Privacy Policy
and Personal Data Processing

1. General Provisions

This Privacy Policy (the 'Policy') sets out how personal data of users of the fram.group website (the 'Website') provided to FRAM GROUP LLC (PSRN 1267700027759, TIN 9719085391, the 'Operator') is processed and protected.

The Policy has been developed in accordance with Federal Law No. 152-FZ of 27 July 2006 'On Personal Data' and applies to all personal data the Operator may receive from a user of the Website.

By using the Website, You agree to the terms of this Policy. If You do not agree with its terms, please stop using the Website.

2. What Data We Collect

The Operator may collect the following categories of data:

• Contact data — name, phone number and email address, if You provide them voluntarily through the contact form or another communication channel.
• Technical data — IP address, browser type, operating system, the Website pages You visit, and the time and date of the visit. This data is collected automatically when You visit the Website.
• Cookies — small text files stored on Your device. See section 7 of this Policy for details.

The Operator does not collect special categories of personal data (racial or ethnic origin, political opinions, health data, or biometric data).

3. Purposes of Processing

Personal data is processed for the following purposes:

• Handling incoming enquiries and requests submitted through the contact form or by email.
• Arranging and holding consultations and business negotiations.
• Performing contractual obligations.
• Improving the Website and the user experience.
• Complying with the applicable laws of the Russian Federation.

4. Legal Grounds for Processing

Personal data is processed on the following grounds:

• Consent of the data subject (Article 9 of Federal Law No. 152-FZ). Text of the consent →
• Performance of a contract to which the data subject is a party.
• Compliance with the requirements of Russian law.
• The Operator's legitimate interest in keeping the Website operational and secure.

5. Data Storage and Protection

The Operator takes the necessary organisational and technical measures to protect personal data against unauthorised access, alteration, disclosure or destruction.

Personal data is stored for as long as it is needed to achieve the purposes set out in section 3, or until the data subject withdraws consent. Once that period expires, the data is destroyed or anonymised.

The Operator does not transfer personal data to third parties, except where Russian law so requires or where the data subject has given explicit consent.

6. Your Rights

Under Federal Law No. 152-FZ You have the right to:

• Obtain confirmation that Your personal data is being processed, together with information about that processing.
• Request that personal data be corrected, blocked or destroyed if it is incomplete, outdated, inaccurate or processed unlawfully.
• Withdraw consent to the processing of personal data.
• Appeal against the Operator's actions or inaction to Roskomnadzor or in court.

To exercise Your rights, write to us at: welcome@fram.group

7. Cookies

The Website uses cookies — small text files stored on Your device when You visit the Website. Cookies help the Website work correctly, remember Your preferences (for example, the interface language) and improve the user experience.

We use the following types of cookies:

• Technical (functional) — required for the Website to work. Without them the Website cannot function correctly.
• Analytics — help us understand how visitors interact with the Website so that we can improve it. This data is collected in anonymised form.

Technical cookies are required for the Website to work. Yandex Metrica analytics — visit statistics (pages, referrer, device) and on-page session recording (Webvisor and click map) — is collected from Your first visit: without this data we cannot maintain and improve the Website. Statistics are collected without Your name or contacts; if You submit a request, the Metrica visitor identifier is sent with it — it links the request to the visit and its source. Cookies can be disabled in Your browser settings.

8. Changes to the Policy

The Operator may amend this Policy. If material changes are made, the last-updated date in the Policy header will be changed. We recommend checking the current version of the Policy on this page from time to time.

9. Contacts

For any questions about the processing of personal data, please contact:

• FRAM GROUP LLC
• TIN: 9719085391 · PSRN: 1267700027759
• Address: 13-ya Parkovaya St. 26, bldg. 3, apt. 45, Moscow 105484, Russia
• Email: welcome@fram.group
• Phone: +7 (925) 44-99-000