PRIVACY POLICY

1.1. This Privacy Policy ("Policy") describes how Social Technologies LLC ("we," "us," or "Company") collects, uses, stores, and protects personal data when you use the Cabinet Partners web service ("Service").

1.2. This Policy applies to all personal data we may receive from users of the Service.

1.3. Company details:

• Full legal name: Social Technologies LLC
• Tax ID (INN): 9723159800
• Registration No. (OGRN): 1227700396571
• Address: 115193, Moscow, 5th Kozhukhovskaya st., bldg. 9, office 7p/6a/1
• CEO: Evgeny S. Pavlov
• Email: finance@cabinet.partners

1.4. Key definitions:

• Personal data — any information relating to an identified or identifiable natural person (data subject).
• Processing — any operation performed on personal data, whether automated or manual, including collection, recording, organization, storage, modification, retrieval, use, disclosure, erasure, or destruction.
• Data subject (User) — a natural person whose personal data is processed by the Company.
• Controller — Social Technologies LLC, which determines the purposes and means of personal data processing.

1.5. By registering for the Service, you agree to this Policy and the data processing practices described herein.

2.1. We process personal data on the following legal bases:

• Consent — you provide consent to data processing when you register for the Service;
• Performance of a contract — processing is necessary to provide access to the Service and fulfill our service obligations;
• Legal obligation — processing to comply with applicable tax and accounting requirements;
• Legitimate interests — processing server logs to ensure security, prevent fraud, and maintain Service operability, provided your rights and freedoms are not overridden.

3.1. We process personal data for the following purposes only:

3.2. We do not process personal data for purposes incompatible with those stated above.

4.1. We collect and process the following categories of personal data:

Data you provide during registration:

• Email address.

Data generated through Service use:

• Selected subscription plan.

Data collected automatically when you visit the Service:

• IP address;
• Browser information (User-Agent);
• Date and time of access (server log timestamps).

4.2. We do not process special categories of personal data (such as racial or ethnic origin, political opinions, religious beliefs, health data, or biometric data).

4.3. The personal data we process is not excessive in relation to the stated purposes.

5.1. Personal data is processed using the following methods:

• Automated processing — using computer systems (servers, Service software, databases).

5.2. Processing operations include: collection, recording, organization, storage, modification (updating, changing), retrieval, use, disclosure (transfer), blocking, erasure, and destruction.

5.3. Personal data is stored in databases on our own servers.

5.4. We maintain the confidentiality of personal data during processing.

6.1. We retain personal data for the following periods:

6.2. After the retention period expires, personal data is destroyed in accordance with Section 7 of this Policy.

7.1. Personal data is deleted when:

• the purposes of processing have been achieved or are no longer necessary;
• the retention periods specified in Section 6 have expired;
• you withdraw your consent to processing;
• unlawful processing is discovered;
• a request is received from you or a competent data protection authority.

7.2. Personal data is deleted within 30 (thirty) days of the grounds for deletion arising, unless a different period is required by law.

7.3. Deletion is carried out by permanently removing records from the database. A record of destruction is maintained.

8.1. We may share personal data with third parties in the following cases:

• you have provided consent;
• sharing is required by applicable law;
• sharing is necessary to perform our contract with you.

8.2. We share personal data with the following categories of recipients:

8.3. When engaging third-party data processors, we enter into data processing agreements that include confidentiality and security obligations.

8.4. We take appropriate measures to ensure that any international transfer of personal data complies with applicable data protection requirements.

9.1. We and any persons with access to personal data are obligated not to disclose or distribute personal data without your consent, except as required by law.

9.2. Confidentiality obligations apply to all Company employees with access to personal data and to any third parties processing data on our behalf.

10.1. We implement appropriate organizational and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, disclosure, distribution, and other unlawful processing.

10.2. Our security measures include:

Organizational measures:

• designation of a data protection officer;
• internal policies and procedures for data processing;
• employee training on data protection requirements;
• regular internal audits of data processing compliance.

Technical measures:

• access controls and role-based permissions;
• encrypted connections (HTTPS/TLS) for all data transmission;
• data stored on our own servers with restricted physical and logical access;
• regular database backups;
• server log monitoring for unauthorized access detection.

10.3. In the event of a personal data breach, we will take immediate steps to mitigate the impact and notify the relevant supervisory authority as required by applicable law.

11.1. As a data subject, you have the right to:

• request information about how your personal data is processed;
• request correction, blocking, or deletion of your personal data if it is incomplete, outdated, inaccurate, or no longer necessary for the stated purposes;
• withdraw your consent to data processing by sending notice to finance@cabinet.partners;
• file a complaint with the relevant data protection authority or seek judicial remedy;
• claim compensation for damages caused by unlawful data processing.

11.2. To exercise your rights, send a request to: finance@cabinet.partners or by mail to: 115193, Moscow, 5th Kozhukhovskaya st., bldg. 9, office 7p/6a/1.

12.1. We are obligated to:

• inform you about data processing when collecting personal data;
• respond to your requests regarding data processing within 10 (ten) business days;
• cease unlawful processing within 3 (three) business days of discovery;
• cease processing and delete personal data within 30 (thirty) days of receiving a withdrawal of consent, unless retention is required by contract or law;
• make this Policy publicly available;
• conduct internal audits of data processing compliance.

13.1. Personal data is stored on our own servers. We comply with applicable data localization requirements.

13.2. Any cross-border transfer of personal data is conducted in compliance with applicable data protection requirements.

14.1. The Service uses cookies — small text files placed on your device when you visit the Service.

14.2. We use the following categories of cookies:

14.3. Our cookies do not contain personal data in plain text and are not used for marketing tracking.

14.4. You can manage cookies through your browser settings. However, disabling cookies may limit Service functionality.

15.1. We may update this Policy from time to time. The date of the last update is indicated at the top of this document.

15.2. The updated Policy takes effect upon publication on the Service website, unless otherwise specified.

15.3. The current version of this Policy is publicly available on the Service website.

15.4. Continued use of the Service after changes to this Policy constitutes your acceptance of the updated Policy.

16.1. This Policy is a publicly available document.

16.2. For any questions about personal data processing, you may contact us:

• Email: finance@cabinet.partners
• Mail: 115193, Moscow, 5th Kozhukhovskaya st., bldg. 9, office 7p/6a/1

16.3. You also have the right to file a complaint with the relevant data protection supervisory authority in your jurisdiction.