PRIVACY POLICY

POLICY
on Personal Data Processing and Protection

1. General Provisions

1.1. This Policy on Personal Data Processing and Protection (hereinafter referred to as the «Policy») of LLC «S.E.A. Company» (MSRN 5137746162032, TAX ID 7728864231) (hereinafter referred to as the «Operator») describes the Operator’s principles and approaches to the processing and protection of personal data (hereinafter referred to as «Personal Data» or «PD»), as well as the Operator’s obligations and liability in carrying out such processing and protection.
1.2. This Policy applies to the website https://sea-company.com (hereinafter referred to as the «Website»).
1.3. The Operator fully ensures compliance with the rights and freedoms of individuals when processing Personal Data and takes measures to ensure fulfillment of obligations established by Federal Law No. 152-FZ dated 27 July 2006 «On Personal Data» and other regulatory legal acts adopted pursuant thereto.

2. The categories of Personal Data Subjects whose Personal Data is processed by the Operator include:

● visitors and users of the Operator’s Website;
● customers and clients who have entered into an agreement with the Operator;
● prospective customers, clients, and counterparties who have provided their data for the purpose of obtaining a commercial proposal.

3. Personal Data is processed for the following purposes:

● providing Personal Data Subjects with access to the functional capabilities of the Operator’s Website;
● conclusion and performance of contracts, as well as fulfillment of obligations related thereto;
● verification of the Personal Data Subject’s information as a client/prospective client, customer, or counterparty of the Operator;
● analysis of the effectiveness of the Operator’s web resources (Website), evaluation of media, search engine, and social advertising channels, analysis of conversion rates, adaptation of the Website to business objectives, and assessment of mobile traffic volumes;
● preparation and provision of responses to requests submitted by Website Users;
● communication, sending messages, notifications, requests, responses, payment and settlement documents, and other legally significant documents;
● sending advertising and informational communications via email, SMS, messengers, and other communication channels;
● exercising rights and fulfilling obligations established by the legislation of the Russian Federation.

4. Categories of Personal Data Processed

4.1. With respect to the categories of Personal Data Subjects «users», «prospective customers/clients», «customers», and «clients», the Operator processes general categories of Personal Data.
4.2. The following Personal Data may be processed:
● surname, first name, and patronymic;
● email address;
● telephone number;
● year, month, date, and place of birth;
● photographs;
● IP address;
● cookies;
● data collected through web analytics tools (including Yandex.Metrica);
● any other Personal Data voluntarily provided by the Personal Data Subject.

5. Personal Data Retention Periods Depending on the Purpose of Processing

6. Legal Grounds for Personal Data Processing

6.1. The legal basis for Personal Data processing consists of regulatory legal acts pursuant to and in accordance with which the Operator processes Personal Data, including:
● the Constitution of the Russian Federation;
● Federal Law No. 152-FZ of 27 July 2006 «On Personal Data» (hereinafter referred to as «152-FZ»);
● agreements concluded with the Personal Data Subject;
● the consent of the Personal Data Subject to the processing of Personal Data.

7. Procedure and Conditions for Personal Data Processing

7.1. The processing of personal data by the Operator is carried out in compliance with the principles and rules provided for by Federal Law No. 152-FZ dated 27.07.2006 "On Personal Data" and this Policy.
7.2. The processing of personal data is carried out with the consent of the subjects of personal data, unless otherwise follows from the legislation of the Russian Federation.
7.3. Consent to the processing of personal data may be revoked by the personal data subject, unless otherwise provided by the legislation of the Russian Federation. In case of withdrawal of consent by the subject, the Operator stops processing them or ensures the termination of such processing, and if the storage of personal data is no longer required for the purposes of personal data processing, destroys the personal data or ensures their destruction within a period not exceeding thirty days from the date of receipt of the said withdrawal, unless otherwise provided by contract or law.
7.4. If the purpose of personal data processing is achieved, the Operator stops processing personal data or ensures its termination and destroys personal data or ensures their destruction within a period not exceeding thirty days from the date of achievement of the purpose of personal data processing, unless otherwise provided by contract or law.
7.5. The processing of personal data is carried out by the Operator in the following ways:
● using computer technology (automated processing);
● with direct human involvement without the use of computer technology (non-automated processing).
7.6. Only those employees of the Operator whose job responsibilities include processing personal data are allowed to process personal data.
7.7. These employees have the right to receive only those personal data that they need to perform their official duties.
7.8. The operator has the right to entrust the processing of personal data to another person on the basis of an agreement concluded with this person, including a state or municipal contract.
7.9. The Operator cooperates with a number of partners to ensure the operation of its websites and the provision of services. Such partners process personal data only according to the Operator's instructions and in accordance with them. For example, personal data can be processed for the purposes of information, consulting services, hosting, search for performers, and analytics.

8. Confidentiality of personal data and the possibility of transferring personal data to third parties

8.1. Access to personal data is limited in accordance with the legislation of the Russian Federation and the Operator's local legal acts on the processing and protection of personal data. The operator does not disclose or distribute personal data to third parties without the consent of the personal data subject, unless otherwise provided by federal law.
8.2. Access to personal data processed by the Operator on the basis of and in compliance with regulatory legal acts is provided to authorized state authorities upon request.
8.3. The transfer of personal data to authorized executive authorities and organizations (the Ministry of Internal Affairs of the Russian Federation, the Ministry of Foreign Affairs of the Russian Federation, the Federal Tax Service, the Pension Fund of the Russian Federation, the Federal Compulsory Medical Insurance Fund of the Russian Federation, and others) is carried out in accordance with the requirements of the legislation of the Russian Federation.
8.4. The transfer of personal data is possible in cases stipulated by the concluded Agreement between the Personal Data Subject and the Operator for the purpose of fulfilling the Agreement and the instructions of the Personal Data Subject.
8.5. The Operator cooperates with a number of partners to ensure the operation of its Services, Websites and services. Such partners process personal data only on the instructions of the Operator and in accordance with them. For example, personal data may be processed by providers and contractors for the purposes of information, consulting services, hosting, search for performers, and analytics.

9. Measures to ensure the safety of personal data during their processing

9.1. When processing personal data, the operator takes the necessary legal, organizational and technical measures to protect personal data from unlawful or accidental access to them, destruction, modification, blocking, copying, provision, dissemination of personal data, as well as from other unlawful actions with respect to personal data.
9.2. Ensuring the security of personal data is achieved, in particular:
● by identifying threats to the security of personal data during their processing in PD information systems;
● the application of organizational and technical measures to ensure the security of personal data during their processing in personal data information systems;
● the use of information security tools that have passed the compliance assessment procedure in accordance with the established procedure;
● prevention of unauthorized access to personal data;
● setting rules for access to personal data;
● taking other measures to ensure the protection of personal data.

10. Rights and obligations of Personal Data subjects

10.1. Personal Data subjects are responsible for providing the Operator with reliable information and documents sufficient for the purposes of their processing, as well as for timely updating of Personal Data in cases of their changes.
10.2. Personal Data subjects have the right to:
● get to know your personal data;
● receive information regarding the processing of their personal data;
● request clarification of their personal data, their blocking or destruction if they are incomplete, outdated, inaccurate, illegally obtained or are not necessary for the purpose of processing;
● revoke consent to Personal Data processing;
● to exercise other rights that he is entitled to according to the legislation on personal data.

11. Cookie Policy

11.1. Cookies are a small piece of data that a Website requests from the browser used on the User's computer or mobile device. Cookies reflect the User's preferences or actions on the Site, as well as information about their equipment, date and time of the session. Cookies are stored locally on the User's computer or mobile device. The user can delete the saved Cookies in the settings of the corresponding browser.
11.2. An IP address is a unique network address of a node in a computer network built using the IP protocol.
11.3. The processing of cookies, which are not technically necessary for the functioning of the Site, is carried out on the basis of the User's consent provided by performing active actions in the Website interface provided for by the Consent to the processing of cookies and data using the «Yandex.Metrica» service.
11.4. The User's consent to the processing of cookies and data collected through the «Yandex.Metrica» service is considered received from the moment of clicking the «Accept», «Agree» or other similar button in the information banner of the Site, as well as performing other active actions expressly provided for by the Consent to the processing of cookies and data using the service «Yandex.Metrica».
11.5. The User has the right at any time to change the previously provided cookie settings, to refuse their use through browser settings, or to use other ways of revoking consent provided for by Consent to the processing of cookies and data using the «Yandex.Metrica» service.
11.6. The Policy applies only to the Website. The Operator does not control and is not responsible for third-party sites to which the User can click on the links available on the Site.
11.7. The Policy establishes the Operator's obligations to keep confidential and ensure the confidentiality of User data that the Operator can receive during a User's visit to the Site.
11.8. The operator protects the data that is automatically transmitted to it when the User visits the pages of the Site on which the statistical script of the system («pixel») is installed in volume:
● IP address;
● information about the browser and the address of the page (or another program that provides access to the Site display);
● Access time;
● referrer (address of the previous page);
● other information from Cookies (depending on the type of Cookies).
11.9. With the User's consent, the Site uses the «Yandex.Metrica» web analytics service provided by Yandex LLC, subject to the following conditions:
● The «Yandex.Metrica» web analytics service uses Cookies;
● Information about the use of the Website by the User, collected using Cookies, is subject to transfer to Yandex and stored on Yandex servers located in the Russian Federation. Yandex processes the information received to evaluate the User's use of the Site and compile reports on the Site's activities.
11.10. Yandex processes the information received in accordance with the procedure established by:
● The Cookie Policy posted on the Internet at: https://yandex.ru/legal/cookies_policy;
● The Terms of Use of the «Yandex.Metrica» service, posted on the Internet at: https://yandex.ru/legal/metrica_termsofuse;
● The Privacy Policy posted on the Internet at: https://yandex.ru/legal/confidential
Types of Cookies used by the Operator
● Session sessions
Such Cookies exist only in temporary memory during the time when the User is on the Site page. Browsers usually delete session Cookies after the User closes the Website window. Session Cookies allow the Site to remember information about the User's choice on the previous page of the Site in order to avoid the need to re-enter information.
● Permanent ones.
Cookies that are stored on the User's computer and are not deleted when the browser is closed. Persistent Cookies can save user settings for the Site, allowing you to use these preferences in future browsing sessions. These Cookies allow you to identify the User as a unique user of the Site, and when returning to the Site, they help you remember information about the User and previous actions.
● Statistical data.
Such Cookies include information about how the User uses the Website. For example, which pages the User visits, which links they follow. The main purpose of such Cookies is to improve Website functions.
● Required.
The minimum set of Cookies, the use of which is necessary for the correct operation of the Site.
11.11. Purposes of collecting User's Cookie Data
● Cookies are used by the Operator in order to improve the operation of the Website.
● Information about User actions is processed to improve the Operator's products and services, determine User preferences, and provide targeted information on the Operator's products and services.

Mandatory (technical) cookies are used, regardless of the User's consent, solely to ensure the functioning of the Site.
Statistical, analytical, functional and other cookies that are not technically necessary are used only after obtaining the appropriate User consent.

12. Depersonalization of personal data upon receipt of a request for the provision of personal data obtained as a result of depersonalization of personal data

12.1. Upon receipt of a request for the provision of personal data obtained as a result of depersonalization of personal data, the Operator depersonalizes the personal data processed by him in accordance with the requirements for depersonalization of personal data, methods of depersonalization of personal data and the procedure for depersonalization of personal data approved by Decree of the Government of the Russian Federation dated August 1, 2025 No. 1154.
12.2. When depersonalizing personal data, the Operator ensures:
● compliance with the Rules of depersonalization of personal data and methods of depersonalization of personal data, approved by Decree of the Government of the Russian Federation dated August 1, 2025 No. 1154;
● separate storage of personal data and depersonalized data;
● taking measures to ensure the security of anonymized data in accordance with the Law on Personal Data;
● exclusion of information from anonymized data, access to which is restricted by federal laws;
● the use of algorithms and programs for electronic computers for depersonalization of personal data, providing the possibility of providing depersonalized data from the Operator's information system to the state information system of the Ministry of Digital Development, Communications and Mass Media of the Russian Federation, specified in Article 13.1 of the Law on Personal Data, without loss of such data and (or) their modification;
● the possibility of making changes and additions to depersonalized data, maintaining the relevance of depersonalized data and the possibility of re-applying the methods of depersonalization of personal data approved by Decree of the Government of the Russian Federation No. 1154 of August 1, 2025, without the possibility of converting depersonalized data to its original form, allowing to determine their belonging to a specific user of the site, as well as the integrity of the array of depersonalized data and their compliance with the requirement to provide anonymized data.
12.3. The Operator's compliance with the depersonalization requirements should exclude the presence of information in the personal data obtained as a result of depersonalization, access to which is restricted by federal laws.
12.4. The operator, in accordance with the requirement to provide personal data obtained as a result of depersonalization of personal data, provides personal data obtained as a result of depersonalization of personal data to the state information system of the authorized body in the field of information technology regulation in accordance with the procedure established by the Government of the Russian Federation in coordination with the federal executive governmental body authorized in the field of security.

13. The order of destruction and blocking of personal data

13.1. In case of detection of unlawful processing of personal data when contacting the site user, the Operator blocks the unlawfully processed personal data related to this user from the moment of such request for the verification period.
13.2. In case of detection of inaccurate personal data when contacting the site user, the Operator blocks personal data related to this user from the moment of such request for the verification period, if the blocking of personal data does not violate the rights and legitimate interests of the site user or third parties.
13.3. In case of confirmation of the inaccuracy of personal data, the Operator, based on the information provided by the user of the site or other necessary documents, clarifies the personal data within seven working days from the date of submission of such information and removes the blocking of personal data.
13.4. In case of detection of unlawful processing of personal data carried out by the Operator, the Operator, within a period not exceeding three working days from the date of this detection, stops the unlawful processing of personal data.
13.5. If it is impossible to ensure the legality of the processing of personal data, the Operator shall destroy such personal data within a period not exceeding ten working days from the date of detection of the unlawful processing of personal data.
13.6. The Operator notifies the site user about the elimination of violations or the destruction of personal data.
13.7. If the fact of unlawful or accidental transfer (provision, dissemination, access) of personal data is established, which has resulted in a violation of the rights of the site user, the Operator, from the moment such incident is identified by the Operator, the authorized body for the protection of the rights of personal data subjects or another interested person, notifies the authorized body for the protection of the rights of personal data subjects.:
● within twenty-four hours about the incident that occurred, about the alleged causes that led to the violation of the rights of the site user, and the alleged harm caused to the rights of the site user, about the measures taken to eliminate the consequences of the relevant incident, and also provides information about the person authorized by the Operator to interact with the authorized body for the protection of the rights of personal data subjects, according to issues related to the identified incident;
● within seventy-two hours on the results of the internal investigation of the identified incident, as well as provides information about the persons whose actions caused the identified incident (if any).13.8. В случае достижения цели обработки персональных данных Оператор прекращает обработку персональных данных и уничтожает персональные данные в срок, не превышающий тридцати дней с даты достижения цели обработки персональных данных.
13.9. If the user withdraws consent to the processing of his personal data, the Operator stops processing them and, if the storage of personal data is no longer required for the purposes of personal data processing, destroys the personal data within a period not exceeding thirty days from the date of receipt of the said withdrawal.
13.10. The specified period may be extended, but not for more than five working days if the Operator sends a reasoned notification to the user of the site indicating the reasons for extending the deadline for providing the requested information.
13.11. If it is not possible to destroy personal data within the period specified in this privacy policy, the Operator shall block such personal data and ensure the destruction of personal data within a period not exceeding six months, unless another period is established by federal laws.
13.12. After the expiration of the regulatory retention period for documents containing the personal data of the site user, or upon the occurrence of other legal grounds, the documents must be destroyed.
13.13. For these purposes, the operator creates an expert commission and conducts an expert examination of the value of the documents.
13.14. According to the results of the examination, the documents containing the personal data of the user of the site and subject to destruction:
● on paper - destroyed by shredding in a shredder;
● in electronic form - the media on which the information is stored are erased or physically destroyed.
13.15. If the processing of personal data was carried out by the Operator without the use of automation tools, the document confirming the destruction of personal data of the users of the site is an act on the destruction of personal data.
13.16. If the processing of personal data was carried out by the Operator using automation tools, the documents confirming the destruction of personal data of the site users are an act on the destruction of personal data and an upload from the event log in the personal data information system.

14. Responsibility for violation of the rules governing the processing and protection of personal data of users of the site

14.1. Persons guilty of violating the rules governing the receipt, processing and protection of personal data of users of the site are subject to disciplinary, material, civil, administrative and criminal liability in accordance with the procedure established by the current legislation of the Russian Federation.
14.2. Moral damage caused to the user of the website as a result of violation of his rights, violation of the rules for processing personal data established by the Law on Personal Data, as well as requirements for the protection of personal data established in accordance with the said Federal Law, is subject to compensation in accordance with the legislation of the Russian Federation. Compensation for moral damage is carried out independently of compensation for property damage and losses incurred by the user of the site.

15. Changing the policy in the field of personal data processing and protection

15.1. This Policy may be changed or terminated unilaterally by the Operator without prior notice to the User. The new version of the Policy comes into force from the moment it is posted on the website, unless otherwise provided by the new version of the Policy.

16. Consent to the collection and processing of personal data using the Operator's websites

16.1. Consent to the processing of personal data is provided by the personal data subject in the ways provided for by the legislation of the Russian Federation, this Policy and the relevant consent forms posted on the Operator's Website.

17. Operator's details

LLC «S.E.A. Company»
MSRN 5137746162032
TAX ID: 7728864231
Address: 121471, Moscow, ext. ter. Mozhaisky municipal district, Bagritskogo str., 18, sq. 130
E-mail: info@sea-company.com
Phone number: +7 495 926 3602