Personal Data Processing Policy
Privacy Policy

1. General Provisions
This personal data processing policy is in accordance with the requirements of Federal Law dated 27.07.2006 No. 152-FZ "On Personal Data" (hereinafter referred to as the "Personal Data Law") and defines the procedure for processing personal data and measures to ensure the security of personal data undertaken by FLHUB Accounting & Bookkeeping L.L.C. (hereinafter referred to as the "Operator").

1.1. The Operator considers the observance of human and civil rights and freedoms in the processing of their personal data as its most important goal and condition for the implementation of its activities, including the protection of the rights to privacy, personal and family secrets.
1.2. This Operator's policy regarding the processing of personal data (hereinafter referred to as the "Policy") applies to all information that the Operator may receive about visitors to the website https://flhub.ae/.

2. Basic Concepts Used in the Policy
2.1. Automated processing of personal data: processing of personal data using computing technology.
2.2. Blocking of personal data: temporary cessation of personal data processing (except in cases where processing is necessary for personal data clarification).
2.3. Website: a set of graphic and informational materials, as well as computer programs and databases, ensuring their availability on the Internet at the network address https://flhub.ae/.
2.4. Information system of personal data: a set of personal data contained in databases, and information technologies and technical means ensuring their processing.
2.5. Depersonalization of personal data: actions resulting in the impossibility of determining the affiliation of personal data to a specific User or other subject of personal data without the use of additional information.
2.6. Processing of personal data: any action (operation) or a set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
2.7. Operator: a state body, municipal body, legal or natural person, independently or together with other persons organizing and/or performing the processing of personal data, as well as determining the purposes of processing personal data, the composition of personal data to be processed, actions (operations) performed with personal data.
2.8. Personal data: any information relating directly or indirectly to a defined or identifiable User of the website https://flhub.ae/.
2.9. Personal data allowed by the subject of personal data for dissemination: personal data to which the subject of personal data provides access to an unlimited number of persons by giving consent to the processing of personal data allowed for dissemination in the manner prescribed by the Personal Data Law (hereinafter referred to as "personal data allowed for dissemination").
2.10. User: any visitor to the website https://flhub.ae/.
2.11. Provision of personal data: actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Dissemination of personal data: any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or at making personal data available to an unlimited number of persons, including publication in mass media, placement in information and telecommunication networks, or providing access to personal data in any other way.
2.13. Cross-border transfer of personal data: transfer of personal data to the territory of a foreign state to a foreign state authority, a foreign natural or foreign legal person.
2.14. Destruction of personal data: any actions resulting in the irrevocable destruction of personal data with the impossibility of further restoration of personal data content in the personal data information system and/or destruction of personal data physical carriers.

3. Basic Rights and Obligations of the Operator
3.1. The Operator has the right to:
— receive accurate information and/or documents containing personal data from the subject of personal data;
— in case of withdrawal of consent to the processing of personal data by the subject of personal data, as well as in case of sending a request to stop processing personal data, the Operator has the right to continue processing personal data without consent of the subject of personal data if there are grounds specified in the Personal Data Law;
— independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations provided by the Personal Data Law and adopted in accordance with it regulatory legal acts, unless otherwise provided by the Personal Data Law or other federal laws.

3.2. The Operator must:
— provide the subject of personal data, at their request, information regarding the processing of their personal data;
— organize the processing of personal data in accordance with the procedure established by the current legislation of the Russian Federation;
— respond to inquiries and requests from subjects of personal data and their legal representatives in accordance with the requirements of the Personal Data Law;
— report to the authorized body for the protection of the rights of subjects of personal data upon the request of this body necessary information within 10 days from the date of receipt of such a request;
— publish or otherwise provide unlimited access to this Policy regarding the processing of personal data;
— take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, dissemination of personal data, as well as from other unauthorized actions regarding personal data;
— stop transferring (disseminating, providing, accessing) personal data, stop processing and destroy personal data in the manner and cases provided by the Personal Data Law;
— fulfill other duties provided by the Personal Data Law.

4. Basic Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects have the right to:
— receive information regarding the processing of their personal data, except in cases provided by federal laws. The information is provided to the subject of personal data by the Operator in an accessible form, and it should not contain personal data relating to other subjects of personal data, except in cases where there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it is established by the Personal Data Law;
— demand that the operator clarify their personal data, block, or destroy it if the personal data is incomplete, outdated, inaccurate, illegally obtained, or not necessary for the stated purpose of processing, as well as take measures provided by law to protect their rights;
— set a condition of prior consent when processing personal data in order to promote goods, works, and services on the market;
— withdraw consent to the processing of personal data, as well as send a request to stop processing personal data;
— appeal to the authorized body for the protection of the rights of personal data subjects or to the court against unlawful actions or inaction of the Operator in the processing of their personal data;
— exercise other rights provided by the legislation of the Russian Federation.

4.2. Personal data subjects are obliged to:
— provide the Operator with accurate data about themselves;
— inform the Operator about the clarification (updating, changing) of their personal data.

4.3. Persons who have provided the Operator with false information about themselves or information about another subject of personal data without the consent of the latter bear responsibility in accordance with the legislation of the Russian Federation.

5. Principles of Personal Data Processing
5.1. The processing of personal data is carried out on a legal and fair basis.
5.2. The processing of personal data is limited to achieving specific, predetermined, and legitimate goals. The processing of personal data incompatible with the purposes of collecting personal data is not allowed.
5.3. It is not allowed to combine databases containing personal data, the processing of which is carried out for purposes incompatible with each other.
5.4. Only personal data that meet the purposes of their processing are subject to processing.
5.5. The content and volume of processed personal data correspond to the stated purposes of processing. The redundancy of processed personal data in relation to the stated purposes of their processing is not allowed.
5.6. During the processing of personal data, the accuracy of personal data, their sufficiency, and, if necessary, relevance to the purposes of personal data processing are ensured. The Operator takes the necessary measures and/or ensures their adoption to delete or clarify incomplete or inaccurate data.
5.7. The storage of personal data is carried out in a form that allows determining the subject of personal data, no longer than required by the purposes of personal data processing, unless the period for storing personal data is established by federal law, a contract to which the subject of personal data is a party, beneficiary, or guarantor. The processed personal data is destroyed or depersonalized upon achieving the purposes of processing or in case of losing the need to achieve these purposes, unless otherwise provided by federal law.

6. Purposes of Personal Data Processing
The purpose of processing: informing the User by sending electronic letters.
Personal data: last name, first name, patronymic, phone numbers.
Legal grounds: Federal Law "On Information, Information Technologies, and Information Protection" dated 27.07.2006 No. 149-FZ.
Types of personal data processing: collection, recording, systematization, accumulation, storage, destruction, and depersonalization of personal data.

7. Conditions for Personal Data Processing
7.1. The processing of personal data is carried out with the consent of the subject of personal data to the processing of their personal data.
7.2. The processing of personal data is necessary for achieving the goals stipulated by an international treaty of the Russian Federation or the law, for performing the functions, powers, and duties assigned by the legislation of the Russian Federation to the operator.
7.3. The processing of personal data is necessary for the administration of justice, the execution of a judicial act, an act of another body or official#### 8. Procedure for Collecting, Storing, Transferring, and Other Types of Personal Data Processing
The security of personal data processed by the Operator is ensured through the implementation of legal, organizational, and technical measures necessary to fully comply with the requirements of applicable legislation in the field of personal data protection.

8.1. The Operator ensures the safety of personal data and takes all possible measures to prevent unauthorized access to personal data.

8.2. Personal data of the User will never, under any circumstances, be transferred to third parties, except in cases related to the implementation of current legislation or if the subject of personal data has given consent to the Operator to transfer data to a third party to fulfill obligations under a civil law contract.

8.3. In case of inaccuracies in personal data, the User can update them independently by sending a notification to the Operator's email address Hubprofi@gmail.com marked "Update of personal data."

8.4. The period for processing personal data is determined by achieving the purposes for which the personal data was collected unless another period is stipulated by the contract or applicable legislation. The User may at any time withdraw their consent to the processing of personal data by sending a notification to the Operator via email to the Operator's email address Hubprofi@gmail.com marked "Withdrawal of consent to the processing of personal data."

8.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by these parties (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data and/or with these documents. The Operator is not responsible for the actions of third parties, including those mentioned in this clause service providers.

8.6. Restrictions established by the subject of personal data on the transfer (except for providing access), as well as on the processing or conditions for processing (except for obtaining access) of personal data allowed for dissemination, do not apply in cases of processing personal data in state, public, and other public interests defined by the legislation of the Russian Federation.

8.7. The Operator ensures the confidentiality of personal data when processing personal data.

8.8. The Operator stores personal data in a form that allows identifying the subject of personal data, no longer than required by the purposes of processing personal data, unless the period for storing personal data is established by federal law, a contract to which the subject of personal data is a party, beneficiary, or guarantor.

8.9. The condition for the termination of the processing of personal data may be the achievement of the purposes of processing personal data, the expiration of the consent of the subject of personal data, the withdrawal of consent by the subject of personal data, or a request to stop processing personal data, as well as the detection of unlawful processing of personal data.

9. List of Actions Performed by the Operator with Received Personal Data
9.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), retrieves, uses, transfers (distributes, provides, accesses), depersonalizes, blocks, deletes, and destroys personal data.

9.2. The Operator performs automated processing of personal data with the receipt and/or transmission of the received information through information and telecommunications networks or without such networks.

10. Cross-border Transfer of Personal Data
10.1. The Operator, before starting cross-border transfer of personal data, must notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out cross-border transfer of personal data (such notification is sent separately from the notification of intention to process personal data).

10.2. The Operator, before submitting the above notification, must obtain the relevant information from the foreign state authorities, foreign individuals, foreign legal entities to whom the cross-border transfer of personal data is planned.

11. Confidentiality of Personal Data
The Operator and other persons who have gained access to personal data must not disclose personal data to third parties or distribute personal data without the consent of the subject of personal data unless otherwise provided by federal law.

12. Final Provisions
12.1. The User can get any clarifications on issues of interest regarding the processing of their personal data by contacting the Operator via email Hubprofi@gmail.com.

12.2. Any changes to the personal data processing policy by the Operator will be reflected in this document. The Policy is valid indefinitely until replaced by a new version.

12.3. The current version of the Policy is freely available on the Internet at https://flhub.ae/pk.