Policy on the Processing and Protection of Users' Personal Data

This Policy on the Processing and Protection of Users’ Personal Data (hereinafter – the “Policy”) is adopted and in force at Amond Smith Ltd, a limited liability company, located at: Russian Federation, 119180, Moscow, Malaya Polyanka St., 12A, floor 1, office 7 (hereinafter – the “Company” or “we”).

We collect, use and protect personal data that you provide to us when using our websites and mobile applications (hereinafter – the “websites”) from any device and when communicating with us in any form, in accordance with this Policy.

By using our websites and providing us with your personal data, you consent to the processing of your personal data in accordance with this Policy.

1. Key Terms

“Personal data” – any information relating directly or indirectly to an identified or identifiable individual (personal data subject).

“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, updating (modification), retrieval, use, transfer (distribution, provision, access), anonymization, blocking, deletion, destruction of personal data.

2. Data We Collect

We collect:

• personal data you provide when filling in forms on our websites, including contact forms, newsletter subscriptions, and registration for events (webinars, conferences);
• personal data and other information contained in messages you send to us;
• personal data you provide via job and internship application websites;
• personal data you provide when submitting requests for the purchase of DVDs and other products offered by the Company;
• technical data automatically transmitted by the device you use to access our websites, including device specifications and IP address;
• information stored in “cookies” sent to your device, browser information, date and time of access to the website, requested page addresses, and other similar information;
• other data about you that you choose to provide on our websites.

3. Purposes of Data Processing

We process your personal data exclusively for the purposes for which it was provided, including:

• registering you on our websites to provide access to specific sections;
• providing you with information about the Company, our services, and events;
• communicating with you when you contact us;
• organizing your participation in our events and surveys;
• sending you our newsletters;
• fulfilling obligations imposed on the Company by the laws of the Russian Federation;
• for other purposes with your consent.
• We process technical data to:
• ensure the operation and security of our websites;
• improve the quality of our websites.

We do not publish your personal data in publicly available sources. We do not make decisions that produce legal consequences for you or otherwise affect your rights and legitimate interests based solely on automated processing of personal data.

We may also send you notifications about new products and services, special offers, and events. You may always opt out of receiving such communications by sending an email to moscow@amondsmith.ru with the note “Unsubscribe from notifications about new products, services and special offers.”

4. Your Rights

Protecting your rights and freedoms in the field of personal data is a key priority of the Company.

To protect your rights and freedoms, at your request we will:

• confirm whether we process your personal data and provide you with access to it within 30 days of receiving your request;
• inform you of the source and composition of your personal data that we process;
• inform you of the legal basis, purposes, terms, and methods of processing your personal data;
• make necessary corrections if your personal data is incomplete, inaccurate, or outdated within 7 business days of receiving confirmation, and notify you of the changes;
• inform you of any actual or intended cross-border transfer of your personal data;
• inform you of the names and locations of organizations that have access to your personal data or to whom your data may be disclosed with your consent;
• inform you of the name or full details and address of individuals authorized to process your personal data with your consent;
• notify you about how you may exercise your rights regarding the processing of your personal data;
• unsubscribe you from our newsletters;
• cease processing your personal data within 30 days of receiving your consent withdrawal if no other legal basis exists under Russian law;
• cease unlawful processing of your personal data if confirmed, and notify you of corrective measures taken;
• destroy your personal data if confirmed to be unlawfully obtained or irrelevant to declared processing purposes within 7 business days, and notify you of measures taken;
• respond to your questions regarding your personal data processed by us.

5. How to Contact Us

You may contact us regarding the processing of your personal data by sending an email with the subject “Personal Data Request” (or “Withdrawal of Consent to Personal Data Processing” if withdrawing consent) to moscow@amondsmith.ru or by mail to: 119180, Moscow, Malaya Polyanka St., 12A, floor 1, office 7.

6. Personal Data Security

To ensure the security of your personal data during processing, we take necessary and sufficient legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, alteration, blocking, copying, provision, dissemination, as well as other unlawful actions.

To provide adequate protection of your personal data, we assess potential harm in the event of a security breach, and identify relevant security threats when processing personal data in information systems.

The Company has adopted internal regulations on personal data security. Employees with access to personal data are familiar with this Policy and the internal regulations.

7. Cross-Border Transfer of Personal Data

We transfer your personal data to foreign countries. Ensuring the security of your personal data during cross-border transfer is very important to us. We take all necessary measures to guarantee confidentiality and security of your personal data.

Cross-border transfer of personal data to foreign countries that do not provide adequate protection is carried out only with your written consent, or for the performance of a contract to which you are a party, as well as in other cases provided by Russian legislation on personal data.

8. Termination of Personal Data Processing

We terminate the processing of your personal data:

• upon the occurrence of conditions for termination of processing or expiration of the set period;
• upon achieving the purposes of processing or if there is no further need for them;
• at your request, if the processed personal data was unlawfully obtained or is unnecessary for declared purposes;
• if unlawful processing is detected and lawfulness cannot be ensured;
• upon expiration of your consent or its withdrawal, if no other legal basis exists under Russian law;
• in case of liquidation of the Company.

9. Cookies

We use “cookies.” Cookies are small text files stored on your device’s hard drive during website use, designed to help customize the user interface to your preferences.

Most browsers allow you to refuse cookies and delete them from your device.

10. Links to Third-Party Websites

Our websites may contain links to third-party websites and services we do not control. We are not responsible for the security or privacy of any information collected by such websites or services.

11. Policy Updates

We may update this Policy as necessary. We recommend that you periodically check the current version of this Policy. By continuing to use our websites after changes, you confirm your agreement with the updates.

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If you have any questions about this Policy, please contact the person responsible for personal data processing in the Company by sending an email with the note “Personal Data Request” to: moscow@amondsmith.ru