Privacy Policy1. General ProvisionsThis Personal Data Processing Policy is drafted in accordance with the requirements of Federal Law No. 152-FZ of July 27, 2006, "On Personal Data" (hereinafter referred to as the "Personal Data Law") and defines the procedure for processing personal data and the measures implemented by Leshok Yury Nikolaevich (hereinafter referred to as the "Data Controller") to ensure the security of personal data.1.1. The Data Controller's highest priority and a fundamental condition for conducting its activities is the observance of human and civil rights and freedoms when processing their personal data, including the protection of privacy rights, and personal and family confidentiality.1.2. This Policy of the Data Controller regarding the processing of personal data (hereinafter referred to as the "Policy") applies to all information that the Data Controller may obtain about visitors to the website https://exodus-go.ru/.2. Key Terms Used in the Policy2.1. Automated Processing of Personal Data — processing of personal data using computer technology.2.2. Blocking of Personal Data — temporary cessation of personal data processing (except in cases where processing is necessary to clarify personal data).2.3. Website — an aggregate of graphical and informational materials, as well as computer programs and databases that make them available on the internet at the network address https://exodus-go.ru/.2.4. Personal Data Information System — an aggregate of personal data contained in databases and the information technologies and technical means that enable their processing.2.5. Depersonalization of Personal Data — actions that make it impossible to determine, without the use of additional information, which specific User or other data subject the personal data belongs to.2.6. Processing of Personal Data — any action (operation) or set of actions (operations) performed with personal data, with or without the use of automation tools, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.2.7. Data Controller — a state body, municipal body, legal entity, or individual who independently or jointly with others organizes and/or carries out the processing of personal data, and also determines the purposes of processing personal data, the composition of personal data to be processed, and the 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 https://exodus-go.ru/.2.9. Personal Data Authorized by the Data Subject for Dissemination — personal data to which access by an unlimited number of persons has been granted by the data subject by consenting to the processing of personal data permitted by the data subject for dissemination in the manner prescribed by the Personal Data Law (hereinafter referred to as "Data for Dissemination").2.10. User — any visitor to the website https://exodus-go.ru/.2.11. Provision of Personal Data — actions aimed at disclosing personal data to a specific person or a specific group of persons.2.12. Dissemination of Personal Data — any actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or at making personal data available to an unlimited group of persons, including publication of personal data in the media, posting on information and telecommunication networks, or providing access to personal data in any other way.2.13. Cross-Border Transfer of Personal Data — the transfer of personal data to the territory of a foreign state to an authority of a foreign state, a foreign individual, or a foreign legal entity.2.14. Destruction of Personal Data — any actions resulting in the irreversible destruction of personal data with no possibility of further restoration of the content of the personal data in the personal data information system and/or the destruction of the physical media containing the personal data.3. Key Rights and Obligations of the Data Controller3.1. The Data Controller has the right to:— Receive reliable information and/or documents containing personal data from the data subject;— Continue processing personal data without the consent of the data subject if there are grounds specified in the Personal Data Law, in case the data subject withdraws consent to the processing of personal data or submits a request to cease processing personal data;— Independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations stipulated by the Personal Data Law and related regulatory legal acts, unless otherwise provided by the Personal Data Law or other federal laws.3.2. The Data Controller is obligated to:— Provide the data subject, upon request, with information concerning the processing of their personal data;— Organize the processing of personal data in accordance with the procedure established by current Russian legislation;— Respond to inquiries and requests from data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;— Provide the authorized body for the protection of data subjects' rights with the necessary information within 10 days from the date of receiving such a request;— Publish or otherwise ensure unrestricted access to this Policy regarding the processing of personal data;— Implement legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision, dissemination, as well as from other unlawful actions regarding personal data;— Cease the transfer (distribution, provision, access) of personal data, cease processing, and destroy personal data in the manner and cases provided for by the Personal Data Law;— Fulfill other obligations stipulated by the Personal Data Law.4. Key Rights and Obligations of Data Subjects4.1. Data Subjects 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 data subject by the Data Controller in an accessible form and must not contain personal data relating to other data subjects, except in cases where there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;— Demand that the Data Controller clarify, block, or destroy their personal data if the data is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, and take legal measures to protect their rights;— Impose a 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 submit a demand to cease processing personal data;— Lodge a complaint with the authorized body for the protection of data subjects' rights or in a court of law regarding unlawful actions or inaction of the Data Controller in processing their personal data;— Exercise other rights provided for by Russian legislation.4.2. Data Subjects are obligated to:— Provide the Data Controller with accurate information about themselves;— Inform the Data Controller of any updates or changes to their personal data.4.3. Persons who have provided the Data Controller with inaccurate information about themselves, or information about another data subject without the latter's consent, shall bear responsibility in accordance with Russian legislation.5. Principles of Personal Data Processing5.1. The processing of personal data is carried out on a lawful and fair basis.5.2. The processing of personal data is limited to achieving specific, predetermined, and lawful purposes. Processing of personal data incompatible with the purposes of collection is not permitted.5.3. Merging databases containing personal data processed for incompatible purposes is not permitted.5.4. Only personal data that meets the purposes of their processing is subject to processing.5.5. The content and volume of processed personal data correspond to the stated purposes of processing. Redundancy of processed personal data in relation to the stated purposes is not permitted.5.6. When processing personal data, accuracy, sufficiency, and, where necessary, relevance in relation to the purposes of processing are ensured. The Data Controller takes necessary measures and/or ensures their implementation to delete or clarify incomplete or inaccurate data.5.7. Storage of personal data is carried out in a form that allows identification of the data subject for no longer than required by the purposes of processing, unless the storage period is established by federal law, an agreement to which the data subject is a party, beneficiary, or guarantor. Processed personal data is destroyed or depersonalized upon achieving the processing purposes or when the need to achieve them is lost, unless otherwise provided by federal law.6. Conditions for Processing Personal Data6.1. Processing of personal data is carried out with the consent of the data subject to the processing of their personal data.6.2. Processing of personal data is necessary to achieve the objectives stipulated by an international treaty of the Russian Federation or law, for the performance of functions, powers, and duties imposed on the Data Controller by Russian legislation.6.3. Processing of personal data is necessary for the administration of justice, execution of a judicial act, act of another body, or official subject to execution in accordance with Russian legislation on enforcement proceedings.6.4. Processing of personal data is necessary for the performance of an agreement to which the data subject is a party, beneficiary, or guarantor, as well as for concluding an agreement on the initiative of the data subject or an agreement under which the data subject will be a beneficiary or guarantor.6.5. Processing of personal data is necessary for the exercise of the rights and legitimate interests of the Data Controller or third parties, or for achieving socially significant objectives, provided that this does not violate the rights and freedoms of the data subject.6.6. Processing is carried out of personal data to which access has been granted by the data subject or at their request to an unlimited number of persons (hereinafter referred to as "publicly available personal data").6.7. Processing is carried out of personal data subject to publication or mandatory disclosure in accordance with federal law.7. Procedure for Collection, Storage, Transfer, and Other Types of Personal Data ProcessingThe security of personal data processed by the Data Controller is ensured by implementing legal, organizational, and technical measures necessary to fully comply with the requirements of current legislation in the field of personal data protection.7.1. The Data Controller ensures the security of personal data and takes all possible measures to prevent unauthorized access to personal data.7.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to the execution of current legislation or when the data subject has consented to the Data Controller transferring the data to a third party to fulfill obligations under a civil contract.7.3. In case inaccuracies in personal data are identified, the User can update them independently by sending a notification to the Data Controller's email address go@exodus.ru with the subject line "Update of Personal Data."7.4. The period for processing personal data is determined by the achievement of the purposes for which the personal data were collected, unless a different period is stipulated by contract or current legislation.The User may at any time withdraw their consent to the processing of personal data by sending a notification to the Data Controller via email to go@exodus.ru with the subject line "Withdrawal of Consent to Personal Data Processing."7.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by these parties (Data Controllers) in accordance with their User Agreement and Privacy Policy. The Data Subject is obliged to familiarize themselves with the aforementioned documents. The Data Controller is not responsible for the actions of third parties, including the service providers mentioned in this clause.7.6. Prohibitions established by the data subject on the transfer (except for providing access) and on the processing or conditions of processing (except for obtaining access) of Data for Dissemination do not apply in cases of processing personal data in state, public, and other public interests as defined by Russian legislation.7.7. The Data Controller ensures the confidentiality of personal data during their processing.7.8. The Data Controller stores personal data in a form that allows identification of the data subject for no longer than required by the purposes of processing, unless the storage period is established by federal law, an agreement to which the data subject is a party, beneficiary, or guarantor.7.9. Conditions for ceasing the processing of personal data may include achievement of the processing purposes, expiration of the data subject's consent period, withdrawal of consent by the data subject, a demand to cease processing personal data, or the identification of unlawful processing of personal data.8. List of Actions Performed by the Data Controller with the Received Personal Data8.1. The Data Controller performs collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.8.2. The Data Controller performs automated/manual processing of personal data with the receipt and/or transmission of the received information via information and telecommunication networks or without it.9. Cross-Border Transfer of Personal Data9.1. Before commencing activities related to the cross-border transfer of personal data, the Data Controller is obligated to notify the authorized body for the protection of data subjects' rights of its intention to carry out such transfer (this notification is sent separately from the notification of intention to process personal data).9.2. Before submitting the aforementioned notification, the Data Controller is obligated to obtain relevant information from the foreign state authorities, foreign individuals, and foreign legal entities to whom the cross-border transfer of personal data is planned.10. Confidentiality of Personal DataThe Data Controller and other persons who have gained access to personal data are obligated not to disclose them to third parties and not to disseminate personal data without the consent of the data subject, unless otherwise provided by federal law.11. Final Provisions11.1. The User can obtain any clarifications on questions regarding the processing of their personal data by contacting the Data Controller via email at go@exodus.ru.11.2. This document will reflect any changes to the Data Controller's personal data processing policy. The Policy remains in effect indefinitely until replaced by a new version.11.3. The current version of the Policy is freely available on the Internet at https://exodus-go.ru/en/privacy/. 