POLICY OF LIMITED LIABILITY COMPANY "LEAGUE OF EXTRAORDINARY GENTLEMEN" REGARDING THE PROCESSING OF PERSONAL DATA
1. GENERAL PROVISIONS
1.1. This Policy of Limited Liability Company "League of Extraordinary Gentlemen" regarding the processing of personal data (hereinafter – the Policy) establishes the rules for processing personal data and applies to personal data processed by the Website Administration when providing users access to the Website functionality, including the possibility for Users to submit a request to purchase the EVA PRO System or Equipment.
1.2. Use of the Website functionality, including filling out the application form, is possible only if the User consents to the processing of their personal data.
1.3. All matters not regulated by this Policy shall be governed by the legislation of the Russian Federation, including the Federal Law "On Personal Data".

2. TERMS AND DEFINITIONS
Personal Data – any information related to a directly or indirectly identified individual (data subject).
Website Administration – LLC "League of Extraordinary Gentlemen", the owner and operator of the Website, TIN 7751251681, OGRN 1237700255616, registered at: 127106, Moscow, Marfino Municipal District, Gostinichny proezd, building 4B, premises 1N/5, which processes the Users' personal data and determines the purposes, scope of personal data, and operations performed with them.
Website User (hereinafter – User) – a person who accesses the Website, regardless of whether they submit a request for purchasing the EVA PRO System and/or Equipment. By submitting a request on the Website, the User confirms that they are authorized to act on behalf of and in the interests of the represented legal entity.
Consent to the processing of personal data – by performing the actions defined in clause 6.3 of the Policy, the User confirms that they have read this Policy and agree to its terms. If the User disagrees, they must immediately cease using the Website functionality.
Processing of personal data – any action or set of actions performed using automated means with the User’s personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, anonymization, blocking, deletion, destruction of personal data.
Automated processing of personal data – processing using computing technology.
Destruction of personal data – any actions resulting in the irreversible destruction of personal data, making their further recovery impossible, including the destruction of physical media.
Website – the entirety of all information (textual and graphic) and functionality available online at https://lvd1.store, including all internal pages, owned by the Website Administration.
Cookies – small pieces of data sent by a web server and stored on the User’s device. Cookies contain small text fragments used to store information about browser usage. They allow storing and retrieving identification data and other information on computers, smartphones, and other devices.
Web beacons – electronic images (1×1 pixel or empty GIFs). Web beacons help the Website Administration recognize specific types of information on the User’s device, such as cookies, time and date of page visits, and a description of the page containing the beacon.
IP address – a number from the address space of a data transmission network based on the IP protocol that uniquely identifies the terminal (computer, smartphone, tablet, or other device) or communication means that belong to the User.
EVA PRO System (also referred to as "System") – a hardware and software complex owned by the Website Administration.
Equipment – the range of products presented on the Website and available for purchase.


3. PURPOSES OF PERSONAL DATA PROCESSING
3.1. The Website Administration processes only those personal data that are necessary for using the Website or for fulfilling agreements and contracts with the User.
3.2. The Website Administration performs automated processing of the User’s personal data for the following purposes:
  • identifying the User who submitted a request to purchase the System/Equipment;
  • establishing feedback with the User, including sending notifications, inquiries related to the purchase of the System/Equipment, and processing requests and applications from the User;
  • conducting negotiations with the User;
  • notifying the User about the status of the order;
  • providing effective customer and technical support to the User in case of problems related to the use of the Website, System/Equipment;
  • providing the User with special offers, price information, newsletters, and promotional materials and other messages from the Website Administration. The User may opt out of receiving such informational messages.
3.3. If necessary, the list of Users’ personal data processed by the Website Administration may be changed at any time with prior notification to Users by publishing an updated version of this Policy.

4. SCOPE AND CATEGORIES OF PERSONAL DATA PROCESSED
4.1. The personal data allowed for processing under this Policy and provided by Users include:
  • User's name (full name or any variation entered by the User);
  • Phone number;
  • Email address.
4.2. The Website Administration also processes data automatically transmitted during the use of the Website, including but not limited to: IP address, cookie data, web beacons, browser information (or other software used to access the Website), device type, visited pages, time spent on pages, clicked links and their sequence, scroll data (how far down the page the User scrolled), search queries on the website, active/inactive time on the Website, approximate location based on IP address, and precise geolocation if the User allows it in their browser.
4.3. Cookies transferred from the Website Administration to the User's device and back may be used by the Website Administration for achieving the purposes of personal data processing.
4.4. If the User does not wish their personal data to be collected via cookies, they can disable them in their browser settings. However, this may result in some essential features of the Website becoming unavailable or the Website functioning incorrectly.
4.5. The User agrees that their devices and software used to access the Website may or may not support disabling cookie operations or deleting previously received cookies, depending on their version and configuration.
4.6. The Website Administration may also use web beacons alone or in conjunction with cookies to collect information about Website usage. Users can block web beacons by disabling image loading in their browser settings.
4.7. The Website Administration has the right to process data collected via analytics services, which are used:
  • to collect data on Website usage;
  • to create conversion and user activity statistics for product analytics;
  • to fix errors. This collected information does not identify the User.
4.8. The Website Administration does not process special categories of personal data related to race, ethnicity, political opinions, religious or philosophical beliefs, or sex life.


5. UPDATING, CORRECTING, DELETING, DESTROYING, AND STORING PERSONAL DATA
5.1. Personal data processing, including storage and destruction, is carried out in the Website Administration’s CRM system with servers located in the Russian Federation.
5.2. The Website Administration may store personal data on hosting provider servers, which must also be located in the Russian Federation and have measures in place for data protection.
5.3. Personal data is stored for five years from the date of signing the supply agreement for the EVA PRO System/Equipment — the period during which the equipment is in use and there may be a need to contact the User for software updates.
5.4. Upon expiration of the storage period, personal data will be irreversibly deleted from the CRM system using automation tools.
5.5. The User may change, update, supplement, or delete their personal data at any time via the Website interface.
If the interface is not functioning or lacks such functionality, or in other cases, the User may request in writing that the Website Administration clarify, block, or destroy their data if it is incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the stated purposes.
5.6. If the Website Administration finds personal data to be incomplete or inaccurate, it must take action within seven business days from discovering the issue or receiving information from the User, including:
  • updating the data or deleting it if it cannot be updated;
  • destroying data that was unlawfully obtained or is not required for the stated purpose.
The Website Administration will notify the User of these changes and take reasonable steps to notify third parties to whom the data was transferred.
5.7. All information collected by third-party services, such as payment systems, delivery services, and other service providers, is stored and processed in accordance with their own user agreements and privacy policies. Users must review those documents on their own. The Website Administrator is not responsible for the actions of third parties mentioned in this section.

6. CONSENT TO THE PROCESSING OF PERSONAL DATA
6.1. The User makes the decision to provide their personal data and gives consent to their processing freely, voluntarily, and in their own interest.
6.2. The consent to the processing of personal data provided by the User is specific, informed, conscious, and unambiguous.
6.3. The User gives their consent to the processing of personal data by checking the relevant checkbox. A User who has given consent is considered to have read and accepted the terms of this Policy.
6.4. The consent is valid until the end of the data retention period defined in clause 5.3 of the Agreement, or until the purposes for which the data is processed are no longer relevant, or until the consent is withdrawn by the User — whichever occurs first.
6.5. The User may withdraw their consent to the processing of personal data at any time by sending a written statement in free form to the Website Administration via email: info@lvd1.ru.
6.6. Upon withdrawal of consent, the Website Administration shall cease processing the personal data and, if the data is no longer required for the stated purposes, destroy it within the period established by law.

7. MEASURES TAKEN TO PROTECT USERS' PERSONAL DATA
7.1. The security of personal data processed by the Website Administration is ensured through legal, organizational, and technical measures required to fully comply with applicable data protection laws.
7.2. The Website Administration ensures the integrity of personal data and takes all reasonable steps to prevent unauthorized access, including restricting staff access to Users' data.
7.3. The Website Administration appoints responsible persons to implement data confidentiality and protection measures.
7.4. The Website Administration develops and enforces internal regulations governing the processing of personal data.

8. RIGHTS AND OBLIGATIONS OF THE PARTIES
8.1. Rights and Obligations of the Website Administration
8.1.1. The Website Administration has the right to:
  • process the User's personal data;
  • independently determine the scope and list of necessary measures to ensure compliance with legal obligations;
  • change the terms of this Policy at any time. The updated Policy comes into force once published on the Website. The Website Administration recommends regularly reviewing the Policy to stay informed of the current version.
8.1.2. The Website Administration is obliged to:
  • provide the User with information regarding the processing of their personal data upon request;
  • ensure personal data of Russian Federation citizens is processed using databases located within the territory of the Russian Federation;
  • ensure the security and confidentiality of Users’ personal data;
  • respond to Users’ requests and inquiries, including from their legal representatives;
  • provide unrestricted access to this Policy;
  • take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, alteration, blocking, copying, provision, distribution, or other unlawful actions;
  • fulfill other duties as required by law.
8.2. Rights and Obligations of the User
8.2.1. The User has the right to:
  • receive information about the processing of their personal data, except in cases restricted by federal law;
  • request clarification, blocking, or deletion of their data if it is incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the stated purpose, and take legally allowed steps to protect their rights;
  • appeal to the Federal Service for Supervision in the Sphere of Telecom, Information Technologies and Mass Communications (Roskomnadzor) or to court in case of unlawful actions or inaction by the Website Administration;
  • exercise other rights granted by law.
8.2.2. The User is obliged to:
  • provide accurate personal data to the Website Administration;
  • inform the Website Administration about any updates or changes to their personal data.
8.3. Persons who provide false information about themselves or data about another individual without their consent are liable under the laws of the Russian Federation.

9. FINAL PROVISIONS
9.1. This Policy is permanently available on the Website of the Website Administration at the following link: https://lvd1.store
9.2. This Policy is valid indefinitely until it is replaced by a new version.
9.3. The platform on which the Website is hosted does not process the personal data collected by the Website Administration; it only provides computing capacity, which may be used by the Administration to collect the necessary data.
9.4. All suggestions or questions regarding this Policy may be directed to the Website Administration by email at: info@lvd1.ru
Obshchestvo s ogranichennoy otvetstvennostyu
«Liga Vydaiushchikhsia Dzhentelmenov»
Short name: OOO «LVD»
TIN 7751251681 / KPP 771501001
OGRN 1237700255616