Personal Data Processing Policy

Date of publication: revised version dated 30 June 2026.

Confidentiality Agreement on the Use of Personal Data

This Privacy Policy regarding personal information (hereinafter — the "Policy") applies to all information that the Site Administration may receive about the User while the User uses the website https://www.czl.ru (hereinafter — the "Site") and in the course of the performance of any agreements and contracts with the User.

Use of the Site constitutes the User's unconditional consent to this Policy and to the terms of processing of the User's personal information; if the User does not agree with these terms, the User must refrain from accessing https://www.czl.ru and cease using the materials and services of the Site.

1. Terms Used in This Agreement

1.1. **Site** — the totality of texts, graphic elements, design, images, program code, photo and video materials, and other results of intellectual activity available on the Internet under the domain name https://www.czl.ru.

1.2. **Site Administration** — Promenergolab LLC, the entity holding the rights to administer the Site.

1.3. **User** — any person who has accessed the Site and accepted the terms of this Agreement, regardless of whether they have completed the registration and authorization procedures.

2. Users' Personal Information Processed by the Site

2.1. For the purposes of this Policy, the "User's personal information" means:

2.1.1. Personal information that the User provides about themselves independently in the course of using the Site, including the User's personal data:

- The User's surname, first name, and patronymic;
- The User's e-mail address;
- The User's telephone number;
- The organization where the User works.

2.1.2. Data that is automatically transmitted to the Site in the course of its use by means of software installed on the User's device, including:

- IP address;
- Operating system used;
- Cookie data;
- Information about the User's browser (or other program used to access https://www.czl.ru);
- Technical characteristics of the hardware and software used by the User;
- Screen resolution and color settings;
- Languages used by the visitor;
- Flash version and JavaScript support;
- Type of mobile device;
- Geographic location;
- Number of visits to the site and page views;
- Number of pages viewed;
- Duration of stay on the site;
- Search queries used by the visitor to reach the site;
- Referring pages;
- Date and time of access to the Site;
- Addresses of the requested pages.

Data about the user of the mobile software application:

- Information about the user's mobile device (including the device identifier);
- Location information;
- Information about the user's contacts;
- Data on network connections;
- Data on system settings and other similar information.

2.1.3. Other information about the User, the processing of which is provided for by the terms of use of the Site.

2.2. This Policy applies only to information processed in the course of using the Site. The Site Administration does not control and is not responsible for the processing of information by third-party websites that the User may access via links available on the Site, including in the section containing links to partner websites.

2.3. The Site Administration does not verify the accuracy of the personal information provided by the User and is not in a position to assess the User's legal capacity. However, the Site Administration proceeds on the assumption that the User provides accurate and sufficient personal information and keeps such information up to date.

3. Purposes of Processing Users' Personal Information

3.1. The Site collects and stores only that personal information which is necessary for the provision of the Site's functions or for the performance of agreements and contracts with the User, except where the law requires mandatory storage of personal information for a period established by law.

3.2. The Site Administration processes the User's personal information for the following purposes:

3.2.1. Communicating with the User and providing the User with individualized information services, including sending notifications, requests, and information relating to the use of the Site; processing requests and applications from the User; using the User's data for registration on the Site and registration for the Site's events;

3.2.2. E-mail newsletter distribution.

**Please note!** By submitting a request, the User is automatically subscribed to promotional mailings (in the form of e-mail messages). The User has the right to unsubscribe from promotional mailings via the link contained in any e-mail sent by the Site (unsubscribe links are located at the end of each e-mail);

3.2.3. Improving the quality of the Site and its usability, and developing new services;

3.2.4. Advertising purposes and targeting of advertising materials;

3.2.5. Conducting statistical and other research based on anonymized data.

4. Terms of Processing Users' Personal Information and Its Transfer to Third Parties

4.1. The Site Administration stores Users' personal information in accordance with the Site's internal regulations.

4.2. The User grants the Site the right to perform the following actions (operations) with personal data:

- collection;
- recording;
- systematization;
- accumulation;
- storage;
- clarification (updating, modification);
- retrieval;
- use;
- blocking;
- deletion;
- destruction of personal data.

4.3. The confidentiality of the User's personal information is maintained, except in cases where the User voluntarily provides information about themselves for public access to an unlimited number of persons — for example, in reviews of the Site's operation or in public comments on individual pages of the Site. The User agrees that a certain part of their personal information becomes publicly available.

4.4. The Site is entitled to transfer the User's personal information to third parties in the following cases:

4.4.1. The User has consented to such actions;

4.4.2. The transfer is required under Russian or other applicable law within the framework of a procedure established by law;

4.4.3. The transfer takes place as part of a sale or other transfer of the business (in whole or in part), in which case all obligations to comply with the terms of this Policy with respect to the personal information received are transferred to the acquirer;

4.4.4. For the purpose of ensuring the possibility of protecting the rights and legitimate interests of the Site or third parties in cases where the User violates the Site's User Agreement or this Policy.

4.5. When processing Users' personal data, the Site Administration is guided by Federal Law of the Russian Federation No. 152-FZ "On Personal Data" dated 27 July 2006.

5. Modification and Deletion of Personal Information. Mandatory Data Retention

5.1. The User may at any time modify (update, supplement) the personal information provided by them, or any part thereof, by contacting the Site Administration at info@czl.ru.

5.2. Consent to data processing may be withdrawn by the User by sending a corresponding written notification to the Site Administration by e-mail at info@czl.ru.

5.3. The rights provided for in clauses 4.1 and 4.2 of this Policy may be restricted in accordance with the requirements of the law. In particular, such restrictions may include an obligation for the Site to retain information modified or deleted by the User for a period established by law and to transfer such information, in accordance with a legally established procedure, to a state authority.

6. Processing of Personal Information Using Cookies and Counters

6.1. Cookies transmitted by the Site to the User's equipment and by the User's equipment to the Site may be used by the Site Administration to provide the User with personalized services, to target advertising shown to the User, for statistical and research purposes, and to improve the Site.

6.2. The User acknowledges that the hardware and software used by them to visit websites on the Internet may have a function for blocking cookie operations (for any websites or for specific websites), as well as for deleting previously received cookies.

6.3. The Site Administration is entitled to establish that certain functions are available only on the condition that the acceptance and receipt of cookies is permitted by the User.

6.4. The structure of a cookie, its content, and its technical parameters are determined by the Site Administration and may be changed without prior notice to the User.

6.5. Counters placed on the Site may be used to analyze the User's cookies, to collect and process statistical information about the use of the Site, and to ensure the operability of the Site as a whole or of its individual functions in particular. The technical parameters of the counters' operation are determined by the Site Administration and may be changed without prior notice to the User.

7. Measures Applied to Protect the User's Personal Information

7.1. The Site Administration takes the necessary and sufficient organizational and technical measures to protect the User's personal information from unlawful or accidental access, destruction, modification, blocking, copying, or dissemination, as well as from other unlawful actions by third parties.

8. Amendments to the Privacy Policy. Applicable Law

8.1. The Site Administration has the right to unilaterally amend this Privacy Policy at any time. When amendments are made, the current version indicates the date of the latest update. The new version of the Policy takes effect from the moment it is published, unless otherwise provided by the new version of the Policy.

8.2. The current version is always available at: https://www.czl.ru/contacts/privacy-policy/. The Site Administration has no means of sending Users notifications of such changes; therefore, we strongly recommend that you periodically visit this page to check whether any changes have appeared that conflict with your convictions and principles.

8.3. This Policy, and the relations between the User and the Site Administration arising in connection with the application of this Privacy Policy, are governed by the law of the Russian Federation.

9. Feedback. Questions and Suggestions

9.1. The User may send any suggestions or questions regarding this Policy to the Site Administration at: info@czl.ru.

This document is an English translation of the Russian original provided for convenience only. In case of any discrepancy between the two versions, the Russian version shall prevail: https://www.czl.ru/contacts/privacy-policy/