Personal Data Processing Policy

Version of 07.10.2026

This is an English translation provided for convenience. The legally binding text is the Russian version.

1. General provisions

This policy sets out how personal data of visitors to aristocratpro.ru (the “Website”) is processed and protected. It has been drawn up in accordance with Federal Law No. 152-FZ of 27.07.2006 “On Personal Data” (the “Law”).

Personal data operator: [full legal name], INN [INN (taxpayer ID)], OGRN [OGRN (registration number)], address: [registered address] (the “Operator”). Contacts for personal data enquiries: studio@aristocrat.com.

The policy is publicly available at https://aristocratpro.ru/privacy/.

2. Whose data is processed and what data

The Operator processes personal data of Website visitors who submit a request through the form on the Website:

• name;
• phone number;
• e-mail address;
• any information the visitor provides in the message.

Together with the request, the IP address, browser details and the address of the page from which the request was sent are stored automatically to protect the Website from spam and abuse.

The Operator does not process special categories of personal data or biometric personal data.

3. Purposes of processing

• reviewing the request and contacting the visitor at their request;
• consulting, estimating costs and preparing a commercial proposal;
• concluding and performing a contract, should the visitor decide to conclude one;
• protecting the Website from spam and abuse.

4. Legal grounds

The data subject’s consent to the processing of their personal data (Article 6(1)(1) of the Law), which the visitor gives separately by ticking the corresponding box in the form (consent text), and the conclusion and performance of a contract to which the data subject is a party (Article 6(1)(5) of the Law).

5. Procedure and conditions of processing

Processing is automated and includes collection, recording, systematisation, accumulation, storage, clarification, retrieval, use, transfer (provision, access), blocking, deletion and destruction of personal data.

Recording, systematisation, accumulation, storage, clarification and retrieval of personal data of citizens of the Russian Federation are carried out using databases located in the Russian Federation (the Website’s server is hosted by a Russian hosting provider).

6. Transfer of personal data

The Operator does not sell personal data and does not transfer it to third parties except as set out below.

• To respond to requests quickly, the Operator receives a notification of each request, containing the data provided in it, in the Telegram messenger and at its Gmail e-mail address. The servers of these services are located outside the Russian Federation (Telegram — United Arab Emirates, Google LLC — USA), so sending such notifications is a cross-border transfer of personal data. It is carried out on the basis of the data subject’s consent and after notifying Roskomnadzor in accordance with Article 12 of the Law.
• Transfer at the request of authorised government bodies in cases provided for by law.

7. Processing and retention periods

Personal data is processed until the purposes of processing are achieved, but no longer than 3 (three) years from the date of the visitor’s last enquiry, or until consent is withdrawn, unless there are other legal grounds. The data is then destroyed within 30 days. If a contract has been concluded, the data is retained for the period required by law for keeping contract documents.

8. Rights of the data subject

The visitor has the right to:

• obtain information about the processing of their personal data;
• demand clarification, blocking or destruction of the data if it is incomplete, outdated, inaccurate or processed unlawfully;
• withdraw consent to the processing of personal data;
• appeal against the Operator’s actions to Roskomnadzor or in court.

Requests and withdrawals of consent are sent to studio@aristocrat.com or to the Operator’s address. The Operator responds within 10 working days of receiving the request; this period may be extended by no more than 5 working days with notice of the reasons.

9. Protection of personal data

The Operator takes legal, organisational and technical measures to protect personal data from unauthorised access, alteration, disclosure and destruction: data is transmitted from the Website over the secure HTTPS protocol, and only authorised persons of the Operator have password-protected access to requests.

10. Cookies and web analytics

The Website does not use cookies, web analytics services or visit counters, and does not store any information about the visitor in their browser. Fonts and other Website files are loaded from the Website’s own server.

11. Final provisions

The Operator may amend this policy. A new version takes effect from the moment it is published on the Website. The current version is always available at https://aristocratpro.ru/privacy/.