Personal data processing policy

1. Yug-BusinessPartner LLC (OGRN: 1092311000418, INN: 2311114861) respects privacy and is committed to protecting the personal information you provide to us. We would like to familiarize you with the following principles that underpin our policy regarding your personal data.
2. In the course of conducting business, Yug-BusinessPartner LLC processes the personal data of individuals—data subjects. In order to maintain its business reputation and ensure full compliance with federal legislation, Yug-BusinessPartner LLC (hereinafter referred to as the Operator) considers it crucial to ensure the legality and fairness of personal data processing, as well as maintaining its confidentiality and the security of its processing processes.
3. Yug-BusinessPartner LLC's personal data processing policy (hereinafter referred to as the Policy) has been developed to define the main purposes, procedures, and conditions for processing personal data by the Operator, as well as measures to ensure the security of personal data.
4. This Policy has been developed in accordance with Federal Law No. 152-FZ of July 27, 2006, "On Personal Data," and Federal Law No. 519-FZ of December 25, 2020, "On Amendments to the Federal Law "On Personal Data."
5. Yug-BusinessPartner LLC processes personal data based on and in accordance with the requirements of the current legislation of the Russian Federation, as specified in Appendix No. 2 to this document.
6. This Policy applies to all information containing personal data of personal data subjects that Yug-Businesspartner LLC and its associated legal entities may obtain about the personal data subject during the course of Yug-Businesspartner LLC's activities.
7. This Policy applies to all transactions performed at Yug-Businesspartner LLC with personal data, with or without the use of automated tools.
8. All employees of the Operator are guided by the provisions of this Policy.
9. The provisions of this Policy serve as the basis for the development of internal administrative documents by Yug-Businesspartner LLC detailing the processing and protection of personal data.
10. This Policy is publicly available and must be published on the official website of Yug-Businesspartner LLC or otherwise provided with unrestricted access to this document.
11. The policy is approved by order of the General Director of Yug-BusinessPartner LLC and is subject to revision when changes are made to the current legislation in the field of processing and protection of personal data.

When processing personal data, Yug-Businesspartner LLC adheres to the principle of sufficiency and appropriateness of personal data processing.

Yug-Businesspartner LLC processes personal data for the following purposes:

• providing services to the Data Subject, the provision of services by the Data Subject based on the concluded agreement, and the fulfillment of obligations thereunder;
• conducting surveys and information;
• conducting HR activities;
• implementing employment and other directly related relationships;
• implementing the activities of Yug-Businesspartner LLC;
• achieving the goals stipulated by law, and for the implementation and fulfillment of the functions, powers, and duties imposed on Yug-Businesspartner LLC by the legislation of the Russian Federation.

Personal data refers to any information directly or indirectly related to an identified or identifiable individual (Personal Data Subject), processed by Yug-BusinessPartner LLC for the achievement of predetermined purposes:

• Subjects whose personal data is processed in connection with the fulfillment of concluded contracts and accepted and established obligations;
• Employees and their close relatives;
• Job applicants;

3.1. Yug-BusinessPartner LLC processes the personal data of the following categories of Personal Data Subjects:

• Subjects whose personal data is processed in connection with the fulfillment of concluded contracts and accepted and established obligations;
• Employees and their close relatives;
• Job applicants;
• Employees of counterparties;
• Clients of Yug-BusinessPartner LLC, their representatives, and beneficiaries;
• Users of Yug-BusinessPartner LLC websites;
• individuals residing at the facilities of Yug-BusinessPartner LLC;

3.2. Yug-BusinessPartner LLC processes the following categories of personal data of personal data subjects:

• publicly available personal data;
• biometric personal data;
• other personal data, including: gender, age, passport details, TIN, state pension insurance number (SNILS), address information and contact details, citizenship, payment details, work permits and residence permits in other countries, military registration information, information on criminal convictions, family composition information, education and profession information, information on advanced training and additional education, information on an academic degree, information on achievements, information automatically received when accessing the websites of Yug-Businesspartner LLC using cookies, which are fragments of text that are automatically saved in the memory of your internet browser using the websites of Yug-Businesspartner LLC; information received as a result of the actions of subjects on the websites of Yug-Businesspartner LLC, including: sending comments, requests, feedback and questions, etc.

As part of its operations, Yug-BusinessPartner LLC collects, records, systematizes, accumulates, stores, clarifies (updates, changes), retrieves, uses, transfers (distributes, provides, accesses), depersonalizes, blocks, deletes, and destroys personal data.

Yug-BusinessPartner LLC processes personal data, including storing it, using servers located in the Russian Federation.

Yug-BusinessPartner LLC does not transfer personal data cross-border.

Yug-BusinessPartner LLC processes personal data based on the consent of the data subject to the processing of their personal data in accordance with the stated processing purposes.

When processing personal data, Yug-BusinessPartner LLC takes the necessary and sufficient legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, distribution, as well as from other illegal actions in relation to personal data, including:

• appointing a person responsible for organizing the processing of personal data;
• adopting internal regulations and other documents in the area of ​​processing and protecting personal data;
• limiting and monitoring the composition of employees with access to personal data;
• familiarizing Yug-BusinessPartner LLC employees directly involved in the processing of personal data with the provisions of Russian Federation legislation on personal data and internal administrative documents on personal data processing;
• obtaining consent from personal data subjects for the processing of their personal data, except in cases stipulated by Russian Federation legislation;
• organizing the accounting of documents containing personal data;
• identifying threats to the security of personal data when processing it in personal data information systems;
• Implementation of organizational and technical measures to ensure the security of personal data when processed in personal data information systems;
• Implementation of internal control over measures taken to ensure the security of personal data;
• Organization of work with information systems in which personal data is processed;
• Other measures stipulated by Russian Federation legislation in the field of personal data.

If inaccuracies in personal data are discovered, Yug-BusinessPartner LLC will take the following measures:

Blocks personal data;

• Clarifies or ensures the clarification of personal data within 7 (seven) days from the date of provision of such information, updates the personal data, and removes the block in personal data information systems;
• If the illegality of personal data processing is confirmed, processing will be terminated within 3 (three) business days from the date of such discovery; If it is impossible to ensure the lawfulness of personal data processing, Yug-BusinessPartner LLC will destroy such personal data or ensure its destruction within 10 (ten) business days from the date of discovery of the unlawful processing of personal data.

In accordance with the law, Yug-BusinessPartner LLC will cease processing personal data in the following cases:

The purposes of personal data processing have been achieved;

• The personal data subject's consent to the processing of their personal data is revoked; or Yug-BusinessPartner LLC's activities are terminated (liquidation or reorganization).
• The storage periods for personal data are limited by the purposes of personal data processing, the revocation of consent to the processing of personal data, and the provisions of Rosarchive Order No. 236 of December 20, 2019, "On Approval of the List of Standard Management Archival Documents Generated in the Course of Activities of State Bodies, Local Governments, and Organizations, Indicating Their Storage Periods."

The personal data subject has the right to:

• receive information about the processing of his personal data;
• receive information concerning the processing of his personal data in the manner, form and terms established by law, except for cases stipulated by the Federal Law "On Personal Data". Information is provided to the personal data subject in an accessible form, and it must not contain personal data related to other personal data subjects, except for cases where there are legal grounds for disclosing such personal data;
• clarify his personal data;
• revoke consent to the processing of personal data;
• appeal to the authorized body for the protection of the rights of personal data subjects or in court against illegal actions or inactions in the processing and protection of his personal data;
• to protect his rights and legitimate interests, including compensation for damages and (or) compensation for moral damage in court;
• to exercise other rights stipulated by the legislation of the Russian Federation.

The right of a personal data subject to access his/her personal data may be limited in accordance with federal laws, including if:

• the processing of personal data, including personal data obtained as a result of operational-search, counterintelligence and intelligence activities, is carried out for the purposes of national defense, state security and law enforcement;
• the processing of personal data is carried out by the bodies that detained the personal data subject on suspicion of committing a crime, or brought charges against the personal data subject in a criminal case, or applied a preventive measure to the personal data subject before charges are brought, with the exception of cases provided for by the criminal procedure legislation of the Russian Federation, if the suspect or accused is allowed to familiarize themselves with such personal data;
• the processing of personal data is carried out in accordance with the legislation on combating the legalization (laundering) of proceeds from crime and the financing of terrorism;
• the personal data subject's access to his/her personal data violates the rights and legitimate interests of third parties;
• the processing of personal data is carried out in cases stipulated by the legislation of the Russian Federation on transport security, in order to ensure the stable and safe functioning of the transport complex, to protect the interests of the individual, society and the state in the sphere of the transport complex from acts of illegal interference.

6.1. Yug-BusinessPartner LLC has the right to:

• process the personal data of the Data Subject in accordance with the stated purpose;
• require the Data Subject to provide accurate personal data necessary for the performance of the contract, provision of the service, identification of the Data Subject, and in other cases stipulated by the Law on Personal Data;
• process publicly available personal data of individuals;
• process personal data subject to publication or mandatory disclosure in accordance with the legislation of the Russian Federation;
• entrust the processing of their personal data to another person with the consent of the Data Subject, unless otherwise provided by federal law, based on an agreement concluded with that person. Any person processing personal data on behalf of the Foundation is obligated to comply with the principles and rules for processing personal data stipulated by the Federal Law "On Personal Data"
• provide personal data of subjects to third parties if required by the current legislation of the Russian Federation (transfer personal data to inquiry and investigative bodies, and other authorized bodies on the grounds stipulated by the current legislation of the Russian Federation);
• use personal data of a subject without their consent, in cases stipulated by the legislation of the Russian Federation;
• refuse to provide personal data in cases stipulated by the legislation of the Russian Federation.
• defend their interests in court;

6.2. Yug-Businesspartner LLC is obligated to:

• organize the processing of personal data in accordance with the requirements of the Federal Law "On Personal Data";
• inform the personal data subject or their representative of the availability of personal data relating to the relevant personal data subject, and provide access to such personal data upon request by the personal data subject or their representative, or within 30 days of receipt of the request from the personal data subject or their representative;
• if the provision of personal data is mandatory in accordance with federal law, the operator is obliged to explain to the personal data subject the legal consequences of refusing to provide their personal data;
• take measures necessary and sufficient to ensure the fulfillment of obligations stipulated by the Federal Law "On Personal Data" and regulatory legal acts adopted in accordance therewith.

• Information regarding the processing of personal data is provided to the personal data subject or their legal representative upon request or appeal to Yug-BusinessPartner LLC.
• The request may be sent electronically to Yug-BusinessPartner LLC's email address: info@mandrogi.ru and signed with an electronic signature in accordance with Russian Federation law.
• The request is registered within three business days of its receipt.
• Information regarding the request or a refusal to provide information is sent to the personal data subject or their representative within thirty calendar days of the request's receipt.

Yug-BusinessPartner LLC provides information regarding the availability of personal data and its processing to the subject in an accessible form. This information does not contain information related to other personal data subjects.

List of Terms and Definitions and Their Use.

1. Personal data – any information relating to a directly or indirectly identified or identifiable individual (personal data subject): your first and last name, postal address or passport number, telephone number, profession, or personal interests.
2. In this Policy, unless the context otherwise requires, the following capitalized terms have the following meanings:

2.1 Personal Data Operator (Operator) – Yug-BusinessPartner LLC, 350000, Krasnodar Krai, Krasnodar, Gimnazicheskaya St., Bldg. 65, Offices 305 and 308, which independently or jointly with other persons organizes and/or carries out the processing of personal data, and determines the purposes of personal data processing, the scope of personal data to be processed, and the actions (operations) performed with personal data.

2.2 Website - mandrogi.ru, as well as the mobile application (regardless of platform).

3. Processing of personal data - any action (operation) or set of actions (operations) with personal data, performed with or without the use of automated tools. Processing of personal data includes, but is not limited to: collection; recording; systematization; accumulation; storage; clarification (updating, modification); retrieval; use; transfer (distribution, provision, access); depersonalization; blocking; deletion; destruction.
4. Automated processing of personal data - the processing of personal data using computer technology.
5. Dissemination of personal data - actions aimed at disclosing personal data to an indefinite number of persons.
6. Provision of personal data - actions aimed at disclosing personal data to a specific person or a specific number of persons.
7. Blocking of personal data - temporary cessation of processing of personal data (except in cases where processing is necessary to clarify personal data).
8. Destruction of personal data – actions that make it impossible to restore the contents of personal data in a personal data information system and/or that result in the destruction of tangible media containing personal data.
9. Anonymization of personal data – actions that make it impossible to determine the attribution of personal data to a specific data subject without the use of additional information.
10. Personal data information system – the totality of personal data contained in databases and the information technologies and technical means that support their processing.
11. Cross-border transfer of personal data – the transfer of personal data to a foreign government agency, a foreign individual, or a foreign legal entity.
12. Cookies – small pieces of data that are received and processed by the device you use to access the Websites. Cookies store and send back to the Websites information that helps you use the Websites and allows us to remember your preferences over time, such as browser settings or to recognize your account. For more information about cookies, their description, the purposes of their use and possible ways to manage them, please follow our Cookie Policy.

The Websites use the following types of cookies:

• Strictly necessary cookies/technical cookies: These cookies are essential for the operation of the Websites and the provision of the Services to you; among other things, they allow us to identify your hardware and software, including your browser type;
• Statistical/analytical cookies: These cookies allow us to recognize users, count their number, and collect information such as your transactions on the Websites and Services, including information about the web pages you visit and the content you access;
• Performance cookies: These cookies collect information about how users interact with the Websites and/or Services, which allows us to identify errors and test new features to improve the performance of the Websites and Services;
• Functional cookies: These cookies allow us to provide certain features to make your use of the Websites easier, for example, by storing your preferences (such as language and location);
• (Third-party) tracking/advertising cookies: These cookies collect information about users, traffic sources, pages visited, and the advertisements displayed to you, as well as the page you clicked on to reach the advertised page. They allow us to display advertisements that may be of interest to you based on the analysis of the Personal Information collected about you. They are also used for statistical and research purposes.

The information contained in cookies is used only for the purposes specified in this Policy. The collected data will then be stored on your device for a period that may depend on the relevant cookie type, but not exceeding the period necessary to achieve its purpose. After this period, it will be automatically deleted from your system.

Personal information collected through cookies placed on your device may be transferred to and accessed by third parties specified in this Policy. Your consent to the use of cookies may be requested upon your first visit to the Websites. If you change your mind after you've accepted the use of cookies, you can do so by deleting the cookies stored in your browser (usually through your browser settings—please refer to your browser manual or the browser developer's website). You may then be prompted again to request your consent, and you can make a different choice. If you refuse cookies, this may prevent you from using certain features of the Websites and affect your ability to use the Websites. You can also change your browser settings to accept or reject all cookies or cookies from specific websites by default.

Legal grounds for processing personal data.

1. The Labor Code of the Russian Federation of 30.12.2001 No. 197-FZ, as amended and supplemented;
2. The Civil Code of the Russian Federation of 30.11.1994 No. 51-FZ, as amended and supplemented;
3. Federal Law of the Russian Federation of 08.02.1998 N 14-FZ (as amended on 31.07.2020, as amended on 24.02.2021) "On Limited Liability Companies" and other current legislative acts of the Russian Federation for entrepreneurial activities aimed at making a profit.

Newsletter Rules

The Website and Services Administration of Yug-BusinessPartner LLC (OGRN: 1092311000418, INN: 2311114861) (hereinafter referred to as the "Contractor") provides the opportunity to use the Contractor's newsletters in accordance with the terms of these Newsletter Rules.

The Website and Services Administration of Yug-BusinessPartner LLC (OGRN: 1092311000418, INN: 2311114861) notifies you as a user of the Contractor's websites—mandrogi.ru and mobile app. By registering for the loyalty program on the Contractor's website and providing your contact information, you expressly consent to the Contractor sending you information and promoting its activities through relevant newsletters by direct contact using all means of communication, including, but not limited to, mail, SMS, voice mail, email, social media, and any type of instant messaging.

If you have subscribed to a newsletter in the relevant section of the Contractor's website by providing your contact information (e.g., email), you have the right to unsubscribe from such newsletters at any time by sending a notice to the Contractor.

If you no longer wish to receive newsletters from the Contractor, you can unsubscribe from such newsletters by sending an email to the following address: info@mandrogi.ru.

This consent is given for the purpose of receiving the Contractor's news, as well as corporate informational and advertising newsletters.

By giving this consent, you confirm that you are acting of your own free will and in your own interests, and undertake to provide accurate information when registering or subscribing through the appropriate forms on the Contractor's website. You are also aware that if you have any questions regarding this opt-out, you can seek assistance by sending an email to the following address: info@mandrogi.ru.

By using the Contractor's Websites and Services and/or entering your personal and contact information, you confirm that you have read the Contractor's Personal Data Protection and Processing Policy.

This consent is valid indefinitely.