REGULATIONS ON PROCESSING OF PERSONAL DATA OF THE SERVICE'S CLIENTS

TABLE OF CONTENTS

1. Terms and definitions

2. General Provisions

3. Personal Data Processing Principles

4. Purposes of Personal Data Processing

5. List of Personal Data Processed

6. Procedure and Conditions of Personal Data Processing

7. Location of Databases with Information Containing Personal Data

8. Duration of Personal Data Storage

9. Rights and Obligations of Personal Data Subjects

10. Personal Data Confidentiality

11. Transfer of Personal Data to Third Parties

12. Final provisions

1. TERMS AND DEFINITIONS

1.1. Blocking of personal data shall mean temporary cessation of processing of personal data (except for cases when processing is necessary for clarification of personal data).

1.2. Personal Data Protection shall mean a set of measures of technical, organisational, and technical and organisational nature aimed at protecting information relating to a Personal Data subject defined or identified on the basis of such information.

1.3. Client shall mean a natural person initiating the Transfer to the Recipient, having the relevant legal capacity, who has performed actions aimed at conclusion of the Agreement by accepting the terms and conditions of the Service's Offer located on the website at the link: https://id-pay.ru/offer  (hereinafter referred to as the Offer).

1.4. Confidentiality of personal data shall mean a requirement binding on the Operator or any other person who has obtained access to personal data not to allow disclosure of personal data to third parties and their dissemination for purposes not set out herein without the consent of the Personal Data Subject or the existence of another legal basis.

1.5. Processing of personal data shall mean any action (operation) or set of actions (operations) performed with or without the use of automation means with personal data, including collection, recording, systematisation, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), depersonalisation, blocking, deletion, destruction of personal data, unless otherwise expressly stated herein.

1.6. Publicly available personal data shall mean personal data to which access is granted to an unlimited number of persons with the consent of the Personal Data Subject or which, in accordance with federal laws, are not subject to the requirement of confidentiality.

1.7. Operator shall mean the General Payment Technologies Limited Liability Company (GPT LLC) OGRN 1207700150173 TIN 9703011965, address of the legal entity: 123112, Russian Federation, Moscow, Nab. Presnenskaya 12, floor/office 33/33, implementing and organising the processing of Personal Data, as well as determining the purposes of processing Personal Data, the composition of Personal Data Subject to processing, the methods of processing Personal Data and actions (operations) performed with Personal Data.

1.8. Officer responsible for the organization of personal data processing (hereinafter also referred to as Officer responsible for the organisation of Personal Data processing) means the authorized person (employee of the Operator or an external contractor engaged by the Operator), whose obligations include the following:

1) to provide internal control over compliance by the Operator and its employees with the legislation of the Russian Federation on personal data, including requirements for the protection of personal data;

2) inform the Operator's employees of the provisions of the legislation of the Russian Federation on personal data, local acts on personal data processing, and requirements for the protection of personal data;

3) organise the receipt and processing of requests and inquiries from subjects of personal data or their representatives and/or control the receipt and processing of such requests and inquiries.

1.9. Personal Data (hereinafter also PD) means any information relating to an identified or identifiable natural person (Personal Data Subject).

1.10. Provision of Personal Data shall mean actions aimed at disclosure of Personal Data when using the Service.

1.11. IDpay 2.0 Service (hereinafter referred to as the Service) is a digital service for cross-border transfers IDpay 2.0, which is a proprietary development of the Company (as defined below) and includes versions for smartphones running on iOS, Android and Huawei HarmonyOS operating systems, information about which is available on the website on the information and telecommunications network "Internet" (hereinafter referred to as the Internet) at the following link: https://id-pay.ru/.

1.12. Personal Data Subject(s) (hereinafter also referred to as Personal Data Subject) shall mean any natural person using the Service and (or) its components, who has provided Personal Data and accepted the terms and conditions of these Regulations on Processing of Personal Data of the Service's Clients and the Offer, including the Clients.

1.13. Destruction of personal data shall mean actions resulting in making it impossible to restore the content of personal data in the personal data information system and (or) as a result of which material carriers of personal data are destroyed.

1.14. Other terms used in these Regulations on Processing of Personal Data of Service Clients (hereinafter referred to as the Regulations), the meaning of which is not defined in these Regulations, shall have the meaning specified in the Offer, the Federal Law of the Russian Federation dated 27.07.2006 No. 152-FZ "On Personal Data," other regulatory legal acts of the Russian Federation governing legal relations in the field of personal data processing.

2. GENERAL PROVISIONS

2.1. These Regulations are developed to determine the basic principles, purposes, conditions, and methods of processing Personal Data of the Personal Data Subjects, the list of Personal Data being processed, the rights of Personal Data Subjects, as well as the requirements for the protection of Personal Data established for the Service.

2.2. These Regulations apply to Clients of the Service. Any use of the Service means that the Personal Data Subject agrees to the terms and conditions of these Regulations.

2.3. By using the Service, the Personal Data Subject grants the Operator consent to process their Personal Data to the extent and on the terms provided by these Regulations, including the transfer of such data to the persons listed in Section 11 hereof. The consent of the Personal Data Subject to the processing of their Personal Data may be given by the Personal Data Subject or their representative in any form that allows confirming the fact of the consent, in particular, by agreeing with these Regulations.

2.3.1. By using the Service, the Client confirms that he/she has read, agrees and accepts the terms and conditions of these Regulations.

2.4. The Service may request access to the photo and file system for the purposes of obtaining information about the Client, verification of Client data necessary for compliance with the requirements of the current legislation of the Russian Federation.

2.5. The procedure for using the Service is defined in the Offer. The Client undertakes to familiarise himself with the Offer and to comply with its provisions.

2.6. The regulations apply to both automated and non-automated processing of personal data by the Operator.

2.7. The Regulations are subject to review and, if necessary, updating in case of changes in the functionality of the Service.

2.8. Client agrees to accept such changes and monitor the Service for changes to these Regulations from the date of such changes.

3. PERSONAL DATA PROCESSING PRINCIPLES

3.1. When processing Personal Data, the Operator may perform the following actions with personal data: collection, recording, systematisation, accumulation, storage, clarification (update, change), extraction, use, transfer, including cross-border (provision, access), blocking, deletion, destruction of personal data, including in the Operator's information systems.

3.2. Personal Data shall be processed by the Operator on the basis of the following principles:

3.2.1. Personal data is collected and processed on the basis of fairness, reasonableness, and lawfulness.

3.2.2. Personal data is stored for predetermined purposes and is not used in any other way incompatible with the purposes stated in these Regulations.

3.2.3. Personal data is adequate, relevant, and not excessive for the purposes of processing.

3.2.4. Processing of personal data that is inconsistent with the purposes for which the data was collected is not permitted.

3.2.5. Databases containing personal data processed for mutually incompatible purposes may not be merged.

3.2.6. Only those personal data may be processed that fulfil the purposes for which they are processed.

3.2.7. The content and scope of the personal data processed must correspond to the stated purposes of processing.

3.2.8. Processing of personal data that is redundant in relation to the stated purposes of its processing is not permitted.

3.2.9. When processing personal data, the accuracy of personal data, their sufficiency, relevance to the purposes of personal data processing shall be ensured. Incomplete ot inaccurate data should be deleted or updated.

3.2.10. Personal data shall be stored in a form that allows identification of the Personal Data Subject for no longer than required by the purposes of personal data processing, unless the period of personal data storage is established by law, contract to which the Personal Data Subject is a party, beneficiary, or guarantor.

3.2.11. Upon achievement of the processing purposes or in case of loss of necessity to achieve these purposes, at the lawful request of the Personal Data Subject or of the authorised judicial and executive authorities, the personal data shall be destroyed or anonymised unless otherwise provided for by the current legislation of the Russian Federation.

3.2.12. For the purposes of personal data protection, the Operator uses localised technologies.

4. PURPOSES OF PERSONAL DATA PROCESSING

4.1. The Operator processes Personal Data in order to provide the Client with the opportunity to use the Service, including the payment and information functionality of the Service, as well as for the following purposes:

4.1.1. Exercising the functions, powers and duties assigned to the Operator by the current legislation of the Russian Federation;

4.1.2. Receipt by the Client of services on making transfers of monetary funds through the use of the Service;

4.1.3. Establishing feedback with the Personal Data Subject, including sending notifications regarding the use of the Service, processing requests and applications from the Personal Data Subject;

4.1.4. Execution of acts of court, acts of other bodies or officials subject to execution in accordance with the current legislation of the Russian Federation;

4.1.5. To exercise the rights and legal interests of the Operator;

4.1.6. For other lawful purposes within the functionality of the Service available to Client.

5. LIST OF PERSONAL DATA PROCESSED

5.1. The Operator may process the following Personal Data Subject's personal data:

5.1.1. Surname, first name, patronymic;

5.1.2. Citizenship;

5.1.3. Registered residence address and actual residence address;

5.1.4. Date and place of birth;

5.1.5. Sex;

5.1.6. Data of the identity document (passport), including passport number, issuing authority, date and place of issue, address of registration at the place of residence, and code of the unit that issued the passport;

5.1.7. A document confirming registration in the individual (personified) accounting system (including SNILS);

5.1.8. Marital status, property status;

5.1.9. Education, occupation details;

5.1.10. Income and expenses data;

5.1.11. Number of the insured person's compulsory health insurance policy;

5.1.12. Data of the migration card and the document confirming the foreign citizen's right to stay (residence) in the Russian Federation;

5.1.13. Taxpayer identification number (TIN);

5.1.14. TIN (for Clients and Counterparties from the Republic of Armenia);

5.1.15. E-mail;

5.1.16. Client's phone number;

5.1.17. Photo of the identity document (passport);

5.1.18. Payer's Identification Number (PIN; for Clients and Counterparties from the Republic of Belarus);

5.1.19. Other information provided by the Client to the Operator in applications, letters, questionnaires, agreements and other documents.

5.2. The Operator does not process special categories of Personal Data, including but not limited to biometric Personal Data, Personal Data related to political views, religious or philosophical beliefs.

6. PROCEDURE AND CONDITIONS OF PERSONAL DATA PROCESSING

6.1. The Operator receives Personal Data from the Personal Data Subject directly while the Personal Data Subject is using the Service.

6.2. When processing Personal Data, the Operator:

6.2.1. Takes necessary and sufficient measures to ensure compliance with the requirements of the legislation in the field of personal data;

6.2.2. Takes legal, organisational, and technical measures to protect Personal Data from unauthorised or accidental access, destruction, alteration, blocking, copying, disclosure, dissemination, as well as from any other illegal actions concerning Personal Data;

6.2.3. Appoints an Officer responsible for the organisation of personal data processing;

6.2.4. Approves local regulatory acts and issues regulatory documents in the field of Personal Data processing;

6.2.5. Ensures that employees of the Operator directly involved in Personal Data processing are informed about the legislation in the field of Personal Data;

6.2.6. Provides training to the Operator's employees directly involved in the processing of Personal Data on the rules for working with Personal Data;

6.2.7. Publishes these Regulations or otherwise ensures that the Client has unrestricted access hereto and opportunities for familiarisation herewith;

6.2.8. Notifies the Personal Data Subjects or their legal representatives in accordance with the established procedure regarding the existence of Personal Data concerning the respective Personal Data Subjects, provides the opportunity to familiarize themselves with these Personal Data upon requests from the Personal Data Subjects or their legal representatives, unless otherwise established by the legislation of the Russian Federation;

6.2.9. Ceases processing and destroys Personal Data in cases provided by the legislation of the Russian Federation;

6.2.10. Performs other actions stipulated by the legislation of the Russian Federation.

6.3. To ensure the security of processed Personal Data, the Operator takes the necessary legal, organisational and technical protection measures.

6.4. The Operator's Personal Data protection system is based on the principles of:

6.4.1. Centrality — the data protection system must be centrally managed;

6.4.2. Promptness — Personal Data security measures applied as part of the protection system must be prompt;

6.4.3. Purposefulness — Personal Data security measures applied within the framework of the protection system must have clear objectives to which they are directed;

6.4.4. Integrity — the protection system should include a set of measures aimed at ensuring Personal Data security, complementing and supporting each other;

6.4.5. Preventiveness — the Personal Data security measures applied within the protection system must be preventive in nature;

6.4.6. Reliability — the Personal Data protection system shall provide sufficient guarantees to the Operator that the processed Personal Data are adequately protected.

6.5. In order to exercise internal control over the compliance of personal data processing with the requirements established by the Operator, the Operator organises periodic inspections of compliance with the conditions of Personal Data processing.

6.6. The Operator takes all necessary organisational, administrative, legal, and technical measures to protect the Personal Data of the Client.

6.7. The Officer responsible for the organisation of personal data processing shall:

6.7.1. Carry out internal control over compliance by the Operator and its employees with the legislation of the Russian Federation;

6.7.2. Inform the the Operator's employees about the provisions of the legislation of the Russian Federation and requirements for the protection of Personal Data;

6.7.3. Organize the receipt and processing of requests and inquiries from the Personal Data Subjects or their representatives regarding Personal Data processing, and/or control the receipt and processing of such requests and inquiries;

6.7.4. Develop and submit for approval documents defining the Operator's policy regarding Personal Data processing;

6.7.5. Control the development and updating of documents on Personal Data processing and documents that establish procedures aimed at preventing and detecting violations of the legislation of the Russian Federation, as well as eliminating the consequences of such violations;

6.7.6. Conduct internal control and/or audits to ensure compliance of Personal Data processing with the legislation of the Russian Federation and other regulatory acts enacted pursuant thereto;

6.7.7. Assess the harm that may be caused to the Personal Data Subjects in case of violation of applicable law, and determine, with due account for the scale of such harm, the sufficiency of the measures taken by the Operator aimed at ensuring compliance with the obligations provided for by the legislation of the Russian Federation;

6.7.8. To take other necessary measures to work with personal data in accordance with the current legislation of the Russian Federation.

7. LOCATION OF DATABASES WITH INFORMATION CONTAINING PERSONAL DATA

7.1. The Operator processes Personal Data within the territory of the Russian Federation.

7.2. Databases containing personal data are located on the territory of the Russian Federation in strict compliance with the legislation of the Russian Federation

8. DURATION OF PERSONAL DATA STORAGE

8.1. The Operator shall ensure storage of the Personal Data Subject's Personal Data for the entire period of the Personal Data Subject's use of the Website.

8.2. Personal Data Subject may at any time notify the Operator of withdrawal of consent to process Personal Data.

8.3. The Operator processes Personal Data in accordance with the legislation of the Russian Federation.

9. RIGHTS AND OBLIGATIONS OF PERSONAL DATA SUBJECTS

9.1. The Personal Data Subject has the right:

9.1.1. To receive information about the Operator's processing of his/her Personal Data and the main purposes of the processing;

9.1.2. To obtain, within a reasonable period of time and without undue delay or excessive costs, confirmation of the processing of Personal Data by the Operator, as well as obtain information about the personal data processed by the Operator in an understandable form in cases stipulated by law, provided that the Operator has no legal obstacles to provide the said information;

9.1.3. To demand the rectification of inaccurate Personal Data and to demand the destruction of Personal Data if their processing does not correspond to the purposes of Personal Data processing;

9.1.4. To resort to legal remedies in case of non-compliance with a request for confirmation of processing, amendment, or erasure of Personal Data;

9.1.5. To withdraw consent to the processing of Personal Data by the Operator.

9.2. The Personal Data Subject may address the Operator in accordance with Federal Law of the Russian Federation dated 27.07.2006 No. 152-FZ "On Personal Data" by sending a written application to the Operator at the following address: 123112, Russian Federation, Moscow, Nab. Presnenskaya, 12, floor/office 33/33.

9.3. The Personal Data Subject has the right to demand from the Operator by sending a written request to clarify his/her Personal Data, block or destroy it if the Personal Data is incomplete, outdated, inaccurate, illegally obtained, or not necessary for the stated purpose of processing, as well as take measures provided for by the current legislation of the Russian Federation to protect his/her rights.

9.4. The Personal Data Subject shall:

9.4.1. Ensure the security of access data to the Client's Account in the Service;

9.4.2. To update as necessary the data posted in the Service or transferred under these Regulations.

9.5. The achievement of the goals of processing Personal Data and (or) withdrawal of the Personal Data Subject's consent to their processing may be a condition for terminating the processing of Personal Data.

10. PERSONAL DATA CONFIDENTIALITY

10.1. Information related to personal data, which has become known to the Operator, is confidential information and is protected by the current legislation of the Russian Federation.

10.2. Employees of the Operator and other persons who have access to the processed personal data have signed an obligation of non-disclosure of confidential information, as well as warned of possible disciplinary, administrative, civil and criminal liability in case of violation of norms and requirements of the current legislation in the field of personal data processing.

11. TRANSFER OF PERSONAL DATA TO THIRD PARTIES

11.1. The Operator may transfer the obtained personal data to the following persons:

11.1.1. To counterparties entering into contractual relations with the Operator;

11.1.2. To state authorities in fulfillment of the Operator's obligations under the procedure established by the legislation of the Russian Federation;

11.1.3. To other third parties to support the Service Operator's activities and to ensure compliance with the legislation of the Russian Federation.

11.2. The Operator does not provide or disclose Personal Data to third parties without the required legal grounds, such as, among other things, the consent of the Subject of Personal Data and/or an agreement or contract.

11.3. When transferring Personal Data to counterparties engaging in contractual relations with the Operator, the Operator shall remain responsible for the actions of such third parties as if they were its own.

11.4. When transferring Personal Data to third parties, the Operator guarantees the safety and confidentiality of Personal Data Subject's Personal Data during the process of parameter autocompletion. Further interaction with such third parties is carried out by the Personal Data Subject independently.

12. FINAL PROVISIONS

12.1. These Regulations shall be effective from the date of the publication and shall remain in effect indefinitely until replaced by new Regulations, if necessary.

12.2. The Operator has the right to unilaterally change the terms of the Regulations.

12.3. Due to the fact that the text of the Regulations is freely available on the Service, the Client should independently follow the amendments made to the Regulations.

12.4. These Regulations shall apply to personal data obtained both before and after the implementation of these Regulations.

12.5. These Regulations, as well as all amendments thereto, shall be approved by the Operator and shall come into force from the date of their publication in the Service. From the date of entry into force of the present version of the Regulations, the previous version shall be deemed invalid.

12.6. These Regulations have similar versions also in English, Armenian, Russian languages. In case of discrepancies in the interpretation of the Russian version of the Regulations and the English and/or Armenian versions of the Regulations, the Russian version of the Regulations shall prevail.


Revision as of June 30, 2025