Appendix No. 1
APPROVED
by Order of JSC “DAO Tech”
dated 19 March 2025, No. 05
Privacy Policy for the Processing of Personal Data
(“Privacy Policy”)
JSC “DAO Tech” (Revision No. 1)
This Privacy Policy for Personal Data (hereinafter, the “Privacy Policy”) applies to all information that this website—where the text of this Privacy Policy is posted—may receive about a User, as well as to any programs and products made available on the website.
1. Definitions1.1. For the purposes of this Privacy Policy, the following terms shall have the meanings set out below:
1.1.1.
“Website Administration” – the authorized individuals who manage the website on its behalf and who organize and/or carry out the processing of personal data, determine the purposes of such processing, the scope of personal data to be processed, and the actions (operations) performed with personal data.
1.1.2.
“Personal Data” – any information relating directly or indirectly to an identified or identifiable natural person (data subject).
1.1.3.
“Processing of Personal Data” – any operation or set of operations performed with or without the use of automated means on personal data, including collection, recording, systematization, accumulation, storage, updating (revision, alteration), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, or destruction of personal data.
1.1.4.
“Confidentiality of Personal Data” – a mandatory requirement binding on the Website Administration to prevent deliberate disclosure of personal data without the consent of the data subject or another lawful basis.
1.1.5.
“User” – an individual who has access to the website via the Internet and uses the website for personal purposes.
1.1.6.
“Website” – a set of logically linked web pages united under one domain name (address) on the Internet.
1.1.7.
“Cookies” – small fragments of data sent by a web server and stored on the user’s device (computer, mobile phone, tablet, etc.). The web client or browser sends these fragments to the web server in an HTTP request each time it attempts to open a page of the corresponding Website.
1.1.8.
“IP Address” – a unique network address of a node in an IP‑based computer network.
2. General Provisions2.1. The User’s use of the website constitutes acceptance of this Privacy Policy and the terms governing processing of the User’s personal data.
2.2. If the User disagrees with the terms of this Privacy Policy, the User must discontinue use of the website.
2.3. This Privacy Policy applies solely to this website. The Website Administration neither controls nor is responsible for third‑party websites that the User may access via links available on this website.
2.4. The Website Administration does not verify the accuracy of personal data provided by the User.
3. Subject Matter of the Privacy Policy3.1. This Privacy Policy establishes the Website Administration’s obligations not to intentionally disclose personal data that the User provides in response to various requests from the Website Administration (e.g., when registering on the website, placing an order, subscribing to notifications, etc.).
3.2. Personal data permitted for processing under this Privacy Policy are provided by the User by completing special forms on the website and typically include:
3.2.1. Surname, given name, and (if applicable) patronymic;
3.2.2. Contact telephone number;
3.2.3. E‑mail address and other data.
3.3. The Website Administration also takes measures to protect personal data automatically transmitted during visits to website pages, including:
– IP address;
– information from Cookies;
– browser information (or other software used to access the website);
– access time;
– addresses of visited pages.
3.3.1. Disabling Cookies may result in the inability to access the website.
3.3.2. The website collects statistics on visitors’ IP addresses. This information is used to identify and resolve technical problems and to monitor the legality of transactions performed.
3.4. Any other personal information not expressly specified above (purchase history, browsers and operating systems used, etc.) shall not be intentionally disclosed, except in the circumstances provided for in Clauses 5.2 and 5.3 of this Privacy Policy.
4. Purposes of Collecting the User’s Personal Data4.1. The Website Administration may use the User’s personal data for the following purposes:
4.1.1. Identifying a User registered on the website.
4.1.2. Providing the User with access to personalized resources of the website.
4.1.3. Establishing feedback with the User, including sending notices and requests related to the use of the website, the provision of services, and processing queries and requests from the User.
4.1.4. Determining the User’s location to ensure security and prevent fraud.
4.1.5. Verifying the accuracy and completeness of personal data provided by the User.
4.1.6. Providing effective customer and technical support to the User in case of issues related to website use.
4.1.7. Conducting advertising activities with the User’s consent.
4.1.8. Granting the User access to partner websites or services for the purpose of receiving their offers, updates, or services.
5. Methods and Periods of Processing Personal Information5.1. Personal data are processed for an indefinite period in any lawful manner, including in personal data information systems with or without the use of automation tools.
5.2. Personal data may be disclosed to authorized government bodies only on the grounds and in accordance with the procedures established by applicable law.
6. Obligations of the Parties6.1.
The User undertakes to: 6.1.1. Provide accurate and truthful personal data necessary for using the website.
6.1.2. Update or supplement provided personal data in case of changes.
6.1.3. Take measures to protect access to confidential data stored on the website.
6.2.
The Website Administration undertakes to: 6.2.1. Use received information solely for the purposes specified in Section 4 of this Privacy Policy.
6.2.2. Not disclose the User’s personal data, except as provided in Clauses 5.2 and 5.3 of this Privacy Policy.
6.2.3. Block personal data related to the respective User from the moment of a request by the User, the User’s legal representative, or an authorized body for the protection of data subjects’ rights, for the period of verification if inaccurate personal data or unlawful actions are discovered.
7. Liability of the Parties7.1. The Website Administration is liable for intentional disclosure of the User’s personal data in accordance with applicable law, except where such disclosure occurs in the circumstances specified in Clauses 5.2, 5.3, and 7.2 of this Privacy Policy.
7.2. In case of loss or disclosure of personal data, the Website Administration is not liable if the confidential information:
7.2.1. Became public domain prior to its loss or disclosure.
7.2.2. Was received from a third party prior to receipt by the Website Administration.
7.2.3. Was obtained by third parties through unauthorized access to website files.
7.2.4. Was disclosed with the User’s consent.
7.3. The User bears responsibility for the legality, accuracy, and veracity of the personal data provided, in accordance with applicable law.
8. Dispute Resolution8.1. Before filing a lawsuit over disputes arising from relations between the User and the Website Administration, submission of a claim (a written proposal for voluntary settlement of the dispute) is mandatory.
8.2. The recipient of the claim shall, within 30 calendar days of receiving it, provide the claimant with written notice of the outcome of the claim review.
8.3. If no agreement is reached, the dispute shall be referred to a court of competent jurisdiction in accordance with applicable law.
8.4. This Privacy Policy and the relations between the User and the Website Administration are governed by the laws of the Russian Federation.
9. Additional Terms9.1. The Website Administration may amend this Privacy Policy without the User’s consent.
9.2. The updated Privacy Policy becomes effective upon its posting on the website unless otherwise specified by the new edition of the Privacy Policy.
By continuing to use our Website, you consent to the processing of Cookies and other user data in accordance with this Privacy Policy.