TERMS AND DEFINITIONS

Company – Pragma Solutions Ltd., a legal entity incorporated under the laws of the Hong Kong Special Administrative Region (address: 7/F MW TOWER 111 BONHAM STRAND, SHEUNG WAN, HONG KONG, email: hi@pragma.me).

User – an individual using the functionality of the Service.

Service – an integrated intellectual property object, including software, databases, graphic content, and other materials combined to operate the website at https://pragma.me/en and its subdomains (the "Site"), as well as the PRAGMA Telegram bot (the Service's Telegram account enabling Users to access its functionality).

Personal Data Law – Federal Law No. 152-FZ dated 27.07.2006 "On Personal Data".

Personal Data – the term is used in accordance with the Personal Data Law, taking into account international best practices in personal data protection in countries with adequate levels of protection. It includes any information relating to an individual or identifying them directly or indirectly, in particular through an identifier such as name, surname, ID number, location data, online identifier, or one or more characteristics specific to the physical, genetic, mental, economic, or cultural identity of that person.

Personal Data Processing – any action (operation) or set of actions (operations) performed with or without the use of automation tools involving personal data, including collection, recording, systematization, accumulation, storage, updating (modification), retrieval, use, transfer (provision, access), anonymization, blocking, deletion, and destruction of personal data.

Other terms used in this Policy are interpreted according to the Personal Data Law and other regulatory acts of the Russian Federation regarding personal data.

GENERAL INFORMATION

This Policy defines the key principles, purposes, conditions, and methods for processing personal data, the rights of Users, and the measures taken by the Company to ensure the security of personal data.

By using the Service, the User unconditionally and explicitly agrees to this Policy and the terms of personal data processing outlined herein. If the User does not agree, they must immediately stop using the Service.

The Company may amend this Policy if the personal data processing conditions change. The current version is always available at the bottom of the Site's pages and in the PRAGMA Telegram bot description.

PURPOSES OF PERSONAL DATA PROCESSING

The following actions may be performed by the Company with personal data: collection, recording, systematization, accumulation, storage, updating, retrieval, use, transfer, blocking, deletion, and destruction.

Some personal data may be stored longer if required by the Personal Data Law, even after a deletion request.
The processed personal data do not fall under special or biometric categories as per Articles 10–11 of the Personal Data Law.

STORAGE AND SECURITY OF PERSONAL DATA

The Company processes User data using databases and servers located in the Russian Federation.
If personal data of a particular User is processed outside Russian jurisdiction, the User consents to its processing on Russian servers.

The Company adheres to technical and organizational requirements under the Personal Data Law and continuously improves its security systems as needed.

All employees follow internal rules and procedures regarding data processing and comply with the technical and organizational measures required for data protection.

DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES

As a general rule, the Company does not share data with third parties, except for:

• Third parties involved in the Company’s service delivery (e.g., hosting providers, payment processors);

• Third parties to whom the Company assigns its rights/obligations under agreements;

• Third parties with the User’s explicit consent;

• Russian or foreign authorities if required by law.

Data is shared in minimal volume and only to fulfill the purposes of this Policy or comply with applicable laws.
Cross-border transfer of personal data may be conducted to fulfill the purposes outlined in this Policy.

USER RIGHTS REGARDING PERSONAL DATA

Right of Access
Users may request confirmation of data processing and receive an electronic copy of their personal data.

Right to Rectification
Users may request correction, blocking, or deletion of their personal data if it is incomplete, outdated, inaccurate, unlawfully obtained, or no longer needed.

Right to Object to Automated Decisions
Users may request clarification of decisions made solely based on automated processing and their legal effects. Disagreements may be challenged.

Right to Withdraw Consent
Users may withdraw their consent to data processing at any time.

Right to File a Complaint
Users may file a complaint with the Russian data protection authority (Roskomnadzor) if they disagree with how their data is processed.

To exercise these rights, the User must submit a request including:

• Identity document details (for the User or their representative);

• Evidence of data processing by the Company;

• Signature of the User or representative.

If the request lacks required information or access rights, the Company may reject it with justification.

The Company must respond within 10 business days (extendable by 5 days in exceptional cases), unless otherwise stated by law.

User access may be limited by law, especially if it infringes the rights of third parties.