Сommercial Real Estate Developer

1. General Provisions
This personal data processing policy is drawn up in accordance with the requirements of Federal Law No. 152-FZ "On Personal Data" dated 27.07.2006 (hereinafter referred to as the Personal Data Law) and defines the procedure for processing personal data and measures to ensure the security of personal data undertaken by LLC "ZG Invest" (hereinafter referred to as the Operator).
1.1. The Operator considers the observance of human and civil rights and freedoms in the processing of personal data to be one of its primary goals and conditions for conducting its activities, including the protection of the right to privacy, personal and family secrets.
1.2. This Operator’s policy on personal data processing (hereinafter referred to as the Policy) applies to all information that the Operator may obtain about visitors to the website https://zemskiygroup.ru.
2. Key Terms Used in the Policy
2.1. Automated processing of personal data – processing of personal data using computing technology.
2.2. Blocking of personal data – temporary suspension of personal data processing (except where processing is necessary for data clarification).
2.3. Website – a collection of graphical and informational materials, as well as software and databases ensuring their availability on the Internet at https://zemskiygroup.ru.
2.4. Personal data information system – a set of personal data contained in databases and the information technologies and technical means that ensure their processing.
2.5. Depersonalization of personal data – actions that result in the impossibility of determining the affiliation of personal data to a specific User or other data subject without additional information.
2.6. Processing of personal data – any action (operation) or a set of actions (operations) performed with or without the use of automation tools on personal data, including collection, recording, systematization, accumulation, storage, updating (modification), retrieval, usage, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
2.7. Operator – a state authority, municipal authority, legal entity, or individual that independently or jointly with others organizes and/or performs the processing of personal data and determines the purposes of personal data processing, the composition of personal data subject to processing, and actions (operations) performed with personal data.
2.8. Personal data – any information relating directly or indirectly to a specific or identifiable User of the website https://zemskiygroup.ru.
2.9. Personal data permitted by the data subject for distribution – personal data that has been made publicly accessible by the data subject through explicit consent for processing, provided in accordance with the Personal Data Law (hereinafter referred to as publicly available personal data).
2.10. User – any visitor to the website https://zemskiygroup.ru.
2.11. Provision of personal data – actions aimed at disclosing personal data to a specific person or a specific group of people.
2.12. Distribution of personal data – any actions aimed at disclosing personal data to an indefinite number of people (transferring personal data) or making personal data publicly available, including publication in mass media, placement in information and telecommunication networks, or providing 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 an authority of a foreign state, a foreign individual, or a foreign legal entity.
2.14. Destruction of personal data – any actions that irreversibly delete personal data, preventing further recovery of their content in the personal data information system and/or destroying physical media containing personal data.
3. Main Rights and Obligations of the Operator
3.1. The Operator has the right to:

• Obtain reliable information and/or documents containing personal data from the data subject.
• Continue processing personal data without the consent of the data subject if there are legal grounds as specified in the Personal Data Law.
• Independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations under the Personal Data Law unless otherwise provided by federal law.

3.2. The Operator must:

• Provide the data subject, upon request, with information concerning the processing of their personal data.
• Organize the processing of personal data in accordance with applicable Russian legislation.
• Respond to requests from data subjects and their legal representatives in accordance with the requirements of the Personal Data Law.
• Notify the authorized body for the protection of personal data subjects' rights upon request of such a body within 30 days of receiving the request.
• Publish and ensure unrestricted access to this Policy regarding personal data processing.
• Take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, distribution, as well as other unlawful actions regarding personal data.
• Stop the transfer (distribution, provision, access) of personal data, cease processing, and destroy personal data in the manner and cases provided for by the Personal Data Law.
• Fulfill other obligations as required by the Personal Data Law.

4. Key Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects have the right to:

• Receive information regarding the processing of their personal data, except in cases provided for by federal law. The information is provided to the personal data subject by the Operator in an accessible form and must not contain personal data related to other personal data subjects unless 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.
• Require the Operator to clarify their personal data, block, or destroy it if the personal data is incomplete, outdated, inaccurate, unlawfully obtained, or is not necessary for the stated processing purpose, and also take legally prescribed measures to protect their rights.
• Set a condition for prior consent when processing personal data for the purpose of marketing goods, works, and services.
• Withdraw consent for the processing of personal data.
• Appeal to the authorized body for the protection of personal data subjects' rights or in court against unlawful actions or inaction of the Operator when processing their personal data.
• Exercise other rights provided for by Russian law.

4.2. Personal data subjects must:

• Provide the Operator with accurate data about themselves.
• Inform the Operator about any updates (changes) to their personal data.

4.3. Individuals who have provided the Operator with false information about themselves or information about another personal data subject without their consent bear responsibility in accordance with Russian law.
5. The Operator May Process the Following Personal Data of the User
5.1. Surname, first name, and patronymic.
5.2. Email address.
5.3. Phone numbers.
5.4. The website also collects and processes anonymized data about visitors (including cookies) using internet analytics services (Yandex.Metrica, Google Analytics, and others).
5.5. The above-mentioned data are hereinafter collectively referred to as Personal Data in this Policy.
5.6. The Operator does not process special categories of personal data related to racial or national origin, political views, religious or philosophical beliefs, or intimate life.
5.7. The processing of personal data permitted for distribution from the special categories of personal data specified in Part 1, Article 10 of the Personal Data Law is allowed if the prohibitions and conditions established by Article 10.1 of the Personal Data Law are met.
5.8. The User's consent to the processing of personal data permitted for distribution is provided separately from other consents for the processing of their personal data. In doing so, the conditions stipulated, in particular, by Article 10.1 of the Personal Data Law are observed. The requirements for the content of such consent are established by the authorized body for the protection of the rights of personal data subjects.
5.8.1. The User provides consent for the processing of personal data permitted for distribution directly to the Operator.
5.8.2. The Operator is required, no later than three business days from the moment of receiving the User’s consent, to publish information about the processing conditions, as well as any restrictions or conditions regarding the processing of personal data that are permitted for distribution to an unlimited number of persons.
5.8.3. The transfer (distribution, provision, access) of personal data permitted by the data subject for distribution must be terminated at any time upon the request of the data subject. This request must include the surname, first name, and patronymic (if available), contact information (phone number, email address, or mailing address) of the data subject, as well as a list of personal data whose processing must be stopped. The personal data specified in this request may only be processed by the Operator to whom the request is addressed.
5.8.4. Consent for the processing of personal data permitted for distribution ceases to be valid upon the Operator receiving the request specified in Clause 5.8.3 of this Personal Data Processing Policy.
6. Principles of Personal Data Processing
6.1. Personal data processing is carried out on a lawful and fair basis.
6.2. The processing of personal data is limited to achieving specific, predefined, and lawful purposes. Processing that is incompatible with the purposes of personal data collection is not permitted.
6.3. The merging of databases containing personal data, where the processing is carried out for purposes that are incompatible with each other, is not permitted.
6.4. Only personal data that corresponds to the purposes of its processing is subject to processing.
6.5. The content and scope of the processed personal data must correspond to the declared purposes of processing. Excessive processing of personal data in relation to the stated purposes is not permitted.
6.6. When processing personal data, the accuracy, sufficiency, and, where necessary, the relevance of personal data to the purposes of processing must be ensured. The Operator takes necessary measures and/or ensures that such measures are taken to delete or clarify incomplete or inaccurate data.
6.7. The storage of personal data is carried out in a form that allows identifying the personal data subject for no longer than required by the purposes of personal data 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. Processed personal data is destroyed or anonymized upon achieving the purposes of processing or if the need to achieve these purposes is lost, unless otherwise provided by federal law.
7. Purpose of Processing User's Personal Data
7.1. The purpose of processing the User's personal data is:

• Informing the User by sending emails;
• Conclusion, execution, and termination of civil law contracts;
• Providing the User with access to services, information, and/or materials available on the website https://zemskiygroup.ru.

7.2. The Operator also has the right to send the User notifications about new products and services, special offers, and various events. The User may opt out of receiving informational messages at any time by sending an email to info@zemskiygroup.ru with the subject "Unsubscribe from notifications about new products, services, and special offers."
7.3. Anonymized user data collected through internet analytics services is used to gather information about User activity on the website, improve the website’s quality, and enhance its content.
8. Terms of Personal Data Processing
8.1. The processing of personal data is carried out with the consent of the personal data subject for the processing of their personal data.
8.2. The processing of personal data is necessary for the implementation of an agreement where the personal data subject is a party, beneficiary, or guarantor, as well as for the execution of an agreement initiated by the personal data subject or an agreement under which the personal data subject will be a beneficiary or guarantor.
8.3. The processing of personal data is necessary for the exercise of the Operator’s rights and legitimate interests or third parties' rights and legitimate interests, provided that this does not violate the rights and freedoms of the personal data subject.
8.4. The processing of personal data is carried out when the personal data is publicly available or at the request of the data subject.
9. Security of Personal Data
9.1. The Operator ensures the security of personal data through legal, organizational, and technical measures necessary to comply with the requirements of applicable personal data protection laws.
9.2. To prevent unauthorized access to personal data, the Operator applies the following measures:

• Use of security software and organizational measures to protect data access.
• Detection of unauthorized access to personal data and immediate response to threats.
• Restriction of access to personal data only to employees who require it for work duties.
• Regular updates of security policies and personal data processing guidelines.

10. Procedure for Collecting, Storing, Transmitting, and Other Types of Personal Data Processing
The security of personal data processed by the Operator is ensured through legal, organizational, and technical measures necessary for full compliance with applicable legislation in the field of personal data protection.
10.1. The Operator ensures the confidentiality of personal data and takes all possible measures to prevent unauthorized access.
10.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases required by law or when the User has given explicit consent to the Operator to transfer data to a third party for the fulfillment of contractual obligations.
10.3. If inaccuracies in personal data are detected, the User can update them independently by sending a notification to the Operator’s email at info@zemskiygroup.ru with the subject "Updating Personal Data."
10.4. The duration of personal data processing is determined by the achievement of the purposes for which the data was collected unless otherwise specified by a contract or applicable law.
The User may withdraw their consent for personal data processing at any time by sending a notification to the Operator via email at info@zemskiygroup.ru with the subject "Withdrawal of Consent for Personal Data Processing."
10.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by these entities in accordance with their own User Agreements and Privacy Policies. The personal data subject (User) is responsible for reviewing these documents in a timely manner. The Operator is not responsible for the actions of third-party service providers mentioned in this section.
10.6. Any restrictions imposed by the personal data subject on data transfer (except for providing access), as well as on processing conditions (except for access retrieval), do not apply when personal data is processed in the interests of the state, society, or other public interests as defined by Russian law.
10.7. The Operator ensures the confidentiality of personal data during processing.
10.8. The Operator stores personal data in a format that allows the identification of the data subject for no longer than necessary for the purposes of processing unless a different retention period is established by federal law or a contract to which the personal data subject is a party, beneficiary, or guarantor.
10.9. The processing of personal data is terminated when the processing objectives are achieved, the subject's consent expires or is withdrawn, or if unlawful processing of personal data is identified.
11. List of Actions Performed by the Operator with Received Personal Data
11.1. The Operator performs the following actions with personal data:

• Collection, recording, systematization, accumulation, storage, updating (modification), retrieval, usage, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction.

11.2. The Operator carries out automated processing of personal data, including obtaining and/or transmitting the information received via information and telecommunication networks or without such transmission.
12. Cross-Border Transfer of Personal Data
12.1. Before initiating a cross-border transfer of personal data, the Operator must ensure that the foreign country receiving the data provides reliable protection of personal data subjects' rights.
12.2. The cross-border transfer of personal data to countries that do not meet the above requirements is permitted only with the written consent of the personal data subject and/or for the execution of a contract in which the personal data subject is a party.
13. Confidentiality of Personal Data
The Operator and any other individuals who have obtained access to personal data must not disclose or distribute personal data to third parties without the consent of the personal data subject, unless otherwise provided by federal law.
14. Final Provisions
14.1. The User may obtain any clarifications on issues related to the processing of their personal data by contacting the Operator via email at info@zemskiygroup.ru.
14.2. Any changes to the Operator’s personal data processing policy will be reflected in this document. The policy remains valid indefinitely until replaced by a new version.
14.3. The current version of the Policy is publicly available on the Internet at https://zemskiygroup.ru.