Policy regarding the processing of personal data of clients of Metrika Nedvizhimost LLC

1. General provisions

1.1. The Personal Data Processing Policy (hereinafter referred to as the Policy) is aimed at protecting the rights and freedoms of individuals whose personal data is processed by Metrika Nedvizhimost LLC (hereinafter referred to as the Operator).

1.2. The Policy has been developed in accordance with the requirements of the Constitution of the Russian Federation, Federal Law dated 27.07.2006 No. 152-FZ "On Personal Data" (hereinafter — the Federal Law "On Personal Data").

1.3. The Policy contains information subject to disclosure in accordance with Part 1 of art. 14, Part 2 of art. 18.1 of the Federal Law "On Personal Data", and is a publicly available document.

2. Information about the operator

2.1. The Operator operates at the address: Tyumen region, Tyumen, Chelyuskintsev str., 10, office 508.

3. Information about the processing of personal data

3.1. The Operator processes personal data on a lawful and fair basis in order to fulfill the functions, powers and duties assigned by the legislation, exercise the rights and legitimate interests of the Operator, the Operator's employees and third parties.

3.2. The Operator receives personal data directly from the subjects of personal data. By submitting their personal data to Metrika Nedvizhimost LLC, the personal data subject confirms his consent to their processing in any way for the purposes, in the manner and to the extent established by the current legislation of the Russian Federation.

3.3. As part of the use of the Website, the personal data subject undertakes to provide only reliable Information and is responsible for the information provided by him/her. The operator does not verify the accuracy of the information provided by the personal data subject and assumes that the personal data subject provides reliable and sufficient information and controls its relevance. The personal data subject undertakes to update the Information in a timely manner by editing it on the Website. The Company has the right to request, and the personal data subject is obliged to provide, upon such request, documents and information necessary to identify the personal data subject as a party to the agreement and/or the party using the relevant Service, as well as documents confirming the accuracy of the Information provided and the legality of the use /offer of the Product and/or the connection of the personal data subject with the Product specified in the Advert.

3.4. The Operator processes personal data in automated and nonautomated ways, using computer technology and without using such means.

3.5. Personal data processing activities include collection, recording, systematization, accumulation, storage, clarification (updating, change), extraction, use, transfer (dissemination, provision, access), depersonalization, blocking, deletion and destruction.

4. Processing of personal data of Clients

4.1. The Operator processes the Clients' personal data within the legal relationship with the Operator regulated by Part two of the Civil Code of the Russian Federation dated January 26, 1996 No. 14-FZ (hereinafter referred to as the Clients).

4.2. The Operator processes the personal data of Clients in order to comply with the legislation of the Russian Federation, as well as in order to:

— inform about new services, special promotions and offers;

— execution of service contracts;

— conclusion and execution of the terms of the contract;

— settlements with service users;

— review the claims of service users.

4.3. In the process of using the Website's Services (interacting with other personal data subjects through the Website's interface, placing Adverts, browsing the Website's pages, etc.), the personal data subject independently and voluntarily decides to provide the Company with personal and other information about the personal data subject (surname, first name, patronymic, pseudonym of the personal data subject, email address, mobile phone number, as well as any other information provided by the personal data subject, including information contained in messages, sent to other personal data subjects through the feedback form in the Website interface, information about the actions of the personal data subject on the Website, etc.) for the purposes of executing the User Agreement. The Personal data subject hereby declares his consent to the automated, as well as without the use of automation means, processing of personal and other data of the personal data subject by the Company and its affiliates by performing the actions provided for in paragraph 3 of Article 3 of the Federal Law dated 27.07.2006 No. 152-FZ "On Personal Data" for processing by another Personal Data Subject and/or third parties acting on behalf of the Company, including for the purposes of: providing consulting support to Personal Data Subjects in connection with the use of the Website, checking Adverts for compliance with the User Agreement, delivering messages to other Personal Data Subjects, obtaining statistical and analytical data to improve the functioning of the Website and/or Services, expanding the range of Services provided, receiving information and/or advertising messages from the Company or third parties, preventing or suppressing illegal and/or unauthorized actions of personal data subjects or third parties, ensuring compliance with the requirements of the current legislation of the Russian Federation. The Company takes all necessary measures to protect the personal data of the Personal Data Subject from unauthorized access by third parties.

4.4. The Operator processes the Clients' personal data with their consent provided by the Clients and/or their legal representatives by performing implicative actions on this website, including, but not limited to, placing an order, registering in a personal account, subscribing to the newsletter, in accordance with this Policy.

4.5. The Operator processes the clients' personal data for no longer than the purposes of personal data processing require, unless otherwise provided by the requirements of the legislation of the Russian Federation.

4.6. The Operator processes the following personal data of Clients:

— Last name, first name, patronymic;

— Date of birth;

— Address;

— Contact phone number;

— Email address.

4.7. In order to fulfill the current Legislation, the Operator processes information of the following nature: One—time - necessary for the purpose of a single Client's request to the Operator, in order to receive feedback from employees of Metrika Nedvizhimost LLC;

5. Information on ensuring the security of personal data

5.1. The Operator appoints a person responsible for organizing the processing of personal data to fulfill the duties stipulated by the Federal Law "On Personal Data" and the regulatory legal acts adopted in accordance with it.

5.2. The Operator applies a set of legal, organizational and technical measures to ensure the security of personal data to ensure the confidentiality of personal data and their protection from unlawful actions:

— provides unlimited access to the Policy, a copy of which is available at the Operator's location, and can also be posted on the Operator's website.;

— in compliance with the Policy, approves and enacts the "Regulation on Personal Data Processing" document (hereinafter referred to as the Regulation) and other local acts;

— familiarizes employees with the provisions of the legislation on personal data, as well as with the Policy and the Regulation;

— provides access of employees to personal data processed in the Operator's information system, as well as their material carriers, only to perform employment duties;

— establishes rules for access to personal data processed in the Operator's information system, as well as ensures registration and accounting of all actions with them.;

— assesses the harm that may be caused to personal data subjects in case of violation of the Federal Law "On Personal Data";

— identifies threats to the security of personal data during their processing in the Operator's information system;

— applies organizational and technical measures and uses information protection tools necessary to achieve the established level of personal data security;

— detects the facts of unauthorized access to personal data and takes measures to respond, including restoring personal data that has been modified or destroyed as a result of unauthorized access to it;

— evaluates the effectiveness of measures taken to ensure the security of personal data prior to the commissioning of the Operator's information system;

— performs internal control of compliance of personal data processing with the Federal Law "On Personal Data", regulatory legal acts adopted in accordance with it, requirements for personal data protection, Policies, Regulations and other local acts, including control over measures taken to ensure the security of personal data and their level of security during processing in the Operator's information system.

5.3. By posting Adverts on the Website, the Personal Data Subject specifies the Information specified in the Advert as publicly available and understands that the posted information is publicly available on the Website, that is, it is available for review to any Website visitor (to an unlimited number of people) in all countries of the world where it is possible to use the Internet and access the Website, accordingly The personal data subject understands and assumes all risks associated with such information posting, including, but not limited to: the risk of an email address being included in spam mailing lists, the risk of an email address being passed on to various types of scammers, the risk of a phone number being passed on to SMS spammers and/or SMS scammers, and other risks arising from such information posting.

5.4. The Company does not pre-verify any type of Information posted and/or disseminated by the Personal Data Subject through the Website. The Company has the right, at its discretion, to refuse to post and/or disseminate any Information to the Personal Data Subject or to delete any Information posted by the Personal Data Subject on the Website, and the Personal Data Subject understands and agrees that he/she must independently assess all risks associated with the posting and dissemination of any Information, including the assessment of reliability, completeness, or usefulness of this.

6. Rights of personal data subjects

6.1. The personal data subject has the right to:

— to receive personal data related to this subject and information related to their processing;

— to clarify, block or destroy his/her personal data if they are incomplete, outdated, inaccurate, illegally obtained or are not necessary for the stated purpose of processing;

— to revoke his/her consent to the processing of personal data;

— to protect his/her rights and legitimate interests, including indemnification and compensation for moral damage in court;

— to appeal the actions or omissions of the Operator to the authorized body for protection the rights of personal data subjects or in court;

— to receive information regarding the processing of his/her personal data, including information containing:

1) confirmation of the fact of personal data processing by the operator;

2) legal grounds and purposes of personal data processing;

3) the purposes and methods of personal data processing used by the operator;

4) the name and location of the operator, information about persons (with the exception of the operator's employees) who have access to personal data or to whom personal data may be disclosed on the basis of an agreement with the operator or on the basis of a federal law;

5) the personal data being processed, related to the relevant personal data subject, and the source of its receipt, unless another procedure for submitting such data is provided by the federal law;

6) terms of processing personal data, including the terms of their storage;

7) the procedure for the exercise by a personal data subject of the rights provided by this Federal Law;

8) information about the completed or proposed cross-border data transfer;

9) the name or surname, first name, patronymic and address of the person who processes personal data on behalf of the operator, if the processing has been or will be entrusted to such a person;

10) other information provided by this Federal Law or other federal laws.

6.2. In order to exercise their rights and legitimate interests, personal data subjects have the right to contact the Operator or send a request in person or with the help of a representative. The request must contain the information specified in Part 3 of Article 14 of the Federal Law "On Personal Data".

6.3. The Client may revoke his/her consent to the processing of personal data in accordance with Article 9 of Federal Law dated 27.07.2006 No. 152-FZ "On Personal Data" by sending a corresponding written application to the postal address of the Operator specified in this Policy.