CONFIDENTIALITY AND PERSONAL DATA PROTECTION POLICY

CONFIDENTIALITY AND PERSONAL DATA PROTECTION POLICY
This Confidentiality and Personal Data Protection Policy (hereinafter referred to as the “Confidentiality Policy”) has been developed by NEOTERIC ARCHITECTURE&DESIGN (INN: 7704488549, KPP: 770401001, OGRN: 1197746276782, located at: 1-iy Smolensky pereulok, 21, Moscow, 121099, Russian Federation , here and after referred to as the “Company”).

The Confidentiality Policy shall establish the procedure for obtaining, collecting, accumulating, storing, processing, using, ensuring the protection of, and disclosing personal data through the Company’s website https://neoteric.ru/ (here and after referred to as the “Website”) and shall apply to all information that the Company may receive about you as a user (hereinafter referred to as the “User”) during the use of the Website.

Please carefully review the Confidentiality Policy and its provisions if you wish to use the features and technical capabilities of the Website.

By using the Website, the User shall confirm their explicit and unconditional agreement with this Confidentiality Policy and the terms of processing the User’s personal data. In case of disagreement with the terms of the Confidentiality Policy, the User shall immediately cease using the Website.

3.1. This Confidentiality Policy imposes an obligation upon the Website Administration and Authorized Persons to maintain confidentiality and ensure the protection of Users’ personal data.
3.2. The Confidentiality Policy establishes the purpose(s) and legal grounds for processing personal data, the categories of personal data subjects, the composition of personal data, the procedures for processing personal data and cookies (for which the User of the Website has provided consent), as well as the procedure for distributing communications to Users.
3.3. The personal data permitted for processing under this Confidentiality Policy shall be provided by the User through the following means:

registration forms – by completing forms provided by the User to receive feedback and subscribe to newsletters;
email – by receiving/sending electronic messages in interactions with the Administration or Authorized Persons;
other sources – including, but not limited to, social networks (e.g., Telegram, Whatsup), marketing research, and publicly accessible sources, through which the Website Administration or Authorized Persons may gain access to personal data.

3.4. The Administration shall collect only those personal data that the User knowingly and voluntarily provides for the purpose of utilizing the resources and functionalities of the Website and/or for communication with the Administration or Authorized Persons.
3.5. When the User utilizes any of the sources specified in this Policy, the processing of their personal data shall include, but may not be limited to, the following:

the User’s last name and first name;
the User’s contact phone number;
the User’s email address;
other confidential information about the User or User’s contacts, additionally provided by the User (including, but not limited to, information related to education, place of work, professional experience, place of residence, marital status, etc.).

3.6. The Website Administration shall refrain from collecting data whose collection is restricted and/or prohibited under the Law of Russian Federation On the Protection of Personal Data, and shall not process personal data that pose a special risk to the rights and freedoms of data subjects.
3.7. The Website Administration shall not verify the accuracy of personal data provided by the User.
3.8. In addition to the data specified in Section 3.5 of this Confidentiality Policy, the Website Administration reserves the right to automatically collect cookies.
3.9. Any other personal or confidential information not specified above shall be securely stored and not disclosed, except in cases provided for in Sections 7.5 – 7.6 of this Confidentiality Policy.

4.1. The Website Administration uses web analytics services (Google Console, Google Analytics, Hotjar) and advertising services for the Website (Google Ads). The Administration also collects its own session Cookies exclusively for tracking Website visit statistics and optimizing and tailoring the Website to align with each User’s interests.
4.2. The web analytics and advertising services employed by the Website use Cookies, which are stored on the User’s electronic device to facilitate the analysis of Website usage and record information about the User’s online behavior. Cookies do not harm the User’s electronic device and do not contain viruses.
4.3. Cookies may collect the following information:

IP addresses of the User’s electronic device (computer, phone, tablet, etc.)
information on Cookies data stored in the User’s browser;
information about the User’s electronic devices (computers, phones, tablets, etc.);
information about the User’s browser, including name, version, etc.;
access time and duration of visits to the Website;
URLs of the Website pages viewed by the User;
URLs of previous pages from which the User accessed the Website;
language settings of the User’s browser.

4.4. This Confidentiality Policy provides for the processing of "session" and "persistent" Cookies:

“Session” Cookies are temporary and are stored only until the end of the browser session;
“Persistent” Cookies remain on the User’s electronic device or storage media until the User deletes them;

4.5. Information about the User’s use of the Website, generated by Cookies from web analytics and advertising services, is transmitted to and stored on the servers of the specified services. These services shall use this information to evaluate the User’s engagement with the Website, compile reports on Website activity, and provide other services to the Website Administration related to Website operations and Internet usage. The IP address transmitted from the User’s browser in connection with these services shall not be combined with any other data held by such services.
4.6. The Website Administration may process:

essential Cookies, which are necessary to make the Website functional by enabling core functions such as page navigation and access to secure areas of the Website. The Website cannot operate properly without these Cookies;
statistical Cookies, which assist the Website Administration in understanding how visitors interact with the Website by collecting and anonymously reporting data;
marketing Cookies, which are used to track Website Users. The purpose of these Cookies is to display advertisements that are relevant and engaging to individual Users, thereby increasing their value to advertisers.

4.7. The User reserves the right to refuse the use of Cookies by adjusting the appropriate settings in their browser software or by sending a request via email to the Website Administration. In the event that the User refuses to allow the processing of Cookies, certain functions of the Website may not be fully accessible to the User.

10.1. The data subject shall have the following rights:

to be informed of the sources of collection, the location of their personal data, the purpose of its processing, and the location or place of residence (stay) of the controller or processor of personal data, or to issue an appropriate authorization for obtaining such information to authorized representatives, except in cases provided by law;
to receive information about the conditions of access to personal data, including information about third parties to whom their personal data is transferred;
to access their personal data;
to receive a response within 30 (thirty) calendar days from the date of the request, except as otherwise provided by law, indicating whether their personal data is being processed and, if so to obtain the content of such personal data;
to submit a reasoned request to the personal data controller objecting to the processing of their personal data;
to submit a reasoned request for the alteration or destruction of their personal data by any controller or processor of personal data if such data is processed unlawfully or is inaccurate;
to protect their personal data from unlawful processing and accidental loss, destruction, damage, or concealment, delay, or non-provision, or provision in a delayed manner, as well as to protect against information that is inaccurate or that may harm the honor, dignity, or business reputation of an individual;
to file complaints regarding the processing of their personal data with the Russian Federation`s Parliament Commissioner for Human Rights or through judicial proceedings;
to apply legal remedies in cases of violations of personal data protection legislation;
to include reservations regarding restrictions on the right to process their personal data at the time of granting consent;
to withdraw consent for the processing of personal data;
to be informed of the mechanisms for automated processing of personal data;
to be protected from automated decision-making that has legal consequences for them.

10.2. To exercise their rights, the User shall submit a scanned copy of a reasoned written request to the Website Administration’s email address from the email address specified by the User in the feedback form or when subscribing to the mailing list.
10.3. Users may appeal against actions or inactions of the Website Administration:

under the legislation of Russian Federation – to the Russian Federation`s Parliament Commissioner for Human Rights or through judicial proceedings;
under the legislation of European Union member states – to the authorized data protection authority of the country of which the data subject is a citizen.

10.4. The data subject is obligated to:
10.4.1. Comply with the provisions of this Confidentiality Policy.
10.4.2. Notify the Website Administration in accordance with this Confidentiality Policy in the event of any changes to the personal data for which they have provided processing consent.