PRIVACY POLICY AND PERSONAL DATA PROCESSING RULES

OF JSC “ATOMIC CAPITAL”


1. GENERAL PROVISIONS
This Privacy Policy (hereinafter referred to as the "Policy") applies to all information that JSC "Atomic Capital" (Primary State Registration Number 1247700514181, hereinafter referred to as the "Company," "Operator") may receive about users of the Company's website in the course of providing services in the field of investment consulting.

2. TERMS AND DEFINITIONS
·         BLOCKING OF PERSONAL DATA – temporary suspension of personal data processing (except when processing is necessary for clarification of personal data).
·         WEBSITE (SITE) – a set of graphic and informational materials, as well as computer programs and databases that ensure their availability on the Internet at the network address XXX.
·         PERSONAL DATA INFORMATION SYSTEM – a set of personal data contained in databases and the information technologies and technical means that ensure their processing.
·         ANONYMIZATION OF PERSONAL DATA – actions as a result of which it becomes impossible to determine the ownership of personal data to a specific personal data subject without the use of additional information.
·         PROCESSING OF PERSONAL DATA – any action or set of actions performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, destruction of personal data.
·         TRANSFER OF PERSONAL DATA (PROVISION OF PERSONAL DATA) – actions aimed at disclosing personal data to a specific person or a defined group of persons.
·         PERSONAL DATA – any information relating directly or indirectly to the User.
·         USER – an individual, visitor of the Company's website, providing their personal data.
·         DISTRIBUTION OF PERSONAL DATA – actions aimed at disclosing personal data to an indefinite group of persons.
·         DESTRUCTION OF PERSONAL DATA – actions as a result of which it becomes impossible to restore the content of personal data in the personal data information system and/or as a result of which the material carriers of personal data are destroyed.

3. CONDITIONS FOR PROCESSING USERS' PERSONAL INFORMATION AND ITS TRANSFER TO THIRD PARTIES
3.1. The Operator processes the User's personal data only if the User independently fills out and/or submits such data through special forms located on the Website. By filling out the relevant forms and/or submitting their personal data to the Operator, the User expresses their informed and conscious consent to the processing of their personal data under the terms provided in this Policy, and also guarantees that:
3.1.1. they have provided complete and accurate information and understand that they bear responsibility for providing false or incomplete information;
3.1.2. they have reached the age of 14 or are a legal representative of a minor and have the right to give such consent in accordance with the legislation of the Russian Federation;
3.1.3. they have carefully and fully read this Policy and the terms of personal data processing contained therein.
3.2. Personal data processing is carried out by the Operator on the territory of the Russian Federation. The Operator does not process special categories or biometric personal data of Users.
3.3. The confidentiality of the User's personal information is maintained, except in cases where the User voluntarily provides information about themselves for public access to an unlimited circle of persons.
3.4. The processing of the User's personal data is carried out without limitation of time by the following methods: collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, destruction of personal data, including in personal data information systems using automation tools or without using such tools. Personal data processing is carried out in accordance with the Federal Law of 27.07.2006 No. 152-FZ "On Personal Data."
3.5. In the event of loss or disclosure of personal data, the Operator informs the User about the loss or disclosure of personal data.
3.6. The Operator takes necessary organizational and technical measures to protect the User's personal information from unauthorized or accidental access, destruction, modification, blocking, copying, distribution, as well as from other unlawful actions of third parties.
3.7. The Operator, together with the User, takes all necessary measures to prevent losses or other negative consequences caused by the loss or disclosure of the User's personal data.

4. CATEGORIES OF PERSONAL DATA PROCESSED
The Company may process the following personal data of website users:
·         Full name (Surname, First name, Patronymic)
·         Phone number
·         Email address

5. PURPOSES OF PERSONAL DATA PROCESSING
Personal data processing is carried out exclusively for the following purposes:
·         Ensuring feedback with users (responding to inquiries, providing consultations)
·         Providing investment consulting services
·         Compliance with the requirements of the legislation of the Russian Federation

6. DISPUTE RESOLUTION
6.1. Before applying to a court with a claim on disputes arising from relations between the User and the Operator, it is mandatory to submit a claim (a written proposal for voluntary dispute resolution).
6.2. The recipient of the claim shall notify the claimant in writing of the results of the claim consideration within 10 (ten) working days from the date of receipt of the claim.
6.3. If an agreement is not reached, the dispute will be referred to the courts at the location of the Operator.
6.4. The current legislation of the Russian Federation applies to this Privacy Policy and the relations between the User and the Operator.

7. ADDITIONAL TERMS
7.1. The Operator has the right to make changes to this Privacy Policy without the User's consent.
7.2. The new Privacy Policy comes into effect from the moment it is posted on the Website, unless otherwise provided by the new version of the Privacy Policy.
7.3. The Operator undertakes to ensure the availability of this Policy on the Website.
7.4. All proposals or questions regarding this Privacy Policy should be sent to the email address posted on the Website.