Personal Data Processing Policy

Ulyanovsk, 21.11.2025

1. General Provisions

This Personal Data Processing Policy has been drawn up in accordance with the requirements of the Federal Law of July 27, 2006 No. 152-FZ “On Personal Data” (hereinafter referred to as the Personal Data Law) and defines the procedure for processing personal data and the measures to ensure the security of personal data undertaken by LLC “AviaPlus” (hereinafter referred to as the Operator).

1.1. The Operator considers the protection of human and civil rights and freedoms during the processing of personal data, including the protection of the right to privacy, personal and family secrets, as its most important goal and condition for conducting its activities.

1.2. This Operator’s Personal Data Processing Policy (hereinafter referred to as the Policy) applies to all information that the Operator may obtain about visitors to the website https://aviaplusgroup.com

2. Main Terms Used in the Policy

2.1. Automated processing of personal data – processing of personal data using computing equipment.

2.2. Blocking of personal data – temporary cessation of the processing of personal data (except in cases where processing is necessary to clarify personal data).

2.3. Website – a set of graphic and informational materials, as well as computer programs and databases that ensure their accessibility on the Internet at https://aviaplusgroup.com

2.4. Personal Data Information System – a set of personal data contained in databases and the information technologies and technical means that ensure their processing.

2.5. Anonymization of personal data – actions as a result of which it is impossible to determine, without additional information, the affiliation of personal data to a specific User or other personal data subject.

2.6. Processing of personal data – any action (operation) or a set of actions (operations) performed using automation tools or without using such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), anonymization, blocking, deletion, destruction of personal data.

2.7. Operator – a state body, municipal body, legal entity, or individual, independently or jointly with others, organizing and/or carrying out the processing of personal data, as well as determining the purposes of personal data processing, the composition of personal data to be processed, and the actions (operations) performed with personal data.

2.8. Personal data – any information relating directly or indirectly to a specific or identifiable User of the website https://en.aviaplusgroup.com

2.9. Personal data permitted by the data subject for dissemination – personal data whose access by an unlimited number of persons is provided by the data subject by giving consent for processing personal data permitted for dissemination in accordance with the Personal Data Law (hereinafter referred to as personal data permitted for dissemination).

2.10. User – any visitor of the website https://aviaplusgroup.com

2.11. Provision of personal data – actions aimed at disclosing personal data to a certain person or a certain group of persons.

2.12. Dissemination of personal data – any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or at providing access to personal data for an unlimited number of persons, including disclosure in mass media, placement in information and telecommunication networks, or providing access to personal data in any other way.

2.13. Cross-border transfer of personal data – transfer of personal data to the territory of a foreign state to a foreign governmental authority, foreign individual, or foreign legal entity.

2.14. Destruction of personal data – any actions as a result of which personal data is irreversibly destroyed with no possibility of further recovery of personal data content in the personal data information system and/or the physical carriers of personal data are destroyed.

3. Main Rights and Obligations of the Operator

3.1. The Operator has the right to:

receive reliable information and/or documents containing personal data from the personal data subject;

in the event of withdrawal of consent to personal data processing by the personal data subject, or submission of a request to stop processing personal data, the Operator may continue processing personal data without the consent of the data subject if there are grounds provided for in the Personal Data Law;

independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations provided by the Personal Data Law and normative legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.

3.2. The Operator is obliged to:

provide the personal data subject, upon request, with information regarding the processing of their personal data;

organize the processing of personal data in accordance with the current legislation of the Russian Federation;

respond to requests and inquiries from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;

provide the authorized body for the protection of personal data subjects with the necessary information upon request within 10 days of receiving such request;

publish or otherwise ensure unrestricted access to this Personal Data Processing Policy;

take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision, dissemination, as well as other unlawful actions regarding personal data;

cease the transfer (dissemination, provision, access) of personal data, stop processing, and destroy personal data in the manner and cases provided by the Personal Data Law;

perform other obligations provided by the Personal Data Law.

4. Main Rights and Obligations of Personal Data Subjects

4.1. Personal data subjects have the right to:

receive information regarding the processing of their personal data, except in cases provided by federal laws. Information is provided in an accessible form and must not contain personal data relating to other subjects, unless there are legal grounds for disclosure;

request the Operator to clarify, block, or destroy their personal data if the personal data is incomplete, outdated, inaccurate, illegally obtained, or not necessary for the stated purpose of processing, and take measures provided by law to protect their rights;

set a condition of prior consent for processing personal data for marketing purposes;

withdraw consent to personal data processing and submit a request to stop processing personal data;

appeal to the authorized body for the protection of personal data subjects or in court against unlawful actions or inaction of the Operator regarding the processing of their personal data;

exercise other rights provided by the legislation of the Russian Federation.

4.2. Personal data subjects are obliged to:

provide the Operator with accurate data about themselves;

inform the Operator of updates, corrections, or changes to their personal data.

4.3. Persons providing false information about themselves or another personal data subject without the consent of the latter bear responsibility in accordance with the legislation of the Russian Federation.

5. Principles of Personal Data Processing

5.1. Processing of personal data is carried out on a lawful and fair basis.

5.2. Processing is limited to achieving specific, predetermined, and lawful purposes. Processing incompatible with the purpose of collection is not allowed.

5.3. Combining databases containing personal data for incompatible purposes is not allowed.

5.4. Only personal data that meets the purposes of processing are subject to processing.

5.5. The content and volume of processed personal data correspond to the declared purposes. Redundant data relative to the purpose is not allowed.

5.6. Accuracy, sufficiency, and relevance of personal data to processing purposes must be ensured. The Operator takes necessary measures to delete or clarify incomplete or inaccurate data.

5.7. Personal data is stored in a form that allows identification of the subject no longer than required by processing purposes, unless otherwise specified by federal law or contract. Upon achieving processing purposes or losing necessity, data is destroyed or anonymized, unless federal law provides otherwise.

6. Purposes of Personal Data Processing

No.	Purpose of Processing	Legal Basis	Categories of Data Subjects	Categories of Personal Data	Methods of Processing	Processing & Storage Period	Destruction Procedure
6.1	Processing of applications submitted by potential clients through forms on the Website	Consent of the personal data subject (Clause 1, Part 1, Article 6 of Federal Law No. 152-FZ)	Individuals who submitted an application via the Website	Name, phone number, email address	Collection, recording, systematization, storage, use	No more than 90 (Ninety) days from the date of receipt of the application	Data must be destroyed by deleting it from all electronic databases within 30 (Thirty) business days.
6.2	Conclusion and performance of service agreements for air cargo transportation	Conclusion and performance of an agreement to which the personal data subject is a party (Clause 5, Part 1, Article 6 of Federal Law No. 152-FZ)	Clients (counterparties) under service agreements	Full name, passport details, job position, phone number, email address	Collection, recording, systematization, storage, use, transfer (to partner transport and logistics companies)	5 (Five) years from full performance of the agreement, unless otherwise provided by the legislation of the Russian Federation	Data must be anonymized or destroyed upon expiration of the established period.

7. Conditions for Personal Data Processing

7.1. Processing is carried out with the consent of the personal data subject.

7.2. Processing is necessary to achieve goals provided by an international treaty of the Russian Federation or law, for the fulfillment of powers and duties assigned by the legislation.

7.3. Processing is necessary for justice, execution of a court or official act.

7.4. Processing is necessary for execution of a contract involving the personal data subject.

7.5. Processing is necessary to protect rights and legal interests of the Operator or third parties or for socially significant purposes, provided it does not violate rights of the personal data subject.

7.6. Public personal data may be processed with access granted by the data subject.

7.7. Personal data required for publication or mandatory disclosure under federal law may be processed.

8. Procedure for Collection, Storage, Transfer and Other Types of Processing of Personal Data

The security of personal data processed by the Operator is ensured through the implementation of legal, organizational, and technical measures necessary to fully comply with the requirements of applicable legislation in the field of personal data protection.

8.1. The Operator ensures the safekeeping of personal data and takes all possible measures to prevent unauthorized access to personal data.

8.2. The Operator may transfer personal data to third parties only for the purposes specified in Section 6 of this Policy, as well as in cases expressly provided for by the legislation of the Russian Federation.

8.3. If inaccuracies in personal data are identified, the User may update them independently by sending the Operator a notice to the Operator’s email address sales@aviaplusgroup.com with the subject line “Personal Data Update”.

8.4. The period of personal data processing is determined by the achievement of the purposes for which the personal data was collected, unless another period is provided for by an agreement or applicable legislation. The User may revoke their consent to the processing of personal data at any time by sending the Operator a notice via email to the Operator’s email address sales@aviaplusgroup.com with the subject line “Withdrawal of Consent to Personal Data Processing”.

8.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by these parties (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject must independently familiarize themselves with these documents. The Operator is not responsible for the actions of third parties, including the service providers listed in this clause.

8.6. Restrictions imposed by the personal data subject on the transfer (except for granting access), processing, or conditions of processing (except for access) of personal data permitted for dissemination do not apply in cases of processing personal data in state, public, or other public interests as defined by Russian legislation.

8.7. When processing personal data, the Operator ensures the confidentiality of personal data.

8.8. The Operator stores personal data in a form that allows identification of the personal data subject for no longer than required by the purposes of processing, unless a different retention period is established by federal law or by an agreement to which the personal data subject is a party, beneficiary, or guarantor.

8.9. Grounds for termination of personal data processing may include achievement of the purposes of personal data processing, expiration of the period of the personal data subject’s consent, withdrawal of consent by the personal data subject, a demand to cease personal data processing, or identification of unlawful personal data processing.

9. Actions Performed by the Operator with Personal Data

9.1. Collection, recording, systematization, accumulation, storage, updating, extraction, use, transfer, anonymization, blocking, deletion, and destruction of personal data.

9.2. Automated processing may involve data transfer via telecommunication networks.

10. Cross-Border Transfer of Personal Data

10.1. Before cross-border transfer, the Operator must notify the authorized body.

10.2. Before notification, the Operator must obtain relevant information from foreign authorities or entities involved.

11. Confidentiality of Personal Data

The Operator and other persons with access must not disclose or distribute personal data without consent, unless required by federal law.

12. Final Provisions

12.1. Users may request clarifications regarding personal data processing via sales@aviaplusgroup.com

12.2. Any changes to the policy will be reflected in this document. The policy is valid indefinitely until replaced.

12.3. The current version of the Policy is publicly available at Privacy policy