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    Privacy Policy

    Last updated: 2025

    1. General Provisions

    This personal data processing policy determines the procedure for processing personal data and measures to ensure the security of personal data undertaken by Captain Works LTD (hereinafter referred to as the Operator).

    1.1. The Operator sets as its primary goal and condition for its activities the observance of the rights and freedoms of a person and citizen when processing their personal data, including the protection of the rights to privacy, personal and family secrets.

    1.2. This policy of the Operator regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator may receive about visitors to the website captain.works.

    2. Key Concepts Used in the Policy

    2.1. Automated processing of personal data – processing of personal data using computer technology.

    2.2. Blocking of personal data – temporary cessation of 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, ensuring their availability on the internet at the network address captain.works.

    2.4. Information system of personal data – a set of personal data contained in databases and information technologies and technical means ensuring their processing.

    2.5. Anonymization of personal data – actions resulting in the impossibility of determining, without the use of additional information, the ownership of personal data to a specific User or another subject of personal data.

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

    2.7. Operator – a state body, municipal body, legal entity, or individual that independently or jointly with other persons organizes and/or performs the processing of personal data, as well as determines the purposes of personal data processing, the composition of personal data to be processed, 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 captain.works.

    2.9. Personal data allowed by the subject of personal data for distribution – personal data to which an unlimited number of persons have been granted access by the subject of personal data by giving consent to the processing of personal data allowed by the subject of personal data for distribution in the manner prescribed by the Personal Data Law (hereinafter referred to as personal data allowed for distribution).

    2.10. User – any visitor to the website captain.works.

    3. Basic 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 subject of personal data;
    • continue processing personal data without the consent of the subject of personal data if the subject of personal data withdraws consent to the processing of personal data or sends a request to cease processing personal data, provided there are grounds specified in the Personal Data Law;
    • independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of the obligations provided for by the Personal Data Law and the regulatory 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 subject of personal data, upon their request, with information regarding the processing of their personal data;
    • organize the processing of personal data in accordance with the procedure established by the current legislation;
    • respond to inquiries and requests from subjects of personal data and their legal representatives in accordance with the requirements of the Personal Data Law;
    • inform the authorized body for the protection of the rights of subjects of personal data upon its request of the necessary information within 10 days from the date of receipt of such a request;
    • publish or otherwise ensure unrestricted access to this Policy regarding the processing of personal data;
    • take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other unlawful actions with personal data;
    • cease the transfer (distribution, provision, access) of personal data, cease processing, and destroy personal data in the manner and cases provided for by the Personal Data Law;
    • fulfill other obligations provided for by the Personal Data Law.

    4. Basic 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 for by federal laws;
    • demand that the Operator clarify their personal data, block or destroy them if the personal data are incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing;
    • set a precondition of consent when processing personal data for promoting goods, works, and services in the market;
    • withdraw consent to the processing of personal data, as well as send a request to cease processing personal data;
    • appeal to the authorized body for the protection of the rights of subjects of personal data or in court the unlawful actions or inaction of the Operator when processing their personal data.

    5. Principles of Personal Data Processing

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

    5.2. The processing of personal data is limited to achieving specific, pre-defined, and lawful goals. It is not allowed to process personal data that is incompatible with the purposes of collecting personal data.

    5.3. It is not allowed to combine databases containing personal data, the processing of which is carried out for purposes that are incompatible with each other.

    6. Contact Information

    The User can receive any clarifications on issues of interest regarding the processing of their personal data by contacting the Operator via email at [email protected].

    CAPTAIN WORKS LTD. 111 Fulham Palace Road, London, United Kingdom, W6 8JA