Privacy Policy of ENERGOTRADE LLC, dated September 29, 2025

This Privacy Policy (hereinafter – the Policy) has been developed in accordance with the provisions of the Constitution of the Russian Federation, Federal Law No. 149-FZ of July 27, 2006 “On Information, Information Technologies and Protection of Information”, Federal Law No. 152-FZ of July 27, 2006 “On Personal Data” (hereinafter – the Personal Data Law), and other regulatory legal acts in the field of personal data protection and processing applicable in the territory of the Russian Federation. The Policy defines the general principles of collection, use, and protection of information obtained by ENERGOTRADE LLC (hereinafter – the Company) from users of the website https://invertomatic.ru/ (hereinafter – the Website). It has been developed to ensure transparency regarding how the Company processes all information obtained in the course of interaction with the Website and is a supplement to the ENERGOTRADE LLC Policy on Personal Data Processing and the ENERGOTRADE LLC Cookie Policy.

1. General Provisions

1.1. The operator responsible for the collection and processing of information is Limited Liability Company “ENERGOTRADE”, TIN 7735198624, PSRN 1237700115168, Legal address: 124460, Moscow, Municipal District Matushkino, Zelenograd, Passage 4801-Y, Building 5.

1.2. Use of the Website constitutes the user’s unconditional consent to this Policy and the terms of processing of all information obtained by the Company. If the user does not agree with the terms of the Policy, the user must refrain from using the Website.

1.3. This Policy governs the processing of information obtained exclusively through the Website https://invertomatic.ru/. The Company is not responsible for the actions and policies of third-party websites that may be linked to from the Website.

1.4. Matters relating to the processing of users’ personal data, including purposes, legal grounds, retention periods, security measures, and the rights of data subjects, are regulated in detail by the ENERGOTRADE LLC Policy on Personal Data Processing, available at https://invertomatic.ru/.

1.5. Matters relating to the use of cookies and similar technologies on the Website, including their types and how they can be managed, are regulated in detail by the ENERGOTRADE LLC Cookie Policy, available at https://invertomatic.ru/.

1.6. The Website administration develops measures to protect the personal data of Website users.

2. Key Definitions

- Website User (User): Any individual who accesses the Website and uses its functionality.

- Website: A set of graphic and informational materials, as well as computer programs and databases that make them available on the Internet at https://invertomatic.ru/.

- Company: ENERGOTRADE LLC as specified in clause 1.1 of this Policy.

- Information: Any data, information, and materials obtained by the Company from the User or in the course of the User’s use of the Website, including both personal and non-personalized data.

- Non-Personalized Information (Anonymized Data): Information that does not relate to a directly or indirectly identified or identifiable individual and does not allow the User to be identified.

- Personal Data: Any information relating to a directly or indirectly identified or identifiable individual (personal data subject).

- Personal Data Processing: Any action (operation) 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 (dissemination, provision, access), anonymization, blocking, deletion, and destruction of personal data.

3. What Information We Collect

The Company collects two main types of information:

3.1. Personal Data: Information that allows the User to be directly or indirectly identified (for example, last name, first name, patronymic, contact details, position, place of work). The full list of personal data collected, as well as the purposes, legal grounds, and methods of their processing, are set out in detail in the ENERGOTRADE LLC Policy on Personal Data Processing.

3.2. Non-Personalized Information: Data that does not allow a specific User to be identified. This information is collected automatically upon each visit to the Website and includes:

- IP address.

- Device data (type, model, operating system).

- Web browser type and version.

- Information about visited Website pages, time and date of the visit.

- Referrer (the address of the page from which the User navigated to the Website).

- Information obtained through cookies and similar technologies (details in the Cookie Policy).

4. How We Use Information

The Company uses the information collected (both personal data and non-personalized information) for the following purposes:

4.1. Ensuring the Operation of the Website: Maintaining the Website’s functionality, improving its navigation, and providing access to its services.

4.2. Analytics and Statistics: Collecting and analyzing anonymized data on user behavior on the Website to improve the quality of services, content, and Website functionality.

4.3. Marketing and Advertising: Using non-personalized information (for example, interest data collected via cookies) to display relevant advertising and offers to the User. The use of personal data for advertising and commercial purposes is carried out in accordance with the ENERGOTRADE LLC Policy on Personal Data Processing and only with the corresponding consent.

4.4. Communication with the User: Interacting with Users in response to their requests. The processing of personal data for these purposes is carried out in accordance with the ENERGOTRADE LLC Policy on Personal Data Processing.

4.5. Security: Protecting the Website and users from unauthorized access, fraud, and other unlawful actions.

5. Disclosure of Information to Third Parties

5.1. The Company may transfer non-personalized information (for example, aggregated statistical data, web analytics data) to third parties for research, analysis, service improvement, or marketing purposes. Such information does not allow a specific User to be identified.

5.2. The transfer of personal data to third parties is carried out strictly in accordance with the terms and purposes set out in the ENERGOTRADE LLC Policy on Personal Data Processing, and only where there are lawful grounds (User consent, performance of a contract, legal requirement, etc.).

When transferring personal data of Website users, the Website administration warns the persons receiving such information that these data may be used only for the purposes for which they were provided and requires written confirmation from such persons of compliance with this condition.

All information on the transfer of personal data of Website users is recorded to monitor the lawfulness of the use of such information by the persons who received it.

In order to improve service quality and ensure the possibility of legal protection, the Website administration is entitled to store log files of actions performed by users in the course of using the Website.

6. Information Protection

The Company takes necessary and sufficient legal, organizational, and technical measures to protect all collected information from unlawful or accidental access, destruction, modification, blocking, copying, dissemination, and other unlawful actions. Detailed measures for ensuring the security of personal data are described in the ENERGOTRADE LLC Policy on Personal Data Processing.

Personal data of Website users are stored electronically in the Website’s personal data information system, as well as in archival copies of the Website databases.

When storing personal data of Website users, organizational and technical measures are observed that ensure their integrity and exclude unauthorized access to them.

Only employees of the Website administration who are authorized to work with personal data of Website users and who have signed a non-disclosure agreement regarding personal data of Website users may have access to the processing of personal data of Website users.

7. Rights and Obligations of the Website Administration

7.1. The Website administration is entitled to establish requirements for the composition of users’ personal data that must be provided for use of the Website; in doing so, the Website administration is guided by this Privacy Policy, the Constitution of the Russian Federation, and other federal laws.

7.2. The Website administration does not verify the accuracy of personal data provided by Website users, assuming that they act in good faith and keep their personal data information up to date.

7.3. The Website administration is not responsible for the voluntary transfer by Website users of their contact details, password, or login to third parties.

7.4. The Website administration is not entitled to obtain and process personal data of Website users concerning their political, religious, and other beliefs and private life.

7.5. The Website administration, at its own expense, ensures the protection of personal data of Website users from unlawful use or loss in the manner established by the legislation of the Russian Federation.

7.6. The Website administration takes measures necessary and sufficient to fulfill the obligations provided for by the Personal Data Law and the regulatory legal acts adopted in accordance therewith. The Website administration independently determines 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 therewith.

8. User Rights

The User’s rights with respect to their personal data (the right of access, modification, deletion, withdrawal of consent, etc.) are set out in detail in the ENERGOTRADE LLC Policy on Personal Data Processing.

9. Procedure for Destruction and Blocking of Personal Data

9.1. If unlawful processing of personal data is identified upon a request from a Website user, the Website administration blocks the unlawfully processed personal data relating to that user from the moment of such request for the period of verification.

9.4. If unlawful processing of personal data carried out by the Website administration is identified, the Website administration ceases the unlawful processing of personal data within three business days from the moment of identification.

9.5. If it is impossible to ensure the lawfulness of personal data processing, the Website administration destroys such personal data within ten business days from the date of identification.

9.6. The Website administration notifies the Website user of the elimination of the violations committed or of the destruction of personal data.

9.7. If a fact of unlawful or accidental transfer (provision, dissemination, access) of personal data resulting in a violation of the Website user’s rights is established, the Website administration notifies the authorized body for the protection of the rights of personal data subjects:

- within 24 hours of the incident that occurred, of the presumed causes that led to the violation of the Website user’s rights, and of the presumed harm caused to the Website user’s rights, of the measures taken to eliminate the consequences of the relevant incident, and also provides information about the person authorized by the Website administration to interact with the authorized body for the protection of the rights of personal data subjects on matters related to the identified incident;

- within 72 hours of the results of the internal investigation of the identified incident, and also provides information about the persons whose actions caused the identified incident (if available).

9.8. If the Website user withdraws consent to the processing of their personal data, the Website administration ceases their processing and, if retention of the personal data is no longer required for the purposes of personal data processing, destroys the personal data within 30 days from the date of receipt of the withdrawal.

9.9. If a Website user requests that the Website administration cease processing of personal data, the Website administration ceases their processing within 10 business days, except in cases provided for by the Personal Data Law.

The specified period may be extended by no more than 5 business days if the Website administration sends the Website user a reasoned notice stating the reasons for extending the period for providing the requested information.

9.10. If it is not possible to destroy personal data within the period specified in this Privacy Policy, the Website administration blocks such personal data and ensures their destruction within a period not exceeding 6 months, unless another period is established by federal laws.

9.11. After the expiration of the statutory retention period for documents containing personal data of a Website user, or upon the occurrence of other lawful grounds, the documents are subject to destruction.

10. Changes to the Policy

The Company reserves the right to make changes to this Privacy Policy. When changes are made, the date of the last update is indicated in the Policy heading. The new version of the Policy takes effect from the moment it is posted on the Website, unless otherwise provided by the new version of the Policy.

11. Contact Information

All suggestions or questions regarding this Policy should be sent to the email address indicated on the Company’s Website in the “Contacts” section.

Date of last update: September 29, 2025.