Personal Data Processing Policy

Personal Data Processing Policy of ARTAR CONSTRUCTION LLC: what data are processed, purposes, legal grounds, periods, rights of data subjects and the operator's contacts.

Version of October 21, 2026

This English translation is provided for convenience. In case of any discrepancy, the Russian version shall prevail.

This Personal Data Processing Policy (the "Policy") sets out the procedure for processing and protecting the personal data of users of the Artar Construction website (the "Website").

The operator of personal data is ARTAR CONSTRUCTION Limited Liability Company (OOO «АРТАР КОНСТРАКШН»), OGRN 1231600006978, INN 1655493038 (the "Operator").

The Policy has been developed in accordance with the Constitution of the Russian Federation, Federal Law No. 152-FZ of 27.07.2006 "On Personal Data" and other applicable regulations of the Russian Federation in the field of personal data.

This Policy applies to personal data that the Operator receives when visitors use the Website, send inquiries, requests and résumés, correspond in the chat on the Website, or otherwise interact with the Operator.

1. General provisions

1.1. The Operator considers respect for human and civil rights and freedoms in the processing of personal data to be one of the main conditions of its activities.

1.2. Personal data are processed lawfully, fairly and only to the extent necessary to achieve the purposes defined by this Policy.

1.3. The Operator does not process personal data in a manner incompatible with the purposes of their original collection.

1.4. The content and scope of the personal data processed correspond to the stated purposes of processing. The Operator seeks to avoid processing excessive personal data.

1.5. The Operator takes the necessary legal, organizational and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision, dissemination and other unlawful actions.

1.6. This Policy is freely available on the Website.

2. Key terms

For the purposes of this Policy, the following terms are used:

Personal data means any information relating directly or indirectly to an identified or identifiable individual.

Personal data subject means the individual to whom the relevant personal data relate.

Operator means ARTAR CONSTRUCTION LLC, which, alone or jointly with others, organizes and (or) carries out the processing of personal data and determines the purposes of such processing, the personal data to be processed and the actions performed with them.

Processing of personal data means any action or set of actions performed with personal data, with or without the use of automation tools, including collection, recording, systematization, accumulation, storage, clarification, retrieval, use, transfer, depersonalization, blocking, deletion and destruction.

Automated processing of personal data means processing of personal data using computer equipment.

Provision of personal data means actions aimed at disclosing personal data to a particular person or a particular group of persons.

Dissemination of personal data means actions aimed at disclosing personal data to an indefinite group of persons.

Blocking of personal data means temporary suspension of the processing of personal data, except where processing is necessary to clarify them.

Destruction of personal data means actions that make it impossible to restore the content of personal data.

Depersonalization of personal data means actions that make it impossible, without additional information, to determine whether personal data belong to a particular subject.

Cookies are small pieces of data that may be stored on the user's device when visiting websites.

3. Categories of personal data subjects

The Operator may process personal data of the following categories of individuals:

visitors of the Website;
persons who send the Operator inquiries, questions and requests for works and services, including through the chat on the Website;
representatives of clients, counterparties and potential counterparties of the Operator;
candidates for vacancies who send the Operator résumés and information about themselves;
users registered on the Website;
other individuals who interact with the Operator through the Website or the communication channels indicated on the Website.

4. What personal data may be processed

Depending on how the user interacts with the Website, the Operator may process the following personal data:

4.1. Data provided by the user

Such data may include:

first name;
last name and patronymic, if provided by the user;
email address;
phone number;
organization name and position, if the user provides such information in connection with a business inquiry;
the content of an inquiry, request or chat message, as well as attached files;
information contained in a résumé (for candidates for vacancies);
account data, if the user has registered on the Website;
other information the user voluntarily provides to the Operator.

The user decides how much information to provide when contacting the Operator, unless otherwise expressly required to use a particular function of the Website.

4.2. Technical information

When the Website is visited, the technical means of the Website, servers, information security systems and analytics tools used may automatically process technical information, including:

IP address;
date and time of the visit;
address of the requested page;
address of the page from which the user came to the Website;
browser type and version;
device type;
information about the operating system;
technical identifiers;
cookies;
information about the user's actions on the pages of the Website;
other technical information automatically transmitted by the user's browser or device.

Such information may constitute personal data if it makes it possible to identify a particular individual directly or indirectly.

4.3. Special categories and biometric data

The Operator does not aim to collect and process information about racial or ethnic origin, political views, religious or philosophical beliefs, health, intimate life, or biometric personal data of Website users.

Users are advised not to send such information to the Operator, including in résumés and chat messages, without necessity and an appropriate legal basis.

5. Purposes of personal data processing

5.1. Ensuring the operation and security of the Website

The Operator may process users' technical data in order to:

ensure the correct operation of the Website;
ensure information security;
detect and prevent abuse and unlawful actions;
diagnose technical errors;
protect the Operator's information infrastructure.

5.2. Handling inquiries and requests

Personal data may be processed in order to:

receive and consider questions, inquiries and requests for works and services;
prepare answers, estimates and commercial proposals;
answer in the chat on the Website, including by an automated assistant based on the materials of the Website;
maintain feedback;
resolve disputes or problem situations.

5.3. Concluding and performing contracts

In interactions concerning works, services and other cooperation, data may be processed in order to:

conduct negotiations;
prepare and conclude contracts;
perform contractual obligations;
maintain business communication with clients and counterparties.

5.4. Recruitment

Information received from candidates for vacancies may be processed in order to:

consider the résumé and the candidate for a vacancy;
contact the candidate and conduct an interview;
decide whether to conclude an employment contract.

5.5. Analysis and development of the Website

When the Operator uses web analytics systems, technical information may be processed in order to:

assess Website traffic;
analyze the use of particular pages and materials;
identify technical problems;
improve the structure and usability of the Website.

5.6. Compliance with the law

Personal data may be processed in order to fulfill the obligations imposed on the Operator by the legislation of the Russian Federation, as well as to exercise and protect the rights and legitimate interests of the Operator and third parties in cases provided for by law.

6. Legal grounds for personal data processing

The Operator processes personal data where there is an appropriate legal basis.

Depending on the specific situation, such grounds may be:

the consent of the personal data subject to the processing of their personal data;
the need for processing to conclude a contract at the initiative of the personal data subject or to perform a contract to which the subject is a party or beneficiary;
the need for processing to fulfill the Operator's obligations provided for by the legislation of the Russian Federation;
the need for processing to exercise the rights and legitimate interests of the Operator or third parties, provided that the rights and freedoms of the personal data subject are not violated;
other grounds provided for by the legislation of the Russian Federation.

If personal data are processed on the basis of the user's consent, such consent is executed separately from other documents and information in accordance with the requirements of the legislation of the Russian Federation.

7. Procedure and methods of personal data processing

7.1. Personal data may be processed with or without the use of automation tools, or by a combination of both.

7.2. The Operator may perform the following actions with personal data: collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, provision in cases provided for by law, depersonalization, blocking, deletion and destruction.

7.3. The Operator does not disclose personal data to third parties or disseminate them without an appropriate legal basis, except in cases provided for by the legislation of the Russian Federation.

7.4. Access to personal data is granted only to those employees and other authorized persons who need such access to perform their duties.

7.5. Persons who have been granted access to personal data must keep them confidential, unless otherwise provided for by law.

8. Transfer of personal data to third parties

8.1. To ensure the operation of the Website and the activities of the Operator, third parties may be involved in the processing of personal data in cases provided for by law, including:

providers of hosting and technical infrastructure, including the developer of the platform on which the Website runs;
providers of email, SMS and other communication services;
providers of automated text processing services used for the assistant in the chat on the Website;
providers of web analytics services, if such services are used;
other contractors who need access to the data to carry out the Operator's instructions.

8.2. Third parties are involved where there is a legal basis provided for by law and in compliance with the requirements for confidentiality and protection of personal data.

8.3. The Operator may provide personal data to government authorities and other authorized persons in the cases and manner established by the legislation of the Russian Federation.

8.4. The Operator does not sell users' personal data.

9. Localization and cross-border transfer of personal data

9.1. When collecting personal data of citizens of the Russian Federation, including via the Internet, the Operator ensures compliance with the requirements of the legislation of the Russian Federation for the recording, systematization, accumulation, storage, clarification and retrieval of such data using databases that meet the requirements of the law.

9.2. If cross-border transfer of personal data is necessary, the Operator carries out such transfer only where there are legal grounds and after completing the procedures and requirements provided for by the legislation of the Russian Federation.

9.3. Before a cross-border transfer begins, the Operator takes the measures provided for by law to determine whether such transfer is possible and to ensure the protection of the rights of personal data subjects.

10. Cookies and web analytics

10.1. The Website may use cookies and similar technologies.

10.2. Cookies may be necessary for the correct operation of the Website, security, saving user settings, the operation of the chat, and analysis of traffic and use of the Website.

10.3. The user may restrict or prohibit the storage of cookies in their browser settings. In this case, some functions of the Website may not work correctly.

10.4. If third-party web analytics systems are used on the Website, they may receive technical information in accordance with the settings of such systems, this Policy and the requirements of applicable law.

10.5. Where the use of certain cookies or analytics technologies requires the user's consent, such consent is requested separately in the manner provided on the Website.

11. Periods of processing and storage of personal data

11.1. Personal data are processed no longer than required by the purposes of their processing, unless a different period is provided for by the legislation of the Russian Federation, a contract or another legal basis.

11.2. Data received in connection with a user's inquiry or request are stored for the period necessary to consider the inquiry and for subsequent interaction with the user, and, where there are legal grounds, for the period necessary to protect the rights and legitimate interests of the Operator.

11.3. Data related to contractual relations may be stored for the term of the relevant contract and after its termination for the periods established by the legislation of the Russian Federation.

11.4. Information received from candidates for vacancies is stored for the period necessary to consider the candidate, unless the candidate has consented to longer storage.

11.5. Technical information and web analytics data are stored for the periods necessary for the relevant purposes, taking into account the settings of the information systems and analytics services used.

11.6. When the purposes of processing have been achieved or the need to achieve them has ceased, personal data are destroyed or depersonalized, unless otherwise provided for by law.

11.7. If consent to the processing of personal data is withdrawn, processing carried out solely on the basis of such consent stops, and the data are destroyed, unless the Operator has another legal basis for their further processing.

12. Protection of personal data

12.1. The Operator takes the necessary and sufficient legal, organizational and technical measures to comply with the requirements of the law in the field of personal data.

12.2. Depending on the nature of the information processed and the information systems used, such measures may include:

appointing persons responsible for organizing the processing of personal data;
adopting internal documents on the processing and protection of personal data;
restricting access to personal data;
using identification and authentication tools;
controlling access to information systems;
backing up necessary information;
using protection against malicious software;
taking measures to detect and prevent unauthorized access;
assessing the effectiveness of the protection measures taken;
recording and investigating incidents involving personal data;
other measures provided for by law and necessary given the nature of the processing.

13. Rights of the personal data subject

In cases provided for by law, the personal data subject has the right to:

receive information about the processing of their personal data;
demand that their personal data be clarified if they are incomplete, outdated or inaccurate;
demand blocking or destruction of personal data where there are grounds provided for by law;
withdraw previously given consent to the processing of personal data;
object to processing in cases provided for by law;
demand that unlawful processing be stopped;
protect their rights and legitimate interests by means provided for by law;
appeal against actions or inaction of the Operator to the authorized body for the protection of the rights of personal data subjects or in court;
exercise other rights granted by the legislation of the Russian Federation.

14. How to contact the Operator

14.1. On matters of personal data processing, exercising the rights of the personal data subject, clarification, blocking or destruction of data, and withdrawal of consent, the user may contact the Operator:

Email: artar.c@bk.ru
Postal address: office 548, 1A Nikolaya Ershova St., Kazan, Republic of Tatarstan, 420061

14.2. The request must contain information that allows the Operator to identify the applicant and determine which personal data the request concerns.

14.3. If necessary, the Operator may request additional information required to confirm the applicant's identity and to prevent unauthorized access to another person's personal data.

14.4. Requests are considered in the manner and within the periods provided for by the legislation of the Russian Federation.

15. Withdrawal of consent to the processing of personal data

15.1. If processing is carried out on the basis of the user's consent, the user may withdraw such consent.

15.2. To withdraw consent, the user may send a request to the email address artar.c@bk.ru or to the Operator's postal address.

15.3. Upon receiving the withdrawal, the Operator stops processing personal data carried out solely on the basis of the withdrawn consent, unless there are other legal grounds for continuing the processing.

16. Personal data of minors

16.1. The Website is not specifically intended for collecting personal data of minors.

16.2. The Operator does not aim to purposefully collect personal data of minors through the Website.

16.3. If the Operator becomes aware that personal data of a minor have been provided without the necessary legal basis, the Operator takes the measures provided for by law in respect of such data.

17. Advertising and informational messages

17.1. The mere fact that a user sends an inquiry or request or provides contact details does not mean automatic consent to receive advertising messages.

17.2. If the Operator sends advertising or marketing messages in cases where the law requires the prior consent of the recipient, such messages are sent only if the relevant consent has been given.

17.3. The user may opt out of such messages in the manner indicated in them or by contacting the Operator.

18. Changes to the Policy

18.1. The Operator may periodically amend this Policy, including in connection with changes in legislation, the information systems used, the functionality of the Website or the procedure for processing personal data.

18.2. The current version of the Policy is published on the Website and takes effect upon publication, unless otherwise specified in the version itself.

18.3. Users are advised to periodically review the current version of this Policy.

19. Operator details

ARTAR CONSTRUCTION Limited Liability Company

INN: 1655493038
KPP: 165501001
OGRN: 1231600006978

Legal and actual address:
office 548, 1A Nikolaya Ershova St., Kazan, Republic of Tatarstan, 420061

Director:
Irada Mamedovna Alieva

Phone:
+7 900 055-53-33

Email:
artar.c@bk.ru