Personal Data Processing Policy

This personal data processing policy (hereinafter referred to as the Policy) has been compiled in accordance with the requirements of Federal Law No. 152-FZ of July 27, 2006, "On Personal Data." It defines the personal data processing procedures and security measures taken by SPN.Communications LLC and NP SZ RASO (hereinafter referred to as the Operators) when providing the Operators' services located on the website http://roadshowpetersburg.com (hereinafter referred to as the Site). This policy applies to all information the Operators may obtain about Site visitors.

By completing the relevant forms and/or submitting their personal data to the Operators, the User consents to this Policy and the terms and conditions for the processing of their personal data specified therein. If the User disagrees with these terms and conditions, they must refrain from using the services provided on the Site.

1. BASIC TERMS

1.1. Automated processing of personal data – the processing of personal data using computer technology;

1.2. Blocking of personal data – temporary cessation of the processing of personal data (except in cases where processing is necessary to clarify the personal data);

1.3. Website – a collection of graphic and informational materials, as well as computer programs and databases, ensuring their availability on the internet at the address http://roadshowpetersburg.com;

1.4. Personal data information system – a collection of personal data contained in databases and the information technologies and technical means that enable their processing;

1.5. Anonymization of personal data – actions that make it impossible to determine the attribution of personal data to a specific User or another personal data subject without the use of additional information;

1.6. Personal data processing – any action (operation) or set of actions (operations) performed with or without the use of automated tools with personal data, including collection, recording, updating, systematization, accumulation, storage, clarification (updating, modification, correction), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, or destruction of personal data;

1.7. Personal data – any information relating directly or indirectly to an identified or identifiable User of the website http://roadshowpetersburg.com;

1.8. User – any visitor to the website http://roadshowpetersburg.com;

1.9. Provision of personal data – actions aimed at disclosing personal data to a specific person or a specific group of persons;

1.10. Dissemination of personal data – any actions aimed at disclosing personal data to an indefinite number of persons (transferring personal data) or making personal data available to an indefinite number of persons, including disclosing personal data in the media, posting it on information and telecommunications networks, or providing access to personal data by any other means;

1.11. Destruction of personal data – any actions resulting in the irreversible destruction of personal data, making it impossible to subsequently restore the contents of the personal data in the personal data information system, and/or the destruction of tangible storage media for the personal data.

2. GENERAL PROVISIONS

2.1. For the purposes of this Policy, the User's personal data means:

2.1.1. Personal information that the User provides about themselves upon registration (creating an account) or while using the Website's services, including, but not limited to:
- Last name, first name, patronymic;
- Email address;
- Telephone numbers;
- Job title;
- Company name.

2.1.2. Data that is automatically transferred to the Website's services during their use via software installed on the User's device, including IP address, cookie data, information about the User's browser (or other program used to access the services), technical specifications of the hardware and software used by the User, the date and time of access to the services, the addresses of requested pages, and other similar information.

2.2. This Policy applies only to the Website. The Site does not control and is not responsible for third-party sites that the User may access via links available on the Site.

3. PURPOSES OF PROCESSING USERS' PERSONAL DATA

3.1. Operators collect and store only the personal data necessary to provide services/information/materials, notify/inform Users, or fulfill agreements and contracts with the User, except in cases where legislation requires mandatory storage of personal data for a specified period.

Operators store personal data in a form that allows identification of the data subject for no longer than required for each purpose of processing, unless a storage period for personal data is established by federal law or contract.

If the User notifies the Operator of their revocation of consent to the processing of personal data, the Operators will cease processing the User's personal data within 10 business days of receipt.

A notice of revocation of consent to the processing of personal data should be sent to the email address: info@petersburg-roadshow.com, or by written request to the legal address: Varshavskoe Shosse, Building 9, Bldg. 28, Office 1, Room 16, Moscow, Russian Federation, 117105.

3.2. The Operators process the User's personal data for the following purposes:

3.2.1. Identifying the User registered on the Website.

3.2.2. Providing the User with access to the personalized resources of the Website.

3.2.3. Establishing feedback with the User, including sending notifications and requests regarding the use of the Website, provision of services, and processing requests and applications from the User.

3.2.4. Determining the User's location for security and fraud prevention.

3.2.5. Confirming the accuracy and completeness of the personal data provided by the User.

3.2.6. Creating an account if the User has consented to the account creation or if account creation is necessary for the provision of services.

3.2.7. Notifying the User of the Website about new products and services, special offers, and various events. The User can always unsubscribe from receiving informational messages by sending an email to the Operators at the email address specified in Section 3.1 of the Policy.

3.2.8. Providing the User with effective customer and technical support should any issues related to the use of the Website arise.

3.2.9. Anonymized User data collected through internet statistics services is used to collect information about the User's actions on the Website and to improve the quality of the Website and its content.

4. TERMS OF PROCESSING USERS' PERSONAL DATA
AND TRANSFER TO THIRD PARTIES, LEGAL BASIS FOR PROCESSING

4.1. The Website stores Users' personal data in accordance with the internal regulations of specific services.

4.2. The User's personal data is kept confidential, except in cases where the User voluntarily provides information about themselves for general access by an unlimited number of persons. By using certain services, the User agrees that a certain portion of their personal data will become publicly available.

4.3. The Website reserves the right to transfer the User's personal data to third parties in the following cases:

4.3.1. The User has consented to such actions.

4.3.2. The transfer is necessary for the User to use a specific service or to fulfill a specific agreement or contract with the User.

4.3.3. The transfer is required by Russian or other applicable law within the framework of the procedure established by law.

4.3.4. In the event of the sale of the Website, all obligations to comply with the terms of this Policy with respect to the personal data received by the purchaser shall transfer to the purchaser.

4.4. The User's personal data shall be processed indefinitely using the following methods: collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data, including in personal data information systems, with or without the use of automated means. The processing of Users' personal data is carried out in accordance with Federal Law No. 152-FZ of July 27, 2006, "On Personal Data."

4.5. In the event of loss or disclosure of personal data, Operators shall notify the User of the loss or disclosure of such personal data.

4.6. Operators take the necessary organizational and technical measures to protect the User's personal data from unauthorized or accidental access, destruction, modification, blocking, copying, distribution, and other illegal actions by third parties.

4.7. Operators, together with the User, take all necessary measures to prevent losses or other negative consequences caused by the loss or disclosure of the User's personal data.

4.8. The legal basis for processing personal data is the set of regulatory legal acts pursuant to which and in accordance with which the Operators process personal data, including:
- The Constitution of the Russian Federation;
- The Civil Code of the Russian Federation;
- The Labor Code of the Russian Federation;
- The Tax Code of the Russian Federation;
- Federal Law of February 8, 1998, No. 14-FZ "On Limited Liability Companies";
- Federal Law No. 402-FZ of December 6, 2011 "On Accounting";
- other regulatory legal acts governing relations related to the activities of the Operators.

4.9. The legal basis for processing personal data also includes:
- the Operators' charters;
- agreements concluded between the Operators and the User;
- the User's consent to the processing of personal data.

5. OBLIGATIONS OF THE PARTIES

5.1. The User is obligated to:

5.1.1. Provide the personal data necessary to use the Website.

5.1.2. Update and supplement the personal data provided if this information changes.

5.2. The Operators are obligated to:

5.2.1. Use the information received solely for the purposes specified in this Policy.

5.2.2. Ensure the safekeeping of personal data, and not disclose it without the prior written consent of the User, nor sell, exchange, publish, or otherwise disclose the User's personal data provided, except as provided in this Policy.

5.2.3. Block personal data related to the relevant User from the moment of the User's request or appeal, or from their legal representative or authorized body for the protection of the rights of personal data subjects, for the duration of the verification process in the event of detection of inaccurate personal data or illegal actions.

6. LIABILITY OF THE PARTIES

6.1. Operators who fail to fulfill their obligations are liable for damages incurred by the User due to the unauthorized use of personal data, in accordance with Russian Federation law.

6.2. Operators shall not be liable in the event of loss or disclosure of personal data if the personal data:

6.2.1. Was publicly known prior to its loss or disclosure.

6.2.2. Was received from a third party prior to its receipt by the Operators.

6.2.3. Was disclosed with the consent of the User.

7. DISPUTE RESOLUTION

7.1. Before filing a claim in court regarding disputes arising from the relationship between the Website User and the Operators, it is mandatory to submit a claim (a written proposal for a voluntary settlement).

7.2. The recipient of the claim shall notify the claimant in writing of the results of the claim review within 10 calendar days of receipt of the claim.

7.3. If no agreement is reached, the dispute will be referred to the court in accordance with the current legislation of the Russian Federation.

7.4. The current legislation of the Russian Federation shall apply to this Policy and the relationship between the User and the Operators.

8. ADDITIONAL TERMS

8.1. The Operators reserve the right to amend this Policy without the User's consent.

8.2. The new Policy shall take effect from the moment it is posted on the Website, unless otherwise provided in the new version of the Policy.

8.3. Any suggestions or questions regarding this Policy should be sent to the following email address: info@petersburg-roadshow.com.

8.4. The current Policy is posted at: http://roadshowpetersburg.com.