Policy regarding the processing of personal data

1. General Provisions

This personal data processing policy has been drawn up inaccordance with the requirements of the Federal Law of July 27, 2006. No.152-FZ “On Personal Data” (hereinafter referred to as the Law on Personal Data)and determines the procedure for processing personal data and measures toensure the security of personal data taken by ZEN REAL PROPERTY CO.LTD (hereinafter referred to as the Operator).

1.1. The operator sets as its most important goal andcondition for carrying out its activities the observance of the rights andfreedoms of man and citizen when processing his personal data, including theprotection of the rights to privacy, personal and family secrets.

1.2. This Operator’s policy regarding the processing ofpersonal data (hereinafter referred to as the Policy) applies to allinformation that the Operator can obtain about visitors to the website https://zenrealproperty-invest.com.

2. Basic concepts used in the Policy

2.1. Automated processing of personal data - processing ofpersonal data using computer technology.

2.2. Blocking of personal data is a temporary cessation ofprocessing of personal data (except for cases where processing is necessary toclarify personal data).

2.3. Website is a collection of graphic and informationmaterials, as well as computer programs and databases that ensure theiravailability on the Internet at the network address https://zenrealproperty-invest.com.

2.4. Personal data information system is a set of personaldata contained in databases and information technologies and technical meansthat ensure their processing.

2.5. Depersonalization of personal data - actions as a resultof which it is impossible to determine without the use of additionalinformation the ownership of personal data to a specific User or other subjectof personal data.

2.6. Processing of personal data - any action (operation) orset of actions (operations) performed using automation tools or without the useof such tools with personal data, including collection, recording,systematization, accumulation, storage, clarification (updating, changing),extraction, use, transfer (distribution, provision, access), depersonalization,blocking, deletion, destruction of personal data.

2.7. Operator - a state body, municipal body, legal or naturalperson, independently or jointly with other persons organizing and/or carryingout the processing of personal data, as well as determining the purposes ofprocessing personal data, the composition of personal data to be processed,actions (operations) performed with personal data.

2.8. Personal data - any information relating directly orindirectly to a specific or identifiable User of the https://zenrealproperty-invest.com website.

2.9. Personal data authorized by the subject of personal datafor distribution - personal data, access to an unlimited number of persons towhich is provided by the subject of personal data by giving consent to theprocessing of personal data authorized by the subject of personal data fordistribution in the manner prescribed by the Law on Personal Data (hereinafterreferred to as personal data). data authorized for distribution).

2.10. User - any visitor to the website https://zenrealproperty-invest.com.

2.11. Providing personal data - actions aimed at disclosingpersonal data to a certain person or a certain circle of persons.

2.12. Distribution of personal data - any actions aimed atdisclosing personal data to an indefinite number of persons (transfer ofpersonal data) or to familiarize with personal data to an unlimited number ofpersons, including the publication of personal data in the media, posting ininformation and telecommunication networks or providing access to personal datain any other way.

2.13. Cross-border transfer of personal data is the transferof personal data to the territory of a foreign state to an authority of aforeign state, a foreign individual or a foreign legal entity.

2.14. Destruction of personal data - any actions as a resultof which personal data is irretrievably destroyed with the impossibility offurther restoration of the content of personal data in the personal datainformation system and/or material media of personal data are destroyed.

3. Basic rights and obligations of the Operator

3.1. The operator has the right:

— receive from the subject of personal data reliableinformation and/or documents containing personal data;

— in the event that the subject of personal data withdrawsconsent to the processing of personal data, as well as sends a request to stopprocessing personal data, the Operator has the right to continue processingpersonal data without the consent of the subject of personal data if there aregrounds specified in the Law on Personal Data;

— independently determine the composition and list of measuresnecessary and sufficient to ensure the fulfillment of the obligations providedfor by the Law on Personal Data and regulations adopted in accordance with it,unless otherwise provided by the Law on Personal Data or other federal laws.

3.2. The operator is obliged:

— provide the subject of personal data, at his request, withinformation regarding the processing of his personal data;

— organize the processing of personal data in the mannerestablished by the current legislation of the Russian Federation;

— respond to requests and inquiries from personal datasubjects and their legal representatives in accordance with the requirements ofthe Personal Data Law;

— report to the authorized body for the protection of therights of personal data subjects, at the request of this body, the necessaryinformation within 10 days from the date of receipt of such a request;

— publish or otherwise provide unrestricted access to thisPolicy regarding the processing of personal data;

— take legal, organizational and technical measures to protectpersonal data from unauthorized or accidental access, destruction,modification, blocking, copying, provision, distribution of personal data, aswell as from other unlawful actions in relation to personal data;

— stop the transfer (distribution, provision, access) ofpersonal data, stop processing and destroy personal data in the manner andcases provided for by the Law on Personal Data;

— fulfill other duties provided for by the Personal Data Law.

4. Basic rights and obligations of personal data subjects

4.1. Subjects of personal data have the right:

— receive information regarding the processing of his personaldata, except for cases provided for by federal laws. The information isprovided to the subject of personal data by the Operator in an accessible form,and it should not contain personal data relating to other subjects of personaldata, except in cases where there are legal grounds for the disclosure of suchpersonal data. The list of information and the procedure for obtaining it isestablished by the Law on Personal Data;

— require the operator to clarify his personal data, block itor destroy it if the personal data is incomplete, outdated, inaccurate,illegally obtained or is not necessary for the stated purpose of processing, aswell as take measures provided by law to protect their rights;

— put forward the condition of prior consent when processingpersonal data in order to promote goods, works and services on the market;

— to withdraw consent to the processing of personal data, aswell as to send a request to stop processing personal data;

— appeal to the authorized body for the protection of therights of personal data subjects or in court the unlawful actions or inactionof the Operator when processing his personal data;

— to exercise other rights provided for by the legislation ofthe Russian Federation.

4.2. Subjects of personal data are obliged to:

— provide the Operator with reliable information aboutyourself;

— inform the Operator about clarification (updating, changing)of your personal data.

4.3. Persons who provided the Operator with false informationabout themselves or information about another subject of personal data withoutthe latter’s consent are liable in accordance with the legislation of theRussian Federation.

5. Principles for processing personal data

5.1. The processing of personal data is carried out on a legaland fair basis.

5.2. The processing of personal data is limited to theachievement of specific, pre-defined and legitimate purposes. Processing ofpersonal data that is incompatible with the purposes of collecting personaldata is not permitted.

5.3. It is not allowed to combine databases containingpersonal data, the processing of which is carried out for purposes that areincompatible with each other.

5.4. Only personal data that meets the purposes of theirprocessing are subject to processing.

5.5. The content and volume of personal data processedcorrespond to the stated purposes of processing. Redundancy of the processedpersonal data in relation to the stated purposes of their processing is notallowed.

5.6. When processing personal data, the accuracy of personaldata, their sufficiency, and, where necessary, relevance in relation to thepurposes of processing personal data are ensured. The operator takes thenecessary measures and/or ensures that they are taken to delete or clarifyincomplete or inaccurate data.

5.7. The storage of personal data is carried out in a formthat makes it possible to identify the subject of personal data, no longer thanrequired by the purposes of processing personal data, unless the period forstoring personal data is established by federal law, an agreement to which thesubject of personal data is a party, beneficiary or guarantor. The processedpersonal data is destroyed or anonymized upon achievement of the processinggoals or in the event of the loss of the need to achieve these goals, unlessotherwise provided by federal law.

6. Purposes of processing personal data

Purpose of processing: informing the User by sending emails;providing the User with access to services, information and/or materialscontained on the website

Personal data: last name, first name, patronymic, emailaddress, telephone numbers

Legal grounds: statutory (constituent) documents of theOperator, contracts concluded between the operator and the subject of personaldata

Types of processing of personal data: collection, recording,systematization, accumulation, storage, destruction and depersonalization ofpersonal data, sending information letters to an email address

7. Conditions for processing personal data

7.1. The processing of personal data is carried out with theconsent of the subject of personal data to the processing of his personal data.

7.2. The processing of personal data is necessary to achievethe goals provided for by an international treaty of the Russian Federation orlaw, to implement the functions, powers and responsibilities assigned by thelegislation of the Russian Federation to the operator.

7.3. The processing of personal data is necessary for theadministration of justice, the execution of a judicial act, an act of anotherbody or official, subject to execution in accordance with the legislation ofthe Russian Federation on enforcement proceedings.

7.4. The processing of personal data is necessary for theexecution of an agreement to which the subject of personal data is a party orbeneficiary or guarantor, as well as for concluding an agreement on theinitiative of the subject of personal data or an agreement under which thesubject of personal data will be a beneficiary or guarantor.

7.5. The processing of personal data is necessary to exercisethe rights and legitimate interests of the operator or third parties or toachieve socially significant goals, provided that the rights and freedoms ofthe subject of personal data are not violated.

7.6. The processing of personal data is carried out, access toan unlimited number of persons is provided by the subject of personal data orat his request (hereinafter referred to as publicly available personal data).

7.7. We process personal data that is subject to publicationor mandatory disclosure in accordance with federal law.

8. The procedure for collecting, storing, transferring andother types of processing of personal data

The security of personal data processed by the Operator isensured by implementing legal, organizational and technical measures necessaryto fully comply with the requirements of current legislation in the field ofpersonal data protection.

8.1. The operator ensures the safety of personal data andtakes all possible measures to prevent access to personal data by unauthorizedpersons.

8.2. The User’s personal data will never, under anycircumstances, be transferred to third parties, except in cases related to theimplementation of current legislation or in the event that the subject ofpersonal data gives consent to the Operator to transfer data to a third partyto fulfill obligations under a civil law contract.

8.3. If inaccuracies in personal data are identified, the Usercan update them independently by sending a notification to the Operator to theOperator's e-mail address contact@zenrealproperty.com marked “Updating personaldata.”

8.4. The period for processing personal data is determined bythe achievement of the purposes for which the personal data were collected,unless a different period is provided for by the contract or currentlegislation.
The User may at any time withdraw his consent to the processing of personaldata by sending a notification to the Operator via email to the Operator'semail address contact@zenrealproperty.com marked “Withdrawal of consent to theprocessing of personal data.”

8.5. All information that is collected by third-partyservices, including payment systems, communications and other serviceproviders, is stored and processed by these persons (Operators) in accordancewith their User Agreement and Privacy Policy. Subject of personal data and/orwith specified documents. The operator is not responsible for the actions ofthird parties, including the service providers specified in this paragraph.

8.6. Prohibitions established by the subject of personal dataon the transfer (except for providing access), as well as on processing orconditions for processing (except for gaining access) of personal datapermitted for distribution, do not apply in cases of processing personal datain state, public and other public interests determined by law RF.

8.7. When processing personal data, the operator ensures theconfidentiality of personal data.

8.8. The operator stores personal data in a form that makes itpossible to identify the subject of personal data for no longer than requiredby the purposes of processing personal data, unless the period for storingpersonal data is established by federal law, an agreement to which the subjectof personal data is a party, beneficiary or guarantor.

8.9. The condition for terminating the processing of personaldata may be the achievement of the purposes of processing personal data, theexpiration of the consent of the subject of personal data, the withdrawal ofconsent by the subject of personal data or a requirement to cease theprocessing of personal data, as well as the identification of unlawfulprocessing of personal data.

9. List of actions performed by the Operator with receivedpersonal data

9.1. The operator collects, records, systematizes,accumulates, stores, refines (updates, changes), extracts, uses, transfers(distribute, provide, access), depersonalizes, blocks, deletes and destroyspersonal data.

9.2. The operator carries out automated processing of personaldata with or without receiving and/or transmitting the received information viainformation and telecommunication networks.

10. Cross-border transfer of personal data

10.1. Before starting activities for the cross-border transferof personal data, the operator is obliged to notify the authorized body for theprotection of the rights of personal data subjects of its intention to carryout cross-border transfer of personal data (such notification is sentseparately from the notification of the intention to process personal data).

10.2. Before submitting the above notification, the operatoris obliged to obtain relevant information from the authorities of a foreignstate, foreign individuals, foreign legal entities to whom the cross-bordertransfer of personal data is planned.

11. Confidentiality of personal data

The operator and other persons who have access to personaldata are obliged not to disclose to third parties or distribute personal datawithout the consent of the subject of personal data, unless otherwise providedby federal law.

12. Final provisions

12.1. The User can receive any clarification on issues ofinterest regarding the processing of his personal data by contacting theOperator via email contact@zenrealproperty.com.

12.2. This document will reflect any changes to the Operator’spersonal data processing policy. The policy is valid indefinitely until it isreplaced by a new version.

12.3. The current version of the Policy is freely available onthe Internet at https://zenrealproperty-invest.com.