This Personal Data Processing Policy defines the procedure and conditions for the processing of personal data by Limited Liability Company “STS-GeoService” and sets out the measures taken to protect personal data.

This Policy applies to all personal data that Limited Liability Company “STS-GeoService” may receive from users of the website, clients, partners, representatives of organizations, job applicants, and other individuals who provide personal data to the Company.

1. General Provisions

1.1. This Personal Data Processing Policy has been developed in accordance with the applicable legislation of the Russian Federation on personal data.

1.2. The purpose of this Policy is to ensure the protection of the rights and freedoms of individuals when processing their personal data, including the protection of the right to privacy, personal and family secrets.

1.3. The personal data operator is:

Limited Liability Company “STS-GeoService”
Registered office: 140104, Russian Federation, Moscow Region, Ramenskoe, Moskvoretskaya Street, Building 64, Room 106
Address for correspondence: 140104, Russian Federation, Moscow Region, Ramenskoe, Desantnaya Street, Building 18, Post Office Box 1512
Taxpayer Identification Number / Classifier of Industrial Enterprises: 7703783661 / 504001001
Principal State Registration Number: 1137746083859
Email: reception@sts-geo.com
Phone: +7 (495) 517-53-52 / +7 (496) 467-39-27
Website: https://sts-geo.com/eng

1.4. In this Policy, the following terms are used:

Personal data means any information relating directly or indirectly to an identified or identifiable individual.

Operator means Limited Liability Company “STS-GeoService”, which independently or jointly with other persons organizes and carries out the processing of personal data and determines the purposes of personal data processing, the scope of personal data to be processed, and the actions performed with personal data.

Processing of personal data means any action or set of actions performed with personal data, with or without the use of automation tools, including collection, recording, systematization, accumulation, storage, clarification, updating, modification, retrieval, use, transfer, depersonalization, blocking, deletion, and destruction.

User means any individual who visits the website, submits a request, fills out a form, contacts the Company, responds to a vacancy, or otherwise provides personal data to the Company.

2. Principles of Personal Data Processing

2.1. STS-GeoService processes personal data on a lawful and fair basis.

2.2. Personal data is processed only for specific, predetermined, and lawful purposes.

2.3. The Company does not process personal data that is incompatible with the purposes of collecting such data.

2.4. The content and scope of processed personal data correspond to the stated purposes of processing.

2.5. The Company does not process excessive personal data in relation to the stated purposes of processing.

2.6. When processing personal data, the Company ensures the accuracy, sufficiency, and, where necessary, relevance of personal data.

2.7. Personal data is stored in a form that allows the identification of the data subject no longer than required for the purposes of processing, unless a longer storage period is established by law, contract, or another legal basis.

2.8. Upon achieving the purposes of processing, or if the need to achieve such purposes is lost, personal data is deleted, destroyed, or depersonalized, unless otherwise required by applicable law.

3. Categories of Personal Data Processed

3.1. Depending on the nature of interaction with the User, the Company may process the following categories of personal data:

• last name, first name, patronymic, if provided by the User;
• company or organization name;
• phone number;
• email address;
• information contained in requests, messages, comments, feedback forms, and other communications;
• information submitted when responding to vacancies, including resume information, desired position, work experience, education, skills, and attached files;
• other information voluntarily provided by the User.

3.2. When using the website, the Company may also process technical and analytical data, including:

• IP address;
• browser type and version;
• device type;
• operating system information;
• cookie data;
• information about the User’s actions on the website;
• date and time of website access;
• source of transition to the website;
• other technical information necessary for the proper operation and improvement of the website.

3.3. The Company does not intentionally collect special categories of personal data relating to race, nationality, political views, religious or philosophical beliefs, health, intimate life, or biometric personal data, unless such processing is required by law or voluntarily initiated by the User in a document or message sent to the Company.

4. Categories of Personal Data Subjects

4.1. The Company may process personal data of the following categories of individuals:

• website users;
• clients and potential clients;
• representatives and employees of partner organizations;
• representatives and employees of contractors and counterparties;
• persons who submit requests through website forms;
• persons who contact the Company by email, phone, or other communication channels;
• job applicants and candidates;
• other individuals who have provided personal data to the Company.

5. Purposes of Personal Data Processing

5.1. STS-GeoService processes personal data for the following purposes:

• receiving and processing requests submitted through the website;
• providing responses to inquiries from Users, clients, partners, and other persons;
• communicating with Users regarding the Company’s products, technologies, services, projects, and cooperation opportunities;
• preparing and sending information, consultations, technical materials, commercial offers, and other responses related to User requests;
• maintaining business communication with clients, partners, contractors, and representatives of organizations;
• concluding, performing, modifying, and terminating contracts;
• fulfilling obligations under contracts and agreements;
• organizing feedback and communication with the Company;
• considering job applications and communicating with candidates;
• maintaining personnel and candidate records where applicable;
• improving the website, its functionality, usability, and security;
• analyzing website traffic and user interaction with the website;
• ensuring information security and preventing unauthorized access;
• complying with applicable laws and regulatory requirements;
• protecting the rights and legitimate interests of the Company.

6. Legal Grounds for Processing Personal Data

6.1. The legal grounds for processing personal data include:

• consent of the personal data subject to the processing of personal data;
• processing necessary for the performance of a contract to which the personal data subject is a party;
• processing necessary to take steps at the request of the personal data subject prior to entering into a contract;
• processing necessary for compliance with legal obligations imposed on the Company;
• processing necessary for the exercise of rights and legitimate interests of the Company;
• other legal grounds provided by applicable laws of the Russian Federation.

6.2. By submitting personal data through the website, sending an email, contacting the Company by phone, or otherwise providing personal data, the User confirms that the data is provided voluntarily and that the User is familiar with this Policy.

7. Personal Data Processing Operations

7.1. The Company may perform the following actions with personal data:

• collection;
• recording;
• systematization;
• accumulation;
• storage;
• clarification, including updating and modification;
• retrieval;
• use;
• transfer, including provision and access, where permitted by law;
• depersonalization;
• blocking;
• deletion;
• destruction.

7.2. Personal data may be processed using automation tools or without the use of such tools.

8. Procedure and Conditions for Personal Data Processing

8.1. Personal data is processed only by authorized employees or persons acting on behalf of the Company where such processing is necessary for the performance of their duties or contractual obligations.

8.2. The Company takes measures to ensure that persons who have access to personal data comply with confidentiality requirements and personal data protection rules.

8.3. The Company does not disclose personal data to third parties and does not distribute personal data without the consent of the personal data subject, except in cases provided by applicable law or where such transfer is necessary to achieve the purposes of processing.

8.4. Personal data may be transferred to third parties in the following cases:

• the User has given consent to such transfer;
• the transfer is necessary to process the User’s request;
• the transfer is necessary for the conclusion or performance of a contract;
• the transfer is necessary for the technical operation of the website;
• the transfer is required by law, court decision, or request of an authorized government body;
• the transfer is necessary to protect the rights and legitimate interests of the Company.

8.5. The Company does not sell personal data to third parties.

9. Cookies and Technical Data

9.1. The website may use cookies and similar technologies to ensure correct website operation, improve user experience, analyze website traffic, and support website functionality.

9.2. Cookies may be used to store certain settings, identify user sessions, collect statistics, and improve the operation of the website.

9.3. The User may disable or restrict the use of cookies in browser settings. Disabling cookies may affect the availability or correct operation of certain website functions.

9.4. Technical data collected through cookies and similar technologies may be processed together with other information if such data allows the identification of the User.

10. Cross-Border Transfer of Personal Data

10.1. The Company may carry out cross-border transfer of personal data only where there are lawful grounds for such transfer and where the requirements of applicable personal data legislation are met.

10.2. Cross-border transfer of personal data may be performed when it is necessary for the processing of a User request, communication with the User, performance of a contract, use of services necessary for website operation, or compliance with legal requirements.

10.3. Before carrying out cross-border transfer of personal data, the Company takes measures required by applicable laws of the Russian Federation.

11. Personal Data Storage

11.1. Personal data is stored only for the period necessary to achieve the purposes of processing, unless a different storage period is established by law, contract, consent, or another legal basis.

11.2. The storage period may depend on:

• the nature of the User’s request;
• the period of communication with the User;
• the duration of contractual relations;
• the period required for legal, accounting, tax, or corporate documentation;
• the need to protect the rights and legitimate interests of the Company.

11.3. After the purposes of processing have been achieved, or if the User withdraws consent and there are no other legal grounds for processing, personal data is deleted, destroyed, or depersonalized.

12. Protection of Personal Data

12.1. The Company takes necessary legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, distribution, and other unlawful actions.

12.2. Such measures may include:

• limiting access to personal data;
• appointing persons responsible for organizing personal data processing;
• applying internal rules and procedures for personal data processing;
• using technical means to protect information;
• controlling access to information systems;
• ensuring confidentiality of personal data;
• identifying and preventing unauthorized access to personal data;
• restoring personal data modified or destroyed due to unauthorized access, where technically possible;
• monitoring compliance with personal data protection requirements.

13. Rights of Personal Data Subjects

13.1. The personal data subject has the right to:

• receive information concerning the processing of their personal data;
• request clarification, updating, or correction of personal data;
• request blocking or deletion of personal data if it is incomplete, outdated, inaccurate, unlawfully obtained, or no longer necessary for the stated purposes of processing;
• withdraw consent to the processing of personal data;
• request termination of personal data processing;
• appeal against actions or inaction of the Company in relation to personal data processing;
• exercise other rights provided by applicable laws of the Russian Federation.

13.2. To exercise these rights, the personal data subject may contact the Company by email:

reception@sts-geo.com

13.3. The request should contain information sufficient to identify the person making the request and describe the nature of the request.

14. Withdrawal of Consent

14.1. The personal data subject may withdraw consent to the processing of personal data at any time by sending a written request to the Company.

14.2. The request may be sent to:

Email: reception@sts-geo.com

14.3. The recommended subject line is:

“Withdrawal of Consent to Personal Data Processing”

14.4. After receiving the withdrawal of consent, the Company stops processing the personal data, unless further processing is required or permitted by applicable law.

15. Updating, Blocking, and Deletion of Personal Data

15.1. If personal data is inaccurate, incomplete, or outdated, the personal data subject may request its clarification, updating, or correction.

15.2. If personal data has been processed unlawfully or is no longer necessary for the stated purposes of processing, the personal data subject may request blocking or deletion of such data.

15.3. Requests may be sent to:

Email: reception@sts-geo.com

16. Responding to Requests

16.1. The Company considers requests from personal data subjects in accordance with the procedure and time limits established by applicable laws of the Russian Federation.

16.2. If necessary, the Company may request additional information to confirm the identity of the person making the request.

16.3. The Company may refuse to satisfy a request if there are lawful grounds for such refusal, including cases where continued processing is required by applicable law.

17. Confidentiality

17.1. The Company and other persons who have access to personal data are required not to disclose personal data to third parties and not to distribute personal data without the consent of the personal data subject, unless otherwise provided by applicable law.

17.2. Confidentiality obligations remain in force throughout the entire period of personal data processing.

18. Changes to This Policy

18.1. STS-GeoService may amend this Personal Data Processing Policy from time to time.

18.2. The updated version of the Policy becomes effective from the moment it is published on the website, unless otherwise stated in the updated version.

18.3. The current version of this Policy is available on the website at:

https://sts-geo.com/eng/personal-data-processing-policy

19. Contact Information

For any questions related to the processing and protection of personal data, please contact:

Limited Liability Company “STS-GeoService”
Registered office: 140104, Russian Federation, Moscow Region, Ramenskoe, Moskvoretskaya Street, Building 64, Room 106
Address for correspondence: 140104, Russian Federation, Moscow Region, Ramenskoe, Desantnaya Street, Building 18, Post Office Box 1512
Email: reception@sts-geo.com
Phone: +7 (495) 517-53-52 / +7 (496) 467-39-27
Website: https://sts-geo.com/eng

Current version dated June 22, 2026.