Privacy Policy

Moscow, July 21, 2025

This Privacy Policy (hereinafter referred to as the "Policy") applies to all information, including personal data as defined by applicable legislation (hereinafter referred to as "Personal Information"), that LLC "ITMarket" (hereinafter referred to as the "Company") may collect about the User during their use of the website located at the Internet address https://domonap.ru (https://domonap.ru ) (hereinafter referred to as the "Website") and/or the mobile application Domonap (hereinafter referred to as the "Mobile Application"), as well as in the course of fulfilling any agreements or contracts concluded between the Company and Users related to the use of the Website or Mobile Application. The Company may also receive Personal Information from its partners (hereinafter referred to as "Partners"), whose websites, programs, products, or services are used by the User. In such cases, the transfer of Personal Information is only permitted under circumstances established by applicable law and is carried out based on special agreements between the Company and each Partner.

TERMS

  • Administration – authorized employees of the Company responsible for managing the Website and Mobile Application, acting on behalf of LLC "ITMarket" (Tax ID 7706456207), who organize and/or carry out the processing of personal data, determine the purposes of processing, the categories of personal data to be processed, and the actions (operations) performed with personal data. In most cases, Personal Information is processed automatically without access by any employee of the Company. If such access becomes necessary, it will only be granted to those employees who require it to perform their duties. To protect and ensure the confidentiality of data, all employees comply with internal rules and procedures regarding the processing of Personal Information. They must also adhere to all technical and organizational security measures in place for protecting Personal Information.
  • User – an individual who submits their personal information through account authorization, or via the Connection Request Form on the Website or Mobile Application, with the subsequent purpose of transferring data to the Administration.
  • Connection Request Form – a special form where the User provides their personal information for submission to the Administration.
  • Personal Data – any information relating directly or indirectly to a specific or identifiable individual (data subject).
  • Processing of Personal Data – any action (operation) or set of actions (operations) performed with or without automation tools involving personal data, including collection, recording, systematization, accumulation, storage, updating (updating, modification), retrieval, use, transmission (distribution, provision, access), anonymization, blocking, deletion, or destruction of personal data.
  • Confidentiality of Personal Data – the mandatory requirement for the Administration or any other person having access to personal data not to disclose them without the consent of the data subject or absence of another legal basis.
  • Cookies – a small piece of data sent by a web server and stored on the User's computer, which the web client or browser resends to the web server in an HTTP request when attempting to open a page on the corresponding site.
  • IP Address – a unique network address of a node in a computer network built using the IP protocol.
  • Blocking of Personal Data – temporary suspension of personal data processing (except when processing is necessary for clarification of personal data).
  • Disclosure of Personal Data – actions aimed at revealing personal data to an indefinite group of people.
  • Providing Personal Data – actions aimed at disclosing personal data to a specific person or a defined group of persons.

GENERAL PROVISIONS

  • This Policy is an official standard document issued by the Administration, defining the procedures for processing and protecting information about Users.
  • By using the Website or Mobile Application in any way, the User voluntarily and in their own interest consents to the following methods of processing their personal data: collection, recording, systematization, storage, anonymization, accumulation, updating (updating, modification), retrieval, use, transmission (distribution, provision, access), blocking, deletion, and destruction of personal data.
  • The purpose of this Policy is to ensure proper protection of information about the User, including their personal data, from unauthorized access and disclosure.
  • Relationships related to the collection, storage, dissemination, and protection of user information are governed by this Privacy Policy and the current legislation of the Russian Federation.
  • The current version of this Privacy Policy is a public document developed by the Administration and is available to any User of the Internet by clicking on the hyperlink located on the Website or within the Mobile Application.
  • The Administration has the right to make changes to this Privacy Policy. When changes are made, the Administration shall notify Users by publishing the new version of the Privacy Policy on the Website. Upon publication of a new version, the previous versions are archived by the Administration.
  • By authorizing and/or using the Connection Request Form, the User expresses their agreement with the terms of this Privacy Policy.
  • The Administration does not verify the accuracy of the information received (collected) about the User, except in cases specified in the terms of use of certain services, and cannot assess its reliability or whether the User has sufficient legal capacity to provide such Personal Information. Nevertheless, the Administration assumes that the User provides accurate and sufficient Personal Information and updates it timely.
  • The Website or Mobile Application may contain links to other websites. The Administration is not responsible for the content, quality, or security policies of these websites. This privacy statement applies only to information directly posted on this Website.

PERSONAL INFORMATION

For the purposes of this Policy, Personal Information includes:

  • Information voluntarily provided by the User, including personal data (surname, name, patronymic; phone number; email; place of residence; images uploaded by the User).
  • Data transmitted automatically, namely: anonymized data such as cookies, browser parameters and settings, location, and data about actions performed on the Website.
  • Personal data permitted for processing under this Privacy Policy are provided by the User through filling out the Connection Request Form on the Website or Mobile Application and/or through authorization.
  • The Website protects data automatically transmitted during viewing of advertising blocks and when visiting pages containing statistical scripts ("pixels"):
  1. IP address;
  2. information and cookies;
  3. information about the browser (or other software accessing advertisements);
  4. time of access;
  5. URL of the page hosting the ad block;
  6. referrer (address of the previous page).
  7. Any other personal information not listed above (e.g., browsers and operating systems used, etc.) is securely stored and not disclosed, except as permitted by this Privacy Policy.
  • The User’s submission of personal data to the Administration via the Registration Request Form or through authorization constitutes full consent to the transfer of their personal data. By providing their personal data, the User gives full and voluntary consent to the processing, storage, and use of their personal data in accordance with Federal Law No. 152-FZ “On Personal Data” dated July 27, 2006, and under the conditions specified in this Privacy Policy.

PURPOSES OF PERSONAL DATA PROCESSING

The Administration may use the User’s personal information for the following purposes:

  • Timely and complete provision of high-quality services.
  • Conducting marketing, statistical, and other research based on anonymized data.
  • Processing technical service information necessary for providing paid and free features of the Website and Mobile Application to the User.
  • Informational services, including sending promotional and informational materials.
  • Personal data processing is carried out based on the following principles:
  1. Lawfulness, purpose limitation, and fairness in the processing of personal data;
  2. Consistency of the purposes of personal data processing with the purposes previously defined and stated at the time of data collection;
  3. Proportionality of the volume and nature of personal data being processed to the processing methods and purposes;
  4. Prohibition of combining databases containing personal data created for incompatible purposes.
  • The Administration may not process Personal Information without sufficient legal grounds. Therefore, the Administration processes Personal Information only if:
  1. Processing is necessary to fulfill contractual obligations to Users, including ensuring the operation of the Website and Mobile Application;
  2. Processing is necessary to comply with statutory obligations;
  3. Where permitted by applicable law, processing is necessary to pursue the legitimate interests of the Company, provided that such processing does not significantly affect the User’s interests, fundamental rights, or freedoms.
  • The Administration processes Personal Information to safeguard its legitimate interests, for example, in the following cases:
  1. To better understand how Users interact with the Website and Mobile Application;
  2. To enhance, modify, personalize, or otherwise improve the Website and Mobile Application for the benefit of all users;
  3. To offer Users other products and services from the Company or third-party companies that the Company believes may be of interest to the User.

The Administration always processes Personal Information for specific purposes and only uses information relevant to achieving those purposes, for example:

  1. Providing the User with access to the Website and Mobile Application;
  2. Granting access to the User account;
  3. Communicating with the User to send notifications, requests, and information related to the operation of the Website and Mobile Application, fulfilling agreements with Users, and processing requests and applications;
  4. Improving usability of the Website and Mobile Application, and enhancing other Company products and applications;
  5. Developing new products, utilities, and offerings;
  6. Protecting the rights of the User and the Administration;
  7. Collecting, processing, and presenting statistical data, big data, and other research findings.

METHODS AND DURATION OF PERSONAL DATA PROCESSING

  • Processing of the User’s personal data is carried out without time limitation, by any lawful means, including in personal data information systems, with or without automation tools.
  • The User agrees that the Administration may transfer personal data to partners and other third parties, including postal organizations and telecommunications operators.
  • The User’s personal data may be transferred to authorized bodies of the Russian Federation government only on grounds and in the manner prescribed by the laws of the Russian Federation.
  • The Administration takes all necessary organizational and technical measures to protect the User’s personal information from unlawful or accidental access, destruction, alteration, blocking, copying, dissemination, and other unauthorized actions by third parties.
  • In case of loss or unauthorized disclosure of personal data, the Administration shall inform the User.
  • The Administration shall cooperate with the User to take all necessary measures to prevent losses or other negative consequences caused by the loss or disclosure of personal data.
  • By using the Website and Mobile Application, the User consents to the use of cookies and the processing of cookie files and user data for improving the functionality of the Website, retargeting, and statistical marketing research.
  • The User’s personal data are stored exclusively in databases located on hosting servers within the territory of the Russian Federation and are used strictly for the purposes specified in this Privacy Policy.

TRANSFER OF PERSONAL DATA

  • The Administration keeps data confidential, except in cases where processing involves personal data that the User has explicitly allowed to be accessed by an unlimited number of people.
  • Transfer is necessary to achieve the purposes, exercise functions, powers, and responsibilities assigned to the Administration by the legislation of the Russian Federation.
  • Data are transferred in encrypted form using the secure SSL data transmission protocol.
  • Some personal information may be shared with strategic partners working with the Administration to deliver products and services, assist in delivering products and services to consumers, recruit personnel for specific positions, or with banks or payment systems when such disclosure is required for initiating payments through the payment system the User wishes to use. The Administration makes every effort to keep the User’s personal data secure. Personal information may be disclosed in cases described by law or when the Administration deems such actions necessary to comply with legal procedures, court orders, or legal processes required for the User’s interaction with the Website and Mobile Application.
  • Disclosure of personal data upon request by government agencies or local authorities is conducted in accordance with the legislation of the Russian Federation.

PROTECTION OF PERSONAL DATA

  • The Administration takes organizational and technical measures to protect the User’s personal data from unlawful, accidental, or intentional access, destruction, alteration, blocking, and other unauthorized actions by third parties.

RETENTION PERIOD AND DESTRUCTION OF PERSONAL DATA

  • User personal data are stored indefinitely.
  • Personal data of the User are destroyed upon the User’s request or at the initiative of the Administrator without explanation, by deleting the information posted by the User.

USER RIGHTS AND OBLIGATIONS

  • The User is responsible for the accuracy and completeness of the data provided in the Connection Request Form and during registration/authorization on the Website or Mobile Application.
  • The Administration is not responsible for the completeness and accuracy of technical data obtained about the User during registration/authorization on the Website or Mobile Application.
  • At any time, the User has the right to withdraw consent to the processing of their personal data by sending a message to support@domonap.ru or submitting a written notice to the same address marked “Withdrawal of Consent to Personal Data Processing.”
  • Withdrawal of consent results in the complete deletion of the User’s account from the Website and removal of all personal data from processing and storage systems, making it impossible to provide paid or free features of the Website and Mobile Application to the User.
  • Early withdrawal of consent terminates the current non-exclusive license granted to the User without the possibility of restoration.
  • To fulfill the provisions of clause 9.3, the Administration may require identity verification, requesting confirmation in any lawful form. All suggestions and comments regarding this Policy should be sent to support@domonap.ru with the subject line “Regarding Privacy Policy.”
  • The Administration undertakes to review and respond to the User’s inquiry within 30 business days of receipt.
  • All correspondence received by the Company from the User (written/electronic messages) is considered confidential and may not be disclosed without the User’s written consent. Personal data and other information about the User submitting a request may not be used for any purpose other than responding to the request or in cases expressly permitted by law.

RESPONSIBILITY

  • The Administration, failing to fulfill its obligations, shall bear responsibility for damages incurred by the User due to unlawful use of personal data in accordance with the laws of the Russian Federation, except as otherwise provided in this Privacy Policy.
  • In the event of loss or unauthorized disclosure of personal data, the Administration shall not be liable if the personal data have become:
  1. Publicly available prior to their loss or disclosure;
  2. Obtained from a third party before being received by the Administration;
  3. Disclosed with the User’s consent.