ArmFriend · Limited Liability Company “TOPFRIEND”

Personal Data Processing Policy

1. Key Terms

• 1.1. Information — data (messages, records) regardless of the form of its presentation;
• 1.2. Personal data — any information relating to a directly or indirectly identified or identifiable natural person (personal data subject);
• 1.3. Biometric personal data — information characterising the physiological and biological features of a person on the basis of which his or her identity can be established;
• 1.4. Special categories of personal data — personal data concerning racial or ethnic origin, political opinions, religious or philosophical beliefs, health or intimate life;
• 1.5. Personal data subjects — natural persons to whom the personal data provided relates;
• 1.6. Personal data operator — Limited Liability Company “TOPFRIEND” and, in certain cases, third parties authorised by it;
• 1.7. Confidentiality of personal data — the obligation of the personal data operator not to disclose the personal data of a personal data subject to third parties and not to disseminate personal data without the consent of the personal data subject, except in the cases expressly provided for by Federal Law No. 152-FZ of 27 July 2006 “On Personal Data”.

2. Methods of Personal Data Processing

• 2.1. ArmFriend processes personal data both with and without the use of automation tools.
• 2.2. The automated personal data processing tools used by ArmFriend comply with the information security and information protection requirements applicable to technical means.

3. Legal Grounds for Personal Data Processing

• 3.1. The legal grounds for the processing of personal data by the Operator are the following legal acts: the Constitution of the Russian Federation; the Council of Europe Convention for the Protection of Individuals with regard to Automatic Processing of Personal Data; the Civil Code of the Russian Federation; Federal Law No. 152-FZ of 27 July 2006 “On Personal Data”; Federal Law No. 149-FZ of 27 July 2006 “On Information, Information Technologies and Information Protection”; the Federal Law “On Limited Liability Companies”; other legal acts in the field of information protection; the Articles of Association of Limited Liability Company “TOPFRIEND”; and ArmFriend’s agreements with partners.

4. Scope and Categories of Data Processed; Purposes of Processing

• 4.1. ArmFriend may process the personal data of the following persons:
  • 4.1.1. Managers, deputy managers, employees, customers and contractors of Limited Liability Company “TOPFRIEND” and/or its affiliates, including former employees — for the purposes of concluding, extending and terminating employment contracts, work contracts, service agreements and other civil-law contracts; making decisions on appointment to and removal from a position, transfer to another job, and the award of additional compensation; preventing and detecting corruption; preventing and detecting unauthorised access to personal data; and in other cases provided for by law;
  • 4.1.2. Users of the Service and of other websites, programs, applications and services provided by ArmFriend, and representatives of users that are legal entities — for the purposes of concluding, extending and terminating service agreements and work contracts; preventing and detecting corruption; preventing and detecting unauthorised access to personal data; and in other cases provided for by law.
• 4.2. ArmFriend may collect and process the following personal data:
  • 4.2.1. For natural persons — surname, first name, patronymic (if any), contact telephone number(s), e-mail address(es), other means of contact, information on date and place of birth, registration, residence, citizenship, education and qualifications, marital and property status, bankruptcy or its equivalent under the applicable personal law, geolocation data, IMEI and MAC addresses of the devices used to access the Service, and other information to the extent consistent with the statutory purposes of ArmFriend’s activities, this Policy, and the anti-money laundering and counter-terrorist financing (AML/CFT) policy. ArmFriend does not process the User’s biometric personal data or special categories of personal data;
  • 4.2.2. For legal entities — full and abbreviated name, contact telephone number(s), e-mail address(es), other means of contact, information on registration, activities, property status, the introduction of financial rehabilitation, external administration, bankruptcy proceedings or their equivalents under the applicable personal law, documents confirming the authority of representatives, geolocation data, IMEI and MAC addresses of the devices used to access the Service, payment and banking details, and other information to the extent consistent with the statutory purposes of ArmFriend’s activities, this Policy, and the anti-money laundering and counter-terrorist financing (AML/CFT) policy;
  • 4.2.3. ArmFriend may also process information on the operating system version and device model used to log in to the user’s account, the IP address, cookie information (text files stored in the user’s browser that contain service information about website visits, sent by the server to the User’s device to make it more convenient to view websites previously opened by the User within a certain period of time, and containing information on the User’s preferences and browsing history), information on the user’s browser (or other program used to access the Service), the time of access, and the address of the requested page.
• 4.3. ArmFriend collects the above information directly from Users, including upon registration in the Service, including, but not limited to, contact information and registration data. ArmFriend may, however, engage third parties and use third-party services to check and verify the User’s personal data, as well as for compliance purposes.
• 4.4. Under this Policy, the purposes of personal data processing are:
  • 4.4.1. Compliance with federal legislation on ensuring the security and confidentiality of personal data;
  • 4.4.2. Ensuring the normal business operations of Limited Liability Company “TOPFRIEND”, including, but not limited to, hiring employees, concluding contracts with customers and contractors, performing ArmFriend’s obligations under contracts for the performance of work (provision of services), creating and providing access to the Service, and identifying persons and devices accessing the Service;
  • 4.4.3. Combating money laundering and the financing of terrorism.

5. Procedure and Conditions of Data Processing

• 5.1. ArmFriend processes only the information, and only for the purposes, defined in this Policy. The period of processing of users’ information is determined by the purposes of such processing and the requirements of the legislation of the Russian Federation. Personal data is processed by any lawful means, including in personal data information systems, with or without the use of automation tools.
• 5.2. To achieve the purposes of data processing, ArmFriend uses the following processing methods: collection; depersonalisation; transfer; accumulation; storage; consolidation; clarification (updating, modification); blocking; deletion; destruction.
• 5.3. User information may be retained on ArmFriend’s resources for the duration of the contractual relationship between ArmFriend and the user, and for 2 (two) years after the termination of such contracts.
• 5.4. The Administration reserves the right to use users’ e-mail addresses to send informational and promotional messages.

6. Disclosure and Transfer of Personal Data

• 6.1. In the cases specified in this Policy and in other documents relating to the Service, ArmFriend may disclose information received from Users and visitors of the website https://armfriend.com/ to third parties, who may use such information for marketing, advertising or other purposes.
• 6.2. ArmFriend may also disclose aggregated, individual or depersonalised data based on information received from Users and visitors of the website https://armfriend.com/ to investors and potential partners.
• 6.3. ArmFriend may, without prior notice to or consent of the personal data subject, disclose and transfer the user’s personal data where such data must be provided to law enforcement authorities in response to a disclosure request made in accordance with applicable law.
• 6.4. Cases of disclosure include:
  • 6.4.1. Disclosure of information, to the extent necessary, to Service Providers that support the functionality of the Platform. Such disclosure includes, among other things, the provision of depersonalised personal data of Users;
  • 6.4.2. Disclosure of information about the User in special cases, including on the basis of a request from an authorised body.
• 6.5. Personal data is transferred using personal data protection tools that ensure an adequate level of personal data security. Cross-border transfer of personal data is carried out on the grounds and within the limits established by applicable law, including for the purposes of ensuring the completeness, accuracy and reliability of the personal data of the User and/or his or her representative(s), compliance with national or international sanctions regimes, and combating the legalisation (laundering) of money and other property obtained by criminal means, the financing of terrorism, extremism and other unlawful activities.

7. Information Security

• 7.1. ArmFriend applies appropriate security measures to ensure the confidentiality of personal data. ArmFriend takes all organisational and technical measures within its control to protect the user’s personal information from unlawful or accidental access, destruction, alteration, blocking, copying, dissemination, and other unlawful actions by third parties. ArmFriend continuously improves its methods of collecting, storing and processing data, including physical security measures, to counter unauthorised access to its systems for the purpose of theft of property, phishing and other types of fraud.
• 7.2. ArmFriend stores personal data only for the period and to the extent established by applicable law. Paper copies and electronic data records are stored in specialised secure premises and systems that meet information security requirements and rules no less stringent than those established by Federal Law No. 152-FZ of 27 July 2006 “On Personal Data”.
• 7.3. Access to Users’ personal information is permitted only to authorised employees of the Operator. The list of authorised employees is established by order of the General Director or another authorised manager of ArmFriend.
• 7.4. The security of the use of the Service also depends on the user’s compliance with the following recommendations: the user must keep account details, such as login and password, secret from third parties and immediately notify ArmFriend of any suspected unauthorised use of his or her account or credentials. The user must restrict the access of unauthorised persons to the authentication means used in connection with the Service.

8. Control over Personal Data

• 8.1. Users independently choose the scope of collection, use and dissemination of their personal data.
• 8.2. The User may contact us via the request form at https://topfriend.ru/, by e-mail at team@atfmedia.com, via the account https://t.me/atf_ads in the Telegram messenger, or by any other lawful means should any changes to personal data be required, and we will make reasonable efforts to satisfy such a request.

9. Final Provisions

• 9.1. This Privacy Policy is provided “as is”. The User is not entitled to amend it unilaterally.
• 9.2. The Privacy Policy is publicly available at https://armfriend.com/. Users have access to this Policy at any time, without any restriction based on the users’ geolocation.
• 9.3. This Privacy Policy may be amended by ArmFriend unilaterally. We recommend that Users periodically review the terms of this Privacy Policy for changes. If the User does not agree with any amendments to this Policy, such User should cease using the Platform no later than 30 (thirty) days after such amendments take effect and notify ArmFriend of the termination of the processing of such user’s personal data.