Personal Data Processing and Security Policy

1. GENERAL PROVISIONS—WHAT IS THIS DOCUMENT ABOUT?

1.1. This Personal Data Processing Policy (the “Policy”) sets out the procedure for processing and protecting personal data in connection with your use, as a user (the “User” or “you”), of the services we provide. This includes contacting us through forms on our website or in our services, messengers, or bots, as well as registering for and participating in various marketing activities conducted by SPARTA LLC. The Policy applies to all information, including personal data as defined by applicable law, that SPARTA LLC and/or its affiliates may receive about you when you use the website and/or services available at id.admitad.ru and other websites or services that refer to this Policy (the “Site” and the “Service,” respectively). It also sets out the procedure for processing personal data and the measures SPARTA LLC takes to protect personal data (the “Operator” or “we”). Any references on the Site to a “privacy policy” or “personal data policy” refer to this Policy.

1.2. We process personal data in accordance with Federal Law No. 152-FZ of July 27, 2006, “On Personal Data” and other regulatory legal acts of the Russian Federation governing personal data processing.

1.3. The Policy applies to all personal data processing activities conducted by the Operator on the information resource accessible via id.admitad.ru or through the Operator’s mobile applications.

1.4. The Operator may amend this Policy unilaterally.

1.5. Since this Policy is publicly available online, you are responsible for monitoring any changes to it. In the event of any discrepancy, the publicly available version of the Policy prevails.

1.6. This Policy applies to personal data obtained both before and after the Policy takes effect.

1.7. Compliance with the Policy is monitored internally by the person responsible for organizing personal data processing.

1.8. We do not control and are not responsible for third-party websites that the User may access through links available on the Site.

1.9. For the purposes of this Policy, the User’s personal data includes:

• Personal information that the User provides while using or visiting the Site and the services available on the Site, including their email address, name, and other personal data.
• Data automatically transmitted to the Site’s services when they are used through software installed on the User’s device, including the IP address; cookie data (including from web analytics services such as Yandex Metrica); information about the User’s browser or other software used to access the services; technical information about the hardware and software used by the User; the date and time of access to the services; and the addresses of requested pages.
• Data received from third parties, including through integrations with social networks or third-party authentication services.
• The content of communications with Site support, including requests, chat history, and files sent to support.
• Behavioral data generated through interactions with Site features, including search history on the Site and preferences inferred from the User’s activity.
• Other information necessary to fulfill obligations to the User or protect the security of the Service.

2. PURPOSES OF PERSONAL DATA PROCESSING—WHY DO WE PROCESS YOUR DATA?

2.1. This section provides general information about the primary purposes for which we process your personal data. We process personal data to provide Site and/or Service features, including:

2.1.1. Communicating with the User, including sending notifications and requests related to Site use or service delivery, and processing the User’s requests and applications. When you use our services, we provide user support. The available support methods may vary depending on the services you use. We process data when handling requests submitted through chatbots, virtual assistants, feedback forms, email, and in-service support.

2.1.2. Ensuring that the Site and Services operate properly and improving them.

2.1.3. Collecting statistical data.

2.2. We may process personal data for advertising purposes, including targeting advertising materials on the Site and conducting marketing, statistical, and other research, where an appropriate legal basis exists. The Operator may also process personal data for the purposes specified in the consent to personal data processing provided through a data collection form or the Site and/or Service interface. Such purposes may include sending marketing communications or contacting the User and/or registered user at their request.

2.3. The Operator may process personal data to comply with the laws of the Russian Federation.

3. LEGAL BASES FOR PERSONAL DATA PROCESSING—WHEN AND FOR HOW LONG MAY WE PROCESS YOUR DATA?

3.1. We must have a legal basis to process your data. A legal basis is a condition required by law for processing your data. The Operator processes personal data on the following legal bases:

3.1.1. The data subject has consented to the processing of their personal data through an affirmative action, including by selecting a consent checkbox in a data collection form and/or interface when consent is requested. We process the data for the period covered by the consent, unless the consent is withdrawn earlier;

3.1.2. Processing is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, or to perform the functions, powers, and duties assigned to the Operator by the laws of the Russian Federation. We process the data for the period necessary to achieve each specific purpose;

3.1.3. Processing is necessary to perform a contract to which the data subject is a party, beneficiary, or guarantor, or to enter into a contract at the data subject’s request or a contract under which the data subject will be a beneficiary or guarantor. We process the data for the term of the relevant agreement or contract. Other legal bases and retention periods may also apply within a contractual relationship. For example, accounting laws may require a longer data processing period after a contract has ended;

3.1.4. Processing is necessary to exercise the rights and legitimate interests of the Operator or third parties, provided that this does not violate the rights and freedoms of the data subject. We process the data for the period necessary to exercise those rights and protect those legitimate interests.

4. CATEGORIES OF PERSONAL DATA PROCESSED—WHAT DATA DO WE COLLECT?

4.1. We may collect the following categories of personal information about you when you use the Sites and Services:

(i) Personal information: last name, first name, email address, country, username, mobile phone number, ad space name, and ad space type;

(ii) Electronic data: HTTP headers, IP address, cookies, web beacons/pixel tags, browser identifier data, and hardware and software information;

(iii) The date and time of access to the Sites and/or Services;

(iv) Information about your activity when using the Sites and/or Services, such as creating or deleting an affiliate program;

(v) Other information about you that must be processed under the terms governing your use of specific Sites or Services;

(vi) Payment information provided by you or received from partners or other parties involved in processing payment transactions through the Sites or Services and/or providing paid services.

5. USE OF ANALYTICS TOOLS (COOKIES)

5.1. Cookies are small files created and stored by your browser when you visit our Site or use our Service. They remain on your device for no more than one year. Cookies help the Site operate properly, allow us to monitor performance and usage patterns, and help optimize online marketing activities. Other analytics tools may be used on service websites and in mobile applications. For consistency, this Policy uses “cookies” as an umbrella term for all such analytics tools.

We use the following types of analytics tools:

Type of cookie	Description	Purpose	Example
Strictly necessary	Strictly necessary cookies enable Admitad websites and services to function by providing basic features such as site navigation and access to secure areas. Without these cookies, the Site cannot function properly.	To ensure that service interfaces and interactive components display and function properly and remain secure	Cookies that enable login to the Services
Analytics	These cookies allow us to count visits and identify traffic sources so that we can measure and improve Site performance. If you do not allow these cookies, we will not know that you visited the Site.	To identify the most and least popular pages and track how visitors move around the Site.	Cookies that store information about the use of the Services and their individual features, as well as Service preferences
Marketing	These cookies are used for marketing purposes and allow us to show you ads that may be most relevant to your interests. They help us measure advertising campaign performance and personalize content based on your preferences.	To measure advertising campaign performance and personalize content based on preferences	Cookies that store information about the use of advertising services and their individual features, as well as Service preferences
Social media	Social media cookies connect the Site to third-party social media platforms. Many social media cookies are set through plugins, widgets, and share buttons.	To store User data after the User logs in to a social media account through the Site	Cookies that enable authentication through external services

Visiting and using the Services causes cookies to be generated and stored by default.

To disable cookies, you can change your browser settings or use the controls available in the relevant Service interface, where applicable. Disabling all cookies may limit Service functionality.

6. PERSONAL DATA PROCESSING PROCEDURE AND TERMS

The following actions may be performed with the personal data we obtain:

6.1. We collect, record, systematize, accumulate, store, clarify (update and modify), retrieve, use, transfer (distribute, provide, and grant access to), depersonalize, block, delete, and destroy personal data.

6.2. We process personal data by automated means, with or without receiving and/or transmitting the information obtained via information and telecommunications networks.

7. FINAL PROVISIONS—HOW TO CONTACT US

7.1. Our Site allows you to exercise certain rights through Service features, including deleting data from your profile, deleting your profile, and changing your data. Please use these features to exercise your rights.

7.2. You can request clarification on any questions about the processing of your personal data by emailing data-support@admitad.ru.

7.3. We process your personal data only to the minimum extent necessary. If you do not want to provide data and are not required to do so by law, you may refuse to provide personal data. However, in this case, certain Service features may be unavailable, and it may be difficult or impossible to achieve other purposes for processing your data.

7.4. If you no longer want us to process your personal data, you may submit a request to us. We most often process your data under agreements. To stop this processing, you must delete your profile in the relevant Service, thereby terminating the agreement under which the Service is provided. Users may be able to delete their profiles directly within the Services to stop personal data processing. Once you delete your profile, we will stop processing your data under the relevant agreements. You do not need to withdraw your consent to personal data processing in such cases. After receiving your request to stop personal data processing, we may continue to store certain data only where we have a legal basis to do so. This may be necessary to comply with legal obligations or pursue legitimate interests, including for the duration of the applicable limitation period.

7.5. If we receive notice from the User withdrawing consent to personal data processing, we will stop processing the User’s personal data within 10 business days after receiving the notice. Such notices must be sent by email to data-support@admitad.ru or in writing to: 2 Novodmitrovskaya St., Building 1, 6th Floor, Moscow 127015, Russian Federation.

7.6. Any changes to the Operator’s personal data processing policy will be reflected in this document. The Policy remains in effect indefinitely until it is replaced by a new version.

7.7. This Policy is current as of August 5, 2026.