PRIVACY POLICY
of the "Zavereno" Platform

Last updated: 21.06.2025

This Privacy Policy (hereinafter — the “Policy”) describes how personal data of users of the "Zavereno" platform (hereinafter — the “Platform,” “Operator,” “we”) is collected, used, stored, and protected. The Platform is accessible via [insert domain] and/or mobile application.

By using the Platform, you agree to this Policy and the processing of your personal data as described below.

1. GENERAL PROVISIONS

1.1. This Policy is developed in accordance with Federal Law of the Russian Federation No. 152-FZ “On Personal Data” and other applicable regulations in the field of data protection.

1.2. The purpose of this Policy is to ensure the protection of the rights and freedoms of individuals when processing their personal data and to guarantee data security.

2. PERSONAL DATA WE COLLECT

We may collect and process the following categories of personal data:

• Full name;
• Mobile phone number;
• Email address;
• Data obtained via authorization through the Unified Identification and Authentication System (Gosuslugi);
• Taxpayer Identification Number (INN), Pension Insurance Number (SNILS), if required for signing documents with legal force;
• IP address, browser and device information, date and time of access;
• User activity logs on the Platform;
• Other data necessary for providing the Platform’s services.

3. PURPOSES OF DATA PROCESSING

Personal data is processed solely for the following purposes:

• Providing access to the Platform’s functionality;
• Executing electronic document signing;
• User identification;
• Sending notifications and one-time codes (via SMS or email);
• Ensuring security and fraud prevention;
• Compliance with Russian legislation;
• Improving service quality and user experience.

4. LEGAL BASIS FOR PROCESSING

We process personal data based on the following legal grounds:

• The user’s consent;
• Execution of an agreement between the user and the Platform;
• Compliance with legal obligations;
• Our legitimate interests (e.g., fraud prevention, legal defense).

5. DATA PROCESSING AND TRANSFER CONDITIONS

5.1. Data is processed using both automated and non-automated means in accordance with the principles of legality, data minimization, and purpose limitation.

5.2. Only authorized employees and contractors of the Platform have access to personal data, subject to confidentiality agreements.

5.3. Data is not transferred to third parties except in the following cases:

• At the request of government authorities;
• Based on a court order;
• When signing documents via Gosuslugi (EUES);
• To Platform contractors who assist in providing services (e.g., SMS providers, cloud storage).

5.4. All third parties with access to personal data are required to comply with confidentiality and data protection requirements.

6. DATA RETENTION AND DELETION

6.1. Personal data is stored for as long as necessary to fulfill the processing purposes, and no less than required by applicable law.

6.2. After the processing purpose has been fulfilled, the data is either deleted or anonymized unless otherwise required by law (e.g., for legal defense).

7. USER RIGHTS

You have the right to:

• Request information about your personal data;
• Request correction, blocking, or deletion of your data;
• Withdraw your consent at any time;
• File a complaint with Roskomnadzor or a court;
• Obtain a copy of a signed document and information about the signature method.

8. DATA PROTECTION MEASURES

We implement legal, organizational, and technical security measures to protect personal data, including:

• Encryption during transmission and storage;
• Two-factor authentication;
• User activity audits;
• Role-based access restrictions;
• Antivirus protection and firewalls.

9. CHANGES TO THIS POLICY

9.1. We may update this Policy at any time. The latest version will be published on the Platform's website.

9.2. Continued use of the Platform after changes are made constitutes acceptance of the updated Policy.