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§Legal

Consent to Personal Data Processing

1. General

This Consent is given by the user of the company's website (the "Subject") for the processing of their personal data by the company (the "Operator") under Federal Law No. 152-FZ dated 27.07.2006 "On Personal Data" ("FZ-152"). The Consent is an integral part of the Subject's interaction with the website and the Operator's services.

2. Personal data operator

The Operator's full name, INN, OGRN, legal address, and contacts are stated in the Requisites section of the website. The person responsible for organising personal data processing is listed in Contacts.

3. Categories of data processed

The Operator processes the following categories:

  • Identification data: surname, name, patronymic, date of birth, citizenship, ID document details (series, number, issuing authority, date), INN.
  • Contact data: phone, email, messenger IDs (Telegram, WhatsApp), residential address.
  • Financial data: income sources, bank details, payment history with the Operator, 2-NDFL / 3-NDFL certificates, bank statements — only to the extent necessary for the deal and AML compliance.
  • Deal data: target investment parameters, selected property specs, documents sent to the seller or developer on the Subject's behalf.
  • Technical data: IP address, browser type, OS, pages visited, visit time, traffic source (collected automatically via cookies and similar).

4. Purposes

Personal data is processed for the following purposes:

  • concluding and performing the paid services agreement between the Subject and the Operator;
  • selecting properties per the Subject's criteria;
  • supporting the foreign real estate deal, including representation before the seller, developer, notaris, and authorities of the property's country;
  • complying with Russian AML law (Federal Law No. 115-FZ);
  • responding to the Subject's inquiries;
  • notifying the Subject of new properties and offers (subject to separately expressed marketing consent);
  • improving the website and services (analytics, anonymised data).

5. Legal bases

Processing is based on:

  • the Subject's consent expressed by active action (form submission, checkbox, sending a message);
  • conclusion and performance of a contract to which the Subject is a party;
  • the Operator's obligations under Russian law.

6. Processing methods

Processing is performed with automation (CRM, email, cloud services) and without (paper documents). The Operator implements organisational and technical measures to protect data from unauthorised access, modification, distribution, and destruction: encrypted transmission channels, access controls, regular backups, password protection.

7. Third-party sharing

Personal data may be shared with the following third parties strictly to the extent needed to provide services:

  • Operator's legal partners in the property's country (lawyers, notaris, brokers) — for deal preparation and support;
  • escrow-agent banks and payment operators — for payments;
  • tax consultants — under a separate agreement;
  • authorised state bodies of Russia and the property's country — upon duly formalised requests.

Sharing occurs under NDAs or as required by law.

8. Cross-border transfer

Data may be transferred cross-border to countries where properties are located (UAE, Vietnam, Indonesia) and to third jurisdictions where payment and legal partners operate (Kazakhstan, Armenia, UAE). Transfers comply with FZ-152, including prior Roskomnadzor notification where required and separate consent of the Subject.

9. Retention

Personal data is stored for the time necessary for the processing purposes, but not longer than: - 5 years after fulfillment of contract obligations — for clients with whom a deal was completed (per tax and AML law); - 3 years — for potential clients who did not sign a contract; - until consent withdrawal — for marketing communications.

After the retention period, data is destroyed or anonymised.

10. Subject rights

The Subject may:

  • receive information on the existence, nature, purposes and methods of processing;
  • request correction, blocking, or destruction of data if incomplete, outdated, inaccurate, or unlawfully obtained;
  • withdraw consent at any time by written notice to the Operator;
  • appeal the Operator's actions or omissions to Roskomnadzor or a court.

Upon consent withdrawal, the Operator stops processing and destroys data within 30 calendar days, except where retention is required by law.

11. Changes

The Operator may amend this Consent. The current version is published at a permanent link on the website.

12. Contacts

To exercise rights, withdraw consent, or receive processing information, the Subject contacts the Operator via the official email listed in Contacts.

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_This document is a working draft; the final wording is subject to review by the company's legal counsel._