Personal Data Processing Policy

1. General Provisions
This personal data processing policy has been drawn up in accordance with the requirements of Federal Law No. 152-FZ of 27.07.2006 "On Personal Data" (hereinafter referred to as the Personal Data Law) and defines the procedure for processing personal data and the measures taken to ensure the security of personal data by GLOBAL TAX ASSISTANT - FZCO (hereinafter referred to as the Operator).
1.1. The Operator considers the observance of the rights and freedoms of individuals in the processing of their personal data, including the protection of the rights to privacy, personal and family confidentiality, to be its most important goal and condition for carrying out its activities.
1.2. This Operator policy regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator may obtain about visitors to the website https://globaltaxassistant.com/.

2. Key Terms Used in the Policy
2.1. Automated processing of personal data — processing of personal data using computer technology.
2.2. Blocking of personal data — temporary suspension of personal data processing (except in cases where processing is necessary to clarify personal data).
2.3. Website — a collection of graphic and informational materials, as well as computer programs and databases that ensure their availability on the internet at the network address https://globaltaxassistant.com/.
2.4. Personal data information system — a set of personal data contained in databases and the information technologies and technical means that ensure their processing.
2.5. Anonymization of personal data — actions as a result of which it is impossible to determine, without the use of additional information, whether personal data belongs to a specific User or other personal data subject.
2.6. Processing of personal data — any action (operation) or set of actions (operations) performed using automation tools or without such tools with 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 body, municipal body, legal entity or individual that independently or jointly with other persons organizes and/or carries out the processing of personal data, as well as determines the purposes of personal data processing, the composition of personal data subject to processing, and the actions (operations) performed with personal data.
2.8. Personal data — any information relating directly or indirectly to a specific or identifiable User of the website https://globaltaxassistant.com/.
2.9. Personal data permitted by the personal data subject for distribution — personal data to which an unlimited number of persons have been granted access by the personal data subject by giving consent to the processing of personal data permitted by the personal data subject for distribution in the manner provided for by the Personal Data Law (hereinafter referred to as personal data permitted for distribution).
2.10. User — any visitor to the website https://globaltaxassistant.com/.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Distribution of personal data — any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or at familiarizing an unlimited number of persons with personal data, including the publication of personal data in mass media, placement in information and telecommunication networks, or providing access to personal data in any other manner.
2.13. Cross-border transfer of personal data — transfer of personal data to the territory of a foreign state to a foreign state authority, a foreign individual, or a foreign legal entity.
2.14. Destruction of personal data — any actions as a result of which personal data is destroyed irreversibly with no possibility of further restoration of the content of personal data in the personal data information system and/or physical carriers of personal data are destroyed.

3. Basic Rights and Obligations of the Operator
3.1. The Operator has the right to: — receive from the personal data subject accurate information and/or documents containing personal data; — in the event that the personal data subject withdraws consent to the processing of personal data, as well as submits a request to cease the processing of personal data, the Operator has the right to continue processing personal data without the consent of the personal data subject if there are grounds specified in the Personal Data Law; — independently determine the composition and list of measures necessary and sufficient to ensure compliance with the obligations provided for by the Personal Data Law and the regulatory legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.
3.2. The Operator is obliged to: — provide the personal data subject, upon their request, with information concerning the processing of their personal data; — organize the processing of personal data in the manner established by the current legislation of the Russian Federation; — respond to requests and inquiries from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law; — report to the authorized body for the protection of the rights of personal data subjects, upon request of that body, the necessary information within 10 days from the date of receipt of such request; — publish or otherwise ensure unrestricted access to this Policy regarding the processing of personal data; — take legal, organizational and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision, distribution, as well as from other unlawful actions in relation to personal data; — cease the transfer (distribution, provision, access) of personal data, cease processing and destroy personal data in the manner and in the cases provided for by the Personal Data Law; — fulfill other obligations provided for by the Personal Data Law.

4. Basic Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects have the right to: — receive information concerning the processing of their personal data, except in cases provided for by federal laws. The information is provided to the personal data subject by the Operator in an accessible form and must not contain personal data relating to other personal data subjects, except in cases where there are legitimate grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law; — require the Operator to clarify, block, or destroy their personal data if the personal data is incomplete, outdated, inaccurate, unlawfully obtained, or is not necessary for the stated purpose of processing, and to take legally prescribed measures to protect their rights; — impose a condition of prior consent when processing personal data for the purpose of promoting goods, works, and services in the market; — withdraw consent to the processing of personal data, as well as submit a request to cease the processing of personal data; — appeal to the authorized body for the protection of the rights of personal data subjects or through judicial proceedings against unlawful actions or inaction of the Operator in the processing of their personal data; — exercise other rights provided for by the legislation of the Russian Federation.
4.2. Personal data subjects are obliged to: — provide the Operator with accurate information about themselves; — notify the Operator of any clarification (update, modification) of their personal data.
4.3. Persons who have provided the Operator with inaccurate information about themselves, or information about another personal data subject without the latter's consent, shall be held liable in accordance with the legislation of the Russian Federation.

5. Principles of Personal Data Processing
5.1. Personal data processing is carried out on a lawful and fair basis.
5.2. Personal data processing is limited to achieving specific, predetermined, and lawful purposes. Processing of personal data incompatible with the purposes of personal data collection is not permitted.
5.3. The merging of databases containing personal data whose processing is carried out for incompatible purposes is not permitted.
5.4. Only personal data that meets the purposes of its processing shall be subject to processing.
5.5. The content and volume of personal data processed shall correspond to the stated purposes of processing. Excessive personal data processing in relation to the stated purposes is not permitted.
5.6. During the processing of personal data, the accuracy, sufficiency, and, where necessary, relevance of personal data in relation to the purposes of processing shall be ensured. The Operator takes necessary measures and/or ensures that measures are taken to delete or clarify incomplete or inaccurate data.
5.7. Personal data shall be stored in a form that allows identification of the personal data subject for no longer than required by the purposes of personal data processing, unless the retention period of personal data is established by federal law or a contract to which the personal data subject is a party, beneficiary, or guarantor. Processed personal data shall be destroyed or anonymized upon achieving the purposes of processing or in the event that the need to achieve those purposes is lost, unless otherwise provided by federal law.

6. Purposes of Personal Data Processing

• last name, first name, patronymic
• email address
• phone numbers

• Federal Law "On Information, Information Technologies and Information Protection" No. 149-FZ of 27.07.2006

• Collection, recording, systematization, accumulation, storage, destruction and anonymization of personal data
• Sending informational emails to the email address

7. Conditions for Personal Data Processing
7.1. Personal data processing is carried out with the consent of the personal data subject to the processing of their personal data.
7.2. Personal data processing is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, and to exercise the functions, powers, and obligations assigned to the Operator by the legislation of the Russian Federation.
7.3. Personal data processing is necessary for the administration of justice, the execution of a judicial act, or an act of another body or official subject to enforcement in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. Personal data processing is necessary for the performance of a contract to which the personal data subject is a party, beneficiary, or guarantor, as well as for the conclusion of a contract at the initiative of the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor.
7.5. Personal data processing is necessary to exercise the rights and legitimate interests of the Operator or third parties, or to achieve socially significant purposes, provided that the rights and freedoms of the personal data subject are not violated.
7.6. Processing is carried out of personal data to which an unlimited number of persons have been granted access by the personal data subject or at their request (hereinafter referred to as publicly available personal data).
7.7. Processing is carried out of personal data subject to publication or mandatory disclosure in accordance with federal law.

8. Procedure for Collection, Storage, Transfer and Other Types of Personal Data Processing
The security of personal data processed by the Operator is ensured through the implementation of legal, organizational and technical measures necessary to fully comply with the requirements of current legislation in the field of personal data protection.
8.1. The Operator ensures the safety of personal data and takes all possible measures to prevent access to personal data by unauthorized persons.
8.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to the execution of current legislation or if the personal data subject has given the Operator consent to transfer data to a third party for the performance of obligations under a civil law contract.
8.3. In the event of inaccuracies in personal data, the User may update them independently by sending the Operator a notification to the Operator's email address info@globaltaxassistant.com with the subject line "Personal Data Update".
8.4. The period of personal data processing is determined by the achievement of the purposes for which the personal data was collected, unless a different period is provided for by the contract or current legislation. The User may withdraw their consent to the processing of personal data at any time by sending the Operator a notification via email to the Operator's email address info@globaltaxassistant.com with the subject line "Withdrawal of Consent to Personal Data Processing".
8.5. All information collected by third-party services, including payment systems, communication tools and other service providers, is stored and processed by those parties (Operators) in accordance with their User Agreement and Privacy Policy. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this clause.
8.6. Restrictions established by the personal data subject on the transfer (other than granting access), as well as on the processing or conditions of processing of personal data permitted for distribution, do not apply in cases of personal data processing in state, public and other public interests as defined by the legislation of the Russian Federation.
8.7. The Operator ensures the confidentiality of personal data during processing.
8.8. The Operator stores personal data in a form that allows identification of the personal data subject for no longer than required by the purposes of personal data processing, unless the retention period is established by federal law or a contract to which the personal data subject is a party, beneficiary, or guarantor.
8.9. The grounds for terminating personal data processing may include the achievement of the purposes of personal data processing, the expiration of the personal data subject's consent, the withdrawal of consent by the personal data subject or a request to cease processing, as well as the identification of unlawful personal data processing.

9. List of Actions Performed by the Operator with Received Personal Data
9.1. The Operator carries out collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), anonymization, blocking, deletion and destruction of personal data.
9.2. The Operator carries out automated processing of personal data with the receipt and/or transfer of received information via information and telecommunication networks or without such networks.

10. Cross-Border Transfer of Personal Data
10.1. Prior to commencing cross-border transfer of personal data, the Operator is obliged to notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out cross-border transfer of personal data (such notification is sent separately from the notification of intent to process personal data).
10.2. Prior to submitting the above notification, the Operator is obliged to obtain relevant information from the authorities of the foreign state, foreign individuals, and foreign legal entities to whom cross-border transfer of personal data is planned.

11. Confidentiality of Personal Data
The Operator and other persons who have gained access to personal data are obliged not to disclose to third parties or distribute personal data without the consent of the personal data subject, unless otherwise provided by federal law.

12. Final Provisions
12.1. The User may obtain any clarification on matters of interest regarding the processing of their personal data by contacting the Operator via email at info@globaltaxassistant.com.
12.2. Any changes to the Operator's personal data processing policy will be reflected in this document. The Policy is valid indefinitely until replaced by a new version.
12.3. The current version of the Policy is freely available on the internet at https://globaltaxassistant.com/privacy.