1. General Provisions
This Personal Data Processing Policy has been prepared in accordance with the requirements of Federal Law No. 152‑FZ of July 27, 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 undertaken by TWENTY EIGHTY EIGHT REAL ESTATE L.L.C S.O.C (hereinafter referred to as the Operator).
1.1. The Operator considers the observance of human and civil rights and freedoms in the processing of personal data, including the protection of the rights to privacy, personal and family confidentiality, as its most important goal and condition for carrying out its activities.
1.2. This Policy of the Operator regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator may receive about visitors to the website https://2088realestate.com/.

2. Basic Terms Used in the Policy
2.1. Automated processing of personal data — processing of personal data using computer technology.
2.2. Blocking of personal data — temporary suspension of personal data processing (except in cases where processing is necessary to clarify personal data).
2.3. Website — a collection of graphic and informational materials, as well as computer programs and databases, ensuring their availability on the Internet at the network address https://2088realestate.com/.
2.4. Personal data information system — a set of personal data contained in databases and information technologies and technical means ensuring their processing.
2.5. Depersonalization of personal data — actions as a result of which it becomes impossible, without the use of additional information, to determine the ownership of personal data to a specific User or other subject of personal data.
2.6. Processing of personal data — 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 (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
2.7. Operator — a state body, municipal body, legal or natural person, independently or jointly with other persons organizing and/or carrying out the processing of personal data, as well as determining the purposes of personal data processing, the composition of personal data to be processed, and the actions (operations) performed with personal data.
2.8. Personal data — any information relating directly or indirectly to a specific or identifiable User of the website https://2088realestate.com/.
2.9. Personal data permitted by the subject of personal data for dissemination — personal data to which an unlimited number of persons have access, provided by the subject of personal data by giving consent to the processing of personal data permitted by the subject of personal data for dissemination in accordance with the procedure established by the Personal Data Law (hereinafter referred to as personal data permitted for dissemination).
2.10. User — any visitor to the website https://2088realestate.com/.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific circle of persons.
2.12. Dissemination of personal data — any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or at familiarizing an unlimited circle of persons with personal data, including the publication of personal data in mass media, posting in information and telecommunication networks, or providing access to personal data in any other way.
2.13. Cross‑border transfer of personal data
Cross‑border transfer of personal data means the transfer of personal data to the territory of a foreign state, to an authority of a foreign state, or to a foreign individual or foreign legal entity.
2.14. Destruction of personal data

Destruction of personal data means any actions as a result of which personal data are irreversibly destroyed, making it impossible to further restore the content of personal data in the personal data information system and/or physical media containing personal data are destroyed.

3. Basic Rights and Obligations of the Operator
3.1. The Operator has the right to:
- Receive from the subject of personal data reliable information and/or documents containing personal data;
- In the event that the subject of personal data withdraws consent to the processing of personal data, or submits a request demanding the termination of personal data processing, the Operator is entitled to continue processing personal data without the subject’s consent if grounds specified in the Personal Data Law exist;
- Independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations provided for by the Personal Data Law and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.
3.2. The Operator is obliged to:
- Provide the subject of personal data, upon request, with information relating to the processing of his/her 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 inquiries from subjects of personal data and their legal representatives in accordance with the requirements of the Personal Data Law;
- Provide the authorized body for the protection of the rights of personal data subjects, upon request, with the necessary information within 10 days from the date of receipt of such request;
- Publish or otherwise ensure unrestricted access to this Policy regarding the processing of personal data;
- Take legal, organizational, and technical measures to protect personal data against unlawful or accidental access, destruction, alteration, blocking, copying, provision, dissemination, as well as other unlawful actions in relation to personal data;
- Cease the transfer (distribution, provision, access) of personal data, cease processing, and destroy personal data in the manner and cases provided for by the Personal Data Law;
- Fulfill other obligations provided for by the Personal Data Law.

4. Basic Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects have the right to:
- Obtain information relating to the processing of their personal data, except in cases provided for by federal laws. Such information shall be provided to the personal data subject by the Operator in an accessible form and must not contain personal data relating to other personal data subjects, except where there are legal grounds for disclosure of such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
- Demand that the Operator clarify their personal data, block or destroy them if the personal data are incomplete, outdated, inaccurate, unlawfully obtained, or are not necessary for the stated purpose of processing, as well as take measures provided by law to protect their rights;
- Set a condition of prior consent when processing personal data for the purpose of promoting goods, works, and services on the market;
- Withdraw consent to the processing of personal data and submit a demand to terminate the processing of personal data;
- Appeal to the authorized body for the protection of the rights of personal data subjects or to a court against unlawful actions or inaction of the Operator in the processing of their personal data.
- to exercise other rights provided for by the legislation of the Russian Federation.
4.2. Personal data subjects are obliged to:
- Provide the Operator with accurate information about themselves;
- Inform the Operator of clarification (updating, modification) of their personal data.
4.3. Persons who have provided the Operator with inaccurate information about themselves, or information about another personal data subject without the latter’s consent, bear responsibility in accordance with the legislation of the Russian Federation.

5. Principles of Personal Data Processing
5.1. Personal data processing shall be carried out on a lawful and fair basis.
5.2. Personal data processing shall be limited to achieving specific, predetermined, and legitimate purposes. Processing of personal data incompatible with the purposes of personal data collection is not permitted.
5.3. It is not permitted to combine databases containing personal data if their processing is carried out for purposes that are incompatible with each other.
5.4. Only personal data that meet the purposes of their processing shall be subject to processing.
5.5. The content and scope of processed personal data shall correspond to the declared purposes of processing. Excessive personal data in relation to the declared purposes of their processing is not permitted.
5.6. When processing personal data, accuracy, sufficiency, and, where necessary, relevance of personal data in relation to the purposes of processing shall be ensured. The Operator shall take necessary measures and/or ensure that incomplete or inaccurate data are removed or clarified.
5.7. Personal data shall be stored in a form that allows identification of the personal data subject, no longer than required by the purposes of personal data processing, unless the storage period is established by federal law, by a contract to which the personal data subject is a party, beneficiary, or guarantor. Processed personal data shall be destroyed or depersonalized upon achievement of the purposes of processing or in the event of loss of necessity to achieve these purposes, unless otherwise provided by federal law.

6. Purposes of Personal Data Processing
Purpose of processing: Sending notifications to the User about new products and services, special offers, and various events. The User may always refuse to receive informational messages by sending an email to info@2088realestate.com with the note “Refusal of notifications about new products and services and special offers.”
Personal data:
- Email address
- Telephone numbers
- Last name and first name
Legal grounds:
- Constituent (founding) documents of the Operator
Types of personal data processing:
- Sending informational messages to the telephone number via WhatsApp

7. Conditions of Personal Data Processing
7.1. Personal data processing shall be carried out with the consent of the personal data subject to the processing of his/her personal data.
7.2. Personal data processing is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, to exercise the functions, powers, and duties imposed on the Operator by the legislation of the Russian Federation.
7.3. Personal data processing is necessary for the administration of justice, execution of a judicial act, or an act of another body or official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. Personal data processing is necessary for the performance of a contract to which the personal data subject is a party, beneficiary, or guarantor, as well as for the conclusion of a contract at the initiative of the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor.
7.5. Personal data processing is necessary for the exercise of the rights and legitimate interests of the Operator or third parties, or for the achievement of socially significant purposes, provided that this does not violate the rights and freedoms of the personal data subject.
7.6.
Processing of personal data is carried out when access to such data is provided by the personal data subject to an unlimited number of persons or at his/her request (hereinafter referred to as publicly available personal data).
7.7.
Processing of personal data is carried out when such data are subject to publication or mandatory disclosure in accordance with federal law.

8. Procedure for Collection, Storage, Transfer, and Other Types of Personal Data Processing
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.
8.1. The Operator ensures the preservation of personal data and takes all possible measures to prevent unauthorized access to personal data.
8.2. The User’s personal data will never, under any circumstances, be transferred to third parties, except in cases related to compliance with applicable legislation or if the personal data subject has given consent to the Operator to transfer the data to a third party for the fulfillment of obligations under a civil law contract.
8.3. In case of inaccuracies in personal data, the User may update them independently by sending a notification to the Operator’s email address info@2088realestate.com with the note “Update of personal data.”
8.4. The period of personal data processing is determined by the achievement of the purposes for which the personal data were collected, unless another period is provided for by contract or applicable legislation. The User may at any time withdraw his/her consent to the processing of personal data by sending a notification to the Operator via email at info@2088realestate.com with the note “Withdrawal of consent to personal data processing.”
8.5. All information collected by third‑party services, including payment systems, communication tools, and other service providers, is stored and processed by such persons (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject shall familiarize himself/herself with such documents. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this clause.
8.6. Restrictions established by the personal data subject on transfer (except for granting access), as well as on processing or conditions of processing (except for obtaining access) of personal data permitted for dissemination, do not apply in cases of processing personal data in state, public, and other public interests as defined by the legislation of the Russian Federation.
8.7. When processing personal data, the Operator ensures the confidentiality of personal data.
8.8. The Operator stores personal data in a form that allows identification of the personal data subject no longer than required by the purposes of personal data processing, unless the storage period is established by federal law or by a contract to which the personal data subject is a party, beneficiary, or guarantor.
8.9. Grounds for termination of personal data processing may include achievement of the purposes of personal data processing, expiration of the consent of the personal data subject, withdrawal of consent by the personal data subject, or a demand to terminate personal data processing, as well as detection of unlawful processing of personal data.

9. List of Actions Performed by the Operator with Received Personal Data
9.1. The Operator carries out collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
9.2.
The Operator carries out automated processing of personal data with the receipt and/or transfer of the obtained information via information and telecommunication networks or without such networks.

10. Cross‑Border Transfer of Personal Data
10.1. Prior to commencing activities involving the cross‑border transfer of personal data, the Operator must notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out such cross‑border transfer of personal data (this notification is submitted separately from the notification of intent to process personal data).
10.2. Before submitting the above‑mentioned notification, the Operator is obliged to obtain relevant information from the authorities of the foreign state, foreign individuals, or foreign legal entities to whom the cross‑border transfer of personal data is planned.

11. Confidentiality of Personal Data
The Operator and other persons who have gained access to personal data are obliged not to disclose personal data to third parties and not to disseminate personal data without the consent of the personal data subject, unless otherwise provided for by federal law.

12. Final Provisions
12.1. The User may obtain any clarifications on matters of interest relating to the processing of his/her personal data by contacting the Operator via email at info@2088realestate.com.
12.2. Any changes to the Operator’s personal data processing policy will be reflected in this document. The Policy is valid indefinitely until replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet at https://2088realestate.com/privacy/eng.