Consent to Personal Data Processing and Rules for Application of Recommendation Technologies

PERSONAL DATA PROCESSING POLICY

LLC TK "Strojrem"

INN 5257199108 OGRN 1205200037646

Last Updated: October 22, 2025

1. GENERAL PROVISIONS

1.1. This Personal Data Processing Policy (hereinafter – "Policy") has been developed in compliance with the requirements of paragraph 2 of part 1 of Article 18.1 of the Federal Law of July 27, 2006 No. 152-FZ "On Personal Data" (hereinafter – "Personal Data Law") to ensure the protection of human and citizen rights and freedoms in the processing of their personal data, including protection of rights to privacy, personal and family secrets.

1.2. This Policy applies to the following categories of personal data subjects whose information is processed by the Operator: employees; counterparties; clients; website visitors.

1.3. Key concepts used in the Policy:

1.4. Principal rights and obligations of the Operator.

1.4.1. The Operator has the right to:

1.4.2. The Operator is obliged to:

1.5. Principal rights of Personal Data Subjects.

A personal data subject has the right to:

1.6. Monitoring compliance with the requirements of this Policy is carried out by an authorized person responsible for organizing personal data processing at the Operator.

1.7. Liability for violation of the requirements of the legislation of the Russian Federation and local acts of the Operator in the field of personal data processing and protection is determined in accordance with the legislation of the Russian Federation.

2. PRINCIPLES OF PERSONAL DATA PROCESSING

2.1. Personal data processing is carried out by the Operator in accordance with the requirements of the legislation of the Russian Federation and on the basis of the following principles:

3. LEGAL GROUNDS FOR PERSONAL DATA PROCESSING

3.1. The legal basis for personal data processing is a set of regulatory legal acts including:

3.2. The legal basis for personal data processing also includes contracts concluded with the Personal Data Subject and consent of the Personal Data Subject to personal data processing.

4. SCOPE, CATEGORIES AND CONDITIONS OF PROCESSED PERSONAL DATA

Personal data is processed by the Operator for the purposes of:

Categories of personal data subjects:

4.1. Processing of employee personal data

General personal data: surname, name, patronymic; residential address; education; profession; passport details; contact telephone number; income; position; INN; SNILS; marital status.

Special categories: health information; national origin.

Biometric personal data: facial image data.

Processing and storage periods: during the validity of the employment contract and 5 years after its termination.

4.2. Processing of personal data of counterparties and clients

Personal data processed: surname, name, patronymic; residential address; passport details; contact telephone number; email address; gender.

Processing and storage periods: during the validity of the contract and 5 years after its termination.

4.3. Processing of personal data of Website visitors

Personal data processed: surname, name, patronymic; contact telephone number; email address; information collected through metric programs.

5. PROCEDURE FOR PROCESSING PERSONAL DATA USING COOKIE FILES

Cookie files transmitted to the technical devices of the Personal Data Subject may be used to provide personalized services, analyze website traffic, and collect statistical information.

The user may manage the receipt of cookie files by configuring the browser accordingly.

6. ENSURING SECURITY OF PERSONAL DATA

The Operator takes necessary legal, organizational and technical measures to protect personal data from unlawful or accidental access to it, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other unlawful actions in relation to personal data.

7. TRANSBORDER TRANSMISSION OF PERSONAL DATA

The Operator does not carry out transborder transmission of personal data without the consent of the personal data subject.

With the consent of visitors, the Operator may transmit their personal data to LLC "Yandex" (INN 7736207543) when using the software tool "Yandex.Metric".

8. CONCLUDING PROVISIONS

8.1. This Policy is an internal document of the Operator, is publicly available and shall be posted on the Operator's official website.

8.2. This Policy may be amended or supplemented by the Operator unilaterally without special notification of Personal Data Subjects.

8.3. The current version of the Policy is posted on the page at: https://stroyrem-nn.ru/privacy-policy-en.html

8.4. Contact Information:

LLC TK "Strojrem"

INN 5257199108

OGRN 1205200037646

Mailing address: 603022, Nizhny Novgorod, Gagarin Ave. 23A office 2

Tel/fax: 465-51-36

Email: stroyrem.nn@list.ru