Personal Data Processing Policy

I. GENERAL PROVISIONS

1.1. Personal data operator: NordProm Limited Liability Company (NordProm LLC), OGRN 1217800052271, INN 7802892164, KPP 201401001, legal address: 364024, Chechen Republic, Grozny urban district, Grozny,
Akhmatovsky district, st. N.A. Nazarbayeva, 92, office 204 (hereinafter referred to as the Operator).

1.2. This Personal Data Processing Policy (hereinafter referred to as the Policy) has been developed in accordance with Federal Law No. 152-FZ of July 27, 2006, “On Personal Data”
(hereinafter referred to as the Law on Personal Data), Federal Law of March 13, 2006 No. 38-FZ
"On Advertising", as well as other regulatory legal acts of the Russian Federation in the field of protecting the rights of personal data subjects and advertising, and determines the procedure for processing personal data, measures to ensure their security, as well as the rights and obligations of the Operator and personal data subjects.
Concepts contained in Art. 3 The terms “Law on personal data” are used in this Policy with the same meaning.

1.3. This Policy applies to all actions of the Operator related to
with the processing of personal data received:
1.4. In compliance with the requirements of Part 2 of Article 18.1 of the Law on Personal Data, the current version of the Policy is freely available on the Internet information and telecommunications network on the Operator’s Website at: https://prosafe.pro/policyChanges are published at the same address. Users are advised to review the current version of the Policy each time they visit the website or provide personal data.

1.5. This Policy applies only to the Website. The Operator does not control and is not responsible for third-party websites that the User may access via links available on the Website.

II. PURPOSES OF PERSONAL DATA PROCESSING AND CATEGORIES OF PROCESSED DATA

2.1. The operator processes personal data exclusively for the following purposes,
in compliance with the principle of minimization (only those data that are necessary to achieve each specific purpose are processed).

2.1.1. Purpose: providing a response to an inquiry (consultation).
Processed data: name, telephone number, email address, region.
Storage period: 3 (three) calendar years from the date of last interaction
with the user (the last incoming/outgoing email regarding the request, the last call recorded in the CRM, or the date the request was closed).

2.1.2. Purpose: sending informational and advertising materials by e-mail with separate consent of the personal data subject.
Processed data: name and email address.
Storage period: until the moment of withdrawal of consent or refusal to receive the newsletter, as well as
within the period necessary to take into account such refusal and resolve possible claims,
but not more than 3 (three) calendar years from the date of the last actual interaction
with a newsletter (for example, clicking on a link, opening an email, replying to an email).
Advertising materials are sent only with the prior consent of the personal data subject (Appendix 2). Each advertising email provides the opportunity to opt out
From receiving further mailings, including by clicking on the unsubscribe link or sending a notification to the Operator using the contact information specified in this Policy. Advertising materials are also sent in accordance with Article 18 of the Advertising Law.

2.1.3. Purpose: to ensure the functioning of the website, collect traffic statistics, and analyze user behavior.
Processed data: IP address, browser type and version, operating system, date
and access time, pages viewed, cookies, information transmitted by analytics counters.
Storage period: for cookies – no more than 1 (one) calendar year or until they are cleared by the user; for statistical data – no more than 2 (two) calendar years.

2.2. The Operator does not process special categories of personal data (race, nationality, political views, religious or philosophical beliefs, health status, intimate life) and biometric data (fingerprints, facial image
for identification) without separate written consent of the subject of personal data,
except in cases expressly provided for by the legislation of the Russian Federation.

2.3. Requesting excessive data from the user is prohibited. In particular, for the purposes of consultation or mailing, it is not permitted to request the Taxpayer Identification Number (TIN), tax registration certificate number, registered address of residence, or date of birth (if it is not related to
(with the execution of the contract). Such data may be requested only upon conclusion of the contract, if expressly provided for by its terms or by law.

2.4. If the personal data subject revokes consent, the processing of personal data will cease and the data will be destroyed within 30 days, unless there are other legal grounds for storing and processing them.

III. LEGAL BASIS FOR PERSONAL DATA PROCESSING

3.1. Processing is carried out on the following legal grounds: 

IV. CONDITIONS FOR OBTAINING CONSENT TO THE PROCESSING OF PERSONAL DATA

4.1. Consent to the processing of personal data is given by the user freely, of their own free will, and in their own interests. Consent must be specific, objective, and informed
and conscious.

4.2. Consent to the processing of personal data may be expressed by the personal data subject taking an active action that clearly indicates their expression of intent, including by checking a separate checkbox located directly next to the personal data collection form.

4.3. The text accompanying the checkbox must contain a link to this Policy
and consent to the processing of personal data, as well as an indication of the purpose of processing personal data, if required for a specific form.

4.4 Submitting a form without prior consent when such consent is required by law is not permitted.

4.5. Posting photographs of employees, clients, or other third parties on the website, as well as other actions related to the distribution of personal data (dissemination to an unlimited number of persons), requires a separate consent for distribution, either in writing or as a separate checkbox, clearly stating which data will be disclosed to an unlimited number of persons, for what purposes, for how long, and indicating the possible methods of its use. In such consent, the user also has the right to establish prohibitions on the transfer of data to third parties and/or on certain methods of distribution.

V. USE OF COOKIES, IP ADDRESSES, AND ANALYTICS SERVICES

5.1. When visiting the website, the Operator may automatically receive technical data, including the IP address, browser information, operating system, access date and time, pages viewed, as well as other technical data necessary to ensure the functionality of the website, analyze its traffic, and improve the quality of user service.

5.2. The site uses cookies - small text files stored
on the user's device. Cookies may be used to ensure the proper functioning of the website and its individual functions (technically necessary cookies); to remember user settings; and to collect anonymous traffic statistics (analytical cookies).

5.3. The Yandex.Metrica service (provider – Yandex LLC, Russian Federation) is used to collect and analyze website traffic statistics. All data is processed on servers located within the Russian Federation
in accordance with the privacy policy of the specified service and the legislation of the Russian Federation.

5.4. When visiting the site for the first time, the user is shown a notification
about the use of cookies and analytics services with the ability to:
5.5. The user can change cookie settings in the browser at any time, as well as limit or disable the use of analytical cookies, if this is supported by the website interface.

VI. CROSS-BORDER TRANSFER OF PERSONAL DATA

6.1. The operator does not carry out cross-border transfer of personal data (transfer to the territory of a foreign state to a foreign individual or legal entity, or to a government body of a foreign state).

6.2. The processing of personal data (including collection, recording, systematization, accumulation, storage, clarification, extraction) of citizens of the Russian Federation is carried out
using databases located on the territory of the Russian Federation,
except in cases expressly provided for by the legislation of the Russian Federation
and executed in accordance with it. Access to personal data from foreign countries is not provided.

6.3. The operator does not use foreign analytics services, cloud storage,
CRM systems or other data processing tools whose servers are located outside the Russian Federation, without complying with the requirements of the legislation of the Russian Federation
on the cross-border transfer of personal data.

6.4. In the event of a change to the specified procedure, the Operator undertakes to notify Roskomnadzor in advance in accordance with the established procedure, and, if necessary, to obtain separate consent from users for such transfer and make appropriate changes to this Policy.

VII. RIGHTS OF THE PERSONAL DATA SUBJECT (USER)

7.1. The User, whose personal data is processed by the Operator, has the right to:
7.2. Requests related to obtaining information about the processing of personal data, clarification of personal data, termination of processing, withdrawal of consent, as well as refusal to receive advertising materials, can be sent to the email address sale@prosafe.pro or in any other manner specified in this Policy.
For the purposes of identifying the applicant, the Operator has the right to request additional information to confirm that the request comes from the personal data subject
or his/her representative. The requirement to provide a copy of an identity document applies only if there are reasonable doubts regarding the applicant's identity
and taking into account the principle of minimizing personal data.

7.3. The Operator is obliged to consider such a request and provide a reasoned response within a reasonable time, but no later than 30 (thirty) calendar days from the date of receipt of the request, unless a shorter period is established by the legislation of the Russian Federation.

VIII. OPERATOR'S RESPONSIBILITIES

8.1. The operator is obliged to:

IX. PERSONAL DATA PROCESSING TIMES AND DESTRUCTION PROCEDURE

9.1. The terms for processing personal data are set out in Section 2 of this Policy for each purpose separately.

9.2. Upon expiration of the specified period, or upon withdrawal of consent, or upon achievement of the processing purpose (unless a specific period is specified), personal data shall be destroyed. Destruction shall be accomplished by permanently erasing the information
on tangible media (including electronic databases) with the preparation of a report
on destruction (the form of the act is in the Appendix).

9.3. If the user has withdrawn consent, but the Operator retains a legal basis for continuing processing, processing may be continued without the user’s consent,
but only to the extent and for the period required by the legislation of the Russian Federation.

X. MEASURES TO ENSURE THE SECURITY OF PERSONAL DATA

10.1. The operator implements the following set of security measures:
10.2. The Operator’s internal documents (list of measures, job descriptions, event logs, etc.) are kept by the responsible person and are provided to authorized government agencies upon their request in the established manner.

XI. PROCESSING OF PERSONAL DATA BY THIRD PARTIES

11.1. The operator has the right to involve third parties in the processing of personal data,
including persons providing hosting services, mailing lists, and technical support
and web analytics, subject to the conclusion of agreements with them that provide for the obligation to maintain confidentiality and ensure the security of personal data
and process them solely for the purpose of fulfilling the Operator’s instructions.

11.2. The list of third parties engaged by the Operator to process personal data may vary depending on the services used and is available to the personal data subject upon request.

11.3. Transfer of personal data to third parties without the Operator’s permission, as well as
for purposes inconsistent with the stated purposes of processing is prohibited, except in cases expressly provided for by the legislation of the Russian Federation.

XII. POSTING PHOTOS OF EMPLOYEES AND OTHER PERSONS

12.1. If photographs of the Operator's employees are publicly available on the website, separate consent from the relevant person has been obtained for the posting of such photographs
to the dissemination of his personal data. Copies of the consents are kept by the Operator.

12.2. Photographs of clients, partners or other persons who are not employees of the Operator are posted only with their separate informed consent
which specifies: the list of data to be posted, the period of posting, and the purposes of use
and the ability to revoke consent.

12.3. When revoking consent, the photograph must be deleted within 10 (ten) business days from the date of receipt of the relevant application.

XIII. Final Provisions

13.1. All amendments and additions to this Policy shall come into force from the moment of their publication on the website at: https://prosafe.pro/policy, unless otherwise provided by the new version of the Policy.

13.2. The Operator reserves the right to amend this Policy. The new version of the Policy takes effect from the moment it is posted on the website, unless otherwise provided in the new version. Users are advised to review the current version of the Policy when using the website and its services.

13.3. Questions related to the processing of personal data can be directed to:
13.4. This Policy shall come into force on 10.06.2026.
13.5. Consent to receive advertising materials
13.6. Consent to the processing of personal data


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