Personal Data Processing Policy

1. General Provisions
This Personal Data Processing Policy has been drafted in accordance with the requirements of the Federal Law of July 27, 2006, No. 152-FZ "On Personal Data" (hereinafter referred to as the "Personal Data Law") and defines the procedure for processing personal data and measures to ensure the security of personal data taken by Ipoteka.ae mortgage consultant LLC (hereinafter referred to as the "Operator").
1.1. The Operator's primary goal and condition for carrying out its activities is the observance of human and civil rights and freedoms during the processing of personal data, including the protection of the rights to privacy, personal, and family secrets.
1.2. This Policy regarding the processing of personal data (hereinafter referred to as the "Policy") applies to all information that the Operator may obtain about visitors to the website https://ipoteka.ae.

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 personal data processing (unless the processing is necessary to clarify personal data).
2.3. Website — a collection of graphic and information materials, as well as computer programs and databases, ensuring their availability on the Internet at the network address https://ipoteka.ae.
2.4. Personal data information system — a set of personal data contained in databases and the information technologies and technical means that ensure their processing.
2.5. Depersonalization of personal data — actions as a result of which it becomes impossible to determine, without the use of additional information, the ownership of personal data by a specific User or other subject of personal data.
2.6. Processing of personal data — any action (operation) or set of actions (operations) performed with or without the use of automation tools, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (dissemination, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
2.7. Operator — a state body, municipal body, legal entity, or individual, independently or jointly with others, organizing and/or performing the processing of personal data, as well as determining the purposes of processing, the scope of personal data to be processed, and the actions (operations) performed with personal data.
2.8. Personal data — any information relating directly or indirectly to a specific or identifiable User of the website https://ipoteka.ae.
2.9. Personal data authorized by the subject for dissemination — personal data to which an unlimited number of persons are granted access by the subject of personal data by giving consent to the processing of personal data authorized by the subject for dissemination in the manner prescribed by the Personal Data Law.
2.10. User — any visitor to the website https://ipoteka.ae.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific 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, placement 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 restoring the content of personal data in the information system and/or the destruction of physical carriers of personal data.

3. Basic Rights and Obligations of the Operator
3.1. The Operator has the right to:

• Receive accurate information and/or documents containing personal data from the subject;
• Continue processing personal data without the consent of the subject if the subject withdraws consent or requests the termination of processing, provided there are grounds specified in the Personal Data Law;
• Independently determine the scope and list of measures necessary and sufficient to ensure the fulfillment of obligations provided by the Personal Data Law and related regulations.

3.2. The Operator is obliged to:

• Provide the personal data subject, upon their request, with information regarding the processing of their personal data;
• Organize the processing of personal data in accordance with the current legislation;
• Respond to inquiries and requests from personal data subjects and their legal representatives;
• Provide the authorized body for the protection of personal data with necessary information within 10 days of the request;
• Publish or otherwise provide unrestricted access to this Policy;
• Take legal, organizational, and technical measures to protect personal data;
• Stop the transfer, terminate processing, and destroy personal data in cases provided 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 concerning the processing of their personal data, except as provided by federal laws;
• Demand the clarification, blocking, or destruction of their personal data if it is incomplete, outdated, inaccurate, or illegally obtained;
• Set a condition of prior consent when processing data for marketing purposes;
• Withdraw consent to the processing of personal data;
• Appeal against unlawful actions or omissions of the Operator.

4.2. Personal data subjects are obliged to:

• Provide the Operator with accurate data about themselves;
• Inform the Operator about any updates or changes to their personal data.

4.3. Persons who provide the Operator with false information about themselves or information about another subject without their consent shall be liable in accordance with the legislation of the Russian Federation.

5. Principles of Personal Data Processing
5.1. Processing is carried out on a lawful and fair basis.
5.2. Processing is limited to the achievement of specific, predetermined, and legitimate goals.
5.3. Merging databases containing personal data processed for incompatible purposes is not permitted.
5.4. Only personal data that meets the purposes of its processing is subject to processing.
5.5. The content and volume of processed data must correspond to the stated purposes; redundancy is not permitted.
5.6. Accuracy, sufficiency, and relevance of data are ensured; the Operator takes measures to delete or clarify incomplete or inaccurate data.
5.7. Storage is carried out in a form that allows identifying the subject for no longer than required by the purposes of processing, unless the storage period is established by law or contract.

6. Purposes of Personal Data Processing



7. Conditions for Personal Data Processing
7.1. Processing is carried out with the consent of the subject to the processing of their personal data.
7.2. Processing is necessary to achieve goals provided by an international treaty or law for the implementation of functions and duties assigned to the Operator.
7.3. Processing is necessary for the administration of justice or the execution of a judicial act.
7.4. Processing is necessary for the execution of a contract where the subject is a party, beneficiary, or guarantor.
7.5. Processing is necessary to exercise the rights and legitimate interests of the Operator or third parties, provided rights and freedoms are not violated.
7.6. Processing is performed on data to which the subject has granted access to the general public.
7.7. Processing is performed on data subject to mandatory disclosure in accordance with federal law.

8. Procedure for Collection, Storage, Transfer, and Other Processing
8.1. The Operator ensures the safety of data and takes all possible measures to exclude access by unauthorized persons.
8.2. Personal data will never, under any circumstances, be transferred to third parties, except for cases related to the implementation of current legislation or if consent has been given.
8.3. In case of inaccuracies, the User may update them by sending a notification to info@ipoteka.ae with the subject "Personal Data Update."
8.4. The processing period is determined by the achievement of goals; the User may withdraw consent at any time by emailing info@ipoteka.ae with the subject "Withdrawal of consent to personal data processing."
8.5. Information collected by third-party services is stored and processed by those entities according to their own Privacy Policies.
8.6. Restrictions set by the subject on dissemination do not apply in cases of processing in the state or public interest.
8.7. The Operator ensures the confidentiality of personal data during its processing.
8.8. The Operator stores personal data in a form allowing identification for no longer than required by the processing purposes.
8.9. Processing may be terminated upon achieving the goals, expiration of consent, withdrawal of consent, or detection of unlawful processing.

9. List of Actions Performed by the Operator
9.1. The Operator performs: collection, recording, systematization, accumulation, storage, clarification, extraction, use, transfer, depersonalization, blocking, deletion, and destruction.
9.2. The Operator performs automated processing of personal data with or without the transfer of received information via telecommunication networks.

10. Cross-border Transfer of Personal Data
10.1. Before beginning cross-border transfer, the Operator must notify the authorized body for the protection of personal data subjects' rights.
10.2. Before submitting the notification, the Operator must obtain relevant information from the foreign authorities or foreign entities involved.

11. Confidentiality of Personal Data
The Operator and other persons who have gained access to personal data are obliged not to disclose it to third parties or distribute it without the consent of the subject, unless otherwise provided by law.

12. Final Provisions
12.1. The User can obtain clarifications on any issues regarding their personal data by contacting the Operator via email at info@ipoteka.ae.
12.2. Any changes to the policy will be reflected in this document; the Policy is valid indefinitely until replaced by a new version.
12.3. The current version of the Policy is freely available at https://ipoteka.ae/privacy-policy