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Here is a translation of the provided text into formal, legally precise business English, commonly used in corporate privacy policies and terms of service.

Privacy Policy for the Processing of Personal Data

1. Key Terms Used in the Privacy Policy for the Processing of Personal Data on the Websites of Virginia Limited Liability Company

2. General Provisions

2.1. This Privacy Policy for the Processing of Personal Data on the websites of Virginia Limited Liability Company (hereinafter – the Privacy Policy) has been developed and is applied when using the Website.

2.2. The Privacy Policy has been developed in accordance with the requirements of Federal Law No. 152-FZ of July 27, 2006, "On Personal Data" (hereinafter – Federal Law "On Personal Data"), other federal laws regulating the processing of personal data, as well as subordinate regulatory legal acts adopted pursuant thereto.

2.3. The User's use of the Website's services constitutes their unconditional acceptance of this Privacy Policy, the terms of processing the User's personal data, as well as the personal data of Clients voluntarily provided by them. The User confirms that when entering into a civil law contract using the Website on behalf of Clients, they are a representative of such third parties specified in the relevant application on the Website and have obtained the consent of such third parties for the processing of their personal data by the Operator for the purposes set forth in Section 3 of this Privacy Policy.

2.4. In case of disagreement with the terms of the Privacy Policy, the User of the Website must cease using the Website.

2.5. The Privacy Policy defines the main purposes and conditions for the processing of personal data of Users and/or Clients, as well as information on the implemented requirements for the protection of personal data of Users and/or Clients.

2.6. The Privacy Policy applies solely to the Website. Internal regulations governing other aspects of personal data processing have been developed and implemented within Virginia LLC. The Operator does not control and is not responsible for third-party websites to which the User may navigate via links available on the Website.

2.7. The Operator is the operator only of those personal data that it receives from Users when using the Website, with their consent, granted by the User performing conclusive actions on the Website.

2.8. The Website Administration does not verify the accuracy of the personal data provided by the User on the Website. The Website Administration proceeds on the basis that the User provides accurate and sufficient personal data and keeps this information up to date. The User bears sole responsibility for the consequences of providing inaccurate or invalid personal data.

2.9. The User confirms that by providing their own personal data and/or that of the Client and consenting to their processing, they are acting voluntarily, of their own free will and in their own interest, and also confirms their legal capacity. If the beneficiary under a civil law contract concluded between the Operator and the User is an incapacitated personal data subject, the User confirms that:
a. if they are the legal representative of such a subject, they provide their consent to the processing of the subject's personal data upon concluding the contract;
b. if they are not the legal representative of the incapacitated personal data subject, they have obtained the necessary consent for the processing of the subject's personal data from such representative prior to concluding the contract. If the beneficiary under a civil law contract concluded between the Operator and the User is a legally capable personal data subject, the User confirms that they have obtained the necessary consent of such subject for the processing of their personal data by the Operator. The User is obligated to provide such consent upon the Operator's request within no later than 1 (One) business day from the date of receipt of the relevant request from the Operator.

2.10. In order to fulfill obligations under civil law contracts concluded with the User, the Operator has the right to transfer information received from the User to third parties engaged by the Operator for the performance of the relevant contract. Such transfer of information does not constitute a violation of the provisions of this Privacy Policy.

2.11. The Operator uses the information provided by the User of the Website for the purposes set forth in Section 3 of this Privacy Policy.

2.12. Disclosure of information in accordance with the reasonable and applicable requirements of the legislation of the Russian Federation shall not be deemed a breach of obligations.

2.13. By providing their personal data, the User agrees that the personal data provided by them will be processed by Virginia LLC (address: 7 Armyansky Pereulok, Moscow, 101000, Russia; Phone: +7 499 653 58 13; OGRN: 1117746780580; INN: 7701933880), both with the use of automation tools and without the use of such means.

2.14. Personal data permitted for processing under this Privacy Policy are neither special nor biometric and are provided by the User by filling out special forms on the Website on an indefinite basis (until the User withdraws their consent to the processing of personal data). Depending on the web form completed by the User, the data may include the following information:

• Surname, first name, patronymic;

• Contact phone number;

• Email address.
  By using the Website and/or filling out the relevant web forms and/or submitting their personal data to the Operator or the Website Administration, the User expresses their consent to the Privacy Policy posted on the relevant Website.

2.15. The Operator also takes measures to protect personal data that are automatically transmitted during the process of visiting the Website's pages, including from cookies:

• IP address assigned to the User's computer at the time of visiting the Website;

• Session data obtained.
  Cookies may be "session" or "persistent."

Session Cookies
The Website Administration uses session cookies to assign a unique identification number to the User's computer upon each visit to the Website, which are deleted after closing the browser. Such cookies are also used to analyze the User's interaction with the Website (including page visits, links used, and time spent on a particular page).

Persistent Cookies
The Website recognizes persistent cookies that are stored on the hard drives of Users' computers. By assigning unique identifiers to Users' devices, the Website Administration can create a database of Users' actions and preferences (including, for example, the frequency and regularity of visits, and their preferences on the Website). It is important to note that cookies do not contain personal data of Users; they only record their actions.

Consent to the Use of Cookies
Session cookies do not require prior consent from Users; persistent cookies do require such consent.
Users can manage cookies through their web browser settings. Accordingly, they have the option to allow the use of all cookies integrated into the pages, block cookies, enable the use of cookies upon request, or accept or reject cookies. Cookie management varies depending on the browser being used.
While using cookie technology, the Website Administration does not store or use any specific data about Users. The Website Administration draws attention to the fact that the User has the right to configure their browser to refuse registration of requests to the Website or to alert them of requests for such registration. Disabling "cookies" may result in the inability to access the Website.

2.16. If the Website Administration cannot in any way correlate the information specified in clauses 2.14-2.15 of the Privacy Policy with the User (or other individual, where applicable), the Website Administration will not consider such information to be personal data.

2.17. The Website uses the Yandex.Metrica web analytics service using "cookie" technology. Through the Yandex.Metrica service, the Operator processes the following data: information about the User's location; User's gender and age; time spent by the User on the Website; source of the User's arrival on the Website, the device used, the referring website, or the advertisement; which pages the User opens and which buttons they click; statistical data on visits and use of the Website; type and version of the operating system; type and version of the Browser; device type and screen resolution; language of the operating system and Browser; IP address. The Operator uses the Yandex.Metrica service to improve the functionality of the Website, analyze visitor behavior, conduct retargeting, statistical research, and surveys.

3. Purposes of Personal Data Processing

3.1. The Operator collects and stores only that personal data which is necessary for the provision of services or the fulfillment of obligations to the User under the concluded contract for the purpose of providing services, except where legislation provides for the mandatory retention of personal data for a period specified by law.

3.2. The Operator processes the personal data of the User and/or the Client for the following purposes:
3.2.1. To provide the User and/or Client with registration (authorization) on the Website, access to the Website, and any other cases related to such actions.
3.2.2. To provide the User and/or Client with access to personalized resources of the Website, as well as to services, information, and/or materials contained on the Website.
3.2.3. To establish feedback with the User, including sending notifications via email, requests concerning the use of the Website, the provision of services, and processing inquiries and applications from the User.
3.2.4. To create a user account, if the User has given their consent to do so.
3.2.5. To conclude, execute, and terminate civil law contracts.
3.2.6. To provide the User and/or Client with effective customer and technical support in the event of issues related to the use of the Website.
3.2.7. To ensure the operability and security of the Website, to confirm actions taken by Users, to prevent fraud, cyberattacks, and other abuses, and to investigate such incidents.
3.2.8. To conduct statistical and other research based on anonymized data, and to generate statistical reports.

3.3. The Operator has the right to send the User notifications about new products and services, special offers, and various events. The User may at any time opt out of receiving informational messages by sending an email to vip@virginiavip.ru with the subject line "Opt-out of notifications about new products, services, and special offers."