Privacy Policy

Effective date: 4 September 2026

1. General Provisions

This Privacy Policy (“Policy”) describes how personal data is collected and processed when individuals visit or use the website https://aggregate.digital/, including its subdomains and website forms (collectively, the “Website”).

The personal data operator and, where applicable, the data controller is:

Obyedinenie Agregeit LLC
(Russian: ООО «Объединение Агрегейт»)
Taxpayer Identification Number (INN): 6950166982
Primary State Registration Number (OGRN): 1136952008577
Registered address: 28/2 Tchaikovskogo Avenue, Office 708, Tver, Tver Region, 170100, Russian Federation
Email: aggregate-info@aggregate.digital

In this Policy, “Company”, “we”, “us” and “our” refer to Obyedinenie Agregeit LLC.

The Company processes personal data in accordance with the personal data legislation applicable to its activities, including Federal Law No. 152-FZ dated 27 July 2006 “On Personal Data”. The EU General Data Protection Regulation 2016/679 (“GDPR”) and other foreign data protection laws apply only where the relevant processing falls within their territorial scope.

This Policy applies to the processing of personal data in connection with the Website. Separate terms or privacy notices may apply to the Company’s products, services, contractual relationships, technical support or recruitment procedures.

2. Personal Data We Process

Depending on how you use the Website, the Company may process the following categories of personal data:

1. Identification and contact data:

• first name, last name and patronymic, where applicable;
• email address;
• telephone number;
• country and city;
• preferred language.

2. Professional and business information:

• employer or organisation;
• job title;
• business sector;
• information concerning a proposed project, request or area of interest.

3. Account and request data:

• registration and account details;
• information included in requests, applications, questionnaires and messages;
• information relating to requests for demonstrations, quotations, consultations, downloads, partnership, training or technical support;
• correspondence with the Company.

4. Technical and online data:

• IP address;
• cookie identifiers;
• browser type and version;
• device type and operating system;
• referring website;
• pages visited, date, time and duration of visits;
• Website interaction and diagnostic information.

5. Other information voluntarily provided by the user.

Please do not provide personal data relating to another individual unless you are legally authorised to do so.

The Company does not intentionally request special categories of personal data, biometric data or information concerning criminal convictions through the Website. Users should not include such information in free-text fields or messages.

3. Sources of Personal Data

The Company may obtain personal data:

• directly from you when you complete a Website form, register an account, subscribe to communications, download materials or contact the Company;
• automatically when you use the Website, including through cookies, server logs and analytics tools;
• from your employer, organisation or representative where they contact the Company on your behalf;
• from publicly available sources or business partners, where permitted by applicable law.

4. Purposes and Legal Grounds for Processing

4.1. Website Operation and Security

The Company may process personal data to:

• provide access to the Website and its functionality;
• maintain the security and proper operation of the Website;
• prevent misuse and unauthorised access;
• identify and resolve technical problems;
• maintain technical records and logs.

The applicable legal grounds may include compliance with legal obligations, the Company’s legitimate interests in operating and protecting the Website and, where required, the user’s consent.

4.2. Responding to Requests

The Company may process personal data to:

• respond to questions and requests;
• provide product, licensing, technical and commercial information;
• arrange demonstrations, meetings, consultations or training;
• process partnership and project applications;
• provide access to requested materials.

The applicable legal grounds may include taking steps at the user’s request before entering into a contract, performance of a contract, the Company’s legitimate interests in conducting business communications and, where required, consent.

4.3. Registration and Account Administration

The Company may process personal data to create and administer user accounts, authenticate users and provide access to restricted materials or services.

The applicable legal grounds may include performance of a contract, taking steps before entering into a contract and consent, where required by applicable law.

4.4. Marketing Communications

Subject to prior consent where such consent is required, the Company may process contact and professional information to send:

• newsletters;
• invitations to events and webinars;
• information about products, services and updates;
• surveys and other promotional communications.

You may withdraw your consent or unsubscribe at any time by using the unsubscribe link included in the relevant communication or by contacting the Company at aggregate-info@aggregate.digital.

Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

4.5. Website Analytics and Improvement

The Company may process technical data and information about Website usage to:

• understand how the Website is used;
• measure Website traffic and the effectiveness of its content;
• improve the Website, products and services;
• prepare statistical and analytical reports.

Depending on the circumstances and applicable law, such processing may be based on consent or the Company’s legitimate interests.

4.6. Compliance and Protection of Legal Rights

The Company may process personal data to:

• comply with applicable laws and lawful requests of competent authorities;
• maintain records required by law;
• establish, exercise or defend legal claims;
• protect the rights and legitimate interests of the Company, Website users and third parties.

The applicable legal grounds include compliance with legal obligations and the Company’s legitimate interests in protecting its rights.

5. Processing Operations

The Company may perform the following operations with personal data using automated or non-automated means:

collection, recording, systematisation, accumulation, storage, updating, alteration, retrieval, use, provision of access, transfer, blocking, deletion, destruction and, where appropriate, anonymisation.

The Company does not intend to make decisions producing legal or similarly significant effects for Website users solely by automated means.

6. Cookies and Similar Technologies

The Website may use cookies and similar technologies to ensure its proper operation, remember user preferences, analyse Website usage and improve its content and functionality.

Cookies may include:

• cookies necessary for the operation and security of the Website;
• functional cookies;
• analytics cookies;
• other cookies used to improve Website performance and user experience.

Certain cookies may be placed by third-party service providers whose technologies are integrated into the Website. The processing of information by such providers may also be governed by their respective privacy policies.

Users may restrict or disable cookies in their browser settings. Disabling certain cookies may affect the availability or proper operation of some Website functions.

Where required by applicable law, the Company requests the user’s consent to the use of non-essential cookies.

7. Recipients and Service Providers

The Company may engage third parties that provide services necessary for the operation of the Website, communication with users, data storage, technical support, analytics and other related activities.

Such third parties may be granted access to personal data only to the extent necessary to perform the relevant services and subject to applicable confidentiality and data protection requirements.

Personal data may also be disclosed:

• with the data subject’s consent;
• where necessary to respond to the data subject’s request;
• where required by applicable law or a lawful request of a competent authority;
• where necessary to protect the rights and legitimate interests of the Company or third parties;
• in connection with a corporate reorganisation or transfer of the relevant business, subject to applicable legal requirements.

The Company does not sell personal data.

8. Processing of Personal Data in the Russian Federation

Personal data relating to individuals in the Russian Federation is processed in accordance with applicable Russian personal data legislation, including requirements concerning the collection, storage and other processing of personal data.

The Company takes the measures required by applicable law when organising the processing of personal data collected through the Website.

9. International and Cross-Border Processing

The Website may be accessed by users from different countries. The Company may also use service providers, infrastructure or business partners located in different jurisdictions.

Where personal data is transferred to or otherwise processed in another country, the Company applies the requirements and safeguards prescribed by the laws applicable to the relevant processing.

Where applicable, such measures may include obtaining consent, assessing the conditions of the transfer, entering into appropriate contractual arrangements and completing required regulatory procedures.

The publication of this Policy does not replace any separate consent that may be required by applicable law.

10. Retention of Personal Data

Personal data is retained for no longer than is necessary for the purposes for which it was collected, unless a longer retention period is required or permitted by applicable law or is necessary for the establishment, exercise or defence of legal claims.

The applicable retention period may depend on:

• the purpose and nature of the processing;
• the duration of communications or contractual relations;
• legal, accounting and regulatory requirements;
• the need to protect the Company’s legitimate interests.

When personal data is no longer required, it is deleted, destroyed or anonymised in accordance with applicable requirements.

11. Data Security

The Company takes necessary and appropriate legal, organisational and technical measures aimed at protecting personal data against unauthorised or accidental access, alteration, disclosure, provision, blocking, deletion, destruction and other unlawful processing.

The specific measures applied depend on the nature, scope and context of the processing, the technologies used and the risks associated with the processing.

The Company also requires persons authorised to process personal data to maintain its confidentiality and comply with applicable data protection requirements.

12. Rights of Data Subjects

Subject to applicable law, you may have the right to:

• obtain information about the processing of your personal data;
• request access to your personal data;
• request correction of inaccurate or incomplete data;
• request blocking, restriction, deletion or destruction of personal data;
• withdraw your consent;
• object to certain processing activities;
• request data portability, where applicable;
• lodge a complaint with a competent data protection authority;
• seek judicial protection of your rights.

To exercise your rights, please contact the Company at aggregate-info@aggregate.digital or send a written request to its registered address.

A request should contain sufficient information to identify the applicant and the relevant processing. The Company may request additional information reasonably necessary to verify the applicant’s identity and prevent unauthorised disclosure of personal data.

Requests are considered within the time limits established by applicable law.

Data subjects in the Russian Federation may lodge a complaint with the Federal Service for Supervision of Communications, Information Technology and Mass Media (Roskomnadzor) or apply to a court.

13. Additional Information for Individuals in the EEA

This section applies only where the GDPR applies to the relevant processing of personal data.

Depending on the circumstances, the Company may process personal data on one or more of the following legal grounds:

• the data subject’s consent;
• the need to enter into or perform a contract;
• compliance with a legal obligation;
• the Company’s or a third party’s legitimate interests, provided that such interests are not overridden by the data subject’s rights and freedoms.

Where processing is based on legitimate interests, such interests may include operating and securing the Website, responding to business communications, improving the Website and services, preventing misuse and protecting legal rights.

Where processing is based on consent, consent may be withdrawn at any time. Withdrawal does not affect the lawfulness of processing carried out before the withdrawal.

Where the provision of personal data is necessary to enter into or perform a contract, failure to provide such data may prevent the Company from responding to a request or providing the relevant service.

Subject to the conditions and limitations established by the GDPR, individuals may have the right to request access to, correction or deletion of their personal data, restriction of processing or data portability, and to object to processing.

Individuals may also lodge a complaint with the competent data protection supervisory authority.

Requests concerning personal data may be sent to aggregate-info@aggregate.digital.

14. Third-Party Websites

The Website may contain links to third-party websites, platforms or services.

The Company does not control and is not responsible for the privacy practices or content of such third parties. Users should review the relevant third party’s privacy notice before providing personal data.

15. Changes to This Policy

The Company may update this Policy to reflect changes in applicable law, Website functionality or personal data processing practices.

The current version is published at:
https://aggregate.digital/privacy-policy.html

The effective date specified at the beginning of the Policy indicates when it was last updated.

16. Contact Details

For questions, requests or complaints concerning personal data processing, please contact:

Obyedinenie Agregeit LLC
(Russian: ООО «Объединение Агрегейт»)
28/2 Tchaikovskogo Avenue, Office 708
Tver, Tver Region, 170100
Russian Federation

Email: aggregate-info@aggregate.digital