Policy on the Processing of Personal Data

1. General Provisions

This personal data processing policy is drawn up in accordance with the requirements of Federal Law No. 152-FZ dated July 27, 2006, "On Personal Data" (hereinafter referred to as the Personal Data Law) and defines the procedure for processing personal data and measures to ensure the security of personal data taken by iconcorp-la (hereinafter referred to as the Operator).

1.1. The Operator considers the observance of human and civil rights and freedoms during the processing of personal data to be its most important goal and condition for carrying out its activities, including the protection of the rights to privacy, personal and family secrets.

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

2. Key Concepts Used in the Policy

2.1. Automated processing of personal data – processing of personal data using computer technology.

2.2. Blocking of personal data – temporary suspension of personal data processing (except in cases where processing is necessary to clarify personal data).

2.3. Website – a set of graphic and informational materials, as well as software and databases, that ensure their availability on the internet at the network address https://eraservice-la.com.

2.4. Information system of personal data – a set of personal data contained in databases and information technologies and technical means that ensure their processing.

2.5. Depersonalization of personal data – actions that make it impossible to determine the affiliation of personal data to a specific User or another subject of personal data without additional information.

2.6. Processing of personal data – any action (operation) or set of actions (operations) performed using automated means or without such means concerning personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.

2.7. Operator – a state or municipal body, a legal or natural person, independently or jointly with others, organizing and/or carrying out the processing of personal data, as well as determining the purposes of personal data processing, the composition of personal data to be processed, actions (operations) performed with personal data.

2.8. Personal data – any information related directly or indirectly to a specific or identifiable User of the website https://eraservice-la.com.

2.9. Personal data allowed by the subject of personal data for dissemination – personal data provided by the subject of personal data for an unlimited number of persons through their consent for processing of personal data allowed by the subject of personal data for dissemination, in the manner prescribed by the Personal Data Law (hereinafter referred to as personal data allowed for dissemination).

2.10. User – any visitor to the website https://eraservice-la.com.

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

2.12. Dissemination of personal data – any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or at making personal data available to an indefinite number of persons, including publication of personal data in the media, placing them in information and telecommunication networks, or providing access to personal data in any other way.

2.13. Cross-border transfer of personal data – transfer of personal data to the territory of a foreign state to the authority of a foreign state, to a foreign individual or foreign legal entity.

2.14. Destruction of personal data – any actions as a result of which personal data are destroyed irreversibly with the inability to further restore the content of personal data in the personal data information system and/or physical media of personal data are destroyed.

3. Main 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 subject of personal data;
- continue processing personal data without the consent of the subject of personal data in cases specified in the Personal Data Law if the subject revokes their consent to personal data processing or submits a request to stop processing personal data;
- independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations provided by the Personal Data Law and adopted regulatory legal acts, unless otherwise provided by the Personal Data Law or other federal laws.

3.2. The Operator is obliged to:
- provide the subject of personal data with information about the processing of their personal data upon request;
- organize the processing of personal data in accordance with the current legislation of the Russian Federation;
- respond to requests and inquiries from subjects of personal data and their legal representatives in accordance with the requirements of the Personal Data Law;
- provide the necessary information to the authorized body for the protection of the rights of subjects of personal data within 10 days of receiving such a 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, dissemination of personal data, as well as other unlawful actions with personal data;
- stop the transfer (dissemination, provision, access) of personal data, stop processing, and destroy personal data in the manner and cases provided for by the Personal Data Law;
- fulfill other obligations provided by the Personal Data Law.

4. Main Rights and Obligations of Subjects of Personal Data

4.1. Subjects of personal data have the right to:
- receive information regarding the processing of their personal data, except in cases provided for by federal laws. Information is provided to the subject of personal data by the Operator in an accessible form and should not contain personal data relating to other subjects of personal data, unless there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
- request the operator to clarify, block, or destroy their personal data if they are incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the declared purpose of processing, as well as take measures to protect their rights as provided by law;
- require prior consent when processing personal data for marketing purposes;
- revoke consent to the processing of personal data and submit a request to stop processing personal data;
- appeal the unlawful actions or inactions of the Operator in the processing of their personal data to an authorized body or in court;
- exercise other rights provided by the legislation of the Russian Federation.

4.2. Subjects of personal data are required to:
- provide the Operator with accurate data about themselves;
- inform the Operator about updating (changing) their personal data.

4.3. Persons who have submitted inaccurate data about themselves or information about another subject of personal data without the latter's consent are responsible in accordance with the legislation of the Russian Federation.

5. Principles of Personal Data Processing

5.1. The processing of personal data is carried out on a lawful and fair basis.

5.2. The processing of personal data is limited to achieving specific, predetermined, and legitimate purposes. It is not allowed to process personal data that is incompatible with the purposes of collecting personal data.

5.3. It is not allowed to combine databases containing personal data whose processing is carried out for purposes incompatible with each other.

5.4. Only personal data that meet the purposes of their processing are subject to processing.

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

5.6. The accuracy, sufficiency, and relevance of personal data are ensured in relation to the purposes of personal data processing. The Operator takes necessary measures and/or ensures that incomplete or inaccurate data is deleted or clarified.

5.7. Personal data is stored in a form that allows identifying the subject of personal data for no longer than is required by the purposes of personal data processing, unless the storage period is established by federal law, a contract, or an agreement where the subject of personal data is a party, beneficiary, or guarantor. Personal data that is processed is destroyed or depersonalized upon achieving the processing goals or if there is no longer a need to achieve these goals unless otherwise provided by federal law.

6. Purposes of Personal Data Processing

- Purpose of processing**: informing the User by sending emails
- Personal data: surname, first name, middle name, email address, phone numbers
- Legal grounds: statutory (founding) documents of the Operator
- Types of personal data processing: collection, recording, systematization, accumulation, storage, destruction, and depersonalization of personal data; sending informational emails to the email address

7. Conditions for Processing Personal Data

7.1. Personal data processing is carried out with the consent of the subject of personal data.

7.2. Personal data processing is necessary for achieving the purposes provided by an international treaty of the Russian Federation or law, for performing the functions, powers, and duties imposed on the Operator by the legislation of the Russian Federation.

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

7.4. Personal data processing is necessary for the performance of a contract to which the subject of personal data is a party, beneficiary, or guarantor, or for the conclusion of a contract initiated by the subject of personal data or under which the subject of personal data will be the beneficiary or guarantor.

7.5. Personal data processing is necessary for the exercise of the legitimate rights and interests of the Operator or third parties, or for the achievement of socially

significant goals, provided that the rights and freedoms of the subject of personal data are not violated.

7.6. Personal data processing is carried out if access to the personal data is provided to an unlimited number of persons by the subject of personal data or at their request (hereinafter referred to as public personal data).

7.7. Personal data processing is carried out if required by federal law for publication or mandatory disclosure.

8. Procedure for Collecting, Storing, Transferring, 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 applicable personal data protection legislation.

8.1. The Operator ensures the confidentiality of personal data and takes all possible measures to prevent unauthorized access to personal data by unauthorized persons.

8.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to compliance with applicable laws or if the subject of personal data has given consent to the Operator to transfer data to a third party to fulfill contractual obligations.

8.3. If inaccuracies in personal data are detected, the User may update them independently by sending a notification to the Operator's email address inbox.iconcorp@gmail.com marked "Updating personal data."

8.4. The processing period for personal data is determined by the achievement of the purposes for which the personal data was collected unless a different period is specified by the contract or applicable law. The User may withdraw their consent to the processing of personal data at any time by sending a notification to the Operator via email at inbox.iconcorp@gmail.com marked "Withdrawal of consent to the processing of personal data."

8.5. All information collected by third-party services, including payment systems, communication providers, and other service providers, is stored and processed by these parties (Operators) in accordance with their User Agreements and Privacy Policies. The subject of personal data and/or those involved must familiarize themselves with these documents. The Operator is not responsible for the actions of third parties, including those mentioned in this clause, regarding the provision of services.

8.6. The restrictions set by the subject of personal data on the transfer (except for providing access), as well as on the processing or conditions of processing (except for access) of personal data allowed for dissemination, do not apply in cases of processing personal data for state, public, and other public interests as defined by the legislation of the Russian Federation.

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

8.8. The Operator stores personal data in a form that allows identifying the subject of personal data for no longer than is necessary for the purposes of processing personal data unless otherwise provided by federal law, a contract to which the subject of personal data is a party, beneficiary, or guarantor.

8.9. The condition for the termination of personal data processing may be the achievement of the purposes for which the personal data was collected, the expiration of the consent period given by the subject of personal data, the withdrawal of consent by the subject of personal data, or a request for the termination of personal data processing, as well as the discovery of unlawful personal data processing.

9. List of Actions Performed by the Operator with Personal Data Received

9.1. The Operator collects, records, systematizes, accumulates, stores, updates (modifies), extracts, uses, transfers (distributes, provides, accesses), depersonalizes, blocks, deletes, and destroys personal data.

9.2. The Operator carries out automated processing of personal data by receiving and/or transmitting the information received over information and telecommunications networks or without such networks.

10. Cross-border Transfer of Personal Data

10.1. Before starting the activity of cross-border transfer of personal data, the Operator must notify the authorized body for the protection of the rights of personal data subjects about its intention to carry out the cross-border transfer of personal data (this notification is sent separately from the notification of the intention to process personal data).

10.2. Before submitting the above-mentioned notification, the Operator must obtain relevant information from the authorities of the foreign state, foreign individuals, or foreign legal entities to whom it plans to transfer personal data.

11. Confidentiality of Personal Data

The Operator and other persons who have access to personal data are obliged not to disclose personal data to third parties and not to disseminate personal data without the consent of the subject of personal data unless otherwise provided by federal law.

12. Final Provisions

12.1. The User may obtain any clarifications on matters of interest related to the processing of their personal data by contacting the Operator via email inbox.iconcorp@gmail.com.

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

12.3. The current version of the Policy is freely available on the internet at https://eraservice-la.com/privacy.