Privacy Policy

1. General Provisions
This personal data processing policy is drafted in accordance with the requirements of the Federal Law dated 27.07.2006 No. 152-FZ "On Personal Data" (hereinafter referred to as the Personal Data Law) and defines the procedure for processing personal data and measures to ensure the security of personal data undertaken by Trondin Nikita Alexandrovich (hereinafter referred to as the Operator).

1.1. The Operator sets as its most important goal and condition for its activities the observance of human and civil rights and freedoms in the processing of their personal data, including the protection of rights to privacy, personal and family secrets.

1.2. This Operator's policy regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator may obtain about visitors to the website http://paxmercatus.com.

2. Basic Concepts Used in the Policy

2.1. Automated processing of personal data — processing of personal data using computer equipment.

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 computer programs and databases, ensuring their availability on the Internet at the network address http://paxmercatus.com.

2.4. Personal data information system — a collection of personal data contained in databases and information technologies and technical means ensuring their processing.

2.5. Depersonalization of personal data — actions as a result of which it is impossible to determine, without using additional information, the belonging of personal data to a specific User or other subject of personal data.

2.6. Processing of personal data — any action (operation) or set of actions (operations) performed with or without the use of automation means with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.

2.7. Operator — a state body, municipal body, legal entity or individual, independently or jointly with other persons organizing and/or carrying out the processing of personal data, as well as determining the purposes of processing personal data, the composition of personal data to be processed, actions (operations) performed with personal data.

2.8. Personal data — any information relating directly or indirectly to a specific or identifiable User of the website http://paxmercatus.com.

2.9. Personal data permitted by the subject of personal data for distribution — personal data to which access by an unlimited number of persons is provided by the subject of personal data by giving consent to the processing of personal data permitted by the subject of personal data for distribution in the manner prescribed by the Personal Data Law (hereinafter referred to as personal data permitted for distribution).

2.10. User — any visitor to the website http://paxmercatus.com.

2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or specific circle of persons.

2.12. Distribution of personal data — any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or familiarizing with personal data by an unlimited number of persons, including publication of personal data in the media, placement in information and telecommunications networks or providing 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 to a body of authority of a foreign state, foreign natural person or foreign legal entity.

2.14. Destruction of personal data — any actions as a result of which personal data are destroyed irrevocably with the impossibility of further restoration of the content of personal data in the personal data information system and/or material carriers of personal data are destroyed.

3. Basic Rights and Obligations of the Operator

3.1. The Operator has the right to:
— receive from the subject of personal data reliable information and/or documents containing personal data;
— in case of withdrawal by the subject of personal data of consent to the processing of personal data, as well as sending an appeal with a demand to cease processing of personal data, the Operator has the right to continue processing personal data without consent of the subject of personal data in the presence of grounds specified in the Personal Data Law;
— independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations provided for by the Personal Data Law and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.

3.2. The Operator is obliged to:
— provide the subject of personal data upon his request with information regarding the processing of his personal data;
— organize the processing of personal data in the manner established by the current legislation of the Russian Federation;
— respond to appeals and requests of subjects of personal data and their legal representatives in accordance with the requirements of the Personal Data Law;
— report to the authorized body for the protection of rights of subjects of personal data upon request of this body the necessary information within 10 days from the date of receipt of such request;
— publish or otherwise ensure unrestricted access to this Policy regarding the processing of personal data;
— take legal, organizational and technical measures to protect personal data from unauthorized or accidental access to them, destruction, alteration, blocking, copying, provision, distribution of personal data, as well as from other unlawful actions in relation to personal data;
— cease transfer (distribution, provision, access) of personal data, cease processing and destroy personal data in the manner and in cases provided for by the Personal Data Law;
— fulfill other obligations provided for by the Personal Data Law.

4. Basic Rights and Obligations of Subjects of Personal Data

4.1. Subjects of personal data have the right to:
— receive information regarding the processing of their personal data, except in cases provided for by federal laws. Information is provided to the subject of personal data by the Operator in an accessible form, and it should not contain personal data relating to other subjects of personal data, except in cases where there are legal grounds for disclosure of such personal data. The list of information and the procedure for its receipt are established by the Personal Data Law;
— demand from the operator clarification of their personal data, their blocking or destruction in case personal data are incomplete, outdated, inaccurate, unlawfully obtained or are not necessary for the stated purpose of processing, as well as take measures provided by law to protect their rights;
— put forward the condition of prior consent when processing personal data for the purpose of promoting goods, works and services on the market;
— withdraw consent to the processing of personal data, as well as send a demand to cease processing of personal data;
— appeal to the authorized body for the protection of rights of subjects of personal data or in court against unlawful actions or inaction of the Operator in the processing of their personal data;
— exercise other rights provided for by the legislation of the Russian Federation.

4.2. Subjects of personal data are obliged to:
— provide the Operator with reliable data about themselves;
— inform the Operator about clarification (updating, modification) of their personal data.

4.3. Persons who have provided the Operator with false information about themselves, or information about another subject of personal data without the latter's consent, shall be liable in accordance with the legislation of the Russian Federation.

5. Principles of Processing Personal Data

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 collecting personal data is not allowed.

5.3. Combining databases containing personal data, the processing of which is carried out for purposes incompatible with each other, is not allowed.

5.4. Only personal data that meet the purposes of their processing are subject to processing.

5.5. The content and volume of processed personal data correspond to the stated purposes of processing. Excessiveness of processed personal data in relation to the stated purposes of their processing is not allowed.

5.6. When processing personal data, the accuracy of personal data, their sufficiency, and in necessary cases their relevance in relation to the purposes of processing personal data are ensured. The Operator takes necessary measures and/or ensures their adoption to delete or clarify incomplete or inaccurate data.

5.7. Storage of personal data is carried out in a form that allows determining the subject of personal data no longer than required by the purposes of processing personal data, unless the storage period of personal data is established by federal law, contract, party to which, beneficiary or guarantor under which is the subject of personal data. Processed personal data are destroyed or depersonalized upon achievement of the purposes of processing or in case of loss of necessity in achieving these purposes, unless otherwise provided by federal law.

6. Purposes of Processing Personal Data

| Personal Data | Purpose of Processing |
|---------------|----------------------|
| Last name, first name, patronymic | Conclusion of contracts between the operator and the subject of personal data |
| Email address | Sending informational letters to email address |
| Phone numbers | Sending informational letters to email address |

7. Conditions of Processing Personal Data

7.1. Processing of personal data is carried out with the consent of the subject of personal data to the processing of their personal data.

7.2. Processing of personal data is necessary for achieving the purposes provided for by an international treaty of the Russian Federation or law, for exercising the functions, powers and obligations imposed on the operator by the legislation of the Russian Federation.

7.3. Processing of personal data is necessary for the administration of justice, execution of a court act, act of another body or official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.

7.4. Processing of personal data is necessary for the execution of a contract, party to which or beneficiary or guarantor under which is the subject of personal data, as well as for concluding a contract at the initiative of the subject of personal data or a contract under which the subject of personal data will be a beneficiary or guarantor.

7.5. Processing of personal data is necessary for exercising the rights and legitimate interests of the operator or third parties or for achieving socially significant purposes, provided that the rights and freedoms of the subject of personal data are not violated.

7.6. Processing is carried out of personal data to which access by an unlimited number of persons is provided by the subject of personal data or at their request (hereinafter referred to as publicly available personal data).

7.7. Processing is carried out of personal data subject to publication or mandatory disclosure in accordance with federal law.

8. Procedure for Collection, Storage, Transfer and Other Types of Processing of Personal Data

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 in the field of personal data protection.

8.1. The Operator ensures the preservation of personal data and takes all possible measures excluding access to personal data by unauthorized persons.

8.2. Personal data of the User will never, under any circumstances, be transferred to third parties, except in cases related to the execution of current legislation or in case the subject of personal data has given consent to the Operator to transfer data to a third party for the execution of obligations under a civil law contract.

8.3. In case of detection of inaccuracies in personal data, the User may update them independently by sending the Operator a notification to the Operator's email address info@paxmercatus.com with the mark "Updating of personal data".

8.4. The period of 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 the contract or current legislation.

The User may at any time withdraw their consent to the processing of personal data by sending the Operator a notification via email to the Operator's email address info@paxmercatus.com with the mark "Withdrawal of consent to the processing of personal data".

8.5. All information that is collected by third-party services, including payment systems, communication means and other service providers, is stored and processed by the specified persons (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data and/or with the specified documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this paragraph.

8.6. Prohibitions established by the subject of personal data on transfer (except for providing access), as well as on processing or conditions of processing (except for obtaining access) of personal data permitted for distribution do not apply in cases of processing personal data in state, public and other public interests determined by the legislation of the Russian Federation.

8.7. The Operator ensures confidentiality of personal data when processing personal data.

8.8. The Operator carries out storage of personal data in a form that allows determining the subject of personal data no longer than required by the purposes of processing personal data, unless the storage period of personal data is established by federal law, contract, party to which, beneficiary or guarantor under which is the subject of personal data.

8.9. A condition for ceasing the processing of personal data may be the achievement of the purposes of processing personal data, expiration of the validity period of the subject of personal data's consent, withdrawal of consent by the subject of personal data or demand to cease processing of personal data, as well as detection of unlawful processing of personal data.

9. List of Actions Performed by the Operator with Received Personal Data

9.1. The Operator carries out collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion and destruction of personal data.

9.2. The Operator carries out automated processing of personal data with receiving and/or transmitting the received information via information and telecommunications networks or without such.

10. Cross-Border Transfer of Personal Data

10.1. The Operator before starting activities for cross-border transfer of personal data is obliged to notify the authorized body for the protection of rights of subjects of personal data of its intention to carry out cross-border transfer of personal data (such notification is sent separately from the notification of intention to process personal data).

10.2. The Operator before submitting the above notification is obliged to obtain from the authorities of the foreign state, foreign natural persons, foreign legal entities to whom cross-border transfer of personal data is planned, the corresponding information.

11. Confidentiality of Personal Data

The Operator and other persons who have gained access to personal data are obliged not to disclose to third parties and not to distribute personal data without consent of the subject of personal data, unless otherwise provided by federal law.

12. Final Provisions

12.1. The User may obtain any clarifications on questions of interest regarding the processing of their personal data by contacting the Operator via email info@paxmercatus.com.

12.2. This document will reflect any changes to the personal data processing policy of the Operator. The Policy is valid indefinitely until replaced by a new version.

12.3. The current version of the Policy is freely available on the Internet at http://paxmercatus.com.

---