lawfully, fairly and to the minimum extent necessary: only for predefined purposes and only as much as those purposes require.

This English version is provided for convenience. In case of any discrepancy, the Russian version prevails.

The personal data operator is:

• name: [Operator name];
• taxpayer ID / state registration number: [INN/OGRN];
• address: [Address];
• email for personal data requests: [Contact email].

Personal data means any information relating directly or indirectly to an identified or identifiable natural person (the data subject).

Processing means any operation or set of operations performed on personal data, with or without automation, including collection, recording, organization, accumulation, storage, adjustment, retrieval, use, transfer (provision, access), depersonalization, blocking, deletion and destruction.

Other terms are used as defined in the Personal Data Law.

Through the forms on the Website (project inquiry, builder questionnaire, one-to-one work request, AI production request, product launch notification) the Operator receives only the data you provide yourself:

• your name or how you would like to be addressed;
• company or project name — optional;
• contact details: Telegram username, email address or phone number;
• the selected area of cooperation and the task description or comment — to the extent they contain personal data;
• your builder questionnaire answers: niche, market, audience size, goal, needs, budget range and comment;
• the selected work format, production line, or the product whose launch you asked to be notified about.

When you visit the Website, the hosting infrastructure may automatically process technical data: IP address, browser and device information, date and time of the request. [Web analytics tools and cookies, if used on the Website]

The Operator does not process special categories of personal data or biometric data. Please do not include such information in your task description.

Personal data is processed for the following purposes:

• reviewing your inquiry and contacting you via the contact details you provided;
• preparing a cooperation proposal and discussing terms;
• notifying you about the launch of a digital product — only if you left your contact for such a notification yourself;
• concluding and performing a contract, should you decide to enter into one;
• keeping the Website running and secure, including protecting the form against spam and abuse.

The Operator does not use data from the form for marketing mailings without your separate consent.

Processing is based on the data subject's consent to the processing of their personal data (Article 6(1)(1) of the Personal Data Law), given when you submit the form on the Website.

If a contract is concluded between you and the Operator, processing is also carried out to conclude and perform that contract (Article 6(1)(5) of the Personal Data Law).

Personal data is processed both with and without automation. The Operator performs only the operations needed for the purposes set out in this Policy: collection, recording, organization, accumulation, storage, adjustment, retrieval, use, transfer (provision, access), blocking, deletion and destruction.

The Operator takes legal, organizational and technical measures to protect personal data against unlawful or accidental access, destruction, alteration, blocking, copying, provision and dissemination: access is limited to the people who need it, form data is transmitted over HTTPS, and the security features of the services in use are applied.

Personal data is stored no longer than the purposes of processing require: [Retention period], unless a different period is set by law or by a contract with you.

When collecting personal data of citizens of the Russian Federation, the Operator records, organizes, accumulates, stores, adjusts and retrieves it using databases located in the Russian Federation (Article 18(5) of the Personal Data Law). Database location: [Data storage location].

Once the purposes of processing are achieved, or if consent is withdrawn, personal data is destroyed within the time limits set by the Personal Data Law, unless the Operator has another lawful basis for processing it.

The Operator does not sell personal data or make it available to the general public.

To deliver and handle inquiries, the Operator may engage third parties (processors) to process personal data on its behalf under a contract (Article 6(3) of the Personal Data Law). Processors must keep personal data confidential and secure. Processors:

• [Messaging service used to deliver inquiries to the Operator — service name and provider];
• [CRM or automation service inquiries are passed to — name];
• [Website hosting provider — name].

Personal data may be disclosed to public authorities in the cases and manner prescribed by the laws of the Russian Federation.

Some services used to deliver inquiries and run the Website may host servers outside the Russian Federation. In that case, cross-border transfer of personal data is carried out in accordance with Article 12 of the Personal Data Law, including after notifying the authorized data protection authority of the intention to carry it out.

Countries and services to which data may be transferred: [List of countries and services, or a statement that no cross-border transfer takes place].

You have the right to:

• receive information about the processing of your personal data (Article 14 of the Personal Data Law);
• request that your personal data be corrected, blocked or destroyed if it is incomplete, outdated, inaccurate, unlawfully obtained or not necessary for the stated purpose;
• withdraw your consent to processing;
• appeal against the Operator's actions or inaction to the authorized data protection authority (Roskomnadzor) or in court.

To exercise your rights or withdraw consent, send a request to [Contact email]. The Operator reviews requests and responds within the time limits set by the Personal Data Law.

The Operator may amend this Policy. A new version takes effect when it is published on the Website, unless the new version provides otherwise.

The current version of the Policy is always available at [Policy page address].

For any questions about the processing of personal data, contact the Operator:

• email: [Contact email];
• postal address: [Address].