TERRALINE

Personal Data Processing Policy

Last updated: June 2026

This English translation is provided for information only. In the event of any discrepancy, the Russian-language version shall prevail.

1. General Provisions

1.1. This Personal Data Processing Policy (the “Policy”) sets out the procedure for processing and protecting personal data by the Operator in relation to users of https://terra-line.org, customers, prospective customers, and other persons interacting with the Operator.

1.2. The Policy has been developed in accordance with the Constitution of the Russian Federation, the Civil Code of the Russian Federation, Federal Law No. 152-FZ “On Personal Data,” and other applicable laws and regulations of the Russian Federation.

1.3. The Operator is included in the register of personal data operators maintained by Roskomnadzor. Notification registration number: 23-24-026412 dated 25 January 2024.

1.4. Personal data are processed in order to respect and protect human and civil rights and freedoms, including the right to privacy and personal and family confidentiality.

1.5. This Policy applies to all information received by the Operator through https://terra-line.org, by telephone, email, feedback forms, messengers, and other communication channels.

1.6. Information about the use of cookies is available at https://terra-line.org/images/cookie.pdf. Where cookies or similar technologies directly or indirectly identify a User, they are processed in accordance with Federal Law No. 152-FZ.

2. Key Terms

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 required to verify or correct such data.

Website — the collection of software, information, and graphic materials available at https://terra-line.org.

Personal data information system — a set of personal data contained in databases together with information technologies and technical means used for their processing.

Anonymization of personal data — actions making it impossible to determine, without additional information, that personal data relate to a particular data subject.

Processing of personal data — any operation or set of operations performed on personal data, including collection, recording, organization, accumulation, storage, updating, retrieval, use, transfer, anonymization, blocking, deletion, and destruction.

Operator — Individual Entrepreneur Maksim Viktorovich Nasteka, who independently or jointly with other persons organizes and/or carries out personal data processing and determines the purposes, scope, and operations of such processing.

Personal data — any information relating directly or indirectly to an identified or identifiable individual (personal data subject).

User — a visitor to https://terra-line.org or another person interacting with the Operator through the Website or other communication channels.

Provision of personal data — disclosure of personal data to a particular person or a defined group of persons.

Dissemination of personal data — disclosure of personal data to an indefinite group of persons. The Operator disseminates personal data only with the separate consent of the personal data subject.

Cross-border transfer of personal data — transfer of personal data to the territory of a foreign state, a foreign individual or legal entity, a foreign public authority, or an international organization.

Destruction of personal data — actions resulting in the irreversible destruction of personal data without the possibility of recovery.

3. Principles of Personal Data Processing

3.1. Personal data are processed lawfully and fairly.

3.2. Personal data are processed only for specific, predetermined, and lawful purposes. Processing incompatible with the purposes for which the data were collected is prohibited.

3.3. The scope and content of personal data processed correspond to the stated purposes and are not excessive.

3.4. The Operator ensures that personal data are accurate, sufficient, and up to date.

3.5. Personal data are stored no longer than necessary for the purposes of processing, unless another period is established by Russian law, an agreement, or the data subject’s consent.

4. Categories of Data Subjects, Personal Data, Purposes, Legal Grounds, and Retention

CategoryPersonal dataPurposesLegal basisRetention period
Users submitting an application or inquiryFull name, telephone number, service address, content of the inquiry, and other information voluntarily provided by the UserHandling inquiries, providing feedback and consultations, selecting services, and preparing to enter into an agreementConsent; steps taken at the data subject’s request before entering into an agreement; legitimate interests of the OperatorUntil the processing purpose is achieved, consent is withdrawn, or the legally required retention period expires
CustomersData necessary to enter into and perform an agreementConclusion, performance, amendment, and termination of agreements; billing; service records; claims handling; compliance with legal requirementsAgreement; Russian law; legitimate interests of the OperatorDuring the agreement and thereafter for periods required by law and applicable limitation periods
Users who have consented to advertisingTelephone number, email address, messenger identifiers, and other contact detailsSending advertising and marketing communicationsSeparate prior consent to advertising and related personal data processingUntil consent is withdrawn
Website visitorsIP address, browser and device information, technical identifiers, activity data, cookies, and similar technologies where they constitute personal dataWebsite operation, analytics, security, service improvement, and saving User preferencesUser consent and/or the Operator’s legitimate interests where permitted by lawFor the periods specified in the Cookie Policy, or until cookies are deleted or consent is withdrawn

5. Procedure and Conditions for Processing Personal Data

5.1. The Operator processes personal data both by automated means and without such means.

5.2. The Operator does not process special categories of personal data unless otherwise provided by Russian law.

5.3. The Operator does not process biometric personal data of Users.

5.4. The Operator does not make decisions producing legal consequences for a User or otherwise affecting the User’s rights and legitimate interests solely on the basis of automated processing.

5.5. When processing personal data of citizens of the Russian Federation, the Operator uses databases located in the Russian Federation, unless otherwise provided by law.

5.6. The Operator implements the necessary legal, organizational, and technical measures to protect personal data against unlawful or accidental access, destruction, alteration, blocking, copying, provision, dissemination, and other unlawful actions.

6. Transfer of Personal Data to Third Parties and Commissioned Processing

6.1. The Operator may transfer personal data to third parties or commission third parties to process such data only where there is a lawful basis and Russian personal data requirements are observed.

6.2. Personal data may be transferred to:

6.3. Persons processing personal data on behalf of the Operator must comply with applicable legal requirements, maintain confidentiality and security, implement appropriate safeguards, and return or destroy the personal data after the processing purpose has been achieved, unless otherwise required by law or contract.

6.4. The Operator does not disseminate personal data or disclose them to an indefinite group of persons without the separate consent of the data subject, unless otherwise provided by law.

7. Rights of Personal Data Subjects and Contact Procedure

7.1. A personal data subject may obtain information about the processing of their personal data, request correction, blocking, or destruction of such data in cases provided by law, and exercise other rights under Federal Law No. 152-FZ.

7.2. A personal data subject may withdraw consent to personal data processing and/or advertising communications at any time.

7.3. Requests may be sent to: 56 Suvorova Street, Shakhtyorsk, Donetsk People’s Republic, 286211, Russian Federation, or by email to terraline.sh@gmail.com. The request should contain information sufficient to identify the applicant and describe the request.

7.4. The Operator reviews requests and replies within the time limits established by Russian law. Following withdrawal of consent, processing is discontinued and the data are destroyed unless continued storage is required by law, contract, or for the protection of the Operator’s rights and legitimate interests.

8. Correction, Blocking, and Destruction of Personal Data

8.1. Where personal data are confirmed to be inaccurate, the Operator corrects them or arranges for their correction.

8.2. Where unlawful processing is identified, the Operator stops such processing or arranges for it to be stopped.

8.3. Upon achievement of the processing purposes, loss of the need for processing, or withdrawal of consent, the Operator destroys the personal data or arranges for their destruction unless otherwise required by law or contract.

8.4. Destruction is carried out in a manner allowing the fact of destruction to be confirmed where required by law and the Operator’s internal documents.

9. Cross-Border Transfer of Personal Data

9.1. The Operator does not carry out cross-border transfers of personal data except where permitted by Russian law and necessary for the stated processing purposes.

9.2. Before commencing a cross-border transfer, the Operator complies with Article 12 of Federal Law No. 152-FZ, including notification of the competent authority where required.

9.3. Transfer to foreign states that do not provide adequate protection of personal data subjects’ rights is permitted only on grounds established by Federal Law No. 152-FZ.

10. Cookies

The Website uses cookies, which are small text files stored by a browser on the User’s device.

10.1. Essential cookies (no consent required):

10.2. Analytics cookies (used with consent):

On the User’s first visit, consent is requested for non-essential cookies. Consent may be changed or withdrawn through “Cookie Settings” in the Website footer or through the browser settings.

11. Final Provisions

11.1. This Policy takes effect on the date it is published on the Website and remains in force until replaced by a new version.

11.2. The Operator may amend this Policy. A new version takes effect when published on the Website unless that version specifies otherwise.

11.3. The current version of the Policy is publicly available at https://terra-line.org/.

11.4. Questions concerning personal data processing may be sent to terraline.sh@gmail.com or to: 56 Suvorova Street, Shakhtyorsk, Donetsk People’s Republic, 286211, Russian Federation.

TerraLine — Personal Data Processing Policy. Contact: support@terra-line.org