Personal Data Processing and Cookie Policy

Date of publication: 6 June 2025

1. General Provisions

This personal data processing policy has been prepared in accordance with the requirements of Federal Law No. 152-FZ of 27 July 2006 “On Personal Data” (the “Personal Data Law”) and sets out the procedures for processing personal data and the measures taken to ensure the security of personal data by BIZ-MARK Limited Liability Company (Taxpayer Identification Number (INN): 5038190335; Primary State Registration Number (OGRN): 1245000102764) (the “Operator”).

1.1. The Operator considers respect for human and civil rights and freedoms in the processing of personal data, including protection of the right to privacy and the confidentiality of personal and family matters, to be a primary objective and a prerequisite for its activities.

1.2. This policy of the Operator concerning the processing of personal data (the “Policy”) applies to all information that the Operator may obtain concerning visitors to https://biz-mark.ru.

2. Definitions Used in the Policy

2.1. Automated processing of personal data means the processing of personal data using computer technology.

2.2. Blocking of personal data means the temporary suspension of the processing of personal data, except where processing is necessary for the rectification of personal data.

2.3. Website means the collection of graphic and informational materials, together with computer programs and databases, that make such materials available on the Internet at https://biz-mark.ru.

2.4. Personal data information system means a combination of personal data held in databases and the information technologies and technical means used to process such data.

2.5. De-identification of personal data means actions that make it impossible to determine, without additional information, whether personal data relate to a particular User or another data subject.

2.6. Processing of personal data means any action (operation) or combination of actions (operations) performed on personal data, with or without automated means, including collection, recording, systematisation, accumulation, storage, rectification (updating, amendment), retrieval, use, transfer (dissemination, disclosure, provision of access), de-identification, blocking, deletion and destruction of personal data.

2.7. Operator means a state authority, municipal authority, legal entity or individual that, independently or jointly with others, organises and/or carries out the processing of personal data and determines the purposes of such processing, the personal data to be processed, and the actions (operations) to be performed in relation to those data.

2.8. Personal data means any information relating directly or indirectly to an identified or identifiable User of https://biz-mark.ru.

2.9. Personal data authorised by the data subject for dissemination means personal data to which the data subject has granted access to an unlimited number of persons by consenting to the processing of personal data authorised by that data subject for dissemination, in accordance with the procedure established by the Personal Data Law (hereinafter, “personal data authorised for dissemination”).

2.10. User means any visitor to https://biz-mark.ru.

2.11. Disclosure of personal data means actions intended to disclose personal data to a specific person or a specific group of persons.

2.12. Dissemination of personal data means any actions intended to disclose personal data to an unspecified group of persons (transfer of personal data) or to make personal data available to an unlimited number of persons, including publication of personal data in the mass media, posting on information and telecommunications networks, or providing access to personal data by any other means.

2.13. Cross-border transfer of personal data means the transfer of personal data to the territory of a foreign state, to an authority of that state, a foreign individual or a foreign legal entity.

2.14. Destruction of personal data means any actions resulting in the irreversible destruction of personal data, such that the content of the personal data cannot subsequently be restored in a personal data information system, and/or the destruction of physical media containing personal data.

2.15. Cookies are small text files stored on a user’s device (computer, mobile phone or tablet) when visiting websites, which may contain an identifier, settings and information about the user’s interaction with a website.

3. Principal Rights and Obligations of the Operator

3.1. The Operator is entitled to:

• obtain accurate information and/or documents containing personal data from the data subject;
• continue processing personal data without the data subject’s consent where the data subject withdraws consent to the processing of personal data or requests that such processing be discontinued, provided that grounds for such processing exist under the Personal Data Law;
• independently determine the scope and list of measures necessary and sufficient to fulfil the obligations laid down by the Personal Data Law and the regulations adopted pursuant to it, unless otherwise provided by the Personal Data Law or other federal laws.

3.2. The Operator shall:

• provide the data subject, upon request, with information concerning the processing of their personal data;
• organise the processing of personal data in accordance with the applicable legislation of the Russian Federation;
• respond to enquiries and requests from data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
• provide the competent authority for the protection of data subjects’ rights, upon its request, with the required information within 10 days of receiving such a request;
• publish this Policy or otherwise provide unrestricted access to it;
• implement legal, organisational and technical measures to protect personal data against unlawful or accidental access, destruction, alteration, blocking, copying, disclosure, dissemination and any other unlawful actions in relation to personal data;
• cease the transfer of personal data (dissemination, disclosure, provision of access), cease processing and destroy personal data in the circumstances and in accordance with the procedures established by the Personal Data Law;
• fulfil other obligations laid down by the Personal Data Law.

4. Principal Rights and Obligations of Data Subjects

4.1. Data subjects are entitled to:

• obtain information concerning the processing of their personal data, except in cases provided for by federal laws. The Operator shall provide such information in an accessible form, and it shall not contain personal data relating to other data subjects unless there are lawful grounds for disclosing such personal data. The information to be provided and the procedure for obtaining it are established by the Personal Data Law;
• require the Operator to rectify, block or destroy their personal data if the data are incomplete, outdated, inaccurate, unlawfully obtained or unnecessary for the stated purpose of processing, and take measures provided for by law to protect their rights;
• require prior consent to the processing of their personal data for the purpose of promoting goods, works and services on the market;
• withdraw consent to the processing of their personal data and submit a request that such processing be discontinued;
• challenge unlawful acts or omissions of the Operator in the processing of their personal data before the competent authority for the protection of data subjects’ rights or in court;
• exercise other rights provided for by the legislation of the Russian Federation.

4.2. Data subjects shall:

• provide the Operator with accurate information about themselves;
• notify the Operator of any rectification (updating, amendment) of their personal data.

4.3. Persons who provide the Operator with inaccurate information about themselves, or information about another data subject without that data subject’s consent, shall be liable in accordance with the legislation of the Russian Federation.

5. Principles of Personal Data Processing

5.1. Personal data shall be processed lawfully and fairly.

5.2. Personal data shall be processed only for specific, predetermined and lawful purposes. Processing that is incompatible with the purposes for which personal data were collected is prohibited.

5.3. Databases containing personal data processed for mutually incompatible purposes shall not be combined.

5.4. Only personal data relevant to the purposes of processing shall be processed.

5.5. The content and volume of the personal data processed shall correspond to the stated purposes of processing. The personal data processed shall not be excessive in relation to those purposes.

5.6. When processing personal data, the accuracy and adequacy of the data shall be ensured, and the data shall be kept up to date where necessary for the purposes of processing. The Operator shall take the necessary measures and/or ensure that such measures are taken to delete or rectify incomplete or inaccurate data.

5.7. Personal data shall be retained in a form that permits identification of the data subject for no longer than is required for the purposes of processing, unless a retention period is prescribed by federal law or by a contract to which the data subject is a party, beneficiary or guarantor.

Personal data being processed shall be destroyed or de-identified once the purposes of processing have been achieved or when the need to achieve those purposes no longer exists, unless otherwise provided by federal law.

6. Purposes of Personal Data Processing, Categories and List of Personal Data Processed, Legal Bases and Processing Methods

Note: The specific personal data processed may vary. The Operator processes only the data necessary to achieve the stated purposes. Detailed information on the use of cookies is provided in the relevant section of this Policy or in the notice displayed on the Website.

7. Conditions for Personal Data Processing

7.1. Personal data are processed with the data subject’s consent to the processing of their personal data.

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

7.3. Personal data processing is necessary for the administration of justice or the enforcement of a judicial act or an act of another authority or official that is enforceable under the legislation of the Russian Federation on enforcement proceedings.

7.4. Personal data processing is necessary for the performance of a contract to which the data subject is a party or under which the data subject is a beneficiary or guarantor, or for entering into a contract at the data subject’s request or a contract under which the data subject will be a beneficiary or guarantor.

7.5. Personal data processing is necessary for the exercise of the rights and legitimate interests of the Operator or third parties, or for the achievement of objectives of public importance, provided that such processing does not infringe the data subject’s rights and freedoms.

7.6. The Operator processes personal data to which the data subject has granted unrestricted public access, or to which such access has been granted at the data subject’s request (hereinafter referred to as “publicly available personal data”).

7.7. The Operator processes personal data that are subject to publication or mandatory disclosure under federal law.

8. Procedures for the Collection, Storage, Transfer and Other Processing of Personal Data

The security of personal data processed by the Operator is ensured through the implementation of the legal, organisational and technical measures necessary to comply in full with the requirements of applicable personal data protection legislation.

8.1. The Operator safeguards personal data and takes all possible measures to prevent unauthorised persons from accessing them.

8.2. The User’s personal data may be transferred to authorised state authorities of the Russian Federation only on the grounds and in accordance with the procedures established by the legislation of the Russian Federation.

8.3. If inaccuracies in personal data are identified, the User may arrange for the data to be updated by sending a notice to the Operator at info@biz-mark.ru with the subject line “Personal Data Update”.

8.4. Personal data are processed until the purposes for which they were collected have been achieved, unless a different period is prescribed by a contract or applicable law. The User may withdraw consent to personal data processing at any time by sending a notice to the Operator at info@biz-mark.ru with the subject line “Withdrawal of Consent to Personal Data Processing”.

8.5. All information collected by third-party services, including payment systems, communications services and other service providers, is stored and processed by those parties (operators) in accordance with their respective User Agreements and Privacy Policies. The data subject must independently review those documents in a timely manner. The Operator is not liable for the actions of third parties, including the service providers referred to in this clause.

8.6. Prohibitions on transfer (other than the provision of access), and prohibitions or conditions on processing (other than obtaining access), imposed by a data subject in relation to personal data authorised for dissemination do not apply where personal data are processed in state, societal or other public interests specified by the legislation of the Russian Federation.

8.7. The Operator maintains the confidentiality of personal data during processing.

8.8. The Operator stores personal data in a form that permits identification of the data subject for no longer than is required by the purposes of processing, unless the retention period is prescribed by federal law or by a contract to which the data subject is a party or under which the data subject is a beneficiary or guarantor.

8.9. Personal data processing may cease upon achievement of the purposes of processing, expiry of the data subject’s consent, withdrawal of consent by the data subject, receipt of a request to cease processing, or identification of unlawful personal data processing.

9. Operations Performed by the Operator on Personal Data Received

9.1. The Operator collects, records, systematises, accumulates, stores, rectifies (updates, amends), retrieves, uses, transfers (disseminates, discloses, provides access to), de-identifies, blocks, deletes and destroys personal data.

9.2. The Operator performs automated processing of personal data, with or without receiving and/or transmitting the information obtained over information and telecommunications networks.

10. Cookies and Website Analytics

We want you to be able to use our Website as intended. To ensure that it operates correctly, we use cookies that collect information about Users. By continuing to use our Website, you consent to the use of cookies in accordance with this Policy.

10.1. What Are Cookies?

Cookies are small text files, usually consisting of letters and numbers, that are stored on your device (computer, smartphone or tablet) when you visit websites. Cookies enable a website to recognise your device and display our Website in accordance with your preferences.

10.2. Types of Cookies We Use

Our Website uses the following types of cookies:

1. Technical (essential) cookies support the core functions of the Website. The Website cannot function correctly without them.
2. Analytics cookies help us analyse how the Website is used and improve its operation.
3. Functional cookies enable us to remember your settings and preferences.
4. Marketing cookies are used to personalise advertising and track the effectiveness of advertising campaigns.

10.3. Specific Cookies We Use

Data collected through cookies do not constitute special categories of personal data or biometric personal data within the meaning of Articles 10–11 of Federal Law No. 152-FZ and are processed by automated means.

In this case, the legal basis for processing your data is consent to personal data processing, given by the User through conduct indicating consent, namely continued use of the Website.

Upon expiry of the specified processing periods, personal data are destroyed by deleting them from the information systems using the systems’ built-in tools.

10.4. Managing Cookies

You may disable or restrict the sending of cookies at any time through your browser settings:

• Google Chrome: Menu → Settings → Show advanced settings → Privacy → Content settings.
• Mozilla Firefox: Menu → Settings → Privacy & Security → Cookies and Site Data.
• Safari: Settings → Safari → Privacy & Security.
• Microsoft Edge: Menu → Settings → Cookies and site permissions.

Please note that disabling certain cookies may affect the functionality of the Website.

11. Transfers of Data to Third Parties

To provide our services and improve their quality, we transfer information about you to the following third parties: