General Provisions

1. The Operator considers it its primary goal and prerequisite for carrying out its activities to observe the rights and freedoms of individuals when processing their personal data, including the protection of rights to privacy, personal and family secrecy.
2. This Operator's personal data processing policy (hereinafter — the Policy) applies to all information that the Operator may receive about visitors to the website https://ar-cl.ru.

Key Terms Used in the Policy

1. Automated processing of personal data — processing of personal data using computing equipment.
2. Blocking of personal data — temporary suspension of personal data processing (except where processing is necessary to clarify personal data).
3. Website — a collection of graphic and informational materials, as well as software and databases that make them accessible on the internet at the network address https://ar-cl.ru.
4. Personal data information system — a set of personal data contained in databases and the information technologies and technical means that process them.
5. Anonymization of personal data — actions as a result of which it becomes impossible to determine, without using additional information, whether personal data belongs to a specific User or another personal data subject.
6. Processing of personal data — any action (operation) or set of actions (operations) performed with or without the use of automated tools on personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
7. Operator — a state body, municipal body, legal entity, or individual, independently or jointly with others organizing and/or carrying out the processing of personal data, as well as determining the purposes of personal data processing, the composition of personal data to be processed, and the actions (operations) performed on personal data.
8. Personal data — any information relating directly or indirectly to a specific or identifiable User of the website https://ar-cl.ru.
9. Personal data permitted for distribution by the personal data subject — personal data to which an unlimited number of persons have been granted access by the personal data subject by giving consent to the processing of personal data permitted for distribution, in the manner prescribed by the Personal Data Law (hereinafter — personal data permitted for distribution).
10. User — any visitor to the website https://ar-cl.ru.
11. Disclosure of personal data — actions aimed at disclosing personal data to a specific person or a specific group of persons.
12. Distribution of personal data — any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or familiarizing an unlimited number of persons with personal data, including publishing it in mass media, placing it in information and telecommunications networks, or providing access to personal data in any other way.
13. Cross-border transfer of personal data — transfer of personal data to the territory of a foreign state, to an authority of a foreign state, a foreign individual, or a foreign legal entity.
14. Destruction of personal data — any actions as a result of which personal data are permanently destroyed with no possibility of further recovery of the content in the information system and/or the material carriers of personal data are destroyed.

Rights and Obligations of the Operator

1. The Operator has the right to:
2. — receive reliable information and/or documents containing personal data from the personal data subject;
3. — in the event of withdrawal by the personal data subject of consent to the processing of personal data, as well as submission of a request to cease the processing of personal data, the Operator may continue to process personal data without the consent of the personal data subject where grounds specified in the Personal Data Law exist;
4. — independently determine the composition and list of measures necessary and sufficient to fulfill the obligations provided for by the Personal Data Law and the regulatory legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.
5. The Operator is obliged to:
6. — provide the personal data subject, upon request, with information regarding the processing of their personal data;
7. — organize the processing of personal data in accordance with the procedure established by current Russian legislation;
8. — respond to requests and inquiries from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
9. — communicate to the authorized body for the protection of the rights of personal data subjects, upon request, the necessary information within 10 days from the date of receipt of such request;
10. — publish or otherwise ensure unrestricted access to this Policy regarding the processing of personal data;
11. — take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, disclosure, distribution, as well as from other unlawful actions in respect of personal data;
12. — cease the transfer (distribution, 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;
13. — fulfill other obligations provided for by the Personal Data Law.

Rights and Obligations of Personal Data Subjects

1. Personal data subjects have the right to:
2. — receive information regarding the processing of their personal data, except as provided by federal laws. Such information shall be provided by the Operator in an accessible form and must not contain personal data relating to other subjects, except where there are legal grounds for disclosing such data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
3. — require the Operator to clarify, block, or destroy their personal data if it is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, and to take measures provided by law to protect their rights;
4. — stipulate prior consent to the processing of personal data for the purpose of promoting goods, works, and services on the market;
5. — withdraw consent to the processing of personal data, as well as to submit a request to cease the processing of personal data;
6. — appeal to the authorized body for the protection of the rights of personal data subjects or to a court against unlawful actions or inaction of the Operator in processing their personal data;
7. — exercise other rights provided by the legislation of the Russian Federation.
8. Personal data subjects are obliged to:
9. — provide the Operator with reliable data about themselves;
10. — notify the Operator of updates (correction, changes) to their personal data.
11. Persons who have provided the Operator with inaccurate information about themselves, or information about another personal data subject without the consent of the latter, shall be held liable in accordance with the legislation of the Russian Federation.

Principles of Personal Data Processing

1. Processing of personal data is carried out on a lawful and fair basis.
2. Processing of personal data is limited to the achievement of specific, predetermined, and lawful purposes. Processing of personal data incompatible with the purposes of collection is not permitted.
3. Merging of databases containing personal data processed for purposes incompatible with each other is not permitted.
4. Only personal data that meets the purposes of its processing is subject to processing.
5. The content and volume of personal data processed correspond to the stated purposes of processing. Excess of personal data processed in relation to the stated purposes is not permitted.
6. When processing personal data, accuracy, sufficiency, and, where necessary, relevance to the purposes of processing are ensured. The Operator takes necessary measures to delete or clarify incomplete or inaccurate data.
7. Personal data is stored in a form that allows identification of the personal data subject for no longer than required by the purposes of processing, unless the storage period is established by federal law or a contract to which the personal data subject is a party, beneficiary, or guarantor. Personal data is destroyed or anonymized upon achievement of the processing purposes or when the need to achieve those purposes is no longer present, unless otherwise provided by federal law.

Purposes of Personal Data Processing

1. Purpose of processing	informing the User by sending emails
   Personal data	full name email address phone numbers
   Legal grounds	agreements concluded between the operator and the personal data subject
   Types of personal data processing	Collection, recording, systematization, accumulation, storage, destruction, and anonymization of personal data Sending informational emails to the email address

Conditions for Personal Data Processing

1. Processing of personal data is carried out with the consent of the personal data subject.
2. Processing of personal data is necessary to achieve the purposes stipulated by an international treaty of the Russian Federation or by law, for the performance of functions, powers and obligations imposed on the operator by the legislation of the Russian Federation.
3. Processing of personal data is necessary for the administration of justice, execution of a judicial act, or an act of another body or official subject to enforcement under the legislation of the Russian Federation on enforcement proceedings.
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 the beneficiary or guarantor.
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 purposes, provided that the rights and freedoms of the personal data subject are not violated.
6. Processing of personal data to which an unlimited number of persons have been granted access by the personal data subject or at their request (hereinafter — publicly available personal data) is carried out.
7. Processing of personal data subject to publication or mandatory disclosure under federal law is carried out.

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

1. The Operator ensures the safety of personal data and takes all possible measures to prevent access to personal data by unauthorized persons.
2. The User's personal data shall never, under any circumstances, be transferred to third parties, except in cases related to the execution of current legislation or if the personal data subject has given the Operator consent to transfer data to a third party for the fulfillment of obligations under a civil law contract.
3. In the event of inaccuracies in personal data, the User may update them independently by sending the Operator a notice to the email address team@ar-cl.ru with the note "Personal Data Update".
4. The period of personal data processing is determined by the achievement of the purposes for which the personal data was collected, unless a different period is provided by the contract or applicable law.
   The User may at any time withdraw their consent to the processing of personal data by sending the Operator a notice via email to team@ar-cl.ru with the note "Withdrawal of Consent to Personal Data Processing".
5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by those persons in accordance with their User Agreement and Privacy Policy. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this clause.
6. 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 of processing personal data in the state, public, and other public interests defined by the legislation of the Russian Federation.
7. The Operator ensures the confidentiality of personal data when processing it.
8. The Operator stores personal data in a form that allows identification of the personal data subject for no longer than required by the purposes of processing, unless the storage period is established by federal law or a contract to which the personal data subject is a party, beneficiary, or guarantor.
9. The condition for termination of personal data processing may be the achievement of the purposes of processing, expiration of the consent period, withdrawal of consent, or a request to cease processing, as well as the identification of unlawful processing of personal data.

List of Actions Performed by the Operator with Personal Data

1. The Operator performs collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
2. The Operator performs automated processing of personal data with or without receiving/transmitting the obtained information via information and telecommunications networks.

Cross-border Transfer of Personal Data

1. Before commencing cross-border transfer activities, 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 cross-border transfer of personal data (such notification is submitted separately from the notification of the intention to carry out personal data processing).
2. Prior to filing the above notification, the Operator is obliged to obtain from the authorities of a foreign state, foreign individuals, or foreign legal entities to whom cross-border transfer of personal data is planned, the relevant information.

Confidentiality of Personal Data

Final Provisions

1. The User may obtain any clarifications on matters regarding the processing of their personal data by contacting the Operator via email at team@ar-cl.ru.
2. This document will reflect any changes to the Operator's personal data processing policy. The Policy is valid indefinitely until replaced by a new version.
3. The current version of the Policy is freely available on the internet at https://ar-cl.ru/policy/.