REGULATION ON PERSONAL DATA PROCESSING

1. GENERAL PROVISIONS
The Regulation on the processing of personal data (hereinafter referred to as the “Regulation”, “this Regulation”) has been issued and is applied by Sequoia JSC (hereinafter referred to as the “Operator”) in accordance with paragraph 2 of Part 1 of Article 18.1 of Federal Law No. 152-FZ of 27.07.2006 “On Personal Data”.

This Regulation is an official document of the Joint Stock Company Sequoia JSC, Legal address: 121205, Russia, Moscow, Skolkovo Technopark, 42 Bolshoy Boulevard, c. 1 /office ET 3 /OFFICE 1101/5, and defines the procedure for processing and protecting (implemented protection requirements) personal data of individuals using the services of the Service sq-mine.ru located at the network address: sq-mine.ru (hereinafter referred to as the “Site”, “Service”) and its services (hereinafter referred to as Users).

This Regulation defines the policy, procedure and conditions of the Operator regarding the processing of personal data, establishes procedures aimed at preventing and detecting violations of the legislation of the Russian Federation, eliminating the consequences of such violations related to the processing of personal data.

The purpose of this Regulation is to ensure proper protection of information about users, including their personal data, from unauthorized access and disclosure.

Relations related to the collection, storage, dissemination and protection of information about users of the Service are regulated by this Regulation, other official documents of the Operator and the current legislation of the Russian Federation.

The current version of this Regulation, which is a public document, has been published and is available to any Internet user in the form of unlimited access when clicking on the link: http://sq-mine.ru/privacy.php

The Operator has the right to make changes to this Regulation. When making changes to the Regulation, the Operator notifies users about this by posting (publishing) a new version of the Regulation on the Website at the permanent address http://sq-mine.ru/privacy.php no later than 10 days before the entry into force of the relevant changes. Previous versions of the Regulation are stored in the archive of the Operator’s documentation.

This Regulation has been developed and is used in accordance with the Terms of Use of the service sq-mine.ru . If there are contradictions between this Regulation and other official documents of the Operator, this Regulation is subject to application.

By registering and using the Service, the User expresses his unconditional consent to the terms of this Provision.

If the User does not agree with the terms of this Provision, the use of the Site and its services must be immediately terminated.

All issues related to the processing of personal data that are not regulated by this Regulation are resolved in accordance with the current legislation of the Russian Federation in the field of personal data.

2. PURPOSES OF PERSONAL DATA PROCESSING

The processing of personal data is carried out in compliance with the principles and rules provided for by Federal Law No. 152-FZ of 27.07.2006 “On Personal Data” and this Regulation.

The Operator processes information about Users, including their personal data, in order to fulfill the Operator’s obligations to Users regarding the use of the Site and its services.

The Operator processes the personal data of Users in order to fulfill the contract between the Operator and the User for the provision of Website Services (clause 2.2 of the Terms of Use of the service sq-mine.ru ). By virtue of paragraph 2, paragraph 2, Article 22 of the said law, the Operator has the right to process personal data without notifying the authorized body for the protection of the rights of personal data subjects.

3. PRINCIPLES OF PERSONAL DATA PROCESSING

Processing is organized by the Operator on the principles of:

– legality of the purposes and methods of personal data processing, integrity and fairness in the Operator’s activities;

– the reliability of personal data, their sufficiency for the purposes of processing, the inadmissibility of processing personal data that are redundant in relation to the purposes stated when collecting personal data;

– processing only personal data that meet the purposes of their processing;

– compliance of the content and volume of the processed personal data with the stated processing purposes. The processed personal data should not be redundant in relation to the stated purposes of their processing;

– the inadmissibility of combining databases containing personal data, the processing of which is carried out for purposes incompatible with each other;

– ensuring the accuracy of personal data, their sufficiency, and, if necessary, relevance in relation to the purposes of personal data processing. The operator takes the necessary measures or ensures that they are taken to delete or clarify incomplete or inaccurate data;

– storing personal data in a form that allows you to identify the subject of personal data, no longer than the purposes of personal data processing require.

4. COMPOSITION OF PERSONAL DATA

4.1. Personal data of Users includes:

provided by Users and the minimum required for registration on the Site: name, mobile phone number, occupation in relation to the use of the Site and email address;

additionally provided by Users at the request of the Operator in order for the Operator to fulfill its obligations to Users arising from the contract for the provision of Site Services. The Operator has the right, in particular, to request from the User a copy of an identity document or other document containing the User’s name, surname, photo, as well as other additional information that, at the Operator’s discretion, will be necessary and sufficient to identify such a User and will allow to exclude abuse and violations of the rights of third parties.

4.2. Other User information processed by the Operator.

The Operator can also process other User information, which includes:

4.2.1. additional data obtained when accessing the Site, including data on technical means (devices), technological interaction with the Site (including the IP address of the host, the type of the user’s operating system, browser type, geographical location, Internet service provider) and subsequent User actions on the Site.

4.2.2. information obtained as a result of User actions on the Site.

5. PROCESSING OF PERSONAL DATA

5.1. The processing of Users’ personal data is carried out by the Operator on the basis of the principles of personal data processing established by Section 3 of this Regulation.

5.2. The Operator processes Users’ personal data in order to fulfill the contract between the Operator and the User for the provision of Website Services (clause 2.2 of the Terms of Use of the service http://sq-mine/privacy.php . By virtue of paragraph 2, paragraph 2, Article 22 of the said law, the Operator has the right to process personal data without notifying the authorized body for the protection of the rights of personal data subjects.

5.3. Conditions for processing personal data by the Operator.

5.3.1. The processing of personal data is carried out with the consent of the personal data subject (User) to the processing of his personal data, issued by the User to the Operator under the terms of this regulation. The subject of personal data decides to provide his personal data and gives consent to their processing to the Operator freely, by his will and in his interest by performing the following conclusive actions by the User: putting a symbol in a special field under the heading “I agree to the processing of my personal data” in each registration form located on the Internet at the network address: sq-mine.ru . The User’s performance of these conclusive actions indicates that the User’s consent to the processing of his personal data is specific, informed and conscious. Consent to the processing of personal data may be revoked by the subject of personal data (the User) at any time by sending the User a corresponding notification to the Operator’s email address: info@sequoia.holdings

5.3.2. Collection of personal data.
The User’s personal data is collected on the Site during registration, as well as later when the user enters additional information about himself on his own initiative using the Site’s tools. The personal data provided for in clause 4.1.1. of these Regulations are provided by the User and are minimally necessary during registration. Personal data provided for in clause 4.1.2. of this Appendix, are additionally provided by Users with information at the request of the Operator in order for the Operator to fulfill its obligations to Users arising from the contract for the provision of Site Services.

5.3.3. Storage and use of personal data.