Privacy Policy for the Processing of Personal Data

1. General Provisions
This privacy policy for the processing of personal data (hereinafter referred to as the "Policy") has been prepared in accordance with the requirements of Federal Law No. 152-FZ dated 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 implemented by Prestige Residences (hereinafter referred to as the "Operator").

1.1. The Operator considers compliance with human and civil rights and freedoms in the processing of personal data, including the right to privacy, personal and family confidentiality, as its most important goal and condition for conducting its activities.

1.2. This Policy applies to all personal data that the Operator may obtain from visitors of the website https://colibri-views.com/.

2. Key Terms Used in the Policy

2.1. Automated processing of personal data — the processing of personal data using computer technology.
2.2. Blocking of personal data — temporary suspension of the processing of personal data (except in cases where processing is necessary to clarify personal data).
2.3. Website — a collection of graphic and informational materials, as well as software and databases, that ensure their availability on the Internet at the network address https://prestige-residences.com/.
2.4. Personal data information system — a set of personal data contained in databases and the information technologies and technical means that ensure their processing.
2.5. Depersonalization of personal data — actions that result in the inability to determine the ownership of personal data by a specific User or other subject of personal data without the use of additional information.
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 the collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
2.7. Operator — a government body, municipal authority, 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 processing personal data, the composition of personal data to be processed, and the actions (operations) performed with personal data.
2.8. Personal data — any information that directly or indirectly relates to a specific or identifiable User of the website https://prestige-residences.com/.
2.9. Personal data authorized by the data subject for distribution — personal data to which the data subject has granted access to an unlimited number of persons by giving consent for the processing of such data in accordance with the procedure established by the Personal Data Law (hereinafter referred to as “personal data authorized for distribution”).
2.10. User — any visitor of the website https://colibri-views.com/.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Distribution of personal data — any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or making personal data available to an unlimited number of persons, including the publication of personal data in the media, placement in information and telecommunications networks, or providing access to personal data in any other way.
2.13. Cross-border transfer of personal data — the transfer of personal data to the territory of a foreign country to a foreign government body, foreign individual, or foreign legal entity.
2.14. Destruction of personal data — any actions resulting in the irreversible destruction of personal data, making it impossible to restore the content of personal data in the personal data information system and/or resulting in the destruction of physical media containing personal data.

3. Main Rights and Obligations of the Operator

3.1. The Operator has the right to:
– receive accurate information and/or documents containing personal data from the personal data subject;
– continue processing personal data without the consent of the personal data subject if the subject withdraws consent or submits a request to cease processing, provided there are legal grounds for doing so as specified in the Personal Data Law;
– independently determine the scope and list of measures necessary and sufficient to ensure compliance with the obligations stipulated by the Personal Data Law and related regulatory legal acts, unless otherwise provided by the Personal Data Law or other federal laws.

3.2. The Operator is obliged to:
– provide the personal data subject, upon request, with information regarding the processing of their personal data;
– organize the processing of personal data in accordance with the applicable laws of the Russian Federation;
– respond to requests and inquiries from personal data subjects 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 with the necessary information within 10 days from the date of receipt of such a request;
– publish or otherwise provide unrestricted access to this Policy regarding the processing of personal data;
– take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, alteration, blocking, copying, provision, distribution, and other unlawful actions;
– cease the transfer (distribution, provision, access) of personal data, stop processing, and destroy personal data in the manner and cases stipulated by the Personal Data Law;
– fulfill other obligations stipulated by the Personal Data Law.

4. Main Rights and Obligations of Personal Data Subjects

4.1. Personal data subjects have the right to:
– receive information related to the processing of their personal data, except in cases provided for by federal laws. The information is provided to the personal data subject by the Operator in an accessible form and must not contain personal data related to other personal data subjects, except when there are lawful grounds for the disclosure of such personal data. The list of such 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 it if the data is incomplete, outdated, inaccurate, illegally obtained, or unnecessary for the stated purpose of processing, as well as to take legal measures to protect their rights;
– require prior consent when processing personal data for the promotion of goods, works, and services on the market;
– withdraw consent to the processing of personal data and send a demand to cease such processing;
– appeal to the authorized body for the protection of the rights of personal data subjects or in court against unlawful actions or omissions of the Operator during the processing of their personal data;
– exercise other rights provided by Russian legislation.

4.2. Personal data subjects are obliged to:
– provide the Operator with accurate information about themselves;
– notify the Operator of any clarification (update, change) of their personal data.

4.3. Persons who have provided the Operator with false information about themselves or information about another personal data subject without the latter’s consent shall be held liable in accordance with Russian law.



5. Principles of Personal Data Processing

5.1. Personal data must be processed lawfully and fairly.
5.2. Personal data processing must be limited to achieving specific, pre-defined, and lawful purposes. Processing of personal data that is incompatible with the purposes of data collection is not permitted.
5.3. The merging of databases containing personal data, the processing of which is carried out for purposes that are incompatible with each other, is not allowed.
5.4. Only personal data that is relevant to the stated purposes of processing may be subject to processing.
5.5. The content and volume of personal data being processed must correspond to the stated purposes of processing. Processing of excessive personal data relative to the declared purposes is not permitted.
5.6. Accuracy, sufficiency, and, where necessary, relevance of personal data must be ensured during processing in relation to the purposes of processing. The Operator shall take the necessary measures and/or ensure that such measures are taken to delete or update incomplete or inaccurate data.
5.7. Personal data must be stored in a form that allows identification of the data subject no longer than required for the purposes of processing, unless a longer storage period is established by federal law, a contract, or if the data subject is a party, beneficiary, or guarantor under such contract. Once the processing purpose has been achieved or the need to achieve it is no longer present, the processed personal data shall be destroyed or anonymized, unless otherwise provided by federal law.



6. Purpose of Personal Data Processing

Purpose of Processing
To inform the User via email communication.

Personal Data
• Last name, first name, patronymic
• Phone numbers

Legal Grounds
• Charter (incorporation) documents of the Operator

Types of Personal Data Processing
• Collection, recording, systematization, accumulation, storage, destruction, and anonymization of personal data

7. Conditions for Personal Data Processing

7.1. The processing of personal data is carried out with the consent of the personal data subject to the processing of their personal data.
7.2. The processing of personal data is necessary to achieve the objectives stipulated by an international treaty of the Russian Federation or by law, for the performance of the functions, powers, and duties assigned to the Operator by the legislation of the Russian Federation.
7.3. The processing of personal data is necessary for the administration of justice, the execution of a court decision, or an act of another authority or official, subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. The processing of personal data is necessary for the performance of a contract to which the personal data subject is a party, beneficiary, or guarantor, as well as for entering into a contract at the initiative of the personal data subject or a contract under which the data subject will be a beneficiary or guarantor.
7.5. The processing of personal data is necessary for the exercise of the rights and legitimate interests of the Operator or third parties, or for the achievement of socially significant goals, provided that the rights and freedoms of the personal data subject are not thereby violated.
7.6. The processing of personal data is carried out when the data subject has made such data publicly available or at the request of the data subject (hereinafter — publicly available personal data).
7.7. The processing of personal data is carried out when the data is 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 current legislation in the field of personal data protection.

8.1. The Operator ensures the confidentiality of personal data and takes all possible measures to prevent unauthorized access to personal data.
8.2. The User’s personal data shall never, under any circumstances, be transferred to third parties, except in cases related to compliance with applicable legislation or if the data subject has given the Operator consent to transfer the data to a third party for the fulfillment of obligations under a civil law contract.
8.3. If inaccuracies in personal data are detected, the User may update the data independently by sending a notification to the Operator at the email address: hello@prestige-residences.com, with the subject line "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 was collected, unless a different period is established by contract or applicable law.
The User may withdraw their consent to the processing of personal data at any time by sending a notice to the Operator via email to hello@prestige-residences.com with the subject line "Withdrawal of consent to the processing of personal data".
8.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by these parties (Operators) in accordance with their own User Agreements and Privacy Policies. The personal data subject should familiarize themselves with these documents. The Operator bears no responsibility for the actions of third parties, including those listed in this clause.
8.6. Any restrictions imposed by the personal data subject on transfer (other than granting access), as well as on processing or conditions of processing (other than access) of personal data permitted for distribution, shall not apply in cases of processing for governmental, public, or other public interest purposes as defined by Russian legislation.
8.7. The Operator ensures the confidentiality of personal data during processing.
8.8. The Operator stores personal data in a form that allows identification of the personal data subject for no longer than required to fulfill the purposes of personal data processing, unless a longer storage period is required by federal law or a contract to which the data subject is a party, beneficiary, or guarantor.
8.9. Grounds for terminating personal data processing may include achievement of the processing purposes, expiration of the consent period, withdrawal of consent by the data subject, a demand to cease processing, or identification of unlawful processing.

9. List of Actions Performed by the Operator with Collected Personal Data

9.1. The Operator carries out the collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
9.2. The Operator performs automated processing of personal data with or without obtaining and/or transmitting the obtained information through information and telecommunication networks.

10. Cross-Border Transfer of Personal Data

10.1. Before commencing the cross-border transfer of personal data, the Operator must notify the authorized body for the protection of personal data subjects' rights about its intention to carry out such a transfer (this notification is submitted separately from the notification of intent to process personal data).
10.2. Before submitting the above notification, the Operator must obtain relevant information from the authorities of the foreign state, foreign individuals, or foreign legal entities to which the cross-border transfer of personal data is planned.

11. Confidentiality of Personal Data

The Operator and other persons who have access to personal data are obliged not to disclose or disseminate such data to third parties without the consent of the personal data subject, unless otherwise provided by federal law.

12. Final Provisions

12.1. The User may obtain any clarification regarding the processing of their personal data by contacting the Operator via email at: hello@colibri-views.com.
12.2. Any changes to the personal data processing policy by the Operator will be reflected in this document. The Policy remains valid indefinitely until it is replaced with a new version.
12.3. The current version of the Policy is publicly available on the Internet at: https://colibri-views.com/policy.