PART I — PRIVACY POLICY

1. Data Controller Universal Partner Business Center (hereinafter: the "Company," "we," "us") is the operator of personal data collected through this website in accordance with Federal Law No. 152-FZ of the Russian Federation dated 27 July 2006 "On Personal Data."

Registered address: Russia, Moscow Oblast, Dmitrovsky Municipal District.

Contact for data protection matters: info@upbc.ru

2. Data We Collect When you submit an inquiry or contact form on this website, we collect the following personal data:

–       Full name

–       Email address

–       Phone number (if voluntarily provided)

–       Company name and position (if voluntarily provided)

–       Content of your inquiry

We do not collect sensitive personal data (special categories) as defined in Article 10 of Federal Law No. 152-FZ.

3. Purposes and Legal Basis for Processing Your personal data is processed solely for the following purposes:

–       Responding to your inquiry or service request

–       Providing the services you have requested

–       Compliance with applicable legal obligations

The legal basis for processing is your freely given, specific, and informed consent, provided by ticking the consent checkbox prior to submitting the form (Article 6, Federal Law No. 152-FZ).

4. Data Storage and Localization In accordance with Article 18, Part 5 of Federal Law No. 152-FZ (as amended by Federal Law No. 23-FZ of 28 February 2025, effective 1 July 2025), personal data of Russian Federation citizens collected through this website is stored and processed on servers located within the territory of the Russian Federation.

5. Data Retention Personal data is retained for the period necessary to fulfil the stated purposes, and in any event no longer than three (3) years from the date of collection, unless a longer retention period is required by applicable law or the terms of a concluded agreement.

Upon withdrawal of consent, data is destroyed within ten (10) working days, unless retention is required by law.

6. Transfer of Personal Data We do not sell, rent, or transfer your personal data to third parties for commercial or marketing purposes.

Data may be transferred to third parties strictly to the extent necessary for the provision of the requested service (e.g., courier, logistics, or legal partners), and only on the basis of a written agreement that includes data protection obligations.

Cross-border transfer of personal data is carried out in compliance with Article 12 of Federal Law No. 152-FZ. Prior to any cross-border transfer, we ensure that the recipient country provides adequate protection for the rights of data subjects.

7. Your Rights as a Data Subject You have the right to:

–       Access the personal data we hold about you

–       Request correction of inaccurate data

–       Request deletion of your personal data

–       Withdraw your consent to data processing at any time

–       Lodge a complaint with Roskomnadzor (rkn.gov.ru)

To exercise any of these rights, please contact us at: info@upbc.ru

We will respond within thirty (30) calendar days.

8. Cookies This website may use cookies and similar tracking technologies for the purpose of ensuring the technical functioning of the website and collecting anonymous usage statistics. In accordance with Roskomnadzor guidance interpreting Federal Law No. 152-FZ, your use of this website constitutes consent to the placement of technically necessary cookies.

You may disable cookies at any time through your browser settings. Disabling cookies may affect the functionality of certain features of the website.

9. Security The Company implements appropriate technical and organisational measures to protect personal data against unauthorised access, disclosure, alteration, or destruction, in accordance with the requirements of Federal Law No. 152-FZ and Government Decree No. 1119 of 1 November 2012.

10. Supervisory Authority The supervisory authority for personal data protection in the Russian Federation is the Federal Service for Supervision of Communications, Information Technology, and Mass Media (Roskomnadzor).

Website: rkn.gov.ru

PART II — TERMS OF USE

1. Acceptance of Terms By accessing and using this website, you agree to be bound by these Terms of Use. If you do not agree, please discontinue use of the website.

2. Use of Website Content All content published on this website, including but not limited to text, graphics, and structural elements, is the property of Universal Partner and is protected under applicable intellectual property law.

Reproduction, modification, or distribution of any content without prior written consent of the Company is prohibited.

3. Limitation of Liability The Company makes reasonable efforts to ensure the accuracy and currency of the information published on this website. However, the Company does not warrant the completeness or accuracy of such information and shall not be liable for any direct or indirect loss arising from reliance on website content.

The Company shall not be liable for any temporary unavailability of the website due to technical maintenance or circumstances beyond its reasonable control.

4. Governing Law and Jurisdiction These Terms of Use are governed by and construed in accordance with the laws of the Russian Federation. Any disputes arising out of or in connection with the use of this website shall be subject to the exclusive jurisdiction of the courts of the Russian Federation.

5. Amendments The Company reserves the right to amend this Privacy Policy and Terms of Use at any time. The effective date at the top of this document will be updated accordingly. Continued use of the website after publication of amendments constitutes acceptance of the revised terms.

6. Contact For any questions relating to these terms or to the processing of your personal data:

–       Email: info@upbc.ru

–       Address: Russia, Moscow Oblast, Dmitrovsky Municipal District

This document was prepared in accordance with Federal Law No. 152-FZ of the Russian Federation (as amended through 2025), Federal Law No. 23-FZ of 28 February 2025, and applicable guidance issued by Roskomnadzor. This document does not constitute legal advice. For specific legal obligations applicable to your circumstances, please consult a qualified legal professional.