1. General Provisions

1.1. This Privacy Policy (hereinafter the "Policy") has been developed in accordance with the Constitution of the Russian Federation, Federal Law No. 152-FZ of 27 July 2006 "On Personal Data" (hereinafter the "Personal Data Law"), Federal Law No. 149-FZ of 27 July 2006 "On Information, Information Technologies, and Information Protection," and other regulatory legal acts of the Russian Federation in the field of personal data processing and protection.

1.2. The Policy sets out the procedure for processing personal data and the measures taken to ensure the security of personal data by Aeronova LLC (OGRN 1237100000554, INN 7100032055; hereinafter the "Operator") in respect of users of the website https://arnv.pro (hereinafter the "Website").

1.3. The Operator sets as its paramount goal the observance of the rights and freedoms of individuals and citizens when processing their personal data, including the protection of the rights to privacy and to personal and family secrecy.

1.4. This Policy applies to all information that the Operator may obtain about the User during the User's use of the Website, including during registration for webinars and other events held by the Operator.

1.5. The User's use of the Website constitutes the User's unconditional consent to this Policy and to the conditions for the processing of their personal information set out herein. If the User does not agree with the terms of the Policy, the User must cease using the Website.

2. Key Concepts Used in the Policy

The concepts used in this Policy are applied in the meaning defined by the Personal Data Law. For the purposes of this Policy, the following concepts are also used:

• "Personal data" — any information relating, directly or indirectly, to a determined or determinable individual (the personal data subject).
• "Processing of personal data" — any action (operation) or set of actions (operations) performed with or without the use of automation tools on personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
• "Operator" — Aeronova LLC, which, alone or jointly with others, organizes and/or carries out the processing of personal data, and which also determines the purposes of processing personal data, the composition of the personal data to be processed, and the actions (operations) performed with personal data.
• "User" — any visitor to the arnv.pro Website who has registered for a webinar or performed other actions as a result of which personal data was provided to the Operator.
• "Cookies" — a small piece of data sent by a web server and stored on the user's computer, which the web client or web browser sends back to the web server in an HTTP request each time it attempts to open a page of the corresponding website.
• "IP address" — the unique network address of a node in a computer network built on the IP protocol.

3. Composition of the Personal Data Processed

3.1. The Operator may process the following personal data of the User:

• surname, first name, and patronymic;
• email address;
• telephone number;
• information about place of work and position (if provided by the User during registration);
• city (region) of residence (if provided);
• other data voluntarily provided by the User when completing forms on the Website or when communicating with the Operator.

3.2. The Website also collects and processes anonymized data about visitors (including cookies) using internet statistics services (Yandex.Metrica and others).

3.3. The Operator does not process special categories of personal data concerning racial or ethnic origin, political views, religious or philosophical beliefs, state of health, or intimate life, nor biometric personal data, except in cases expressly provided for by the legislation of the Russian Federation.

4. Purposes of Processing Personal Data

4.1. The purposes of processing the User's personal data are:

• registering the User for webinars and other informational and educational events held by the Operator (including events available at https://arnv.pro/webinars);
• sending invitations, reminders, connection links, and other information related to the holding of events;
• providing the User with information about the Operator's activities, products, and services, including through informational and advertising mailings — subject to obtaining the relevant consent;
• maintaining feedback with the User, including sending notifications and responses to requests and inquiries;
• improving the quality of the Website's operation, its usability, and the development of new services;
• conducting statistical and other research based on anonymized data;
• complying with the requirements of the legislation of the Russian Federation.

5. Legal Grounds for Processing Personal Data

5.1. The legal grounds for the Operator's processing of personal data are:

• the Constitution of the Russian Federation;
• the Civil Code of the Russian Federation;
• Federal Law No. 152-FZ of 27 July 2006 "On Personal Data";
• Federal Law No. 149-FZ of 27 July 2006 "On Information, Information Technologies, and Information Protection";
• Federal Law No. 38-FZ of 13 March 2006 "On Advertising" (in respect of the sending of advertising messages);
• the User's consent to the processing of their personal data, expressed through implied actions (completing a form, ticking a checkbox, etc.);
• the Charter of Aeronova LLC;
• contracts (including the offer) concluded between the Operator and the User.

6. Procedure for Collecting, Storing, Transferring, and Otherwise Processing Personal Data

6.1. The security of the personal data processed by the Operator is ensured through the implementation of the legal, organizational, and technical measures necessary to fully comply with the requirements of the applicable legislation on the protection of personal data.

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

6.3. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to compliance with the applicable legislation of the Russian Federation or where the personal data subject has given the Operator consent to transfer the data to a third party for the performance of obligations under a civil law contract.

6.4. The Operator has the right to entrust the processing of the User's personal data to third parties (hereinafter "processors") on the basis of a contract concluded with such persons. In this case, the Operator obliges such persons to maintain confidentiality and to ensure the security of personal data during its processing. The list of the main categories of processors:

• providers of hosting services and server infrastructure;
• email and SMS notification services;
• platforms for holding webinars and videoconferences;
• internet analytics and statistics collection services;
• CRM and marketing automation services.

6.5. Users' personal data is stored on servers located within the territory of the Russian Federation, in accordance with the requirements of Part 5 of Article 18 of the Personal Data Law.

6.6. If inaccuracies are found in the personal data, the User may update them independently by sending the Operator a notice to its email address marked "Updating Personal Data."

6.7. The period for processing personal data is unlimited. The User may withdraw their consent to the processing of personal data at any time by sending the Operator a notice via email to the Operator's email address marked "Withdrawal of Consent to the Processing of Personal Data."

7. Cross-Border Transfer of Personal Data

7.1. Before commencing the cross-border transfer of personal data, the Operator must ensure that the foreign state to whose territory the personal data is to be transferred provides reliable protection of the rights of personal data subjects.

7.2. The cross-border transfer of personal data to the territory of foreign states that do not meet the stated requirements may be carried out only where the personal data subject has given written consent to the cross-border transfer of their personal data and/or for the performance of a contract to which the personal data subject is a party.

8. Rights of the Personal Data Subject

8.1. The User has the right to:

• receive information concerning the processing of their personal data;
• demand the clarification, blocking, or destruction of their personal data where it is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing;
• withdraw consent to the processing of personal data;
• demand the cessation of the processing of personal data in the event of its unlawful processing;
• appeal the acts or omissions of the Operator to the authorized body for the protection of the rights of personal data subjects (Roskomnadzor) or through the courts;
• protect their rights and legitimate interests, including compensation for losses and/or moral damage through the courts.

9. Final Provisions

9.1. The User may obtain any clarification on questions of interest concerning the processing of their personal data by contacting the Operator via email at info@arnv.pro.

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

9.3. The current version of the Policy is freely available on the Internet at: https://arnv.pro/privacy.

Operator's Details

Aeronova Limited Liability Company (Aeronova LLC)

OGRN: 1237100000554

INN: 7100032055

KPP: 774301001