| Alexander Malakhov

Personal Data Processing Policy

1. General Provisions

This Personal Data Processing Policy has been drafted in accordance with the requirements of Federal Law of the Russian Federation No. 152-FZ dated July 27, 2006 "On Personal Data" and determines the procedure for processing personal data as well as the measures taken by Limited Liability Company United Credit Services (hereinafter – the "Operator") to ensure the security of personal data.

1.1. The Operator regards respect for the rights and freedoms of individuals in the processing of their personal data, including the protection of the right to privacy, personal and family secrets, as one of its most important objectives and conditions of its business activities.

1.2. This Operator's Personal Data Processing Policy (hereinafter – the "Policy") applies to all information that the Operator may obtain about visitors to the website https://drmalakhov.com/.

2. Key Terms Used in this Policy

2.1. Automated processing of personal data – processing of personal data by means of computer technology.

2.2. Blocking of personal data – temporary suspension of the processing of personal data (except where processing is required for data clarification).

2.3. Website – a collection of graphic and informational materials as well as computer programs and databases ensuring their availability on the Internet at the address https://drmalakhov.com/.

2.4. Personal data information system – a set of personal data contained in databases and information technologies and technical means that ensure their processing.

2.5. Anonymization of personal data – actions that render it impossible to determine, without the use of additional information, the ownership of personal data by a specific User or other data subject.

2.6. Processing of personal data – any action (operation) or set of actions (operations) performed with or without the use of automation tools on personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.

2.7. Operator – a state authority, municipal authority, legal entity, or individual that, independently or jointly with others, organizes and/or carries out the processing of personal data, as well as determines 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 an identified or identifiable User of the website https://drmalakhov.com/.

2.9. User – any visitor of the website https://drmalakhov.com/.

2.10. Provision of personal data – actions aimed at disclosing personal data to a specific person or group of persons.

2.11. Distribution of personal data – any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or at making personal data available to an unlimited number of persons, including publication in the media, posting in information and telecommunication networks, or providing access to personal data in any other way.

2.12. Cross-border transfer of personal data – transfer of personal data to the territory of a foreign state to a foreign government authority, a foreign individual, or a foreign legal entity.

2.13. Destruction of personal data – any actions resulting in the irreversible destruction of personal data with no possibility of further restoration of their content in the personal data information system and/or resulting in the destruction of physical media containing personal data.

3. Personal Data that may be Processed by the Operator

3.1. Last name, first name, patronymic.

3.2. Email address.

3.3. Telephone numbers.

3.4. Year, month, date, and place of birth.

3.5. Citizenship details.

3.6. Details of an identity document.

3.7. Information on income.

3.8. Information on indebtedness.

3.9. Russian Federation passport details.

3.10. The website also collects and processes anonymized visitor data (including "cookies") through Internet statistics services (Yandex.Metrica, Google Analytics, and others).

3.11. The above data are hereinafter collectively referred to as Personal Data in this Policy.

4. Purposes of Processing Personal Data

4.1. The purpose of processing the User's personal data is to inform the User by sending emails; to conclude, perform, and terminate civil law contracts; to provide the User with access to the services, information, and/or materials contained on the website.

4.2. The Operator is also entitled to send the User notifications about new products and services, special offers, and various events. The User may always opt out of receiving such informational messages by sending an email to the Operator at info@drmalakhov.com with the note "Opt-out of notifications about new products, services, and special offers."

4.3. Anonymized User data collected through Internet statistics services are used to gather information about Users' actions on the website and to improve the quality and content of the website.

5. Legal Grounds for Processing Personal Data

5.1. The Operator processes the User's personal data only if such data are voluntarily provided and/or submitted by the User through special forms available on the website https://drmalakhov.com/. By filling out the relevant forms and/or submitting personal data to the Operator, the User expresses consent to this Policy.

5.2. The Operator processes anonymized User data if this is permitted in the User's browser settings (for example, enabling the storage of cookies and the use of JavaScript technology).

6. Procedure for Collecting, Storing, Transferring, and Other Types of Processing of Personal Data

The security of personal data processed by the Operator is ensured by implementing legal, organizational, and technical measures necessary to fully comply with the requirements of current legislation in the field of personal data protection.

6.1. The Operator ensures the confidentiality of personal data and takes all possible measures to prevent unauthorized access to personal data.

6.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to compliance with applicable law.

6.3. If inaccuracies in personal data are identified, the User may update them independently by sending a notification to the Operator's email address info@drmalakhov.com with the note "Update of personal data."

6.4. The term of processing of personal data is unlimited. The User may at any time withdraw their consent to the processing of personal data by sending an email to the Operator at info@drmalakhov.com with the note "Withdrawal of consent to the processing of personal data."

7. Cross-Border Transfer of Personal Data

7.1. Before commencing the cross-border transfer of personal data, the Operator must ensure that the foreign state to whose territory the transfer is intended provides reliable protection of the rights of personal data subjects.

7.2. The cross-border transfer of personal data to the territory of foreign states that do not meet the above requirements may be carried out only with the written consent of the personal data subject to such transfer and/or if it is necessary to perform a contract to which the personal data subject is a party.

8. Final Provisions

8.1. The User may obtain any clarifications on matters relating to the processing of their personal data by contacting the Operator via email at info@drmalakhov.com.

8.2. Any changes to the Operator's personal data processing policy will be reflected in this document. The Policy is valid indefinitely until it is replaced by a new version.

8.3. The current version of the Policy is freely available on the Internet at: https://drmalakhov.com/privacy.