Privacy Policy for Personal Data Processing

1. **General Provisions**

This privacy policy for personal data processing is developed in accordance with the requirements of the Federal Law of 27.07.2006 No. 152-FZ "On Personal Data" (hereinafter referred to as the Personal Data Law) and determines the procedure for processing personal data and measures to ensure the security of personal data undertaken by Nexus Capital LLC (hereinafter referred to as the Operator).
1.1. The Operator sets as its most important goal and condition for its activities the observance of human and civil rights and freedoms when processing their personal data, including the protection of rights to privacy, personal and family secrets.
1.2. This Policy of the Operator regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator can obtain about visitors to the website https://nexuscapital.ru.

2. **Basic 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 termination of processing of personal data (except in cases where processing is necessary to clarify personal data).
2.3. Website - a set of graphic and information materials, as well as computer programs and databases, ensuring their availability on the internet at https://nexuscapital.ru.
2.4. Information system of personal data - a set of personal data contained in databases and information technologies and technical means ensuring their processing.
2.5. Depersonalization of personal data - actions as a result of which it is impossible to determine without additional information the belonging of personal data to a specific User or another subject of personal data.
2.6. Processing of personal data - any action (operation) or a set of actions (operations) performed using automation tools or without using such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
2.7. Operator - a state body, municipal body, legal entity or individual, independently or together with other persons organizing and/or performing the processing of personal data, as well as determining the purposes of processing personal data, 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 determinable User of the website https://nexuscapital.ru.
2.9. Personal data permitted by the subject of personal data for dissemination - personal data, access to an unlimited number of persons to which is provided by the subject of personal data by giving consent to the processing of personal data permitted by the subject of personal data for dissemination in the manner prescribed by the Personal Data Law (hereinafter - personal data permitted for dissemination).
2.10. User - any visitor to the website https://nexuscapital.ru.
2.11. Provision of personal data - actions aimed at disclosing personal data to a certain person or a certain circle of persons.
2.12. Dissemination of personal data - any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or at familiarizing an unlimited circle of persons with personal data, including the publication of personal data in the media, posting in information and telecommunications networks or providing access to personal data in any other way.
2.13. Cross-border transfer of personal data - the transfer of personal data to the territory of a foreign state to an authority of a foreign state, a foreign individual, or a foreign legal entity.
2.14. Destruction of personal data - any actions as a result of which personal data are destroyed irretrievably with the impossibility of further restoration of the content of personal data in the personal data information system and/or material carriers of personal data are destroyed.

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 subject of personal data;
- Continue processing personal data without the consent of the subject of personal data upon revocation of the consent of the subject of personal data to the processing of their personal data, if there are grounds specified in the Personal Data Law;
- Independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations stipulated by the Personal Data Law and the regulations adopted in accordance with it, 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 concerning the processing of their personal data upon request;
- Organize the processing of personal data in the manner established by 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;
- Inform the authorized body for the protection of the rights of subjects of personal data of the necessary information upon request of this body within 10 days from the date of receipt of such a request;
- Publish or otherwise provide unrestricted access to this Policy regarding the processing of personal data;
- Take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, alteration, blocking, copying, provision, dissemination of personal data, as well as from other unlawful actions in relation to personal data;
- Cease the transfer (dissemination, provision, access) of personal data, cease processing, and destroy personal data in the manner and cases provided for by the Personal Data Law;
- Fulfill other obligations provided for 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 provided by federal laws. Information is provided to the subject of personal data by the Operator in an accessible form, and it should not contain personal data relating to other subjects of personal data, except in cases where 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;
- Require the Operator to clarify their personal data, block, or destroy them if personal data are incomplete, outdated, inaccurate, illegally obtained, or not necessary for the stated purpose of processing, as well as take measures provided by law to protect their rights;
- Set a condition of prior consent when processing personal data for the purpose of promoting goods, works, and services on the market;
- Withdraw consent to the processing of personal data, as well as send a demand to cease processing personal data;
- Appeal against unlawful actions or inactions of the Operator in the processing of their personal data to the authorized body for the protection of the rights of subjects of personal data or in court;
- Exercise other rights provided for by the legislation of the Russian Federation.
4.2. Personal data subjects are obliged to:
- Provide the Operator with reliable data about themselves;
- Inform the Operator about the clarification (updating, changing) of their personal data.
4.3. Persons who provided the Operator with false information about themselves or information about another subject of personal data without the consent of the latter bear responsibility 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 lawful purposes. The processing of personal data incompatible with the purposes of collecting personal data is not allowed.
5.3. It is not allowed to combine databases containing personal data, the processing of which 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 stated purposes of processing. The redundancy of processed personal data in relation to the stated purposes of their processing is not allowed.
5.6. During the processing of personal data, the accuracy of personal data, their sufficiency, and, if necessary, their relevance in relation to the purposes of processing personal data are ensured. The Operator takes the necessary measures and/or ensures their adoption for the deletion or clarification of incomplete or inaccurate data.
5.7. The storage of personal data is carried out in a form that allows determining the subject of personal data, no longer than required by the purposes of processing personal data, unless the period for storing personal data is established by federal law, a contract to which the subject of personal data is a party, beneficiary, or guarantor. The processed personal data are destroyed or depersonalized upon achieving the processing purposes or in case of the loss of necessity in achieving these purposes unless otherwise provided by federal law.

6. **Purposes of Personal Data Processing**

7. **Conditions for Personal Data Processing**

7.1. The processing of personal data is carried out with the consent of the subject of personal data to the processing of their personal data.
7.2. The processing of personal data is necessary to achieve the purposes stipulated by an international treaty of the Russian Federation or by law, for the exercise and performance of functions, powers, and duties imposed by the legislation of the Russian Federation on the Operator.
7.3. The processing of personal data is necessary for the administration of justice, the execution of a judicial act, an act of another body or official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. The processing of personal data is necessary for the performance of a contract to which the subject of personal data is a party or beneficiary or guarantor, as well as for the conclusion of a contract at the initiative of the subject of personal data or a contract under which the subject of personal data will be a beneficiary or guarantor.
7.5. The processing of personal data is necessary for the exercise of the rights and legitimate interests of the Operator or third parties or for achieving socially significant purposes, provided that the rights and freedoms of the subject of personal data are not violated.
7.6. The processing of personal data, access to an unlimited number of persons to which is provided by the subject of personal data or at their request (hereinafter - publicly available personal data), is carried out.
7.7. The processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.

8. **Procedure for Collecting, Storing, Transferring, and Other Types of Processing Personal Data**

8.1. The security of personal data processed by the Operator is ensured by the implementation of legal, organizational, and technical measures necessary to fully comply with the requirements of the current legislation in the field of personal data protection.
8.2. The Operator ensures the preservation of personal data and takes all possible measures to exclude access to personal data by unauthorized persons.
8.3. Personal data of the User will never, under any circumstances, be transferred to third parties, except in cases related to the execution of current legislation or if the subject of personal data has given consent to the Operator to transfer data to a third party to fulfill obligations under a civil law contract.
8.4. In case of identifying inaccuracies in personal data, the User can update them independently by sending a notification to the Operator to the Operator's email address marked "Updating personal data."
8.5. The processing time of personal data is determined by the achievement of the purposes for which personal data were collected, unless a different period is provided by a contract or current legislation. The User can withdraw their consent to the processing of personal data at any time by sending a notification to the Operator to the Operator's email address marked "Withdrawal of consent to the processing of personal data."
8.6. All information collected by third-party services, including payment systems, means of communication, and other service providers, is stored and processed by the specified persons (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data and/or the User is obliged to familiarize themselves with these documents in a timely manner. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.
8.7. The prohibitions established by the subject of personal data on the transfer (except for granting access), as well as on the processing or processing conditions (except for obtaining access) of personal data permitted by the subject of personal data for dissemination, do not apply in cases of processing personal data in state, public, and other public interests defined by the legislation of the Russian Federation.
8.8. The Operator ensures the confidentiality of personal data when processing personal data.
8.9. The Operator stores personal data in a form that allows determining the subject of personal data, no longer than required by the purposes of processing personal data, unless the period for storing personal data is established by federal law, a contract to which the subject of personal data is a party, beneficiary, or guarantor.
8.10. A condition for terminating the processing of personal data may be the achievement of the purposes of processing personal data, the expiration of the consent of the subject of personal data, the withdrawal of consent by the subject of personal data, or the requirement to terminate processing personal data, as well as the detection of unlawful processing of personal data.

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

9.1. The Operator performs the collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
9.2. The Operator performs the automated processing of personal data with the receipt and/or transmission of the received information via information and telecommunication networks or without such.

10. **Cross-border Transfer of Personal Data**

10.1. The Operator, before the start of the cross-border transfer of personal data, is obliged to ensure that the foreign state, to whose territory the transfer of personal data is supposed to be carried out, ensures reliable protection of the rights of subjects of personal data.
10.2. Cross-border transfer of personal data on the territory of foreign states that do not meet the above requirements can be carried out only if there is written consent from the subject of personal data to the cross-border transfer of their personal data and/or the execution of a contract to which the subject of personal data is a party.

11. **Confidentiality of Personal Data**

The Operator and other persons who have gained access to personal data are obliged not to disclose 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 can receive any clarifications on issues of interest related to the processing of their personal data by contacting the Operator via email.
12.2. This document will reflect any changes in the personal data processing policy by the Operator. The Policy is valid indefinitely until replaced with a new version.
12.3. The current version of the Policy is freely available on the internet at https://nexuscapital.ru/privacy_policy.
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