Privacy Policy

Part I — Privacy Policy

Limited Liability Company "Universal Partner Business Center" (short name: LLC "UPDC" / ООО «УПДЦ»; hereinafter — the "Company," "we," "us") is the data controller (operator) of personal data processed through this website, in accordance with Federal Law No. 152-FZ of the Russian Federation dated 27 July 2006 "On Personal Data."

Taxpayer ID (INN): 5007128954  |  Primary State Registration Number (OGRN): 1265000039479

Registered address: 141825, Moscow Region, Dmitrovsky Municipal District, village of Zhukovka, bldg. 3B, Russian Federation.

Contact for data protection matters: info@upbc.ru

2. Data We Collect

When you fill in an inquiry form or a contact form on this website, we collect the following personal data:

• Last name, first name
• Email address
• Phone number (if voluntarily provided)
• Company name and position (if voluntarily provided)
• Content of your inquiry

We do not collect special categories of personal data referred to 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 request for services
• Providing the services you have requested
• Compliance with applicable legal requirements

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). The consent checkbox is not pre-ticked by default.

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), the recording, systematization, accumulation, storage, clarification and retrieval of personal data of citizens of the Russian Federation collected through this website are carried out using databases located within the territory of the Russian Federation.

5. Data Retention Period

Personal data is retained for the period necessary to achieve the stated purposes, and in any event no longer than three (3) years from the date of collection, unless a longer 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 (for example, to 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.

Special conditions for cross-border transfer to certain jurisdictions. With respect to states not included by Roskomnadzor in the list of countries providing adequate protection for the rights of personal data subjects (in particular, the Islamic Republic of Iran and the Republic of Iraq), cross-border transfer of personal data is carried out only after a notification of cross-border transfer has been submitted to Roskomnadzor and documentary confirmation has been obtained from the receiving party regarding the conditions of processing, the security measures applied, and the legal grounds for the subsequent destruction of the data once the purposes of processing have been achieved, in the manner provided for by Article 12, Part 3 of Federal Law No. 152-FZ.

7. Your Rights as a Data Subject

You have the right to:

• obtain access to the personal data we hold about you;
• request the correction of inaccurate data;
• request the deletion of your personal data;
• withdraw your consent to the processing of data 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 respond to requests within thirty (30) calendar days.

8. Cookies

This website may use cookies and similar tracking technologies to ensure the technical operation of the website and to collect anonymized usage statistics.

On your first visit to the website, you are shown a notice allowing you to accept or decline the use of cookies that are not technically necessary, and to configure their use by category — the corresponding management widget is available at the bottom of every page of the website. Technically necessary cookies are used on the basis of your actual use of the website, in accordance with Roskomnadzor's guidance on the application of Federal Law No. 152-FZ.

You may disable cookies at any time through your browser settings or through the cookie management widget on the website. Disabling cookies may affect the functioning of certain features of the website.

9. Security

The Company applies appropriate technical and organizational measures to protect personal data against unauthorized access, disclosure, alteration or destruction, in accordance with the requirements of Federal Law No. 152-FZ and Government Decree of the Russian Federation 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

11. Development of the Website as an International Trading Platform

The Company plans the phased development of this website into an international platform for the registration of traders, manufacturers, logistics and service companies (the "Platform"), within which participants will be able to create profiles, publish information about themselves and upload supporting documents for subsequent interaction with other participants of the Platform.

From the moment the registration and participant-profile functions are launched on the website, the following will additionally be implemented and published: a separate consent to the dissemination of personal data (in accordance with Article 10.1 of Federal Law No. 152-FZ) — for data included in a public profile and made available to other users and visitors of the website; a separate user agreement (Platform rules) governing the registration procedure, verification of participants, publication of materials, and the liability of the parties; and, where applicable, a public offer for the provision of paid Platform services.

The Company will also update the notification submitted to Roskomnadzor under Article 22 of Federal Law No. 152-FZ, taking into account the new purposes and categories of personal data processed, prior to the launch of the functions referred to above.

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 with them, please discontinue use of the website.

2. Use of Website Content

All materials published on this website, including text, graphic and structural elements, are the property of Universal Partner and are protected under applicable intellectual property law.

Reproduction, modification or distribution of any content of the website without the Company's prior written consent 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 losses arising from reliance on the content of the website.

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 the website are 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 shown at the top of this document will be updated accordingly. Continued use of the website after the 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:

• Full company name: Limited Liability Company "Universal Partner Business Center" (LLC "UPDC")
• INN: 5007128954, OGRN: 1265000039479
• Email: info@upbc.ru
• Address: 141825, Moscow Region, Dmitrovsky Municipal District, village of Zhukovka, bldg. 3B, Russian Federation

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