Personal Data Processing Policy

Effective date: May 14, 2026. This is a courtesy translation; the Russian version prevails.

1. General provisions

This Policy has been adopted in accordance with Federal Law No. 152-FZ of July 27, 2006 "On Personal Data" and sets out the procedure for processing personal data, and the measures taken to keep it secure, by NPO TsVBP LLC (ООО «НПО «ЦВБП»») (the "Operator") in connection with the website veter.tech and related services (the "Website").

By using the Website, the user agrees to this Policy and to the terms on which the user's personal data is processed.

2. Operator details

3. Personal data processed

In operating the Website and related services, the Operator may process the following categories of personal data:

• Technical data of Website visitors: IP address, browser type and version, operating system, language, referring page, and date and time of the visit. This data is recorded automatically by the web server.
• Data received when a user contacts the Operator through the Telegram bot @veter_contact_bot: Telegram username, name, Telegram user ID, message text, and attached files and images.
• Contact details received when a user contacts the Operator by email or telephone: surname, first name and patronymic (if provided), telephone number, email address, and the content of the inquiry.

The Operator does not process special categories of personal data (race, nationality, political opinions, state of health, intimate life, etc.) or biometric personal data.

4. Purposes of processing

• Responding to user inquiries and providing requested information about the Operator's products.
• Entering into and performing contracts for the supply of equipment and the provision of services.
• Maintaining the technical operation and security of the Website and protecting it against unauthorized access.
• Performing obligations imposed by the laws of the Russian Federation.

5. Legal grounds for processing

• The user's consent to the processing of personal data, given by using the Website or submitting an inquiry.
• The provisions of Federal Law No. 152-FZ of July 27, 2006 "On Personal Data".
• The provisions of the Civil Code of the Russian Federation governing contractual relations.

6. Processing and retention periods

Technical data recorded by the web server is retained for no more than 90 days from the date of receipt. Inquiry data (including correspondence through the Telegram bot, email and telephone inquiries) is retained for 3 years from the last interaction or until the purposes of processing have been achieved. Data that must be processed under contractual or tax obligations is retained for the periods established by applicable law.

7. Transfer of personal data

The Operator does not transfer personal data to third parties, except as provided by the laws of the Russian Federation and where the transfer is necessary for the operation of the Website and related services:

• The Website's hosting provider, for the technical hosting of the website.
• The Telegram service (Telegram FZ-LLC), when a user contacts the Operator through the Telegram bot, to the extent necessary for the messenger to function.

No cross-border transfer of personal data is carried out without the user's prior consent and notification of the authorized body for the protection of the rights of personal data subjects, in the manner prescribed by applicable law.

8. Data protection measures

The Operator takes legal, organizational and technical measures to protect personal data against unlawful or accidental access, destruction, alteration, blocking, copying and dissemination, and against other unlawful actions, including: restricting employee access to personal data, encrypting data transmitted over the network (HTTPS/TLS), making regular backups, and monitoring the security of the infrastructure.

9. Cookies

The Website may use technical cookies required for the interface to work correctly. These cookies do not contain personal data and are not shared with third parties for advertising purposes. The Website uses the Yandex Metrica web analytics system (Yandex LLC), including its Session Replay (Webvisor) technology, which records visitors' actions on the pages (navigation, scrolling, clicks, cursor movements) and collects anonymized technical data (page address, referrer, device and browser type, IP address). The data is processed by Yandex under its terms of service and does not allow the visitor to be identified. Visitors can opt out of data collection by Metrica in their browser settings (by blocking cookies) or by installing the Yandex Metrica opt-out add-on.

10. Rights of the data subject

Under Article 14 of Federal Law No. 152-FZ, the data subject has the right to:

• obtain information concerning the processing of their personal data;
• request the rectification, blocking or destruction of their personal data if the data is incomplete, outdated, inaccurate or processed in violation of the law;
• withdraw their consent to the processing of personal data;
• challenge the Operator's actions or omissions before the authorized body for the protection of the rights of personal data subjects (Roskomnadzor) or in court.

Requests concerning the processing of personal data should be sent to info@veter.tech. A response will be provided within 30 days of receipt of the request.

11. Amendments to this Policy

The Operator may amend this Policy. The current version is always available at veter.tech/privacy.html. Amendments take effect upon publication on the Website.