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// 152-FZ

Personal Data Processing Policy

Translation for reference only. The legally binding text is the Russian original at avpai.org/privacy. In case of any discrepancies between this English version and the Russian original, the Russian version prevails.

This Policy has been developed in accordance with Federal Law No. 152-FZ "On Personal Data" and defines the procedure for processing personal data and the measures taken to ensure their security on the avpai.org website.

Version dated 12 May 2026.

1. General Provisions

1.1. The personal data operator (hereinafter — the "Operator"): LLC «AVP AI», INN 7720965100, OGRN 1267700122843, registered address: 111401, Moscow, ul. Novogireevskaya, 18/31, premises 4/1/1, email for inquiries: info@avpai.org.

1.1.1. The Operator is entered in the Register of Operators Processing Personal Data maintained by the Federal Service for Supervision of Communications, Information Technology and Mass Media (Roskomnadzor): registration No. 77-26-548497 (Roskomnadzor Order No. 204 dated 22.04.2026).

1.2. The website: https://avpai.org (hereinafter — the "Website").

1.3. Use of the Website constitutes the User's unconditional consent to this Policy and to the conditions for the processing of their personal data set forth herein. If the User does not agree with these conditions, the User must refrain from using the Website.

1.4. The Website is not intended for persons under 18 years of age. The Operator does not knowingly collect personal data of minors.

2. Categories of Personal Data Processed

The Operator processes the following personal data voluntarily provided by the User when filling out forms on the Website:

  • Surname, first name;
  • Company or organization name;
  • Job title;
  • Contact email;
  • Contact phone number;
  • Message submitted through the contact form.

In addition, the following technical data are collected automatically:

  • IP address and browser User-Agent;
  • Cookies (see Section 6);
  • Web analytics data (Yandex.Metrica, where applicable).

3. Purposes of Processing Personal Data

  • Establishing communication with the User — responding to inquiries submitted via a form on the Website;
  • Informing the User about the Operator's products and services (only with a separate consent to receive such communications);
  • Collecting anonymized Website traffic statistics to improve the service;
  • Fulfilling the Operator's obligations under the laws of the Russian Federation.

4. Legal Grounds for Processing

Processing is carried out on the following grounds:

  • Federal Law No. 152-FZ "On Personal Data";
  • The User's consent provided when filling out a form on the Website;
  • A contract concluded between the Operator and the User;
  • Other regulations of the Russian Federation applicable to the Operator's activities.

5. Procedure for Processing Personal Data

5.1. The processing of personal data includes: collection, recording, systematization, accumulation, storage, clarification, retrieval, use, transfer (provision, access), depersonalization, blocking, deletion, and destruction.

5.2. The Operator does not transfer personal data to third parties, except in cases provided for by law or with the User's separate consent.

5.3. Retention period of personal data: until the purposes of processing are achieved, but no longer than 5 years from the date of the User's last interaction with the Website, or until the User withdraws consent.

5.4. The Website's server infrastructure is located in Germany. The processing of personal data of citizens of the Russian Federation is carried out by the Operator in accordance with the requirements of Federal Law No. 152-FZ, including the application of technical and organizational protection measures, access restrictions and encryption of the data transmission channel. As the project develops, the Operator plans to migrate its infrastructure to servers located on the territory of the Russian Federation.

6. Cookies

6.1. The Website uses cookies — small pieces of data stored by the User's browser.

6.2. Categories of cookies:

  • Necessary — ensure the correct operation of the Website (session, authentication). They cannot be disabled.
  • Analytics — Yandex.Metrica and other systems that collect anonymized visit statistics. Used with the User's consent.
  • Marketing — used to personalize advertising messages (only with a separate consent).

6.3. Cookie lifetimes:

  • Session cookies — deleted when the browser is closed;
  • Consent and user-preferences cookies — up to 12 months;
  • Web analytics cookies — up to 24 months (managed by the provider).

6.4. The User may manage cookies through their browser settings or through the consent banner displayed on the first visit to the Website.

7. Security Measures

The Operator implements technical and organizational measures to protect personal data from unauthorized access, alteration, disclosure or destruction, including:

  • Encryption of the data transmission channel (HTTPS/TLS);
  • Access control to information systems;
  • Regular backups;
  • Designation of a person responsible for organizing the processing of personal data.

8. Rights of the User

The User has the right to:

  • Obtain information about which of their personal data are processed by the Operator;
  • Require the clarification, blocking or deletion of their personal data if such data are incomplete, outdated, inaccurate or obtained unlawfully;
  • Withdraw their consent to the processing of personal data at any time by sending a request to info@avpai.org;
  • Appeal the acts or omissions of the Operator to the authorized body for the protection of the rights of personal data subjects (Roskomnadzor) or in court.

9. Operator's Contact Information

For all matters related to the processing of personal data, please contact:

  • Email: info@avpai.org
  • Postal address: 111401, Moscow, ul. Novogireevskaya, 18/31, premises 4/1/1

10. Amendments to this Policy

The Operator is entitled to make amendments to this Policy. The current version is always available at avpai.org/privacy (legally binding Russian text) and at avpai.org/en/privacy (English reference translation). The User shall independently monitor changes to the Policy on each visit to the Website.

Last updated: 12 May 2026.

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