Novosibirsk                                                                      February 22, 2023

Policy on Personal Data Processing

1. General Provisions

This Personal Data Processing Policy has been prepared in accordance with the requirements of Federal Law No. 152-FZ dated July 27, 2006, "On Personal Data" (the "Personal Data Law"), and defines the procedure for processing personal data and the measures taken by LLC Trading Company "LIKOLOR" (the "Operator") to ensure the security of personal data.

1.1. The Operator considers compliance with human and civil rights and freedoms in the processing of personal data, including protection of the right to privacy and personal and family confidentiality, to be its most important objective and a prerequisite for conducting its business activities.

1.2. This Policy of the Operator regarding personal data processing (the "Policy") applies to all information that the Operator may obtain about visitors to the website http://taiga.likolor.ru/.

2. Basic Terms Used in the Policy

2.1. Automated processing of personal data means the processing of personal data using computer technology.

2.2. Blocking of personal data means temporary suspension of the processing of personal data (except where processing is necessary to clarify personal data).

2.3. Website means a set of graphic and informational materials, as well as software and databases, ensuring their availability on the internet at the network address http://taiga.likolor.ru/.

2.4. Personal data information system means a set of personal data contained in databases and the information technologies and technical means ensuring their processing.

2.5. Depersonalization of personal data means actions as a result of which it becomes impossible, without the use of additional information, to determine whether personal data belong to a specific User or another personal data subject.

2.6. Processing of personal data means any action (operation) or set of actions (operations) performed with or without the use of automation tools on personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (dissemination, provision, access), depersonalization, blocking, deletion, and destruction of personal data.

2.7. Operator means a state authority, municipal authority, legal entity, or individual that 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 subject to processing, and the actions (operations) performed with personal data.

2.8. Personal data means any information relating directly or indirectly to an identified or identifiable User of the website http://taiga.likolor.ru/.

2.9. Personal data permitted by the personal data subject for dissemination means personal data to which an unlimited number of persons are granted access by the personal data subject by providing consent to the processing of personal data permitted for dissemination in the manner prescribed by the Personal Data Law (hereinafter referred to as personal data permitted for dissemination).

2.10. User means any visitor to the website http://taiga.likolor.ru/.

2.11. Provision of personal data means actions aimed at disclosing personal data to a specific person or a specific group of persons.

2.12. Dissemination of personal data means any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or at familiarizing an unlimited number of persons with personal data, including publication in mass media, placement in information and telecommunications networks, or granting access to personal data by any other means.

2.13. Cross-border transfer of personal data means the transfer of personal data to the territory of a foreign state, to a foreign state authority, foreign individual, or foreign legal entity.

2.14. Destruction of personal data means any actions resulting in the irreversible destruction of personal data with no possibility of further restoration of the content of personal data in a personal data information system and/or destruction of physical media containing personal data.

3. Basic Rights and Obligations of the Operator

3.1. The Operator has the right to:

— receive from the personal data subject accurate information and/or documents containing personal data;

— where the personal data subject withdraws consent to the processing of personal data, and also submits a request to cease the processing of personal data, continue processing personal data without the subject's consent if there are grounds specified in the Personal Data Law;

— independently determine the composition and list of measures necessary and sufficient to ensure fulfillment of the obligations prescribed by the Personal Data Law and the regulatory legal acts adopted pursuant thereto, unless otherwise provided by the Personal Data Law or other federal laws.

3.2. The Operator is obliged to:

— provide the personal data subject, upon request, with information relating to the processing of his or her personal data;

— organize the processing of personal data in the manner established by the current legislation of the Russian Federation;

— respond to appeals and requests of personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;

— provide the authorized body for the protection of the rights of personal data subjects, upon its request, with the necessary information within 10 days from the date of receipt of such request;

— publish or otherwise ensure unrestricted access to this Policy regarding the processing of personal data;

— adopt legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, alteration, blocking, copying, provision, dissemination, as well as from other unlawful actions involving personal data;

— cease the transfer (dissemination, provision, access) of personal data, cease processing, and destroy personal data in the manner and in the cases provided for by the Personal Data Law;

— perform other obligations provided for by the Personal Data Law.

4. Basic Rights and Obligations of Personal Data Subjects

4.1. Personal data subjects have the right to:

— receive information concerning the processing of their personal data, except in cases provided for by federal laws. The information shall be provided to the personal data subject by the Operator in an accessible form and must not include personal data relating to other personal data subjects, except where there are lawful grounds for disclosure of such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;

— require the operator to clarify, block, or destroy their personal data if such personal data are incomplete, outdated, inaccurate, unlawfully obtained, or are not necessary for the stated purpose of processing, as well as take measures provided by law to protect their rights;

— require prior consent as a condition for the processing of personal data for the purpose of promoting goods, works, and services on the market;

— withdraw consent to the processing of personal data and submit a request to cease the processing of personal data;

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

— exercise other rights provided for by the legislation of the Russian Federation.

4.2. Personal data subjects are obliged to:

— provide the Operator with accurate data about themselves;

— notify the Operator of any clarification (update or change) of their personal data.

4.3. Persons who have provided the Operator with inaccurate information about themselves, or information about another personal data subject without the latter's consent, shall bear liability in accordance with the legislation of the Russian Federation.

5. Principles of Personal Data Processing

5.1. Personal data shall be processed on a lawful and fair basis.

5.2. Personal data processing shall be limited to achieving specific, predetermined, and lawful purposes. Processing of personal data incompatible with the purposes of collecting personal data is not allowed.

5.3. The merging of databases containing personal data processed for purposes incompatible with one another is not allowed.

5.4. Only personal data meeting the purposes of their processing shall be subject to processing.

5.5. The content and volume of processed personal data shall correspond to the declared purposes of processing. Excessive personal data in relation to the declared purposes of processing is not allowed.

5.6. When processing personal data, the accuracy, sufficiency, and, where necessary, relevance of personal data in relation to the purposes of processing shall be ensured. The Operator shall take necessary measures and/or ensure that such measures are taken to delete or clarify incomplete or inaccurate data.

5.7. Personal data shall be stored in a form allowing identification of the personal data subject no longer than required by the purposes of processing, unless the storage period is established by federal law or by a contract to which the personal data subject is a party, beneficiary, or guarantor. Processed personal data shall be destroyed or depersonalized upon achievement of the purposes of processing or if the need to achieve such purposes is lost, unless otherwise provided by federal law.

6. Purposes of Personal Data Processing

7. Conditions for Personal Data Processing

7.1. Personal data shall be processed with the consent of the personal data subject to the processing of his or her personal data.

7.2. Processing of personal data is necessary to achieve purposes provided for by an international treaty of the Russian Federation or by law, to perform functions, powers, and duties imposed on the operator by the legislation of the Russian Federation.

7.3. Processing of personal data is necessary for the administration of justice, execution of a court act, or an act of another body or official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.

7.4. Processing of personal data is necessary for the performance of a contract to which the personal data subject is a party, beneficiary, or guarantor, as well as for entering into a contract at the initiative of the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor.

7.5. Processing of personal data is necessary for the exercise of the rights and legitimate interests of the operator or third parties, or for achieving socially significant objectives, provided that this does not violate the rights and freedoms of the personal data subject.

7.6. Personal data are processed where access to such data is granted by the personal data subject to an unlimited number of persons or at the subject's request (hereinafter referred to as publicly available personal data).

7.7. Personal data subject to publication or mandatory disclosure in accordance with federal law are processed.

8. Procedure for Collection, Storage, Transfer, and Other Types of Personal Data Processing

The security of personal data processed by the Operator is ensured through the implementation of legal, organizational, and technical measures necessary to fully comply with the requirements of current legislation in the field of personal data protection.

8.1. The Operator ensures the safety of personal data and takes all possible measures to exclude access to personal data by unauthorized persons.

8.2. The User's personal data shall never, under any circumstances, be transferred to third parties, except in cases related to compliance with applicable law or where the personal data subject has given consent to the Operator to transfer data to a third party for the performance of obligations under a civil law contract.

8.3. If inaccuracies in personal data are identified, the User may update them independently by sending a notice to the Operator at the Operator's email address sales@likolorpro.ru marked "Personal Data Update".

8.4. The period for processing personal data is determined by achievement of the purposes for which the personal data were collected, unless another period is provided for by the contract or applicable law.

The User may withdraw consent to the processing of personal data at any time by sending a notice to the Operator by email to the Operator's email address sales@likolorpro.ru marked "Withdrawal of Consent to Personal Data Processing".

8.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by such persons (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject shall independently review those documents. The Operator is not liable for the actions of third parties, including the service providers specified in this clause.

8.6. Restrictions established by the personal data subject on transfer (except granting access), as well as on processing or conditions of processing (except obtaining access) of personal data permitted for dissemination, shall not apply in cases of processing of personal data in state, public, and other public interests determined by the legislation of the Russian Federation.

8.7. The Operator ensures the confidentiality of personal data when processing personal data.

8.8. The Operator stores personal data in a form allowing identification of the personal data subject no longer than required by the purposes of processing, unless the storage period is established by federal law or by a contract to which the personal data subject is a party, beneficiary, or guarantor.

8.9. Grounds for termination of personal data processing may include achievement of the purposes of processing, expiration of the subject's consent, withdrawal of consent by the personal data subject or a request to cease processing, as well as the discovery of unlawful processing of personal data.

9. List of Actions Performed by the Operator with Received Personal Data

9.1. The Operator performs collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (dissemination, provision, access), depersonalization, blocking, deletion, and destruction of personal data.

9.2. The Operator carries out automated processing of personal data with receipt and/or transfer of the information obtained via information and telecommunications networks or without such transfer.

10. Cross-Border Transfer of Personal Data

10.1. Before commencing activities involving the cross-border transfer of personal data, the Operator is obliged to notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out such cross-border transfer (such notification shall be sent separately from the notification of intent to process personal data).

10.2. Before submitting the above notification, the Operator is obliged to obtain the relevant information from foreign state authorities, foreign individuals, and foreign legal entities to whom the cross-border transfer of personal data is planned.

11. Confidentiality of Personal Data

The Operator and other persons who have gained access to personal data are obliged not to disclose or disseminate personal data to third parties without the consent of the personal data subject, unless otherwise provided by federal law.

12. Final Provisions

12.1. The User may obtain any clarifications on issues of interest concerning the processing of his or her personal data by contacting the Operator via email at sales@likolorpro.ru.

12.2. Any changes to the Operator's personal data processing policy shall be reflected in this document. The Policy remains in force indefinitely until replaced by a new version.

12.3. The current version of the Policy is publicly available on the internet at http://taiga.likolor.ru/.