Personal Data Processing Policy

1. General provisions

This Personal Data Processing Policy (the “Policy”) is developed in accordance with Federal Law No. 152-FZ of 27 July 2006 “On Personal Data” and defines the procedure for processing personal data and the measures taken to ensure its security.

Personal data operator: STROYINTEGRATSIYA JSC, OGRN 1257700138299, INN 9731148947, address: 35/3 Partizanskaya St., Kuntsevo District, Moscow, 121351, Russia (the “Operator”).

The Policy applies to all information the Operator may obtain about visitors to the aigir.group website (the “Site”). By using the Site and submitting data through its forms, the visitor confirms agreement with this Policy.

For any questions regarding the processing of personal data, you may contact the Operator at privacy@aigir.group.

2. Key terms

• Personal data — any information relating to a directly or indirectly identified or identifiable natural person (the data subject).
• Processing of personal data — any action with personal data: collection, recording, systematization, accumulation, storage, amendment, use, transfer, anonymization, blocking, deletion, destruction.
• Data subject — the natural person to whom the personal data relates.
• Anonymization — actions that make it impossible, without additional information, to attribute personal data to a specific data subject.

3. Categories of subjects and data processed

The Operator processes personal data of the following categories of subjects: Site visitors; persons who submitted a request for a product demo or beta-testing sign-up; persons who contacted the Operator in any other way.

Personal data provided through the Site forms:

• last name, first name, middle name;
• position and company name;
• email address;
• contact phone number.

4. Technical data

When visiting the Site, technical data is processed automatically: IP address, browser and device information, cookies, and data about actions on the Site. This data is used to operate the Site and analyze its traffic (see the “Cookies” section).

5. Purposes of processing

• processing demo and beta-testing requests and contacting the applicant;
• informing about the Operator’s product, services and events (subject to consent);
• improving the quality of the Site and analyzing its use;
• complying with the requirements of the legislation of the Russian Federation.

6. Legal grounds for processing

• consent of the data subject to processing (Article 6(1)(1) of 152-FZ);
• conclusion and performance of a contract to which the data subject is a party;
• exercise of the Operator’s rights and legitimate interests that do not violate the subject’s rights;
• the Constitution of the Russian Federation, the Civil Code of the Russian Federation, 152-FZ and other regulatory legal acts.

7. Procedure and conditions of processing

Personal data is processed on a lawful and fair basis, with and without the use of automation tools.

In accordance with Article 18(5) of 152-FZ, the personal data of Russian citizens is processed using databases located in the territory of the Russian Federation.

The Operator does not disclose or transfer personal data to third parties, except in cases provided for by law or with the subject’s consent. To achieve the purposes of processing, the Operator may engage, under a contract, persons that process data on its behalf (hosting providers located in Russia, a customer relationship management system), in compliance with the confidentiality and security requirements of 152-FZ.

8. Retention and destruction

Personal data is stored no longer than required by the purposes of processing, unless another period is established by law or contract.

Once the purposes of processing are achieved, or upon withdrawal of consent by the subject, personal data is subject to destruction or anonymization within the time limits established by 152-FZ, unless otherwise provided by law.

9. Cookies and web analytics

The Site uses cookies and similar technologies to operate the Site, remember settings (such as interface language and theme), and analyze traffic.

For traffic analysis, the Site uses Yandex.Metrica, a web analytics service provided by Yandex LLC (16 Lva Tolstogo St., Moscow, 119021, Russia). Using cookies, the service collects anonymized data about visits: IP address, browser and device information, referral source, pages viewed, and actions on the Site. This data is transmitted to Yandex LLC and processed under the terms of that service.

The Site has the Session Replay (Webvisor) technology enabled: it anonymously records visitor actions on pages (cursor movements, clicks, scrolling) to assess interface usability. Content entered into form fields is not recorded.

You can opt out of data collection by Yandex.Metrica using the official opt-out tool (yandex.com/support/metrica/general/opt-out.html) or by disabling cookies in your browser settings. This may limit access to certain Site features.

10. Rights of the data subject

In accordance with Article 14 of 152-FZ, the data subject has the right to:

• obtain information regarding the processing of their personal data;
• request the amendment, blocking or destruction of personal data if it is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing;
• withdraw consent to the processing of personal data;
• appeal the Operator’s actions or omissions to Roskomnadzor or in court.

11. Exercising subject rights

To exercise your rights, including withdrawal of consent, send a request to privacy@aigir.group or to the Operator’s registered address. The Operator reviews the request and provides a response within the time limits established by 152-FZ.

12. Security measures

The Operator takes the necessary legal, organizational and technical measures to protect personal data against unlawful or accidental access, destruction, alteration, blocking, copying, provision and distribution, in accordance with Articles 18.1 and 19 of 152-FZ. See the “Security” section for details.

13. Cross-border transfer

The Operator does not carry out cross-border transfer of personal data. Should such a transfer become necessary, it will be carried out subject to compliance with the requirements of 152-FZ, including prior notification of Roskomnadzor.

14. Final provisions

The Operator may amend this Policy. The current version is always available on the Site. The supervisory authority for the protection of data subjects’ rights is the Federal Service for Supervision of Communications, Information Technology and Mass Media (Roskomnadzor).