Privacy Policy

1. General Provisions
This Privacy Policy has been prepared in accordance with the Federal Law of July 27, 2006 No. 152-FZ "On Personal Data" (hereinafter, the "Personal Data Law") and establishes the procedure for processing personal data and the security measures taken by Ino Media LLC (hereinafter, the "Operator") to protect personal data.
1.1 The Operator considers it its primary goal and condition for conducting its activities to comply with the rights and freedoms of individuals and citizens when processing their personal data, including protection of the right to privacy, personal and family confidentiality.
1.2 This Policy of the Operator regarding the processing of personal data (hereinafter, the "Policy") applies to all information that the Operator may collect from visitors to the website https://ino.media.

2. Key Definitions Used in This Policy
2.1 Automated data processing — processing of personal data using computing equipment.
2.2 Data blocking — temporary cessation of personal data processing (except where processing is necessary to clarify the data).
2.3 Website — a collection of graphic and information materials, as well as computer programs and databases that ensure their accessibility on the internet at https://ino.media.
2.4 Personal data information system — a collection of personal data contained in databases and the information technologies and technical means that process them.
2.5 Data de-identification — actions as a result of which it is impossible to determine without additional information the association of personal data with a specific user or other data subject.
2.6 Personal data processing — any action or set of actions performed with or without automated means on personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, disclosure, access), de-identification, blocking, deletion, or destruction of personal data.
2.7 Operator — a state body, municipal body, legal entity, or individual person that independently or jointly with other persons organizes and/or carries out personal data processing, as well as determines the purposes of processing, the scope of personal data to be processed, and the actions performed with personal data.
2.8 Personal data — any information directly or indirectly relating to a defined or identifiable user of the website https://ino.media.
2.9 Personal data authorized for distribution — personal data that the data subject has authorized for unlimited disclosure by giving consent for processing in accordance with the Personal Data Law.
2.10 User — any visitor to the website https://ino.media.
2.11 Data disclosure — actions aimed at revealing personal data to a specific person or a specific group of persons.
2.12 Data distribution — any actions aimed at disclosing personal data to an unlimited number of persons or familiarizing an unlimited number of persons with personal data, including publishing on mass media, placement on information and telecommunications networks, or providing access by any other means.
2.13 Cross-border data transfer — transfer of personal data to the territory of a foreign state to a foreign authority, foreign individual, or foreign legal entity.
2.14 Data destruction — any actions resulting in irreversible destruction of personal data with no possibility of further recovery in the personal data information system and/or destruction of material media of personal data.

3. Main Rights and Obligations of the Operator
3.1 The Operator has the right to:

• Receive accurate information and/or documents containing personal data from data subjects;
• Continue processing personal data without the data subject's consent following withdrawal of consent or a request to cease processing, where legal grounds exist under the Personal Data Law;
• Independently determine the scope and measures necessary to fulfill obligations under the Personal Data Law and related regulations, unless otherwise provided by the Personal Data Law or other federal laws.

3.2 The Operator is obligated to:

• Provide data subjects with information regarding the processing of their personal data upon request;
• Organize personal data processing in accordance with current Russian legislation;
• Respond to requests and inquiries from data subjects and their legal representatives in accordance with the Personal Data Law;
• Provide necessary information to the authorized body for personal data protection within 10 days of receiving a request;
• Publish or otherwise ensure unrestricted access to this Privacy Policy;
• Take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, disclosure, distribution, or other unlawful actions;
• Cease data transfer, distribution, disclosure, and access; stop processing; and destroy personal data in accordance with the procedures and circumstances specified in the Personal Data Law;
• Fulfill other obligations prescribed by the Personal Data Law.

4. Main Rights and Obligations of Data Subjects
4.1 Data subjects have the right to:

• Obtain information regarding the processing of their personal data, except as provided by federal law. Information shall be provided in an accessible form and must not contain personal data of other data subjects unless there is legal grounds for disclosure. The scope and procedure for obtaining such information is established by the Personal Data Law;
• Require the Operator to clarify, block, or destroy their personal data if it is incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the stated purpose of processing, and to exercise rights to protect their interests as provided by law;
• Require prior consent before their personal data is processed for marketing purposes to promote goods, works, or services;
• Withdraw consent to process personal data and require cessation of processing;
• File a complaint with the authorized body for personal data protection or pursue legal remedies against unlawful actions or inaction of the Operator in processing their personal data;
• Exercise other rights provided by Russian legislation.

4.2 Data subjects are obligated to:

• Provide the Operator with accurate information about themselves;
• Notify the Operator of any clarification, updating, or changes to their personal data.

4.3 Persons who provide the Operator with inaccurate information about themselves or information about another data subject without that person's consent are liable in accordance with Russian legislation.

5. Principles of Personal Data Processing
5.1 Processing of personal data shall be conducted on a lawful and fair basis.
5.2 Processing of personal data is limited to the achievement of specific, predetermined, and lawful purposes. Processing of personal data that is incompatible with the purposes of collection is prohibited.
5.3 The consolidation of databases containing personal data processed for incompatible purposes is prohibited.
5.4 Only personal data that meets the objectives of processing shall be processed.
5.5 The content and scope of personal data processed shall correspond to the stated purposes of processing. Processing of personal data that is excessive in relation to the stated purposes is prohibited.
5.6 When processing personal data, accuracy, sufficiency, and where necessary, timeliness of personal data in relation to the purposes of processing shall be ensured. The Operator shall take necessary measures or ensure their implementation to remove or clarify incomplete or inaccurate data.
5.7 Personal data shall be stored in a form that permits identification of the data subject, for no longer than required to achieve the purposes of processing, unless a retention period is established by federal law, contract, or other legal instrument to which the data subject is a party, beneficiary, or guarantor. Processed personal data shall be destroyed or de-identified upon achievement of the stated purposes or upon loss of necessity to achieve these purposes, unless otherwise provided by federal law.

6. Purposes of Personal Data Processing
Purpose of Processing
Conclusion, performance, and termination of civil law agreements
Personal Data

• Full name, first name, patronymic
• Email address
• Phone numbers

Legal Grounds

• Federal Law No. 152 of July 27, 2006 "On the Protection of Personal Data," Article 6 (data subject consent), Federal Law No. 152, Article 10 (necessity for contract performance)

Types of Personal Data Processing

• Collection, recording, systematization, accumulation, and storage of personal data for the purpose of establishing contact with the user and providing service conditions

7. Conditions of Personal Data Processing
7.1 Processing of personal data shall be carried out with the consent of the data subject for the processing of their personal data.
7.2 Processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, and to perform the functions, powers, and obligations imposed on the Operator by the legislation of the Russian Federation.
7.3 Processing of personal data is necessary for the administration of justice, the execution of a court order, an order of another body, or an official order that must be executed in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4 Processing of personal data is necessary for the performance of a contract to which the data subject is a party, a beneficiary, or a guarantor, or for the conclusion of a contract at the initiative of the data subject or a contract in which the data subject will be a beneficiary or guarantor.
7.5 Processing of personal data is necessary for the exercise of the rights and legitimate interests of the Operator or third parties, or to achieve publicly significant objectives, provided that the rights and freedoms of the data subject are not violated.
7.6 Processing of personal data to which unlimited public access has been provided by the data subject or at their request (hereinafter, "publicly available personal data") is permitted.
7.7 Processing of personal data that is required to be published or mandatorily disclosed in accordance with federal law is permitted.

8. Procedure for Collection, Storage, Transfer, and Other Forms of Personal Data Processing
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 current legislation on the protection of personal data.
8.1 The Operator ensures the safety of personal data and takes all possible measures to prevent access to personal data by unauthorized persons.
8.2 A User's personal data will never, under any circumstances, be transferred to third parties, except where required by applicable law or where the data subject has given consent to the Operator to transfer data to a third party for the performance of obligations under a civil law agreement.
8.3 In the event inaccuracies are identified in personal data, the User may update them independently by sending the Operator a notification to the Operator's email address info@inomedia.ru with the notation "Personal Data Update."
8.4 The period of personal data processing is determined by the achievement of the purposes for which the personal data were collected, unless a different period is provided for in a contract or applicable law.
A User may withdraw their consent to personal data processing at any time by sending the Operator a notification via email to the Operator's email address info@inomedia.ru with the notation "Withdrawal of Consent to Personal Data Processing."
8.5 All information collected by third-party services, including payment systems, communications providers, and other service providers, is stored and processed by such persons (Operators) in accordance with their User Agreement and Privacy Policy. The data subject should familiarize themselves with such documents. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this section.
8.6 Restrictions established by the data subject on data transfer (except access provision) and on processing or processing conditions (except access receipt) of personal data permitted for distribution do not apply in cases where personal data is processed in the interests of the state, public interests, and other public interests as defined by Russian legislation.
8.7 The Operator ensures the confidentiality of personal data when processing it.
8.8 The Operator stores personal data in a form that permits identification of the data subject for no longer than required to achieve the purposes of personal data processing, unless a retention period is established by federal law, contract, or other legal instrument to which the data subject is a party, beneficiary, or guarantor.
8.9 Processing of personal data may be terminated upon achievement of the purposes of processing, expiration of the data subject's consent, withdrawal of consent by the data subject, or a request to cease processing, or upon detection of unlawful processing of personal data.

9. List of Actions Performed by the Operator with Received Personal Data
9.1 The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, modifies), extracts, uses, transfers (distributes, discloses, provides access), de-identifies, blocks, deletes, and destroys personal data.
9.2 The Operator performs automated processing of personal data with or without the receipt and/or transfer of obtained information via information and telecommunications networks.

10. Cross-Border Transfer of Personal Data
10.1 Prior to commencing activities involving cross-border transfer of personal data, the Operator is obligated to notify the authorized body for personal data protection of its intention to carry out cross-border transfer of personal data (such notification shall be sent separately from notification of the intention to process personal data).
10.2 Prior to submitting the above notification, the Operator is obligated to obtain appropriate information from the authorities of a foreign state, foreign individuals, and foreign legal entities to which cross-border transfer of personal data is planned.

11. Confidentiality of Personal Data
The Operator and any other persons who have obtained access to personal data are obligated not to disclose or distribute personal data to third parties without the consent of the data subject, unless otherwise provided by federal law.

12. Final Provisions
12.1 A User may obtain clarifications on any questions concerning the processing of their personal data by contacting the Operator via email at info@inomedia.ru.
12.2 Any changes to this personal data processing policy will be reflected in this document. The Policy shall remain in effect indefinitely until replaced by a new version.
12.3 The current version of the Policy is freely available on the Internet at https://ino.media.