Privacy Policy (Personal Data Processing Policy)

Last updated: 17 «September» 2025

1. GENERAL PROVISIONS

1.1. This privacy policy (hereinafter referred to as the "Policy") defines the basic principles, goals, conditions and methods of processing personal data of Individual Entrepreneur Svetlana Afanasyevna Demchenko (OGRNIP: 325774600103887, INN: 510201385086, address: 125212, Moscow, Admirala Makarova Street, house 6A, Bldg. 1, P.O. Box 349) (hereinafter referred to as the "Operator"). 1.2. This Policy has been developed in compliance with the requirements of paragraph 2, Part 1, Article 18.1 of the Federal Law of July 27, 2006 No. 152-FZ "On Personal Data" (hereinafter referred to as the "Personal Data Law"), taking into account the requirements of the Personal Data Law and other regulatory legal acts of the Russian Federation in the field of personal data. 1.3. This Policy applies to all operations performed by the Operator with personal data, with or without the use of automation tools. The Operator processes the personal data of the personal data subject only if they are filled in and (or) sent by the personal data subject independently through forms on the website https://dvaugla.ru (hereinafter referred to as the "Site"). By filling in the relevant forms and (or) sending their personal data to the Operator, the personal data subject expresses consent to this Policy. 1.4. The personal data subject independently decides to provide their personal data and gives consent freely, of their own free will and in their own interests. 1.5. This Policy is subject to update at the initiative of the Operator, as well as in the event of changes in the legislation of the Russian Federation on personal data. The current version of the Policy is always located on the Internet at: https://dvaugla.ru/privacy-policy 1.6. This Policy is an integral part of the Terms of Service, as well as other agreements concluded with the visitor and/or user of the Site (hereinafter referred to as the "User") in the process of using the Site, when this is expressly provided for by their terms. 1.7. The Operator does not control and is not responsible for third-party sites to which the User can follow links available on the Site. Third-party sites may have their own privacy policy and may collect or request other personal data from the User.

2. BASIC CONCEPTS

2.1. For the purposes of this Policy, the following terms are used in the following meaning: 2.1.1. Personal data — any information relating directly or indirectly to a specific or identifiable individual (subject of personal data). 2.1.2. Biometric personal data — information that characterizes the physiological and biological characteristics of a person, on the basis of which his or her identity can be established. 2.1.3. Processing of personal data — any action (operation) or set of actions (operations) performed with the use of automation tools or without the use of such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data. 2.1.4. Automated processing of personal data — processing of personal data using computer technology. 2.1.5. Dissemination of personal data — actions aimed at disclosing personal data to an indefinite number of persons. 2.1.6. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific number of persons. 2.1.7. Blocking of personal data — temporary cessation of processing of personal data (except in cases where processing is necessary to clarify personal data). 2.1.8. 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 tangible media of personal data are destroyed. 2.1.9. Depersonalization of personal data — actions as a result of which it becomes impossible to determine the ownership of personal data by a specific subject of personal data without the use of additional information. 2.1.10. Subject of personal data, Subject — an individual who can be directly or indirectly identified using personal data. 2.1.11. Consent to the processing of personal data, Consent — a written or digital document that confirms the voluntary decision of the Subject to transfer personal data to the Operator in the volume, on the terms and for the purposes determined by this Policy and the agreements concluded between the Subject and the Operator.

3. PRINCIPLES AND PURPOSES OF PERSONAL DATA PROCESSING

3.1. The Operator processes personal data taking into account the need to ensure the protection of the rights and freedoms of personal data subjects, including the protection of the right to privacy, personal and family secrets, based on the following principles: 3.1.1. personal data are processed on a lawful basis. 3.1.2. personal data are processed limited to achieving specific, predetermined and legitimate goals. 3.1.3. personal data may not be processed in a manner that is incompatible with the purposes of collecting personal data. 3.1.4. the content and volume of personal data being processed correspond to the stated purposes of processing. No excess of personal data processed in relation to the stated purposes of their processing is allowed. 3.1.5. when processing personal data, the accuracy of personal data, their sufficiency, and, where necessary, relevance in relation to the purposes of processing personal data are ensured. 3.1.6. personal data are stored in a form that allows the personal data subject to be identified, for no longer than required by the purposes of processing personal data, unless the storage period for personal data is established by federal law, an agreement to which the Personal Data Subject is a party, beneficiary or guarantor. 3.1.7. processed personal data are destroyed or depersonalized upon achieving the processing goals or in the event of loss of need to achieve these goals, unless otherwise provided by federal law. 3.2. The Operator processes personal data for the following purposes: 3.2.1. identification of the Subject for the purpose of concluding any agreements with the Operator and their subsequent execution. 3.2.2. conducting by the Operator of promotions, surveys, interviews, tests and research on the Site. 3.2.3. establishing feedback with the Subject, including, but not limited to: sending mailings, notifications in the form of SMS, emails, oral and written requests, processing requests and applications from the Subject. 3.2.4. confirmation of the accuracy and completeness of the personal data provided by the Subject. 3.2.5. statistical and other research and (or) analytical purposes, subject to the depersonalization of the personal data of the Subject. 3.2.6. registration of the User, provision of services to the User and providing the User with the opportunity to make contacts on the topic of the posted advertisements. 3.2.7. implementation of customer support. 3.2.8. quality control of advertisements presented on the Site. 3.2.9. processing of requests received from government agencies. 3.2.10. access to and use of the functionality of the Site Services. 3.2.11. identifying reviews, conducting speech analytics and research to improve the quality of the Site Services. 3.3. By publishing advertisements and/or reviews on the Site, the User thereby declares his/her consent to the posting in the public domain of personal and other information contained in the advertisement and/or reviews. 3.4. The site uses Promo Codes. The Promo Code may contain identification data to protect against abuse.

4. VOLUME AND CATEGORIES OF PROCESSED PERSONAL DATA, CATEGORIES OF PERSONAL DATA SUBJECTS

4.1. The Operator may process personal data of the following Subjects: 4.1.1. counterparties — individuals and representatives of counterparties — legal entities. 4.1.2. Site visitors 4.2. The personal data processed by the Operator include: 4.2.1. last name, first name, patronymic of the Subject of personal data. 4.2.2. address of residence/stay or other address specified by the Subject when concluding agreements with the Operator. 4.2.3. mobile phone number. 4.2.4. email address. 4.2.5. INN. 4.2.6. User ID. 4.2.7. Identity document details (upon verification). 4.2.8. User photograph. 4.2.9. information collected through metric programs. 4.2.10. history of requests and views on the Site and its services. 4.2.11. cookies, information about the user's location, information about the user's actions on the Site, information about the user's equipment, date and time of the session. 4.2.12. IP address. 4.3. The operator ensures that the content and volume of personal data processed correspond to the stated purposes of processing and, if necessary, takes measures to eliminate their redundancy in relation to the stated purposes of processing.

5. PROCEDURE AND CONDITIONS FOR PROCESSING PERSONAL DATA

5.1. The Operator processes personal data in the following ways: 5.1.1. non-automated processing of personal data. 5.1.2. automated processing of personal data with or without the transfer of the received information via information and telecommunications networks, including processing using automated database management systems and other software. 5.1.3. mixed processing of personal data. 5.2. List of actions performed by the Operator with personal data: collection, systematization, accumulation, storage, clarification (updating, modification), use, distribution (including transfer), depersonalization, blocking, destruction on the territory of the Russian Federation in accordance with the current legislation of the Russian Federation. 5.3. The subject of personal data makes a decision on the provision of his personal data and gives Consent freely, of his own free will and in his own interests. 5.4. The Operator does not process biometric personal data. 5.5. The Operator does not carry out cross-border transfer of personal data. 5.6. The Operator does not process special categories of personal data related to race, nationality, political views, religious or philosophical beliefs, or intimate life. 5.7. The condition for terminating the processing of personal data may be the achievement of the purposes of processing personal data, the expiration of the Consent or the withdrawal of Consent by the Subject of personal data, as well as the detection of unlawful processing of personal data. 5.8. The period for processing personal data is unlimited. The Subject may at any time withdraw their Consent to the processing of personal data by sending the Operator a notice via e-mail to the Operator's e-mail address specified in Section 9 of this Policy, with the note "Withdrawal of consent to the processing of personal data". 5.9. The Operator undertakes to stop processing the personal data of the Subject within 5 (five) business days from the date of receipt of the notice in accordance with paragraph 5.8 of this Policy.

6. BASIC RIGHTS AND RESPONSIBILITIES

6.1. The Operator has the right to: 6.1.1. receive reliable information and (or) documents containing personal data from the Subject. 6.1.2. demand that the Subject of personal data promptly clarify the personal data provided. 6.2. The Operator is obliged to: 6.2.1. process personal data in the manner prescribed by the current legislation of the Russian Federation. 6.2.2. consider requests from the Subject of personal data (his legal representative) regarding the processing of personal data and provide reasoned responses. 6.2.3. provide the Subject of personal data (his legal representative) with the opportunity for free and free access to his personal data. 6.2.4. take measures to clarify, destroy the personal data of the subject of personal data in connection with his (his legal representative) appeal with legal and justified demands. 6.2.5. organize the protection of personal data in accordance with the requirements of the legislation of the Russian Federation. 6.3. Subjects of personal data have the right: 6.3.1. to full information about their personal data processed by the Operator. 6.3.2. to access their personal data, including the right to receive a copy of any record containing their personal data, except for cases stipulated by federal law. 6.3.3. to clarify their personal data, block it or destroy it in cases where the personal data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated purpose of processing. 6.3.4. to revoke Consent to the processing of personal data. 6.3.5. to take measures provided by law to protect their rights. 6.3.6. to exercise other rights stipulated by the legislation of the Russian Federation. 6.4. Personal data subjects are obliged to: 6.4.1. provide the Operator with reliable information about themselves. 6.4.2. provide documents containing personal data in the volume necessary for the purpose of processing. 6.4.3. inform the Operator about clarification (update, change) of their personal data. 6.5. Persons who have transferred to the Operator false information about themselves or information about another Personal Data Subject without the consent of the latter shall be liable in accordance with the legislation of the Russian Federation.

7. PROCEDURE FOR RESOLVING DISPUTES

7.1. All disputes and disagreements that may arise between the Operator and the Subjects on issues not resolved in the text of the Policy must be resolved through negotiations. 7.2. The Parties are obliged to comply with the claim procedure for dispute resolution. Before filing a claim in court on disputes arising from the relationship between the Subject and the Operator, a claim (a written proposal for voluntary settlement of the dispute) is submitted. The period for consideration of the claim is 30 (thirty) calendar days from the date of receipt of the claim, unless another pre-trial settlement procedure is established by the current legislation of the Russian Federation. 7.3. If controversial issues are not resolved through negotiations, disputes arising from the Policy are resolved in a court of general jurisdiction at the location of the Operator. The current legislation of the Russian Federation shall apply to this Policy and the relationship between the Subject and the Operator.

8. Brand and Intellectual Property Protection

8.1. The name "DvaUgla"® is officially registered as a trademark protected under the legislation of the Russian Federation (registration decision dated September 17, 2025). The registration of the name confirms our commitment to high standards of quality and security, which is directly related to the protection of your personal data. 8.2. We guarantee that when using our service, you are dealing with the original, official platform, not a counterfeit or fraudulent website. Legal protection of the name enables us to ensure reliable protection of your personal data and prevent fraudulent attempts conducted in the name of our platform. 8.3. Any unauthorized use of the "DvaUgla"® name without written permission is strictly prohibited and will be pursued in accordance with applicable law. If you have discovered a website or service impersonating "DvaUgla"®, please notify us immediately at legal@dvaugla.ru. 8.4. Please note that currently only the brand name is registered with the Russian Patent Office, while its visual design and logo remain unregistered.

9. Final Provisions

9.1. The Operator reserves the right to amend this Policy at any time without prior notice to the User. The effective date of the current version shall be clearly indicated within the Policy. The updated Policy shall come into effect immediately upon its publication on the Site, unless otherwise specified in the new version. The current version of the Policy shall remain permanently accessible to Users on the Site. 9.2. This Policy is drafted in the Russian language and may be provided to the User for reference in English. In the event of any discrepancy between the Russian-language version of the Policy and its version in any other language, the provisions of the Russian-language version shall prevail and govern the interpretation and application of this Policy.

10. OPERATOR'S DETAILS

IP Demchenko Svetlana Afanasyevna Address: Russian Federation, 125212, Moscow, Admirala Makarova Street, house 6A, Bldg. 1, P.O. Box 349 OGRNIP: 325774600103887 INN: 510201385086 E-mail address: legal@dvaugla.ru Phone: +7 (968) 866-88-60