Personal Data Processing Policy

1. General Provisions

This Personal Data Processing Policy has been drawn up in accordance with the requirements of Federal Law No. 152-FZ "On Personal Data" of 27 July 2006 (hereinafter, the "Personal Data Law") and defines the procedure for processing personal data and the measures taken to ensure the security of personal data by FOX Architecture and Design Studio LLC (hereinafter, the "Operator").
1.1. The Operator regards the observance of human and civil rights and freedoms in the processing of personal data — including the protection of the rights to privacy and to personal and family confidentiality — as the paramount objective and a fundamental condition of conducting its activities.
1.2. This Policy of the Operator with respect to the processing of personal data (hereinafter, the "Policy") applies to all information that the Operator may obtain about visitors to the website https://foxurbangroup.com.

2. Key Terms Used in the Policy

2.1. Automated processing of personal data — the processing of personal data by means of computer technology.
2.2. Blocking of personal data — the temporary suspension of the processing of personal data (except where processing is necessary to verify or correct personal data).
2.3. Website — the collection of graphical and informational materials, together with the computer programs and databases that make them accessible online at the network address https://foxurbangroup.com.
2.4. Personal data information system — the set of personal data contained in databases, together with the information technologies and technical means that ensure its processing.
2.5. De-identification of personal data — actions that make it impossible, without the use of additional information, to attribute personal data to a specific User or other data subject.
2.6. Processing of personal data — any action (operation) or set of actions (operations) performed with personal data, with or without the use of automated means, including collection, recording, systematization, accumulation, storage, verification (updating, modification), retrieval, use, transfer (distribution, provision, access), de-identification, blocking, deletion, and destruction of personal data.
2.7. Operator — a state authority, municipal authority, legal entity, or natural person that, independently or jointly with others, organizes and/or carries out the processing of personal data and determines the purposes of such processing, the categories of personal data to be processed, and the actions (operations) performed with such data.
2.8. Personal data — any information relating directly or indirectly to an identified or identifiable User of the website https://foxurbangroup.com.
2.9. Personal data authorized by the data subject for distribution — personal data to which the data subject has granted access by an unlimited number of persons by giving consent to the processing of personal data authorized for distribution in the manner prescribed by the Personal Data Law (hereinafter, "personal data authorized for distribution").
2.10. User — any visitor to the website https://foxurbangroup.com.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Distribution of personal data — any action aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or at making personal data available to an unlimited number of persons, including the publication of personal data in the mass media, posting it on information and telecommunications networks, or otherwise granting access to it.
2.13. Cross-border transfer of personal data — the transfer of personal data to the territory of a foreign state, to a foreign-state authority, a foreign natural person, or a foreign legal entity.
2.14. Destruction of personal data — any action that results in personal data being irreversibly destroyed, such that the content of the personal data cannot subsequently be recovered within the personal data information system, and/or the destruction of the physical media on which the personal data is stored.

3. Principal Rights and Obligations of the Operator

3.1. The Operator has the right to:
obtain accurate information and/or documents containing personal data from the data subject;
where the data subject withdraws consent to the processing of personal data, or submits a request to cease processing, continue processing the personal data without the data subject's consent, provided that the grounds set out in the Personal Data Law are present;
independently determine the scope and list of measures necessary and sufficient to ensure compliance with the obligations established by the Personal Data Law and the regulatory legal acts adopted thereunder, unless otherwise provided by the Personal Data Law or other federal laws.
3.2. The Operator is obliged to:
provide the data subject, upon request, with information concerning the processing of their personal data;
organize the processing of personal data in the manner prescribed by the applicable legislation of the Russian Federation;
respond to appeals 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 the rights of data subjects, at its request, with the necessary information within 10 days of receiving such request;
publish or otherwise ensure unrestricted access to this Personal Data Processing Policy;
take legal, organizational, and technical measures to protect personal data against unlawful or accidental access, destruction, modification, blocking, copying, provision, or distribution, as well as against other unlawful actions in respect of personal data;
cease the transfer (distribution, provision, access), cease the processing, and destroy personal data in the manner and in the cases provided for by the Personal Data Law;
fulfill other obligations provided for by the Personal Data Law.

4. Principal Rights and Obligations of Data Subjects

4.1. Data subjects have the right to:
receive information concerning the processing of their personal data, except in the cases provided for by federal law. Such information shall be provided to the data subject by the Operator in an accessible form and shall not contain personal data relating to other data subjects, except where there are lawful grounds for disclosing such data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
require the Operator to verify, block, or destroy their personal data where such data is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, and to take the measures provided for by law to protect their rights;
impose a requirement of prior consent to 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 to submit a request to cease the processing of personal data;
appeal to the authorized body for the protection of the rights of data subjects, or through the courts, against any unlawful action or inaction of the Operator in the processing of their personal data;
exercise other rights provided for by the legislation of the Russian Federation.
4.2. Data subjects are obliged to:
provide the Operator with accurate information about themselves;
notify the Operator of any verification (updating, modification) of their personal data.
4.3. Persons who provide the Operator with inaccurate information about themselves, or information about another data subject without that subject's consent, shall be liable in accordance with the legislation of the Russian Federation.

5. Principles of Personal Data Processing

5.1. The processing of personal data shall be carried out on a lawful and fair basis.
5.2. The processing of personal data shall be limited to the achievement of specific, predetermined, and lawful purposes. The processing of personal data in a manner incompatible with the purposes of its collection is not permitted.
5.3. The merging of databases containing personal data that is processed for mutually incompatible purposes is not permitted.
5.4. Only personal data that corresponds to the purposes of its processing shall be processed.
5.5. The content and scope of the personal data processed shall correspond to the stated purposes of processing. The processing of personal data that is excessive in relation to the stated purposes is not permitted.
5.6. In processing personal data, the accuracy of the data, its sufficiency, and — where necessary — its currency in relation to the purposes of processing shall be ensured. The Operator shall take, and/or ensure that there are taken, the necessary measures to delete or correct incomplete or inaccurate data.
5.7. Personal data shall be stored in a form that permits the identification of the data subject for no longer than required by the purposes of processing, unless the storage period for the personal data is established by federal law or by a contract to which the data subject is a party, beneficiary, or guarantor. The personal data processed shall be destroyed or de-identified once the purposes of processing have been achieved, or where the need to achieve those purposes is lost, unless otherwise provided by federal law.

7. Conditions for Processing Personal Data

7.1. Personal data is processed with the consent of the data subject to the processing of their personal data.
7.2. The processing of personal data is necessary to achieve purposes provided for by an international treaty of the Russian Federation or by law, and to perform the functions, powers, and duties imposed on the Operator by the legislation of the Russian Federation.
7.3. The processing of personal data is necessary for the administration of justice, the enforcement of a judicial act, or the enforcement of an act of another authority or official subject to enforcement in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. The processing of personal data is necessary for the performance of a contract to which the data subject is a party, beneficiary, or guarantor, as well as for the conclusion of a contract at the data subject's initiative or a contract under which the data subject will be a beneficiary or guarantor.
7.5. The processing of personal data is necessary for the exercise of the rights and legitimate interests of the Operator or third parties, or for the achievement of objectives of public significance, provided that the rights and freedoms of the data subject are not thereby infringed.
7.6. Personal data is processed where access to it by an unlimited number of persons has been granted by the data subject or at the data subject's request (hereinafter, "publicly available personal data").
7.7. Personal data subject to publication or mandatory disclosure in accordance with federal law is processed.

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

The security of the 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 the applicable legislation on the protection of personal data.
8.1. The Operator ensures the integrity of personal data and takes all possible measures to prevent unauthorized persons from accessing it.
8.2. The User's personal data will under no circumstances be transferred to third parties, except in cases connected with compliance with the applicable legislation, or where the data subject has given the Operator consent to transfer the data to a third party in order to perform obligations under a civil-law contract.
8.3. Should any inaccuracies in personal data be identified, the User may update them independently by sending the Operator a notice to the Operator's email address, info@mad-fox.ru, marked "Update of Personal Data."
8.4. The period for processing personal data is determined by the achievement of the purposes for which the personal data was collected, unless a different period is provided for by contract or by applicable law. The User may withdraw consent to the processing of personal data at any time by sending the Operator a notice by email to the Operator's address, info@mad-fox.ru, marked "Withdrawal of Consent to the Processing of Personal Data."
8.5. All information collected by third-party services, including payment systems, communication services, and other service providers, is stored and processed by those persons (Operators) in accordance with their own Terms of Use and Privacy Policy. The Operator is not liable for the actions of third parties, including the service providers referred to in this clause.
8.6. Any prohibitions established by the data subject on the transfer (other than the granting of access), as well as on the processing or conditions of processing (other than the granting of access), of personal data authorized for distribution shall not apply in cases where personal data is processed in the state, public, and other public interests defined by the legislation of the Russian Federation.
8.7. In processing personal data, the Operator ensures the confidentiality of personal data.
8.8. The Operator stores personal data in a form that permits the identification of the data subject for no longer than required by the purposes of processing, unless the storage period for the personal data is established by federal law or by a contract to which the data subject is a party, beneficiary, or guarantor.
8.9. Grounds for ceasing the processing of personal data may include: the achievement of the purposes of processing; the expiry of the data subject's consent; the withdrawal of consent by the data subject; a request to cease processing; or the discovery of unlawful processing of personal data.

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

9.1. The Operator collects, records, systematizes, accumulates, stores, verifies (updates, modifies), retrieves, uses, transfers (distributes, provides, grants access to), de-identifies, blocks, deletes, and destroys personal data.
9.2. The Operator carries out automated processing of personal data, with or without the receipt and/or transfer of the information obtained via information and telecommunications networks.

10. Cross-Border Transfer of Personal Data

10.1. Before commencing any cross-border transfer of personal data, the Operator is obliged to notify the authorized body for the protection of the rights of data subjects of its intention to carry out such cross-border transfer (this notice is submitted separately from the notice of intention to process personal data).
10.2. Before submitting the notice referred to above, the Operator is obliged to obtain the relevant information from the foreign-state authorities, foreign natural persons, and foreign legal entities to which 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 it to third parties and not to distribute it without the consent of the data subject, unless otherwise provided by federal law.