Personal Data Processing Policy
1. General Provisions
This Personal Data Processing Policy (hereinafter referred to as the “Policy”) has been drafted in accordance with Federal Law No. 152-FZ dated July 27, 2006 “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 LLC “TLS” (hereinafter referred to as the “Operator”).
1.1. The Operator considers compliance with the rights and freedoms of individuals and citizens when processing their personal data—particularly the right to privacy, personal and family confidentiality—as its most important goal and condition for carrying out its activities.
1.2. This Policy applies to all information that the Operator may obtain about visitors to the website https://amberparket.com
2. Key Terms
[Translation continues with numbered items as per original. The translated terms will mirror the Russian content directly.]
2.1. Automated processing of personal data – processing using computer technology.
2.2. Blocking of personal data – temporary suspension of processing (except in cases where processing is necessary for data clarification).
2.3. Website – a set of graphic and informational materials and computer programs and databases available at https://amberparket.com
2.4. Information system of personal data – a set of personal data stored in databases and processed using IT and technical means.
2.5. Depersonalization of personal data – actions rendering it impossible to identify a subject without additional information.
2.6. Processing of personal data – any action performed on personal data with or without automation, including collection, recording, systematization, accumulation, storage, update, retrieval, use, transfer, depersonalization, blocking, deletion, and destruction.
2.7. Operator – a government body, legal or physical person that processes personal data and determines the purposes and means of processing.
2.8. Personal data – any information related directly or indirectly to a specific or identifiable user of the website.
2.9. Personal data permitted for dissemination – data to which the subject has given access to an unlimited number of persons by consent under the Personal Data Law.
2.10. User – any visitor to https://amberparket.com.
2.11. Provision of personal data – actions aimed at disclosing personal data to a specific person or group.
2.12. Dissemination of personal data – actions aimed at disclosing data to an indefinite number of persons or providing access to such data.
2.13. Cross-border transfer of personal data – transfer to a foreign state, foreign person, or organization.
2.14. Destruction of personal data – actions leading to irretrievable destruction of data or the physical media containing it.
3. Operator's Rights and Obligations
3.1. The Operator may:

• Receive accurate data and/or documents from the subject.
• Continue processing personal data without consent under lawful grounds.
• Define necessary and sufficient measures for legal compliance unless otherwise provided by law.
• 3.2. The Operator must:
• Provide the subject with information upon request.
• Organize processing per Russian law.
• Respond to inquiries from data subjects and authorized bodies.
• Provide necessary data to authorities within 10 days of request.
• Ensure open access to this Policy.
• Take legal, organizational, and technical measures for data protection.
• Cease data transfer/processing and destroy data as required.
• Fulfill other obligations under the Personal Data Law.

4. Rights and Obligations of Personal Data Subjects
4.1. Subjects have the right to:

• Receive processing information unless restricted by federal law.
• Demand correction, blocking, or destruction of incomplete or unlawfully obtained data.
• Consent to marketing-related processing.
• Withdraw consent at any time.
• File complaints with authorities or court.
• Exercise other rights under Russian law.
• 4.2. Subjects must:
• Provide accurate personal data.
• Inform the Operator of data updates.
• 4.3. Persons providing false data or data of others without consent bear responsibility under Russian law.

5. Principles of Data Processing
5.1. Processing must be lawful and fair.
5.2. Processing must serve specific, legitimate purposes.
5.3. Incompatible data purposes must not be combined.
5.4. Only relevant data should be processed.
5.5. The amount and content must correspond to the stated purpose.
5.6. Data accuracy and relevance must be maintained.
5.7. Data must not be stored longer than necessary unless otherwise required by law or contract.
6. Purpose of Data Processing
Purpose:

• Informing users via email, SMS, messengers, phone calls.
• Entering, executing, or terminating civil law contracts.
• Granting access to website services and content.
• Personal data:
• Full name
• Email
• Phone number
• Date/place of birth
• Identity document details
• Taxpayer ID and registration data
• Residential and registration address
• Income details
• Legal grounds:
• Charter documents
• Contracts with data subjects
• Federal Law No. 152-FZ
• Types of processing:
• Collection, storage, destruction, depersonalization
• Email newsletters

7. Conditions for Processing
7.1.–7.7. [As listed in the original: consent, legal obligation, court orders, contract performance, public interest, public availability, legal disclosure.]
8. Collection, Storage, and Transfer

• Security ensured via legal, organizational, and technical measures.
• Data is not transferred to third parties except by law or consent.
• Users may update their data by emailing global@amberparket.com.
• Processing duration is limited to purpose or legal contract terms.
• Consent can be withdrawn via email with the subject “Consent Withdrawal”.
• Data handled by third parties (e.g., payment systems) falls under their privacy policies.
• Public interest allows processing despite certain restrictions.
• Data is stored as long as needed for processing purposes.
• Processing stops when purposes are achieved or consent is withdrawn.

9. Operator’s Actions with Personal Data
9.1. Collection, recording, storage, update, use, transfer, depersonalization, blocking, deletion, destruction.
9.2. Automated processing, including data exchange via networks.
10. Cross-border Transfer
10.1. The Operator must notify the relevant authority before starting cross-border transfers.
10.2. The Operator must obtain relevant assurances from foreign recipients.
11. Confidentiality
The Operator and others with access to data must not disclose or distribute personal data without the subject’s consent unless required by law.
12. Final Provisions
12.1. Users may request clarification by emailing global@amberparket.com
12.2. Any changes to the Policy will be reflected in this document and take effect upon publication.
12.3. The current version is available online at https://amberparket.com/privacy.