Personal data processing policy

1. General Provisions
   This personal data processing policy has been compiled in accordance with the requirements of Federal Law No. 152-FZ of July 27, 2006, “On Personal Data” (hereinafter referred to as the Personal Data Law) and defines the personal data processing procedure and the measures taken by Microimpuls LLC (hereinafter referred to as the Operator) to ensure the security of personal data.

1.1. The Operator’s primary goal and condition for carrying out its activities is to respect the rights and freedoms of individuals and citizens when processing their personal data, including the protection of their rights to privacy, personal and family secrets.

1.2. This Operator policy regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information the Operator may receive about visitors to the website https://microimpuls.com/.

2. Key Concepts Used in the Policy
   2.1. Automated processing of personal data means the processing of personal data using computer technology.

2.2. Blocking of personal data means temporarily suspending the processing of personal data (except in cases where processing is necessary to clarify the personal data).

2.3. Website means a collection of graphic and informational materials, as well as computer programs and databases, making them available online at the address https://microimpuls.com/.

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

2.5. Anonymization of personal data means actions that make it impossible to determine the attribution of personal data to a specific User or other personal data subject without the use of additional information.

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

2.7. Operator — a government agency, municipal body, legal entity, or individual that, independently or jointly with others, organizes and/or carries out the processing of personal data, and determines the purposes of personal data processing, the composition of personal data to be processed, and the actions (operations) performed with personal data.

2.8. Personal data — any information relating directly or indirectly to an identified or identifiable User of the website https://microimpuls.com/.

2.9. Personal data permitted for distribution by the data subject are personal data to which the general public has been granted access by the data subject by consenting to the processing of the personal data, which the data subject has permitted for distribution in accordance with the procedure established by the Law on Personal Data (hereinafter referred to as personal data permitted for distribution).

2.10. User — any visitor to the website https://microimpuls.com/.

2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific group of persons.

2.12. Dissemination of personal data — any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or making the general public familiar with personal data, including disclosing personal data in the media, posting it on information and telecommunications networks, or providing access to personal data by any other means.

2.13. Cross-border transfer of personal data — the transfer of personal data to a foreign government, foreign individual, or foreign legal entity.

2.14. 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 media containing the personal data.

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

— receive reliable information and/or documents containing personal data from the personal data subject;

— if the personal data subject revokes consent to the processing of personal data, or requests termination of the processing of personal data, the Operator has the right to continue processing the personal data without the consent of the personal data subject, provided that the grounds specified in the Personal Data Law exist;

— independently determine the composition and list of measures necessary and sufficient to ensure fulfillment of obligations stipulated by the Personal Data Law and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.

3.2. The Operator is obligated to:

— provide the personal data subject, upon request, with information regarding the processing of their personal data;

— organize the processing of personal data in accordance with the procedure established by the current legislation of the Russian Federation;

— respond to inquiries and requests from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;

— notify the authorized body for the protection of the rights of personal data subjects, upon request of such body, of the necessary information within 10 days of the date of receipt of such request;

— publish or otherwise ensure unrestricted access to this Policy regarding the processing of personal data;

— take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, distribution, and other illegal actions in relation to personal data;

— cease the transfer (distribution, provision, access) of personal data, cease processing, and destroy personal data in the manner and cases stipulated by the Personal Data Law;

— fulfill other obligations stipulated by the Personal Data Law.

4. Basic 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 stipulated by federal laws. 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, except in cases where there are legal grounds for disclosure of such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;

— to request that the Operator clarify their personal data, block it, or destroy it if such personal data is incomplete, outdated, inaccurate, illegally obtained, or not necessary for the stated purpose of processing, and to take measures provided by law to protect their rights;

— to require prior consent when processing personal data for the purpose of promoting goods, works, and services;

— to revoke consent to the processing of personal data, as well as to request the termination of the processing of personal data;

— to appeal to the authorized body for the protection of the rights of personal data subjects or in court against the Operator’s unlawful actions or inaction in the processing of their personal data;

— to exercise other rights provided for by Russian legislation.

4.2. Personal data subjects are obligated to:

— provide the Operator with accurate information about themselves;

— to notify the Operator of any clarifications (updates, changes) to their personal data.

4.3. Persons who provide the Operator with false information about themselves or about another personal data subject without their consent are liable in accordance with Russian legislation.

5. Principles of Personal Data Processing
   5.1. Personal data is processed lawfully and fairly.

5.2. Personal data processing is limited to achieving specific, predetermined, and legitimate purposes. Processing of personal data that is incompatible with the purposes for which it was collected is not permitted.

5.3. Combining databases containing personal data processed for incompatible purposes is not permitted.

5.4. Only personal data that is relevant to the purposes for which it is processed is subject to processing.

5.5. The content and volume of personal data processed correspond to the stated purposes of processing. Excessive processing of personal data in relation to the stated purposes of processing is not permitted.

5.6. When processing personal data, the accuracy, sufficiency, and, where necessary, relevance to the purposes of processing are ensured. The operator takes and/or ensures that necessary measures are taken to delete or rectify incomplete or inaccurate data.

5.7. Personal data is stored in a form that allows identification of the personal data subject, for no longer than required for the purposes of processing the personal data, unless the storage period for personal data is established by federal law or an agreement to which the personal data subject is a party, beneficiary, or guarantor. Processed personal data are destroyed or anonymized upon achievement of the processing purposes or in the event of loss of the need to achieve these purposes, unless otherwise provided by federal law.

6. Purposes of Personal Data Processing

7. Terms of Personal Data Processing
7.1. Personal data is processed with the consent of the personal data subject to the processing of their personal data.

7.2. Personal data processing is necessary to achieve the goals stipulated by an international treaty of the Russian Federation or by law, to exercise the functions, powers, and duties imposed on the operator by Russian Federation law.

7.3. Personal data processing is necessary for the administration of justice, the execution of a judicial act, or the act of another body or official subject to execution in accordance with Russian Federation law on enforcement proceedings.

7.4. The processing of personal data is necessary for the performance of an agreement to which the personal data subject is a party, beneficiary, or guarantor, as well as for the conclusion of an agreement initiated by the personal data subject or an agreement under which the personal data subject will be a beneficiary or guarantor.

7.5. The processing of personal data is necessary to exercise the rights and legitimate interests of the operator or third parties, or to achieve socially significant goals, provided that the rights and freedoms of the personal data subject are not violated.

7.6. The processing of personal data is performed if access to it is granted to the general public by the personal data subject or at their request (hereinafter referred to as publicly available personal data).

7.7. The processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.

8. Procedure for the Collection, Storage, Transfer, and Other Processing of Personal Data
   The security of personal data processed by the Operator is ensured by implementing legal, organizational, and technical measures necessary to fully comply with the requirements of current legislation on personal data protection.

8.1. The Operator ensures the security of personal data and takes all possible measures to prevent unauthorized persons from accessing it.

8.2. The User’s personal data will never, under any circumstances, be transferred to third parties, except in cases related to compliance with current legislation or if the personal data subject has consented to the Operator’s transfer of data to a third party for the fulfillment of obligations under a civil law contract.

8.3. If any inaccuracies in personal data are discovered, the User may update them independently by sending a notification to the Operator’s email address msk@microimpuls.com with the subject “Personal Data Update.”

8.4. The processing period for personal data is determined by the achievement of the purposes for which the personal data was collected, unless another period is provided by the agreement or applicable law.
The User may revoke their consent to the processing of personal data at any time by sending a notification to the Operator via email to msk@microimpuls.com with the subject “Revocation of consent to the processing of personal data.”

8.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by the specified parties (Operators) in accordance with their User Agreement and Privacy Policy. The subject of the personal data and/or the specified documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.

8.6. Prohibitions on the transfer (except for granting access), as well as on the processing or processing conditions (except for obtaining access) of personal data permitted for dissemination, established by the personal data subject, do not apply in cases where personal data is processed in the state, public, or other public interests defined by Russian Federation law.

8.7. The Operator ensures the confidentiality of personal data when processing personal data.

8.8. The Operator stores personal data in a form that allows identification of the personal data subject for no longer than required for the purposes of processing the personal data, unless the storage period for personal data is established by federal law or an agreement to which the personal data subject is a party, beneficiary, or guarantor.

8.9. Termination of personal data processing may be conditional upon the achievement of the personal data processing purposes, expiration of the personal data subject’s consent, revocation of consent by the personal data subject, a request to cease processing the personal data, or the 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, changes), retrieves, uses, transfers (distributes, provides, accesses), depersonalizes, blocks, deletes, and destroys personal data.

9.2. The Operator carries out automated processing of personal data, with or without the receipt and/or transmission of the received information via information and telecommunications networks.

10. Cross-border transfer of personal data
    10.1. Prior to commencing any cross-border transfer of personal data, the Operator is obligated to notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out the cross-border transfer of personal data (such notification is sent separately from the notification of intent to process personal data).

10.2. Prior to submitting the above notification, the Operator is obligated to obtain the relevant information from the authorities of the foreign state, foreign individuals, and foreign legal entities to whom the cross-border transfer of personal data is planned.

11. Confidentiality of Personal Data
    The Operator and other persons with access to personal data are obligated not to disclose or distribute personal data to third parties without the consent of the personal data subject, unless otherwise provided by federal law.
12. Final Provisions
    12.1. The User may obtain any clarification on any questions regarding the processing of their personal data by contacting the Operator by email at msk@microimpuls.com.

12.2. This document will reflect any changes to the Operator’s personal data processing policy. This policy is valid indefinitely until replaced by a new version.

12.3. The current version of the Policy is publicly available online at https://microimpuls.com/policy.