1. General Provisions
This Personal Data Processing Policy (the “Policy”) is drafted in accordance with the requirements of Federal Law No. 152-FZ of July 27, 2006 “On Personal Data” (the “Personal Data Law”) and defines the procedures for processing personal data and the security measures undertaken by LLC “AGRORUSURS21” (the “Operator”).
1.1. The Operator considers the protection of human and civil rights and freedoms, including the right to privacy and the protection of personal and family secrets, to be its highest priority in processing personal data.
1.2. This Policy applies to all information that the Operator may receive about visitors to the website https://agroresurs21.com.
2. Key Definitions

• Automated processing of personal data — processing of personal data using computing equipment.
• Blocking of personal data — temporary suspension of personal-data processing (except where processing is necessary to clarify personal data).
• Website — a set of graphic and informational materials, software, and databases ensuring their availability online at https://agroresurs21.com.
• Personal-data information system — a combination of personal-data databases and the technologies and hardware that enable their processing.
• Anonymization of personal data — actions that make it impossible to identify the data subject without additional information.
• Processing of personal data — any operation or set of operations performed with personal data, with or without automation, including collection, recording, systematization, accumulation, storage, updating, retrieval, use, transfer, anonymization, blocking, deletion, or destruction.
• Operator — a state body, municipal body, legal or natural person, alone or jointly with others, that organizes and/or carries out personal-data processing and determines the purposes and content of such processing.
• Personal data — any information relating directly or indirectly to an identified or identifiable individual.
• Public personal data — personal data that the data subject has consented to make accessible to an unrestricted circle of persons.
• Data subject — any visitor to the website https://agroresurs21.com.

3. Operator’s Rights and Obligations
3.1. The Operator has the right to:

• Request from the data subject accurate information and/or documents containing personal data;
• Continue processing personal data without the subject’s consent if grounds specified in the Personal Data Law exist, even after consent is withdrawn;
• Independently determine the necessary and sufficient measures to fulfill its obligations under the Personal Data Law and related regulations.

3.2. The Operator is obliged to:

• Provide the data subject, upon request, with information regarding the processing of their personal data;
• Organize personal-data processing in compliance with applicable Russian legislation;
• Respond to inquiries and requests from data subjects and their lawful representatives;
• Report to the authorized data-protection authority within 10 days upon request;
• Publish or otherwise ensure unrestricted access to this Policy;
• Implement legal, organizational, and technical measures to protect personal data from unauthorized access, alteration, disclosure, or destruction;
• Cease personal-data processing and destroy data when required by law or upon completion of processing purposes.

4. Data Subject’s Rights and Obligations
4.1. Data subjects have the right to:

• Receive information about the processing of their personal data (except where prohibited by federal law);
• Request clarification, blocking, or deletion of incomplete, outdated, inaccurate, or unlawfully obtained personal data;
• Impose conditions on the use of their personal data for marketing purposes;
• Withdraw consent to personal-data processing at any time;
• Appeal the Operator’s actions or inactions to the authorized data-protection authority or in court.

4.2. Data subjects must:

• Provide the Operator with accurate personal data;
• Inform the Operator of any updates or changes to their personal data.

5. Principles of Personal-Data Processing
5.1. Lawfulness and fairness.
5.2. Purpose limitation: data processing must serve specific, lawful purposes.
5.3. No merging of databases used for incompatible purposes.
5.4. Data minimization: only data necessary for the stated purposes may be processed.
5.5. Accuracy and relevance: the Operator must ensure data accuracy and update it as needed.
5.6. Storage limitation: personal data may be stored only as long as necessary to achieve processing purposes, unless otherwise stipulated by law.
6. Purposes, Scope, and Legal Basis for Processing

Processing activities include sending informational emails and making response calls to enquiries.
7. Conditions for Personal-Data Processing
7.1. Processing is based on the data subject’s consent.
7.2.–7.5. Processing may also be necessary for compliance with international treaties, judicial acts, contracts, or to protect the Operator’s or third parties’ legitimate interests without infringing data-subject rights.
7.6. Publicly accessible personal data may be processed without additional consent.
7.7. Data required to be published by law may be processed accordingly.
8. Data Collection, Storage, Transfer, and Other Processing
8.1. The Operator implements all reasonable measures to safeguard personal data.
8.2. Personal data will not be transferred to third parties except as required by law or with the data subject’s consent.
8.3. In case of inaccuracies, data subjects may update their data by emailing agroresurs21@gmail.com with the subject “Data Update.”
8.4. Processing duration is tied to the achievement of stated purposes, unless otherwise required by contract or law.
8.5. Data collected by third-party services (e.g., payment or communication providers) is processed per their own policies; the Operator is not liable for third-party actions.
8.6.–8.9. Any restrictions imposed by the data subject on processing are overridden only in cases defined by law; processing ceases when purposes are achieved or consent is withdrawn.
9. List of Processing Operations
The Operator performs data collection, recording, systematization, accumulation, storage, updating, retrieval, use, transfer, anonymization, blocking, deletion, and destruction, including automated processing via telecommunication networks.
10. Cross-Border Transfer
10.1. Prior to any cross-border transfer, the Operator must notify the authorized data-protection authority.
10.2. The Operator must obtain relevant information from foreign authorities or entities receiving the data before notification.
11. Confidentiality
The Operator and any persons with access to personal data must not disclose or distribute such data without the subject’s consent, except as provided by federal law.
12. Final Provisions
12.1. Data subjects may request clarifications by emailing agroresurs21@gmail.com.
12.2. This Policy remains in force indefinitely until replaced by a new version.
12.3. The current version is publicly available at https://agroresurs21.com/policy.