PRIVACY POLICY

Revision Date:

January 23, 2024

1. This Privacy Policy (hereinafter referred to as the "Policy") is an official document of LLC "Prorok", TIN: 7717695461, OGRN: 1117746204730, address: 117218, Moscow, Kedrova street, 14, c. 1, p. I, floor 5, room 24 (hereinafter referred to as the "Company") and defines the procedure for processing and protecting information about individuals using the services of the website: https://prorokfilm.com (hereinafter referred to as the "Site").

2. The Privacy Policy applies to all information and data that the Company may obtain about users of the global Internet who use the Site (hereinafter referred to as the "User") and its services, and is aimed at regulating the provision of proper protection of information about users, including their personal data, from unauthorized access and disclosure. Issues related to the collection, storage, distribution, and protection of information about Users may be supplemented and set out in other official documents of the Company and in the norms of the current Russian legislation.

3. An integral part of the Policy is the user agreement located at: https://prorokfilm.com/user-agreement (hereinafter referred to as the "User Agreement") and the documents specified in the User Agreement (hereinafter referred to as the "Documents").

4. In this Policy, the following terms and definitions are used in the meaning indicated in accordance with the User Agreement: Site, Company, User, Documents.

Other terms and definitions may be provided in the text of the Policy.

5. The use of the Site, including any services of the Site, is governed by the Documents.

6. If the User does not agree with the terms of the Policy, in order to terminate the effect of the Policy regarding them, the User must cease using the Site, including by visiting the Site.

7. By using the Site and/or any Service of the Site, in any way and in any form within its declared functional capabilities, including: accessing the Site or any services of the Site; other use of the functional capabilities of the Site or any services of the Site, the User confirms that:

a. They have read the terms of the Policy and the Documents in full before starting to use the Site or any services of the Site.

b. They accept all the terms of the Policy and Documents in full without any exemptions and restrictions from the User's side and undertake to comply with them, or in case of disagreement with any terms, the User must refrain completely from using the Site or any services of the Site in any form.

8. The Policy (including any of its parts) and/or the Documents (including any of their parts) may be amended by the Company without any special notice to the Users. The new edition of the relevant documents comes into force from the moment of posting on the Site. The User undertakes to independently check for changes in the specified documents.

9. The following basic concepts are used in the Policy:

• automated processing of personal data — processing of personal data using computer technology;
• blocking of personal data — temporary suspension of the processing of personal data (except in cases where processing is necessary to clarify personal data);
• information system of personal data — a set of personal data contained in databases and ensuring their processing by information technologies and technical means;
• depersonalization of personal data — actions that make it impossible to determine the belonging of personal data to a specific subject of personal data without using additional information;
• processing of personal data — any action (operation) or set of actions (operations) performed with personal data using automation tools or without using such tools, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data;
• operator — a state body, municipal body, legal or natural person, independently or jointly with other persons, organizing and (or) carrying out the processing of personal data, as well as determining the purposes of processing personal data, the composition of personal data subject to processing, actions (operations) performed with personal data;
• personal data — any information related directly or indirectly to a identified or identifiable individual (subject of personal data);
• provision of personal data — actions aimed at disclosing personal data to a specific person or a specific circle of persons;
• dissemination of personal data — actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or acquainting with personal data by an unlimited number of persons, including disclosure of personal data in the media, placing in information and telecommunication networks, or providing access to personal data in any other way;
• cross-border transfer of personal data — transfer of personal data to the territory of a foreign state to the authority of a foreign state, foreign individual, or foreign legal entity;
• destruction of personal data — actions that make it impossible to restore the content of personal data in the information system of personal data and (or) actions resulting in the destruction of material carriers of personal data.

10. Personal information of Users received and processed by the Site:

a. Within this Policy, "User Personal Information" means:

• personal information (including personal data) provided by the User voluntarily when filling out the feedback form on the Site, to the extent minimally necessary for sending data to the Site: name, company name, email address, and contact phone number;
• mandatory information for providing includes: name, company name, valid email address, contact phone number, as well as agreement with the terms of the Documents.

b. Data automatically transmitted to the Site for their use through software installed on the User's device during technological interaction, including:

• electronic data: host IP address (User's unique computer number), information from cookies (allowing identification of the User's browser and storing User settings and other information), information about the User's browser (or other program used to access the Site), access time, requested page address, user operating system type, browser type, date and time of access to the Site and/or Services;
• information about User activity during the use of the Sites and/or Services (e.g., search history; files stored on the Company's server uploaded by users);
• geolocation information;
• other User information necessary for processing in accordance with the terms regulating the use of a specific Site.

c. Information received by the Company from its partners in accordance with the terms of agreements concluded between the User and the respective partner, and agreements concluded between the Company and the partner.

d. The Company may use cookies to collect Personal Information and associate such personal information with the User's device and web browser (detailed in the Cookies Policy).

11. This Policy applies only to the Site. The Company does not control or take responsibility for third-party websites and software that Users may access through links available on the Site, and for the use of personal information provided by the User on third-party sites.

12. The Company does not verify the accuracy of the Personal Information provided by Users and does not control their legal capacity, assuming that the User provides accurate and sufficient Personal Information and keeps this information up to date.

13. By posting information on their personal page, including their personal data, the User acknowledges and agrees that such information may be accessible to other Internet users considering the architectural and functional features of the Site.

14. Objectives of collecting and processing User Personal Information:

a. The Company collects and stores only User Personal Information necessary for providing services (fulfilling agreements and contracts with the User).

b. User Personal Information may be used by the Company for the following purposes:

• to identify the User within the Site and Site services;
• to provide Site Users with the opportunity to use services of the database owner, identifying Site Users to provide them with individual environments and service settings of the database owner;
• for marketing goods, works, services on the market by making direct contacts with the Site User through communication means (including displaying advertisements to users that match their interests);
• to enable communication with the Site User, sending notifications, requests, and information to them, as well as receiving and processing requests, complaints, and applications from Site Users by the Site support service conducted by the Company;
• for analysis and research of User preferences to improve the Service;
• for sending news, advertising, survey, statistical, marketing, and other information about the Site or services of the Company's partners;
• to prevent and detect fraud and illegal use of the Service;
• for selling goods and services to Site Users via the Internet;
• to conduct promotions, incentive lotteries, and contests for Site Users;
• to conduct marketing, statistical, and audit research, including User satisfaction surveys on the Site;
• to provide access to third-party websites and services.

If it is necessary to use User Personal Information for purposes not mentioned in this Policy, the Company requests prior consent/permission from the User.

15. Terms of processing User Personal Information and its transfer to third parties:

a. Processing of User personal data (User Personal Information) by the Company is carried out in accordance with the legislation of the Russian Federation and additionally, where applicable, in accordance with the General Data Protection Regulation (GDPR) of the European Union.

16. Principles of processing personal data:

a. Processing of personal data by the operator is based on the following principles:

• legality and fairness;
• limitation of processing personal data to achieve specific, predetermined, and legitimate goals;
• prohibition of processing personal data incompatible with the purposes of collecting personal data;
• prohibition of combining databases containing personal data processed for purposes incompatible with each other;
• processing only those personal data that meet the purposes of their processing;
• compliance with the content and volume of processed personal data with the stated purposes of processing;
• prohibition of processing personal data excessive in relation to the stated purposes of their processing;
• ensuring the accuracy, sufficiency, and relevance of personal data in relation to the purposes of processing personal data;
• destruction or depersonalization of personal data upon achieving the goals of their processing or in case of loss of the need to achieve these goals, if it is impossible to eliminate violations of personal data committed by the Operator, unless otherwise provided by federal law.

b. User Personal Information is kept confidential, except in cases of voluntary provision of information by the User about themselves for general access to an unlimited number of persons.

c. The Company has the right to transfer User Personal Information to third parties, as well as the results of automated processing of such data based on various information evaluation models, in the form of integer and/or text values and identifiers corresponding to the evaluation criteria specified in requests, for processing by the Company and/or persons specified in this paragraph in the following cases (in all cases, Personal Information will be processed only for the purposes outlined in the Policy, unless otherwise provided by the terms of use of the Sites and/or Services of such third parties):

• the Company may transfer User Personal Information to its employees (within the limits established by the Policy), and its affiliated entities, including other companies within the group of entities to which the Company may belong;
• the User has expressed consent to such actions;
• the transfer is necessary for providing a service to the User, or the transfer of Personal Information is required to provide the corresponding Service or perform a specific agreement or contract concluded with the User;
• the transfer is necessary to comply with the requirements of the current legislation of the Russian Federation (including to prevent and/or suppress illegal and/or unlawful actions by Users) and/or international regulatory legislation. Disclosure of User-provided information may only be made in accordance with the current legislation of the Russian Federation upon the request of the court, law enforcement agencies, as well as in other cases provided for by the legislation of the Russian Federation;
• the transfer is made to the Company's partners (rights holders of audiovisual works posted on the site and regarding which services are provided to the User, owners of websites and applications, advertising networks, and other partners providing services to the Company, including related to the placement and display of advertisements on websites, programs, products, or services owned or controlled by such partners);
• the transfer is made to third parties in relation to which rights or obligations have been assigned, or novation has been made under the relevant agreement;
• the transfer is made to any third party for the purpose of ensuring legal protection of the Company or third parties in case of User violation of the provisions of the Documents, or in a situation where there is a threat of such violation.

17. Measures taken to protect User Personal Information:

a. The Company takes necessary and sufficient organizational and technical measures to protect User Personal Information from unauthorized access, destruction, alteration, blocking, copying, distribution, as well as from other unlawful actions of third parties concerning it.

b. The Company provides access to User Personal Information only to those employees, contractors, and partners of the Company who need this information to ensure and enhance the functioning of the Site and to provide services to the User, and only to the extent necessary and appropriate for the processing purposes specified in clause 2 of this Policy. Accordingly, Personal data is processed automatically without access to it by any of the Company's employees or third parties. If such access is needed, it may be provided only to those employees of the Company or third parties who need it to perform their tasks. To protect and ensure the confidentiality of data, all employees must comply with internal rules and procedures regarding the processing of Personal Information. They must also adhere to all technical and organizational security measures in place to protect users' personal data.

c. Taking into account the current level of technology, the cost of their implementation, the risks associated with the processing, and the nature of personal data, the Company implements and constantly improves sufficient technical and organizational measures to protect users' personal data from unauthorized, accidental, or unlawful destruction, loss, alteration, unauthorized use, disclosure, or access, as well as from other unlawful forms of processing.

d. The Company does not guarantee the security of data transmitted by the User to the Site and its services, unauthorized access to which may be obtained by third parties as a result of any unlawful actions. Any data transmission is done by the User at their own risk.

18. Procedure for storing User Personal Information:

a. Recording, systematization, accumulation, storage, clarification (updating, changing), retrieval of personal data of Russian citizens is stored by the Company exclusively on server capacities located in the territory of the Russian Federation.

b. For users from the European Economic Area or Switzerland: Russia is a jurisdiction outside the European Economic Area that has not been recognized by the European Commission as providing an adequate level of protection for personal data. Therefore, for such Users, the Company takes appropriate measures to ensure that such transfer is carried out in accordance with the applicable EU data protection rules.

c. The Company must ensure that a foreign state, to whose territory it is supposed to transfer personal data, provides adequate protection of the rights of personal data subjects before starting such transfer.

d. Transborder transfer of personal data to the territory of foreign states that do not provide adequate protection of the rights of personal data subjects may be carried out in cases:

• with the written consent of the personal data subject to the transborder transfer of their personal data;
• performance of a contract where the personal data subject is a party.

19. Rights and obligations of Users:

a. If provided for by applicable law, the User has the right to access their Personal Information processed by the Company in accordance with this Policy.

b. If a User believes that any information held by the Company about them is incorrect or incomplete, the User has the right to request the Company to clarify their personal data, block or destroy it if such data is incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the stated processing purpose.

c. If provided for by applicable law, the User has the right to:

• request the deletion of their Personal Information;
• request restrictions on the processing of their Personal Information;
• object to the processing of their Personal Information if provided for by applicable law.

d. The Company will fulfill the above requests in accordance with applicable law.

e. In cases provided for by applicable law, you may also have other rights not mentioned above.

f. Users have the right to send their requests to the Company, including requests regarding the use of their personal data, in writing to the address specified in this Policy, or in the form of an electronic document signed with a qualified electronic signature in accordance with Russian Federation legislation, to the email address: kinoprorok@inbox.ru Each such request must contain the following information:

• the number of the main document identifying the user or their representative;
• information about the date of issue of the specified document and the issuing authority;
• email address provided by the User when filling out the feedback form on the Site;
• the signature of the User or their representative.

g. The Company considers and responds to the User's request within 30 (thirty) days from the date of receipt of the request.

h. All correspondence received by the Company from Users (requests in written or electronic form) is treated as limited access information and is not disclosed without the written consent of the User. Personal data and other information about the User who sent the request may not be used without the User's special consent, except in cases provided by this Policy or for responding to the subject matter of the request received, or as directly provided by law.

20. Other Terms:

a. The Company does not control and is not responsible for the websites and services of third parties that the User may access through links/buttons available on the Site, as well as for the content of such websites and services.

b. Any changes to the policy come into effect from the moment of publishing a new version of the Policy on the Site. Continuing to use the Site after the publication of a new version of the policy on the Site will signify the User's agreement to the changes in the policy. In case of disagreement with the changes in the policy that have come into force, the user must independently stop using the Site.

c. The applicable law for this Policy is the law of the Russian Federation.

d. All disputes regarding the Policy are resolved in accordance with the current legislation of the Russian Federation at the location of the Company.