PRIVACY POLICY

1. GENERAL PROVISIONS
1.1. This document (hereinafter referred to as the Policy) defines the policy regarding the
processing of personal data of users of the website of Aeropilot Limited Liability Company,
Taxpayer Identification Number (INN): 7814759008, Primary State Registration Number
(OGRN): 1197847118336, registration address: 197374, St. Petersburg, Primorsky Prospekt ,
Building 137, Bldg. 1, Letter A, Room 344N, Workplace 2 (hereinafter referred to as the Operator)
on the website in the information and telecommunications network Internet at the address:
https://foxpoint-heli.ru (hereinafter referred to as the Site).
1.2. This Policy has been developed on the basis of paragraph 2 of part 1 of article 18.1 of the
Federal Law of 27.07.2006 No. 152-FZ «On Personal Data», as well as the Recommendations
for drafting a document defining the operator’s policy regarding the processing of personal data,
in the manner established by the Federal Law of 27.07.2006 No. 152-FZ «On Personal Data».
1.3. In compliance with the requirements of Part 2 of Article 18.1 of the Federal Law of July
27, 2006 No. 152-FZ «On Personal Data», the Policy is published in the public domain
on the Operator’s Website at: https://foxpoint-heli.ru .
1.4. This Policy applies only to the Website. The Operator does not control
and is not responsible for third-party websites that the User may access via links available on the
Website.
1.5. This Policy applies to all information that the Operator may receive about website
visitors. https://foxpoint-heli.ru .
1.6. This Policy is subject to update at the initiative of the Operator, as well as
in the event of changes in the legislation of the Russian Federation on personal data.
2. DEFINITIONS
2.1. For the purposes of this Policy, the following terms are used
with the following meaning:
Automated processing of personal data is the processing of personal data using computer
technology;
Blocking of personal data is a temporary cessation of the processing of personal data (except
in cases where processing is necessary to clarify personal data);
Website (Site) – a collection of graphic and informational materials, as well as computer
programs and databases, ensuring their availability on the Internet at the network address:
https://foxpoint-heli.ru ;
Personal data information system – a set of personal data contained in databases and the
information technologies and technical means that ensure their processing;
Depersonalization of personal data – actions as a result of which it is impossible to determine,
without the use of additional information, the ownership of personal data by a specific User or
another Subject of personal data;
Processing of personal data – any action (operation) or set of actions (operations) performed
with the use of automation tools or without the use of such tools with personal data, including
collection, recording, systematization, accumulation, storage, clarification (updating,
modification), extraction, use, transfer (distribution, provision, access), depersonalization,
blocking, deletion, destruction of personal data;
Operator – Aeropilot LLC, a legal entity that independently or jointly with other persons
organizes and (or) carries out the processing of personal data, as well as determines the purposes
of processing personal data, the composition of personal data to be processed, actions (operations)
performed with personal data;
Personal data – any information relating directly or indirectly to a specific or identifiable User
of the website https://foxpoint-heli.ru ;
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User – any visitor to the website https://foxpoint-heli.ru ;
Provision of personal data – actions aimed at disclosing personal data to a specific person
or a specific group of persons;
Dissemination of personal data – any actions aimed at disclosing personal data to an indefinite
number of persons (transfer of personal data) or familiarizing an unlimited number of persons with
personal data, including the publication of personal data in the media, posting on information and
telecommunications networks or providing access to personal data in any other way;
Data Subject, Subject – an individual who can be directly or indirectly identified using
personal data.
Cross-border transfer of personal data – transfer of personal data to the territory of a foreign
state to a foreign government body, a foreign individual or a foreign legal entity;
Destruction of personal data – any actions as a result of which personal data are irrevocably
destroyed with the impossibility of further restoration of the content of personal data in the
personal data information system and (or) as a result of which the tangible media of personal data
are destroyed.
3. LEGAL BASIS FOR PERSONAL DATA PROCESSING
3.1. The legal grounds for processing personal data by the Operator are:
•Constitution of the Russian Federation;
•Civil Code of the Russian Federation;
•Federal Law of July 27, 2006 No. 149-FZ «On Information, Information Technologies and
Information Protection»;
•Decree of the President of the Russian Federation of 06.03.1997 No. 188 “On approval of
the List of confidential information”;
•Resolution of the Government of the Russian Federation of 01.11.2012 No. 1119 «On
approval of the Requirements for the protection of personal data when processing them
in personal data information systems»;
• the User’s consent to the processing of personal data on the Site.
3.2. The Operator processes the User’s personal data only if it is filled in and/or sent by
the User independently through special forms located on the website https://foxpoint-heli.ru .
3.3. By filling out the relevant forms and/or sending their personal data to the Operator, the
User expresses their consent to this Policy.
3.4. The Operator processes anonymized data about the User if this is permitted in the User’s
browser settings (the storage of cookies and the use of JavaScript technology are enabled).
4. PURPOSES OF PERSONAL DATA PROCESSING
4.1. The Operator processes personal data with due regard for the protection of the rights and
freedoms of personal data subjects, including the right to privacy and personal and family
confidentiality. Only personal data that is relevant to the purposes for which it is processed
is subject to processing.
4.2. The Operator processes the User’s personal data for the following purposes:
4.2.1.Conclusion, execution, modification, termination of civil law contracts with the Subject.
4.2.2.Informing about the operation of the Site, including through the use of Internet statistics
services (hereinafter, the «Services»), monitoring and improving the quality of the Services.
4.2.3.Providing the User with access to personalized resources of the Site.
4.2.4.Establishing feedback with the User, including (but not limited to) sending notifications,
requests regarding the use of the Site, provision of services, performance of work, processing
of requests and applications from the User.
4.2.5.Creating an account to facilitate the User’s order processing.
4.2.6.Providing the User with effective customer and technical support in the event
of problems related to the use of the Site.
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4.2.7.Sending advertising and informational mailings, informing about new products,
services, promotions, and special offers (with the User’s consent). The User has the right to
unsubscribe from receiving informational messages at any time by sending an email to
the Operator at info@foxpoint-heli.ru with the subject line «Unsubscribe from notifications about
new products, services, and special offers.»
4.2.8.Anonymized data of Users collected using Internet statistics services is used for the
collection of information about Users’ actions on the Site and to improve the quality of the Site
and its content.
5. VOLUME AND CATEGORIES OF PROCESSED PERSONAL DATA,
CATEGORIES OF PERSONAL DATA SUBJECTS
5.1. The Operator may process personal data of the following Subjects:
5.1.1.The Operator’s counterparties are individuals and representatives of counterparties
that are legal entities;
5.1.2.Site Visitors.
6. PERSONAL DATA PROCESSED BY THE OPERATOR
6.1. Last name, first name, patronymic of the User.
6.2. Mobile phone number.
6.3. Residential address or other address specified when concluding an agreement
with the Operator.
6.4. Email address ( e-mail ).
6.5. Aircraft registration number.
6.6. Data that is automatically transferred to the Site’s Services during their use using software
installed on the User’s device, namely: IP address, cookie data , information about the User’s
browser (or other program used to access the Services), technical characteristics of the equipment
and software used by the User, date and time of access to the Services, addresses of requested
pages, history of requests and views on the Site and its Services.
7. PROCEDURE AND CONDITIONS FOR PROCESSING PERSONAL DATA
7.1. The Operator processes personal data in accordance with the requirements of
the legislation of the Russian Federation in the following ways:
— non-automated processing of personal data;
— automated processing of personal data with or without the transfer of received information
via information and telecommunication networks;
— mixed processing of personal data.
7.2. The list of actions performed by the Operator with the User’s personal data for
the purposes specified in Section 4 of this Policy: collection, recording, systematization,
accumulation, storage, clarification (updating, modification), transfer (provision of personal data
to third parties, granting third parties access to personal data), distribution, depersonalization,
blocking, destruction on the territory of the Russian Federation in accordance with the current
legislation of the Russian Federation.
7.3. Personal data is transferred to third parties only for specific purposes and in strict
compliance with current Russian legislation. Personal data may be transferred to, but is not limited
to, the following third parties (contractors, IT service providers and automation systems,
and government agencies).
7.4. The processing of personal data is carried out by the Operator subject to the receipt of the
User’s consent (hereinafter referred to as the Consent), obtained in accordance with
the requirements of Federal Law No. 152-FZ of July 27, 2006 «On Personal Data», with
the exception of cases established by the legislation of the Russian Federation when the processing
of personal data may be carried out without such Consent.
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7.5. The user decides to provide his personal data and gives consent voluntarily, of his own
free will and in his own interests.
7.6. The period for processing personal data is determined by the achievement of the purposes
for which the data was collected, unless another period is provided by agreement or legislation.
7.7. The processing of personal data required for registering a User account is carried out for
the duration that the User’s account remains active.
7.8. The processing of personal data necessary for the execution of civil contracts (lease,
provision of services, contracting and other contracts) is carried out during the term of such
contract and the limitation period after its expiration for the resolution of possible claims.
7.9. The processing of personal data collected for marketing purposes (mailing) continues
until the consent is revoked by the Subject.
7.10. After the expiration of the specified periods or upon withdrawal of consent, personal
data is subject to anonymization or destruction, unless otherwise required to comply with the
requirements established by the legislation of the Russian Federation.
7.11. Consent may be revoked by sending a written statement (request) to the Operator at the
email address: info@foxpoint-heli.ru to revoke consent to the processing of personal data, marked
«Revocation of consent to the processing of personal data.»
7.12. The Operator distributes personal data authorized for distribution by the User, i.e.,
performs actions aimed at disclosing it to an indefinite number of persons, in compliance with the
requirements, prohibitions, and conditions established by Part 9 of Article 9 and Article 10.1
of Federal Law No. 152-FZ of July 27, 2006, «On Personal Data.» Disclosure to third parties and
distribution of personal data is prohibited without the User’s consent, unless otherwise provided
by federal law. Consent to the processing of personal data authorized for distribution by the User
is issued separately from other consents of the User to the processing of their personal data, taking
into account the Requirements for the Content of Consent to the Processing of Personal Data
Authorized for Distribution by the Personal Data Subject, approved by Order No. 18
of Roskomnadzor dated February 24, 2021.
7.13. When processing personal data, the operator shall take or ensure taking the necessary
legal, organizational and technical measures to protect personal data from unauthorized or
accidental access, destruction, modification, blocking, copying, provision, distribution of personal
data, as well as from other illegal actions in relation to personal data.
7.14. Personal data shall be stored in a form that allows the User to be identified, for a period
no longer than required by the purposes of processing the personal data, except in cases where the
storage period for personal data is established by federal law, an agreement to which the User is
a party, beneficiary, or guarantor .
8. BLOCKING, CLARIFICATION AND DESTRUCTION OF PERSONAL DATA
8.1. Upon receipt of a request or request to identify unlawful processing or inaccuracy of
personal data from the User, their representative or authorized body, the Operator blocks the
relevant data for the verification period, unless this violates the rights of the User or third parties.
8.2. If the inaccuracy of the data is confirmed, the Operator will clarify it within 7 (seven)
working days based on the information provided.
8.3. If unlawful processing is detected, the Operator will cease such processing within
3 (three) business days . If lawful processing cannot be ensured, the data will be destroyed within
10 (ten) business days .
8.4. Once the processing purposes are achieved, personal data are destroyed within a period
of 30 (thirty) days, unless otherwise provided by agreement or legislation.
8.5. If consent is revoked and there are no other grounds for processing, the data shall be
destroyed within 30 (thirty) days from the date of receipt of the revocation.
8.6. If the User provides confirmation of the illegal receipt of data or its inconsistency with
the purposes of processing, such data will be destroyed within 7 (seven) working days .
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8.7. Data is subject to destruction when there is no longer a need for its processing, unless
otherwise provided by federal law.
9. CROSS-BORDER TRANSFER OF PERSONAL DATA
9.1. The operator does not carry out cross-border transfer of personal data.
10. BASIC RIGHTS AND RESPONSIBILITIES
10.1. The operator has the right:
10.1.1. Receive from the Subject accurate information and/or documents
10.1.2. Require the Personal Data Subject to promptly clarify the personal data provided.
10.2. The operator is obliged to:
10.2.1. Process personal data in accordance with the procedure established by the current
legislation of the Russian Federation.
10.2.2. Consider requests from the Personal Data Subject (his/her legal representative)
regarding the processing of personal data and provide reasoned responses.
10.2.3. Provide the Subject of Personal Data (his/her legal representative) with the opportunity
of free and unrestricted access to his/her personal data.
10.2.4. Take measures to clarify and destroy the personal data of the Personal Data Subject in
connection with his (his legal representative’s) appeal with legal and justified demands.
10.2.5. Organize the protection of personal data in accordance with the requirements of
the legislation of the Russian Federation.
10.3. Personal data subjects have the right to:
10.3.1. To receive full information about their personal data processed by the Operator.
10.3.2. To access their personal data, including the right to receive a copy of any record
containing their personal data, except in cases provided for by federal law.
10.3.3. To clarify their personal data, block it or destroy it in cases where the personal data is
incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated purpose of
processing;
10.3.4. To revoke consent to the processing of personal data.
10.3.5. To take measures provided by law to protect their rights.
10.3.6. To exercise other rights provided for by the legislation of the Russian Federation.
10.4. Personal data subjects are obliged to:
10.4.1. Provide the Operator with accurate personal data.
10.4.2. Provide documents containing personal data to the extent necessary for the purpose of
processing.
10.4.3. Notify the Operator about clarification (updating, changing) of your personal data.
10.5. Persons who have provided the Operator with false personal data or pertaining to
another personal data subject subject without the latter’s consent shall be liable
in accordance with the legislation of the Russian Federation.
11. RESPONSIBILITY OF THE PARTIES
11.1. The operator is responsible for violating the requirements of the Federal Law of July
27, 2006 No. 152-FZ «On Personal Data» in accordance with the legislation of the Russian
Federation.
11.2. In the event of disputes and/or disagreements arising from the relationship between the
User and the Operator, such issues shall be resolved in accordance with the current legislation
of the Russian Federation.
12. FINAL PROVISIONS
12.1. The Operator reserves the right to make changes to the Policy without the User’s
consent.
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12.2. The new version of the Policy shall come into force from the moment it is posted on
the Website, unless otherwise provided by the new version of the Policy.
12.3. The new version of the Policy applies to relations that arose after its entry into force.