The Firm

1. 1. General Provisions

This Personal Data Processing Policy is drafted in accordance with the requirements of Federal Law No. 152-FZ of July 27, 2006 “On Personal Data” (hereinafter – the “Personal Data Law”) and defines the procedure for processing personal data and the measures taken by ALPERIYA LLC (hereinafter – the “Operator”) to ensure the security of personal data.

1.1. The Operator considers the observance of human and civil rights and freedoms in the processing of personal data –  including the protection of the rights to privacy, personal and family confidentiality – to be its most important objective and condition for carrying out its activities.

1.2. This Personal Data Processing Policy (hereinafter – the “Policy”) applies to all information that the Operator may receive about visitors to the website https://alperiyapartners.ru.

2. 2. Key Terms Used in the Policy

2.1. Automated processing of personal data – processing of personal data using computer technology.

2.2. Blocking of personal data – temporary suspension of personal data processing (except when processing is necessary to clarify personal data).

2.3. Website – a collection of graphic and informational materials, as well as computer programs and databases, that make such materials available on the Internet at https://alperiyapartners.ru.

2.4. Personal data information system – a set of personal data contained in databases and information technologies and technical tools that ensure their processing.

2.5. Depersonalization of personal data – actions that make it impossible to determine, without the use of additional information, whether personal data belong to a specific User or another personal data subject.

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

2.7. Operator – a state or municipal authority, legal entity, or individual that independently or jointly with others organizes and/or carries out the processing of personal data, and determines the purposes of processing personal data, the composition of personal data to be processed, and the actions (operations) performed with personal data.

2.8. Personal data – any information relating directly or indirectly to an identified or identifiable User of the website https://alperiyapartners.ru.

2.9. Personal data permitted by the data subject for distribution – personal data to which the data subject has granted access to an unlimited number of persons by giving consent for the processing of personal data permitted for distribution in accordance with the procedure established by the Personal Data Law (hereinafter – “personal data permitted for distribution”).

2.10. User – any visitor to the website https://alperiyapartners.ru.

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 actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or at providing access to personal data to an unlimited group of persons, including making personal data publicly available in the media, posting them in information and telecommunications networks, or granting access to personal data in any other way.

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, or to a foreign individual or foreign legal entity.

2.14. Destruction of personal data – any actions resulting in the irreversible destruction of personal data, making it impossible to restore the content of personal data within the personal data information system and/or resulting in the destruction of physical media containing personal data.

3. 3. Basic Rights and Obligations of the Operator

3.1. The Operator has the right to:

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

— continue processing personal data without the data subject’s consent if the data subject withdraws their consent or submits a request to terminate personal data processing, provided that there are grounds specified in the Personal Data Law;

— independently determine the composition and list of measures necessary and sufficient to fulfill the obligations established by the Personal Data Law and regulatory legal acts adopted pursuant to it, 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 accordance with the procedure established by the legislation of the Russian Federation;

— respond to inquiries 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 data subjects’ rights, 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 Personal Data Processing Policy;

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

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

— fulfill other obligations established by the Personal Data Law.

4. 4. Basic Rights and Obligations of Personal Data Subjects

4.1. Personal data subjects have the right to:

— receive information related to the processing of their personal data, except in cases provided for by federal laws. The information must 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, unless there are lawful grounds for disclosing such data. The list of such 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 data are incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the stated purpose of processing, as well as take measures provided by law to protect their rights;

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

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

— appeal to the authorized body responsible for the protection of personal data subjects’ rights or to a court regarding unlawful actions or inaction by the Operator in the processing of their personal data;

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

4.2. Personal data subjects are obliged to:

— provide the Operator with accurate information about themselves;

— notify the Operator of clarification (updating, modification) of their personal data.

4.3. Individuals who provide the Operator with inaccurate information about themselves or information about another personal data subject without that person’s consent bear liability in accordance with the legislation of the Russian Federation.

5. 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 that is incompatible with the purposes for which the data are collected is not permitted.

5.3. It is not permitted to combine databases containing personal data if the processing purposes of such databases are incompatible with one another.

5.4. Only personal data that meet the purposes of their processing are subject to processing.

5.5. The content and scope of the personal data being processed must correspond to the stated purposes of processing. Excessive personal data in relation to the declared purposes of processing is not permitted.

5.6. When processing personal data, the accuracy, sufficiency, and, when necessary, relevance of personal data to the purposes of processing must be ensured. The Operator shall take or ensure the adoption of necessary measures to remove or clarify incomplete or inaccurate data.

5.7. Personal data shall be stored in a form that allows the identification of the personal data subject for no longer than required by the purposes of personal data processing, unless a storage period is established by federal law or a contract to which the personal data subject is a party, beneficiary, or guarantor. Processed personal data shall be destroyed or depersonalized once the purposes of processing are achieved or when the necessity to achieve these purposes is lost, unless otherwise provided by federal law.

6. 6. Purposes of Personal Data Processing

Purpose of Processing	сonclusion, performance, and termination of civil-law contracts
Personal Data Processed	last name, first name, patronymic email address phone numbers
Legal Grounds	Consent of the personal data subject. (The Operator processes the User’s personal data only if the User independently fills out and/or submits them through the special forms available on the website https://alperiyapartners.ru. By completing the relevant forms and/or submitting their personal data to the Operator, the User expresses their consent to this Policy).
Types of Personal Data Processing	Collection, recording, systematization, accumulation, storage, destruction, and depersonalization of personal data Sending informational messages to the email address

7. 7. Conditions for Personal Data Processing

7.1. Personal data are processed with the consent of the personal data subject to the processing of their personal data.

7.2. Personal data processing is necessary to achieve the purposes stipulated by an international treaty of the Russian Federation or by law, or to perform the functions, powers, and duties imposed on the Operator by the legislation of the Russian Federation.

7.3. Personal data processing is necessary for the administration of justice or for the execution of a judicial act, or an act of another authority or official, subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.

7.4. Personal data processing is necessary for the performance of a contract to which the personal data subject is a party, beneficiary, or guarantor, as well as for the conclusion of 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. Personal data processing is necessary for the exercise of the Operator’s or third parties’ rights and legitimate interests, or for the achievement of socially significant goals, provided that the rights and freedoms of the personal data subject are not violated.

7.6. Processing is carried out with respect to personal data made accessible to an unlimited number of persons by the personal data subject or at their request (hereinafter, “publicly available personal data”).

7.7. Processing is carried out with respect to personal data subject to publication or mandatory disclosure in accordance with federal law.

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

8.1. 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 applicable personal data protection legislation.

8.2. The Operator ensures the confidentiality of personal data and takes all possible measures to prevent unauthorized access by third parties.

8.3. Under no circumstances will the User’s personal data be transferred to third parties, except in cases related to the fulfillment of applicable legislation or when the personal data subject has granted the Operator consent to transfer the data to a third party for the performance of obligations under a civil-law contract.

8.4. If inaccuracies in personal data are identified, the User may update their data independently by sending a notification to the Operator via email at info@alperiya.ru with the note “Update of Personal Data”.

8.5. The processing period for personal data is determined by the achievement of the purposes for which the personal data were collected, unless a different period is established by a contract or applicable law.
The User may withdraw their consent to the processing of personal data at any time by sending a notification to the Operator via email at info@alperiya.ru with the note “Withdrawal of Consent to Personal Data Processing”.

8.6. All information collected by third-party services – including payment systems, communication tools, and other service providers – is stored and processed by these parties (Operators) in accordance with their User Agreements and Privacy Policies. The personal data subject must familiarize themselves with those documents. The Operator bears no responsibility for the actions of third parties, including the service providers mentioned in this clause.

8.7. Restrictions established by the personal data subject on the transfer (except for granting access), as well as on the processing or conditions of processing (except for obtaining access) of personal data permitted for distribution, do not apply in cases where personal data are processed in state, public, or other public interests as defined by the legislation of the Russian Federation.

8.8. When processing personal data, the Operator ensures the confidentiality of such personal data.

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

8.10. Grounds for termination of personal data processing may include the achievement of the purposes for which the personal data were collected, the expiration of the validity period of the personal data subject’s consent, the withdrawal of consent by the personal data subject or a request to cease processing, as well as the detection of unlawful processing of personal data.

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

9.1. The Operator performs the following actions with personal data: collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.

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

10. 10. Cross-Border Transfer of Personal Data

10.1. Before initiating activities involving the cross-border transfer of personal data, the Operator must notify the authorized body responsible for the protection of personal data subjects’ rights of its intention to carry out such transfer (this notification is submitted separately from the notification of intent to process personal data).

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

11. 11. Confidentiality of Personal Data

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

12. 12. Final Provisions

12.1. The User may obtain any clarifications on matters related to the processing of their personal data by contacting the Operator via email at info@alperiya.ru.

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

12.3. The current version of the Policy is publicly available on the Internet at https://alperiyapartners.ru.