This English version is provided for informational purposes only. In the event of any discrepancy between the Russian and English versions, the Russian version shall prevail.

1. General ProvisionsThis Personal Data Processing Policy (hereinafter referred to as the “Policy”) has been developed in accordance with the Constitution of the Russian Federation, Federal Law No. 152-FZ dated July 27, 2006 “On Personal Data,” Federal Law No. 149-FZ dated July 27, 2006 “On Information, Information Technologies and Information Protection,” and other applicable laws and regulations of the Russian Federation.
This Policy establishes the procedure for processing the personal data of users of the website https://thefirstagency.ru (hereinafter referred to as the “Website”) and the measures taken by Individual Entrepreneur Daria Valeryevna Andrianova (hereinafter referred to as the “Operator”) to ensure the security of personal data.
By using the Website, the User confirms that they have read this Policy and agree to its terms regarding the processing of personal data.
This Policy is a publicly available document and is made freely accessible on the Website.
2. Information About the Personal Data OperatorPersonal Data Operator
Individual Entrepreneur Daria Valeryevna Andrianova
Taxpayer Identification Number (INN):
672212939414
Current Account:
40802810820001013201
Bank:
Bank Tochka LLC
Bank Identification Code (BIC):
044525104
Correspondent Account:
30101810745374525104
Email address for personal data subjects’ inquiries:
dari.andrianovaa@gmail.com
Telephone:
+7 919 048 43 07
Address for legally significant communications:
dari.andrianovaa@gmail.com
3. Key TermsFor the purposes of this Policy, the following terms shall apply:
Personal Data means any information relating directly or indirectly to an identified or identifiable individual.
Processing of Personal Data means any action or set of actions performed on personal data, including collection, recording, organization, accumulation, storage, clarification, use, transfer, anonymization, restriction, deletion, and destruction.
User means an individual who visits the Website.
Operator means Individual Entrepreneur Daria Valeryevna Andrianova.
4. Purposes of Personal Data ProcessingThe Operator processes personal data solely for the following purposes:

• receiving and processing requests submitted through the Website forms;
• providing consultations regarding the marketing agency’s services;
• preparing commercial proposals;
• entering into, performing, and administering agreements;
• providing services in the fields of digital marketing, advertising, website promotion, contextual and targeted advertising, web analytics, development of marketing strategies, and other services presented on the Website;
• responding to Users’ inquiries;
• exchanging documents and materials required for the performance of an agreement;
• analyzing Website traffic;
• improving the Website;
• providing feedback and communication;
• complying with the requirements of the laws of the Russian Federation;
• sending informational materials and advertising communications only where the User has provided separate consent.

5. Categories of Personal Data SubjectsThe Operator processes the personal data of the following categories of individuals:

• Website visitors;
• prospective clients;
• clients;
• representatives of legal entities;
• individuals who contact the Operator through feedback forms;
• individuals who submit documents through the Website forms.

6. Categories of Personal Data ProcessedDepending on the User’s actions, the following personal data may be processed:
Data provided directly by the User:

• first name;
• last name, if provided;
• telephone number;
• email address;
• Telegram username;
• message content;
• information contained in attached files.

If the User submits any of the following:

• technical specifications;
• commercial documents;
• media materials;
• presentations;
• advertising account information;
• analytical reports;
• other documents,

such information shall be used solely for reviewing the inquiry, preparing a commercial proposal, or performing an agreement.
7. Automatically Collected DataWhen the Website is used, the following data may be processed automatically:

• IP address;
• cookies;
• browser information;
• device information;
• operating system information;
• screen resolution;
• date and time of the visit;
• referral source;
• pages visited;
• duration of the visit;
• User actions;
• data collected by the Yandex Metrica service.

This information is used solely for analytics, ensuring the stable operation of the Website, improving the user experience, and improving the quality of the services provided.
8. Legal Grounds for Personal Data ProcessingPersonal data is processed on the basis of:

• Federal Law No. 152-FZ “On Personal Data”;
• Federal Law No. 149-FZ “On Information, Information Technologies and Information Protection”;
• other applicable laws and regulations of the Russian Federation;
• the consent of the personal data subject;
• an agreement entered into with the User or the need to take steps prior to entering into such an agreement;
• the Operator’s legitimate interests, provided that the rights and freedoms of personal data subjects are respected.

9. Methods of Obtaining Personal DataThe Operator obtains personal data in the following ways:

• when the User completes feedback forms on the Website;
• when the User sends an inquiry to the Operator’s email address;
• when the User contacts the Operator through Telegram, where this option is available on the Website;
• when the User attaches files through the Website forms;
• automatically during the use of the Website through cookies and the Yandex Metrica web analytics service.

The Operator does not intentionally collect special categories of personal data, including information concerning racial or ethnic origin, political opinions, religious or philosophical beliefs, health, intimate life, or biometric data, unless otherwise expressly required by the laws of the Russian Federation or necessary for the performance of an agreement.
The User shall not submit the personal data of third parties through the Website forms without having the appropriate legal grounds to do so.
10. Personal Data Processing ProcedurePersonal data is processed both by automated means and without the use of automated means.
When processing personal data, the Operator may perform the following actions:

• collection;
• recording;
• organization;
• accumulation;
• storage;
• clarification, including updating and modification;
• retrieval;
• use;
• transfer in cases provided for by the laws of the Russian Federation;
• anonymization;
• restriction;
• deletion;
• destruction.

Personal data shall be processed only to the extent necessary to achieve the purposes specified in this Policy.
11. Personal Data Processing and Retention PeriodsPersonal data shall be processed until the purposes of processing have been achieved or until the User withdraws their consent, unless a different retention period is required by the laws of the Russian Federation.
Documents and correspondence relating to the conclusion and performance of agreements may be retained for the periods prescribed by civil, tax, accounting, and other applicable laws of the Russian Federation.
Once the purposes of processing have been achieved or where there are no legal grounds for continued retention, personal data shall be destroyed or anonymized.
12. Disclosure of Personal Data to Third PartiesThe Operator does not sell or distribute Users’ personal data.
Personal data may be disclosed only:

• with the User’s consent;
• where such disclosure is necessary for the performance of an agreement;
• in cases expressly provided for by the laws of the Russian Federation;
• to government authorities upon their lawful request;
• to persons providing technical support services for the Website, provided that they comply with the requirements of the laws of the Russian Federation concerning personal data.

When engaging third parties, the Operator takes reasonable measures to ensure the confidentiality and security of personal data.
13. Use of the Tilda Platform and Request Processing ServicesThe Website is hosted on the Tilda Publishing platform.
When a User completes a feedback form, their data may be processed using Tilda’s technical infrastructure to the extent necessary for the operation of the Website and the transmission of requests to the Operator.
Requests submitted through the Website forms are sent to the Operator’s email address:
dari.andrianovaa@gmail.com
The Operator takes measures to restrict third-party access to received inquiries and ensures that they are processed solely for the stated purposes.
14. Use of Cookies and Yandex MetricaThe Website uses cookies and the Yandex Metrica web analytics service for the following purposes:

• ensuring the proper operation of the Website;
• analyzing Website traffic;
• evaluating the effectiveness of advertising campaigns;
• analyzing user behavior;
• improving the Website;
• improving the user experience.

When the Website is used, the following data may be collected automatically:

• IP address;
• browser information;
• operating system information;
• device type;
• browser language;
• referral source;
• pages viewed;
• time of the visit;
• session duration;
• information about the User’s actions on the Website;
• technical identifiers;
• cookies.

The User may change their browser settings to restrict the use of cookies. If cookies are restricted, certain Website functions may not operate correctly.
15. Cross-Border Transfer of Personal DataAs of the date of approval of this Policy, the Operator does not carry out cross-border transfers of personal data.
Should such a transfer become necessary, the Operator shall ensure compliance with the requirements of the laws of the Russian Federation, including completion of the procedures established by law and obtaining any required consents.
16. Confidentiality of Personal DataThe Operator ensures the confidentiality of personal data and does not disclose it to third parties without a lawful basis.
Access to personal data is granted only to persons who require such access to perform their professional duties or contractual obligations to the Operator.
All persons granted access to personal data must comply with the requirements of the laws of the Russian Federation concerning personal data protection and confidentiality.
17. Personal Data Security MeasuresThe Operator takes the necessary legal, organizational, and technical measures to protect personal data against unlawful or accidental access, destruction, alteration, restriction, copying, distribution, disclosure, and other unlawful actions.
In particular, the Operator takes the following measures to ensure the security of personal data:

• determines the list of persons authorized to access personal data;
• ensures that personal data is processed only to the extent necessary to achieve the stated purposes;
• uses a secure HTTPS connection for the Website;
• restricts access to email accounts and other personal data storage systems;
• takes measures to prevent unauthorized access to information;
• regularly updates software and technical security tools;
• organizes the storage of personal data in a manner that prevents access by unauthorized persons;
• takes other measures required by the laws of the Russian Federation.

The Operator regularly assesses whether the security measures applied are sufficient, taking into account the nature of the personal data processed, potential security threats, and the technologies used.
18. Rights of Personal Data SubjectsThe User has the right to:

• obtain information concerning the processing of their personal data;
• request the clarification, updating, or correction of their personal data;
• request the restriction or destruction of personal data in cases provided for by the laws of the Russian Federation;
• withdraw previously granted consent to the processing of personal data;
• obtain information about the legal grounds and purposes of personal data processing;
• obtain information about personal data retention periods;
• lodge a complaint concerning the Operator’s actions or omissions with the competent authority responsible for protecting the rights of personal data subjects or with a court;
• exercise other rights provided for by the laws of the Russian Federation.

19. Procedure for Withdrawing Consent to Personal Data ProcessingA personal data subject may withdraw their consent to the processing of personal data at any time by sending a written request to:
dari.andrianovaa@gmail.com
It is recommended that the request include:

• the individual’s first and last name, where applicable;
• contact details;
• a description of the request;
• information sufficient to identify the applicant.

Upon receiving the request, the Operator shall review it within the periods prescribed by the laws of the Russian Federation. If there are no other legal grounds for continuing the processing, the Operator shall cease processing the personal data or arrange for its restriction or destruction.
Withdrawal of consent does not affect the lawfulness of personal data processing carried out before the request was received.
20. Procedure for Reviewing InquiriesInquiries from personal data subjects may be submitted to:
dari.andrianovaa@gmail.com
The Operator shall review inquiries within the periods prescribed by Federal Law No. 152-FZ “On Personal Data.”
Where necessary, the Operator may request additional information to verify the applicant’s identity and prevent the unlawful disclosure of personal data to third parties.
21. LiabilityPersons responsible for violating the requirements of the laws of the Russian Federation concerning personal data processing shall be held liable in accordance with the laws of the Russian Federation.
The Operator shall not be liable for the processing of personal data carried out on third-party websites where the User independently accesses such websites through links published on the Website.
22. Amendments to the PolicyThe Operator may amend this Policy in the event of:

• changes to the laws of the Russian Federation;
• changes to the categories or methods of personal data processing;
• the introduction of new Website services, technologies, or functionality;
• changes to the services provided;
• other circumstances affecting the processing of personal data.

A new version of the Policy shall take effect upon its publication on the Website unless a different effective date is specified in the new version.
Users are advised to review the current version of the Policy each time they visit the Website.
23. Final ProvisionsThis Policy shall remain in effect indefinitely until a new version is adopted.
Any matters not governed by this Policy shall be regulated by the laws of the Russian Federation.
If any provision of this Policy is declared invalid or unenforceable, this shall not affect the validity or enforceability of the remaining provisions.
The current version of the Policy is permanently available on the official Website:
https://thefirstagency.ru
24. Operator DetailsPersonal Data Operator
Individual Entrepreneur Daria Valeryevna Andrianova
Taxpayer Identification Number (INN):
672212939414
Current Account:
40802810820001013201
Bank:
Bank Tochka LLC
Bank Identification Code (BIC):
044525104
Correspondent Account:
30101810745374525104
Email address:
dari.andrianovaa@gmail.com
Address for inquiries and legally significant communications:
dari.andrianovaa@gmail.com
Website:
https://thefirstagency.ru