Personal Data Processing Policy

This English translation is provided for convenience. If it differs from the Russian version, the Russian version prevails.

1. General provisions

This Policy applies to all information, including personal data under Russian law (“Personal Data”), that Nezumo LLC (the “Operator”) may receive about any internet user (the “User”) who visits or uses nezumo.ru, app.nezumo.ru, or related services (the “Services”). It is prepared under Federal Law No. 152-FZ of July 27, 2006, “On Personal Data,” and sets out how the Operator processes and protects Personal Data.

The Operator considers respect for human and civil rights, including privacy and personal and family confidentiality, a fundamental condition of Personal Data processing.

2. Key terms

Automated processing means processing with computing equipment. Blocking means a temporary suspension of processing, except when processing is required to correct data. A personal-data information system is a set of databases, technologies, and technical resources used to process Personal Data.

Depersonalization means making it impossible to identify a person without additional information. Processing includes any operation with Personal Data, including collection, recording, organization, accumulation, storage, correction, extraction, use, transfer, depersonalization, blocking, deletion, or destruction.

Personal Data is any information relating directly or indirectly to an identified or identifiable User. Provision means disclosure to a specific person or group; distribution means disclosure to an indefinite group. Cross-border transfer means transfer to a foreign state, authority, individual, or legal entity. Destruction means irreversible deletion from systems and physical media.

3. Data subjects and data categories

The Operator may process data relating to:

1. visitors and Users of the Services;
2. people who contact the Operator with requests, messages, complaints, or suggestions;
3. participants in interviews, surveys, analytics, or marketing research;
4. participants in events organized by the Operator or its partners.

Depending on purpose, the processed data may include a person's name; postal address, telephone number, and email; depersonalized usage data and cookies collected through analytics services; professional information such as employer, role, department, seniority, participation in legal entities, and authority; payment details; and other information required by the relevant form or processing purpose.

4. Processing purposes

1. registering, identifying, and personalizing Users; providing access to registered-only Services; improving usability, products, and service quality;
2. identifying parties to contracts, agreements, and transactions;
3. providing websites and information resources under the Terms of Use and license agreements;
4. sending service notices, replies, newsletters, informational messages, and marketing communications;
5. collecting and analyzing statistics about the Operator's resources, products, goods, work, and services.

Users can unsubscribe from product, offer, and event notices by emailing support@nezumo.ru. Unless a separate agreement prohibits it, the Operator may use a User's employer name, logo, trademarks, and related company information on its website and in marketing and public communications. Depersonalized analytics data is used to understand activity and improve the website and its content.

5. Legal grounds

The Operator processes Personal Data submitted by the User through forms on the Services. By submitting a form or Personal Data, the User consents to this Policy. Depersonalized data is processed when the User's browser permits cookies and JavaScript.

6. Collection, storage, transfer, and other processing

The Operator uses legal, organizational, and technical safeguards required by applicable data-protection law, takes reasonable steps to prevent unauthorized access, and does not transfer Personal Data to third parties except where required by applicable law.

A User may correct inaccurate data in account settings or by emailing support@nezumo.ru. Data is processed only as long as necessary for its purposes or until consent is withdrawn, unless Russian law requires otherwise. Consent may be withdrawn by emailing the Operator.

7. Cross-border transfers

Before a cross-border transfer, the Operator must confirm that the destination country provides reliable protection for data-subject rights. Transfers to countries that do not meet this requirement are allowed only with the data subject's written consent or where necessary to perform a contract to which the data subject is a party.

8. Other provisions

Questions about Personal Data processing may be sent to support@nezumo.ru. The current Policy is a public document available at nezumo.ru and remains effective until replaced.

The Operator may amend the Policy by publishing a new version, effective on its publication date. Users are responsible for checking the current version. Continued use of the Services after changes means acceptance of the updated Policy.