Rud Lifting LLC
TAX ID 7801515090
Legal address: Premises 11-N, Letter A, Building 9/24, Spassky Lane, St. Petersburg, 190031

(in accordance with Federal Law No. 152-FZ of 27.07.2006 "On Personal Data")
Effective date: January 10, 2026

1. General provisions

1.1. This Personal Data Processing Policy (hereinafter referred to as the Policy) defines the procedure and conditions for processing personal data that Individual Entrepreneur Andrey Vladimirovich Bychkov (hereinafter referred to as the Operator) receives from users of the site www.sagenec.com (hereinafter referred to as the Website), including when placing orders, registering, subscribing, and uploading files (photos, images) and the use of the site's services.

1.2. The Operator is the operator of personal data and independently determines the purposes of processing, the composition of the data, and actions (operations) with personal data.

1.3. Using the Website, placing an order, registering in a personal account, uploading files or filling out any form on the Website means the User's unconditional consent to this Policy and the terms of processing his personal data.

1.4. Principles of personal data processing

Personal data is processed on the basis of the following principles (Article 5 of Federal Law No. 152-FZ):

• legality of processing purposes and methods;
• good faith;
• compliance of processing purposes with the purposes of personal data collection;
• compliance of the content and volume of the processed data with the stated purposes of processing;
• the reliability of personal data, their sufficiency, and, if necessary, their relevance to the purposes of processing;
• inadmissibility of processing personal data that is excessive in relation to the stated purposes;
• limitations of processing to achieve specific, pre-defined and legitimate purposes;
• It is unacceptable to combine databases created for incompatible purposes.;
• storage of personal data in a form that makes it possible to identify the subject of personal data for no longer than the purposes of processing require;
• destruction or depersonalization of personal data upon achievement of the processing objectives or in case of loss of the need to achieve them.

1.5. The procedure for granting consent to the processing of personal data Consent to the terms of this Policy and to the processing of personal data is considered provided by the User in the following cases:

• clicking the "Accept", "Agree", "OK", "Continue" or similar buttons in the cookie and analytics notification banner on the first visit to the Site;
• putting a check mark (checkbox) "I agree with the Personal Data Processing Policy" and clicking the button "Place an order", "Register", "Submit" or similar in the order, registration, subscription, file upload forms;
• continued use of the Site after the Policy notification appears (in cases where it is technically impossible to implement an explicit action, but such consent must be supported by an explicit cookie consent banner).

Consent is considered specific, informed and conscious. The text of the Policy is available to the User until the consent is given via a direct link on the checkout/registration page and on the Website.

2. Composition of personal data processed

2.1. The Operator processes the following categories of personal data:

Data provided by the User voluntarily:

• last name, first name, patronymic (if any);
• email address;
• mobile phone number;
• delivery address (postal address, including ZIP code, locality, street, house, apartment/office/entrance, and other details);
• other information that the User voluntarily provides in the forms on the Website;
• photos and other images uploaded by the User voluntarily (avatar, photos of products in reviews, photos for order confirmation, photos of documents, etc.);
• metadata of uploaded files (date of shooting, device model, geolocation — if they are not deleted by the User before uploading).

Technical and analytical data collected automatically:

• IP address;
• device specifications (type, model, operating system, version, screen resolution, browser language, etc.);
• cookies and other browser identifiers;
• data about behavior on the Site (pages viewed, time spent, clicks, scrolling, traffic sources, search queries);
• approximate geolocation (at the regional/city level by IP address).

2.2. The Operator does not process special categories of personal data (about health status, nationality, religious beliefs, etc.), except except in cases where such data is voluntarily and explicitly provided by the User.

2.3. Processing of face images (biometric personal data) Uploaded photos may contain an image of a face and in some cases relate to biometric personal data in accordance with Article 11 of Federal Law No. 152-FZ. The operator does not use uploaded photos as biometric personal data and does not perform identification based on the face image (does not use facial recognition technology). The images are processed solely for the purposes specified in this Policy (display on the website, moderation, order/review execution).

3. Purposes and legal grounds of personal data processing

3.1. Personal data is processed solely for the following purposes and on the appropriate legal grounds:

№	Purpose of processing	Legal basis (art. 6 152-FZ)	Main categories of data
1	Registration, processing, payment and execution of the contract of sale (delivery of goods)	Clause 5, part 1 — execution of the contract	Full name, delivery address, phone, email
2	User identification when placing an order, registering, and interacting with customer support	Clause 5, part 1 — execution of the contract	Full name, email, phone number
3	Communication with the User regarding the order (confirmation, status, changes, delivery problems)	Clause 5, part 1 — execution of the contract	Phone, email, full name
4	Compliance with the requirements of the legislation of the Russian Federation (accounting, tax accounting, issuing checks, refunds)	Paragraph 2 of Part 1 — fulfillment of obligations under the law	Full name, delivery address, phone, email
5	Protection of the rights and legitimate interests of the Operator and the Buyer in case of claims, disputes, refunds, guarantees	Clause 7, Part 1 — legitimate interests of the operator	Full name, delivery address, phone, email
6	Notification of the order status and significant changes to the terms of the agreement (not promotional messages)	Clause 5, part 1 — execution of the contract	Phone, email
7	Analysis of traffic, user behavior, improvement of the Site's operation and convenience	Paragraph 1 of Part 1 — consent of the subject	Technical data, cookies, website behavior
8	Direct marketing (newsletters, promotions, personalized offers) — only with consent	Paragraph 1 of Part 1 — consent of the subject	Email, phone number, full name (if available)
9	Ensuring the functionality of the site's services related to uploading, storing, moderation, and displaying user content (avatars, photo reviews, order photos, etc.)	Clause 5, part 1 — execution of the contract	Uploaded photos, file metadata
10	Moderation and verification of uploaded content for compliance with the rules of the site and the legislation of the Russian Federation	Clause 7, Part 1 — legitimate interests of the operator	Uploaded photos, file metadata

3.2. After the purposes of processing have been achieved (including the expiration of the statutory retention periods), personal data and uploaded files are subject to destruction or depersonalization. Depersonalization is performed in a way that excludes the possibility of identifying a specific subject of personal data without using additional information.

4. Using web analytics services

4.1. Yandex.Metrica The Site uses the Yandex.Metrica web analytics service, owned by Yandex LLC (16 Lva Tolstogo str., Moscow, 119021). The operator is the operator of personal data, and Yandex LLC acts as the processor (the person performing the processing on behalf of the operator) in accordance with Article 6 of Federal Law No. 152-FZ. The data storage period in the Yandex.Metrica system is up to 26 months from the date of its collection (unless the settings have been changed by the tag owner). Data is processed by the Yandex.Metrica service in accordance with:

• The Yandex Privacy Policy: https://yandex.ru/legal/confidential/
• The terms of use of the Yandex.Metrica service: https://yandex.ru/legal/metrica_termsofuse/

5. Transfer of personal data to third parties

5.1. Transfer is carried out only in necessary cases.:

• delivery services and courier companies (for order fulfillment);
• payment systems and banks (for processing payments);
• Yandex LLC — as a handler within Yandex.Metrica;
• hosting providers and cloud storage — for storing files uploaded by the User (photos, images);
• content moderation services (when used) — exclusively for checking uploaded images for compliance with the rules;
• to state bodies — in cases stipulated by law.

5.2. There is currently no cross-border transfer of personal data.

6. Rights of the personal data subject

6.1. The personal data subject has the right to:

• receive information regarding the processing of his personal data;
• to request clarification, blocking or destruction of personal data in case of their incompleteness, obsolescence, unreliability, illegality of receipt or uselessness.;
• revoke consent to the processing of personal data;
• to require restrictions on the processing of personal data.