THE POLICY OF OLGA MAXIMOVNA HOFFMAN, AN INDIVIDUAL ENTREPRENEUR, REGARDING THE PROCESSING OF PERSONAL DATA

published on October 16, 2025

1. General provisions

This personal data processing policy has been compiled in accordance with the requirements of Federal Law No. 152-FZ dated 27.07.2006 “On Personal Data” (hereinafter referred to as the Personal Data Law) and defines the procedure for processing personal data and measures to ensure the security of personal data taken by IP Hoffman Olga Maximovna (hereinafter referred to as the Operator).

1.1. The Operator sets as its most important goal and condition for the implementation of its activities the observance of human and civil rights and freedoms when processing his personal data, including the protection of the rights to privacy, personal and family secrets.

1.2. This Operator’s policy regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator can receive about website visitors https://mister-xnn.com

1.3. The processing and security of personal data is carried out in accordance with the requirements of the Constitution of the Russian Federation, Federal Law No. 152-FZ “On Personal Data”, by-laws, other laws of the Russian Federation defining the cases and specifics of personal data processing, as well as guidelines and methodological documents of the Government of the Russian Federation, the Ministry of Finance of the Russian Federation, Roskomnadzor, FSTEC Russia and the FSB of Russia.

2. Basic concepts used in Politics

2.1. Automated personal data processing is the processing of personal data using computer technology.

2.2. Blocking of personal data is the temporary termination of the processing of personal data (except in cases where the processing is necessary to clarify personal data).

2.3. A website is a collection of graphic and informational materials, as well as computer programs and databases that ensure their availability on the Internet at a network address. https://mister-xnn.com

2.4. The personal data information system is a set of personal data contained in databases and information technologies and technical means that ensure their processing.

2.5. Personal data processing is any action (operation) or set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (provision), depersonalization, blocking, deletion, destruction of personal data.

2.6. The operator is IP Hoffman Olga Maksimovna, OGRNIP: 323527500001282, TIN 525710165309, as the owner of the website, independently or jointly with other persons organizing and/or processing personal data, as well as determining the purposes of personal data processing, the composition of personal data to be processed, actions (operations) performed with personal data.

2.7. Personal data is any information related directly or indirectly to a specific or identifiable natural person (personal data subject).

2.8. A user is an individual, any visitor to a website https://mister-xnn.com

2.9. Personal data subject is an individual whose personal data is being processed.

2.10. Providing personal data is an action aimed at disclosing personal data to a certain person or a certain circle of people.

2.11. Depersonalization of personal data is an action that makes it impossible to determine whether personal data belongs to a specific personal data subject without using additional information.

2.12. Destruction of personal data — any actions as a result of which personal data is permanently destroyed with the impossibility of further restoration of the content of personal data in the personal data information system and/or the material carriers of personal data are destroyed.

3. Basic rights and obligations of the Operator

3.1. The operator has the right to:

• receive reliable information and/or documents containing personal data from the personal data subject;
• if the personal data subject withdraws consent to the processing of personal data, as well as sending a request to terminate the processing of personal data, the Operator has the right to continue processing personal data without the consent of the personal data subject, provided there are grounds specified in the Personal Data Act.;
• independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations stipulated by the Law on Personal Data and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Law on Personal Data or other federal laws.;
• make changes to the personal data processing policy and publish the modified version on the website.

3.2. The operator must:

• to provide the personal data subject, upon his request, with information related to the processing of his personal data;
• organize the processing of personal data in accordance with the procedure established by the current legislation of the Russian Federation;
• respond to requests and requests from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Act;
• to inform the authorized body for the protection of the rights of personal data subjects at the request of this body of the necessary information within 10 days from the date of receipt of such request.;
• to publish or otherwise provide unrestricted access to this Personal Data Processing Policy;
• take legal, organizational and technical measures to protect personal data from unlawful or accidental access to it, destruction, modification, blocking, copying, provision, dissemination of personal data, as well as from other unlawful actions with respect to personal data;
• stop transferring (distributing, providing, accessing) personal data, stop processing and destroy personal data in accordance with the procedure and cases provided for by the Law on Personal Data.;
• perform other duties stipulated by the Law on Personal Data.

4. Basic rights and obligations of personal data subjects

4.1. Subjects of personal data have the right to:

• receive information regarding the processing of his personal data, except in cases provided for by federal laws. The information is provided to the personal data subject by the Operator in an accessible form, and it should not contain personal data related to other personal data subjects, except in cases where there are legitimate grounds for the disclosure of such personal data. The list of information and the procedure for obtaining it are established by the Law on Personal Data;
• to require the operator to clarify his personal data, block or destroy them if the personal data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated purpose of processing, as well as to take legal measures to protect their rights;
• to revoke consent to the processing of personal data, as well as to request the termination of personal data processing;
• to appeal to the authorized body for the protection of the rights of personal data subjects or in court against unlawful actions or omissions of the Operator during the processing of his personal data;
• to exercise other rights provided for by the legislation of the Russian Federation.

4.2. Subjects of personal data are obliged to:

• provide the Operator with reliable personal information;
• inform the Operator about the clarification (updating, modification) of your personal data.

4.3. Persons who have provided the Operator with false information about themselves or information about another personal data subject without the latter’s consent are liable in accordance with the legislation of the Russian Federation.

4.4. Unless a different procedure for interaction between the Operator and the personal data subject is provided for by a relevant document between them (for example, an agreement or the text of consent to the processing of personal data), in order to exercise the right to revoke previously given consent to the processing of personal data, the personal data subject must send an application to the Operator:

• in writing and signed with a handwritten signature – to the address of the individual entrepreneur: Nizhny Novgorod, Rozhdestvenskaya str., 20A;

OR

• in the form of an electronic document and signed with an electronic signature – by e-mail inkognitorelaks@yandex.ru

Such a statement must necessarily contain a description of the requirements of the personal data subject, as well as the following information:

• Full name of the personal data subject;
• the number of the main identity document of the personal data subject or his representative, information about the date of issue of the specified document and the issuing authority, OR other data that uniquely identifies the personal data subject.;
• information confirming the personal data subject’s participation in the relationship with the Operator, OR information confirming the fact of personal data processing by the Operator in another way;
• signature of the personal data subject or his representative.

5. Principles of personal data processing

5.1. Personal data is processed on a lawful and fair basis.

5.2. The processing of personal data is limited to the achievement of specific, predetermined and legitimate purposes. Processing of personal data incompatible with the purposes of personal data collection is not allowed.

5.3. It is not allowed to combine databases containing personal data, the processing of which is carried out for purposes incompatible with each other.

5.4. Only personal data that meets the purposes of their processing is subject to processing.

5.5. The content and volume of personal data processed correspond to the stated purposes of processing. Redundancy of the processed personal data in relation to the stated purposes of their processing is not allowed.

5.6. When processing personal data, the accuracy of personal data, its sufficiency, and, if necessary, its relevance to the purposes of personal data processing are ensured. The Operator takes the necessary measures and/or ensures that they are taken to delete or clarify incomplete or inaccurate data.

5.7. Transparency of personal data processing is ensured: the personal data subject may be provided with relevant information regarding the processing of his personal data.

5.8. Personal data is stored in a form that makes it possible to determine the subject of personal data, no longer than the purposes of personal data processing require, unless the period of personal data storage is established by federal law, an agreement to which the personal data subject is a party, beneficiary or guarantor. The personal data being processed is destroyed upon achievement of the processing objectives or in case of loss of the need to achieve these objectives, unless otherwise provided by federal law.

6. Security, conditions and purposes of personal data processing

6.1. By personal data security, the Operator means the protection of 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 and takes the necessary legal, organizational and technical measures to protect personal data.

6.2. The security of personal data processed by the Operator is ensured through the implementation of legal, organizational and technical measures necessary to fully comply with the requirements of current legislation in the field of personal data protection.

6.3. The conditions of personal data processing by the Operator, including the purposes of personal data processing, the categories and list of personal data processed for each purpose, as well as the categories of subjects whose personal data (hereinafter PD) are processed, are presented in the tables below.

Purpose of PD processing	Categories and list of personal data	Categories of PD subjects
1. Use, including visiting, the Operator’s websites in accordance with the functionality provided	General PD: Full name;Telephone number; e-mail address; Information collected through metric programs, including technical information about user devices and identifiers (cookies, geolocation, IP addresses)	Visitors, Users of websites
2. Making orders for services on the website (online registration), by phone/ messengers/ e-mail	General PD: Full name; Phone number; e-mail address; Location address (only in cases of calling a taxi to a client) Information collected through metric programs, including technical information about user devices and identifiers (cookies, geolocation, IP addresses)	Customers
3. The direction of advertising	General PD: Full name;Contact information (phone number, e-mail address, nicknames and ID in messengers, social.networks, etc.)	Mailing list recipients, Subscribers in social networks.social networks and messengers
4. Preparation, conclusion and execution of civil law contracts	General PD: Full name; Date of birth; Passport data; Contact information (phone number, e-mail address); Registration address; INN; Registration number as an individual entrepreneur and other data contained in the Unified State Register of Legal Entities and other open (public) registers (if the individual is also an individual entrepreneur or self-employed); Bank details; Other data in accordance with the terms of the agreements (if necessary) For representatives General personal data: Full name;Position;Details of powers of attorney	Counterparties, individuals – parties to civil law contracts, Representatives of the parties to civil law contracts

6.4. The Operator processes personal data only if there is at least one of the conditions for processing personal data set out below, within the following time limits:

Legal basis of personal data processing	Duration of personal data processing and storage
With the consent of the personal data subject to the processing of his personal data	During the period for which consent to the processing of personal data was given
To achieve the goals stipulated by an international agreement of the Russian Federation or a law, to carry out and fulfill the functions, powers and duties assigned to the operator by the legislation of the Russian Federation	Within the time limit established by the relevant international treaties or laws.
If it is necessary to process personal data subject to publication or mandatory disclosure in accordance with federal law	Within the time limit established by the relevant laws
For the execution of a judicial act, an act of another body or official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings	During the period necessary for the execution of the relevant act
In connection with the participation of a person in constitutional, civil, administrative, criminal and arbitration proceedings	During the period of participation in the relevant legal proceedings, including the time limits for appealing (challenging) judicial acts, except in cases where a longer period for processing personal data is established by the current legislation of the Russian Federation.
To execute an agreement to which the personal data subject is a party or beneficiary or guarantor, as well as to conclude an agreement on the initiative of the personal data subject or an agreement under which the personal data subject will be the beneficiary or guarantor.	During the term of such an agreement, except in cases where a longer period of personal data processing is established by the current legislation of the Russian Federation or the agreement.
To protect the life, health or other vital interests of the personal data subject, if it is impossible to obtain the consent of the personal data subject	Until the moment when obtaining the consent of the personal data subject becomes possible or when the relevant grounds threatening life, health or other vital interests disappear (depending on which circumstance occurs earlier)
To exercise the rights and legitimate interests of the operator or third parties, provided that the rights and freedoms of the personal data subject are not violated.	During the period necessary for the exercise of rights and legitimate interests. The specific period is determined by the Operator, taking into account the provisions of this Policy, internal documents and local regulations of the Operator, as well as the principles of personal data processing and the requirements of the current legislation of the Russian Federation, including the termination of personal data processing when specific, predetermined and legitimate purposes of such processing are achieved.

6.5. Unless otherwise provided by the legislation of the Russian Federation, the Operator stops processing personal data (in relation to any of the purposes stated above) and destroys them in the following cases::

• achieving the goals of personal data processing and/or eliminating the legal grounds for processing personal data, or terminating the operator’s activities, whichever comes first.

6.6. The specific procedure for the destruction of personal data on media containing personal data, including external/removable electronic media, paper media and personal data information systems, is determined by the Operator in its internal documents and local regulations.

6.7. The period of personal data processing is determined by the achievement of the purposes for which the personal data was collected, unless another period is stipulated by the contract or the current legislation.

6.8. The operator when processing personal data:

• takes measures necessary and sufficient to ensure compliance with the requirements of the legislation of the Russian Federation, internal documents and local regulations of the Operator in the field of personal data;
• issues the Operator’s policy regarding the processing of personal data, local acts on personal data processing;
• applies legal, organizational and technical measures to ensure the security of personal data;
• performs internal control over the compliance of personal data processing with the law and regulatory legal acts adopted in accordance with it, requirements for personal data protection, Operator’s policy regarding personal data processing, and operator’s local acts;
• publishes this Policy regarding the processing of personal data on its website and provides access to the specified document using the means of the relevant information and telecommunications network.;
• applies information security measures;
• discovers facts of unauthorized access to personal data and takes measures;
• restores personal data that has been modified or destroyed due to unauthorized access to it;
• establishes rules for access to personal data processed in the personal data information system;
• monitors the measures taken to ensure the security of personal data;
• familiarizes the Operator’s employees (if any) who directly process personal data with the provisions of the legislation of the Russian Federation, internal documents and local regulations of the Operator in the field of personal data, including the requirements for personal data protection.;
• terminates the processing of personal data and destroys them in cases stipulated by the legislation of the Russian Federation.;
• performs other actions stipulated by the legislation of the Russian Federation in the field of personal data.

7. Cookies, metric programs, third-party services

7.1. In some cases, as described below, the Operator receives and processes personal data automatically using metric programs used on the Operator’s websites and online services. The Operator uses cookies to work with such data.

Cookies are small text files containing some information that are downloaded to a user’s device (PC, smartphone, etc.) while browsing a web page.

Cookies allow sites to recognize user devices, determine user preferences, and collect statistics on how users interact with sites to improve the experience of using such a site or to eliminate various errors or bugs that may occur periodically. However, the list of purposes for which cookies are needed is not exhaustive and depends on the specific website that the user visits or otherwise uses.

In particular, the following cookies may be used on the Operator’s websites:

Category	Description and purpose of use
Technical cookies	These cookies are necessary for the operation of the Operator’s websites and online services, and without them they cannot function properly. Technical cookies allow users to navigate through such sites and services, view their various sections, fill out forms and scroll through checkboxes there.
Analytical cookies	These cookies collect information about how often users visit the Operator’s websites and online services, which sections they view, which links they click on, and how they generally navigate through such sites and services.
Preference cookies	These cookies remember the settings and choices that users make on the Operator’s websites and online services (language, region, search queries, etc.) and thereby ensure that users receive a personalized experience when using such sites and services.
Marketing cookies	These cookies collect information about actions performed by users both on the Operator’s websites and online services, as well as on third-party sites, in order to display the most relevant ads for users, evaluate the effectiveness of such ads, and limit the number of advertising impressions for such users on the Operator’s websites and services.

Users can also independently limit or completely disable the installation of cookies through the settings of their web browser. However, without the use of technical cookies, the Operator’s websites and online services may not work correctly, and some of their functionality may not be available.

By using cookies, the Operator does not aim to identify a specific user of the Operator’s websites and online services.

7.2. All information collected by third-party services, including payment systems, communication facilities and other service providers, is stored and processed by the specified persons (Operators) in accordance with their User Agreement and Privacy Policy. The Operator is not responsible for the actions of third parties, including the service providers specified in this paragraph.

8. List of actions performed by the Operator with the received personal data

8.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), extracts, uses, transfers (distributes, provides, accesses), depersonalizes, blocks, deletes and destroys personal data.

8.2. Consent to the processing of personal data authorized by the personal data subject for dissemination is issued separately from other consents of the personal data subject to the processing of his personal data. The operator is obliged to provide the personal data subject with the opportunity to determine the list of personal data for each category of personal data specified in the consent to the processing of personal data authorized by the personal data subject for dissemination.

8.3. The Operator performs mixed processing of personal data, with or without transmission over the Internet.

9. Transfer of personal data

9.1. If there are appropriate legal grounds established by the legislation of the Russian Federation, the Operator has the right to transfer personal data to third parties without instructing such persons to process personal data.

These persons include, for example, banks that settle accounts with the Operator’s counterparties, the Operator’s counterparties to whom the Operator transmits the data of their representatives’ powers of attorney, government agencies requesting personal data within their competence, etc.

Such persons do not process personal data on behalf of the Operator or in his interests, as they have their own purpose and legal grounds for such processing (for example, banks accept payment documents in accordance with the requirements of banking legislation, and the Operator has no right to interfere in their activities).

9.2. The prohibitions established by the personal data subject on the transfer (other than granting access), as well as on the processing or conditions of processing (other than gaining access) of personal data permitted for distribution, do not apply in cases of processing personal data in the state, public and other public interests defined by the legislation of the Russian Federation.

10. Confidentiality of personal data

The operator and other persons who have obtained access to personal data are obliged not to disclose or distribute personal data to third parties without the consent of the personal data subject, unless otherwise provided by federal law.

11. Information about the implemented requirements for personal data protection

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. The Operator regularly reviews and updates the measures taken to ensure the best possible protection of the personal data being processed. Such measures are described in this Policy, internal documents and local regulations of the Operator.

Such measures include, in particular::

• development and publication of a personal data processing policy on the Website;
• the application of organizational and technical measures to ensure the security of personal data during their processing in personal data information systems necessary to meet the requirements for personal data protection, the implementation of which ensures the levels of personal data security established by the Government of the Russian Federation (Level 4);
• the use of information security tools that have passed the compliance assessment procedure in accordance with the established procedure;
• the use of certified antivirus software with regularly updated databases;
• establishment of rules for access to personal data processed in the personal data information system;
• establishment of individual passwords for access to the personal data information system;
• detection of unauthorized access to personal data and taking measures;
• ensuring the safety of personal data carriers;
• monitoring of measures taken to ensure the security of personal data;
• conducting internal control and proceedings on violations of personal data security requirements.

12. Final provisions

12.1. The personal data subject may receive information on issues of interest related to the processing of his personal data by contacting the Operator. The request of the personal data subject must contain the number of the main document certifying the identity of the personal data subject or his representative, information about the date of issue of the specified document and the issuing authority, information confirming the participation of the personal data subject in relations with the operator (contract number, date of conclusion of the contract, conditional verbal designation and (or) other information), or information that otherwise confirms the processing of personal data by the operator, the signature of the personal data subject or his representative. The request can be sent in the form of an electronic document to the Operator’s e-mail inkognitorelaks@yandex.ru and signed with an electronic signature in accordance with the legislation of the Russian Federation.

12.2. This document will reflect any changes to the Operator’s personal data processing policy. The policy is valid indefinitely until it is replaced by a new version.

12.3. The Operator periodically updates this Policy and has the right to unilaterally change its terms at any time. The Operator recommends that you regularly check the content of this Policy for possible changes. The current version of the Policy is freely available online at https://mister-xnn.com/privacy-policy/. Unless otherwise provided by the Policy, all changes made to it will take effect from the date specified in the Policy.

12.4. In all other matters not provided for by this Policy, the Operator is guided by the provisions of the current legislation of the Russian Federation.