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AXIOM STRATEGY
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Unofficial translation. Only the Russian version of this document is legally binding.

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LEGAL INFORMATION

Personal Data Processing Policy

Version of September 12, 2026

1. General provisions

This Personal Data Processing Policy (the “Policy”) applies to all information that OOO «AXIOM STRATEGY» (INN 9727125320, OGRN 1267700027418, the “Operator”) may obtain about a user of the axiomstrategy.ru website (the “Site”) while the user uses the feedback forms and the AI assistant service located on the Site's pages.

The Policy is drawn up in accordance with Federal Law No. 152-FZ of July 27, 2006 “On Personal Data” and other normative legal acts of the Russian Federation in the field of personal data protection.

2. Composition of the personal data processed

Within the feedback forms and the AI assistant service on the Site, the Operator may process the following personal data: last name, first name, patronymic; phone number; email address; organization name; industry; area of interest; preferred engagement format; the content of the request, including the content of the dialog with the AI assistant attached to the request, and other data voluntarily provided by the user.

The Operator does not collect or process special categories of personal data (information about race, ethnicity, political views, health status, etc.).

3. Purposes of personal data processing

Personal data is processed for the purposes of: responding to the user's request; preparing and sending a commercial offer; providing the requested information materials (company profile, document templates, analytical materials); concluding and performing consulting services agreements; operating the AI assistant service (generating answers to users' questions based on the Operator's materials).

4. Legal grounds for processing

The legal ground for personal data processing is the consent of the personal data subject, given when submitting a request on the Site by ticking the “I consent to the processing of personal data” checkbox. The consent text is a separate document; the Operator records the wording and version in force at the moment the request is submitted.

5. Conditions of processing and disclosure to third parties

Personal data is processed using automation on the Operator's technical resources, and also with the involvement of persons processing the data on the Operator's instruction (part 3 of article 6 of Federal Law 152-FZ) under contracts that obligate them to ensure the confidentiality and security of personal data.

The hosting provider that places the Operator's information systems on the territory of the Russian Federation processes personal data on the Operator's instruction for the purposes of data storage and security of servers and databases.

The LLM service provider Gonka (api.proxy.gonka.gg) receives the text of the user's conversation with the AI assistant in order to generate a response. The provider's infrastructure is distributed: requests may be processed on servers located both inside and outside the Russian Federation; the list of processing countries is determined by the provider.

Contact details (last name, first name, patronymic, email address, phone number) are entered in a separate block of the request form and are not passed into the conversation sent to the LLM service provider. Before the conversation is transmitted to the provider, names, phone numbers, email addresses and other document numbers are automatically removed from it.

Personal data is not disclosed to other third parties, except in cases directly provided for by the legislation of the Russian Federation or with the separate consent of the personal data subject.

The Operator takes the necessary organizational and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying or distribution.

6. Term of processing and storage

Personal data is processed for the term necessary to achieve the purposes stated in section 3 of this Policy, or until the personal data subject withdraws consent, whichever comes first, unless a different retention term is established by a contract or by the legislation of the Russian Federation.

After consent is withdrawn, personal data processing ceases, except in the cases provided for by paragraphs 2–11 of part 1 of article 6 of Federal Law 152-FZ.

7. Rights of the personal data subject

The personal data subject has the right to: obtain information concerning the processing of their personal data; demand clarification, blocking or destruction of personal data if it is incomplete, outdated or inaccurate; withdraw consent to personal data processing by sending a corresponding request to the Operator's email address.

8. Withdrawal of consent to personal data processing

To withdraw consent to personal data processing, the user may send a free-form written request to info@axiomstrategy.ru indicating the last name, first name, patronymic and the email address used when submitting the request on the Site.

9. Final provisions

The Operator may amend this Policy. A new version of the Policy takes effect from the moment it is published on the Site, unless the new version provides otherwise.

The current version of the Policy is always available on this page of the Site.