Personal Data Processing Policy

1. General Provisions

This personal data processing policy is drawn up in accordance with the requirements of Federal Law No. 152-FZ dated 27.07.2006 "On Personal Data" and defines the procedure for processing personal data and measures to ensure the security of personal data taken by the Administration of Surfe.be (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, including the protection of the rights to privacy, personal and family secrets, as its most important goal and condition for carrying out its activities.

1.2. This Policy of the Operator 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://surfe.be/.

2. Basic Terms Used in the Policy

2.1. Automated processing of personal data – processing of personal data using computer technology;

2.2. Blocking of personal data – temporary cessation of the processing of personal data (except in cases where processing is necessary to clarify personal data);

2.3. Website – a set of graphic and information materials, as well as computer programs and databases, ensuring their availability on the Internet at https://surfe.be/;

2.4. Personal data information system – a set of personal data contained in databases and information technologies and technical means ensuring their processing;

2.5. Depersonalization of personal data – actions as a result of which it becomes impossible to determine, without the use of additional information, the ownership of personal data by a specific User or other subject of personal data;

2.6. Processing of personal data – any action (operation) or set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data;

2.7. Operator – a state body, municipal body, legal or natural person, independently or jointly with other persons organizing and (or) carrying out 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 specific or identifiable User of the website https://surfe.be/;

2.9. User – any visitor to the website https://surfe.be/;

2.10. Provision of personal data – actions aimed at disclosing personal data to a certain person or a certain circle of persons;

2.11. Distribution of personal data – any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or at familiarizing an unlimited circle of persons with personal data, including the publication of personal data in the media, placement in information and telecommunication networks, or providing access to personal data in any other way;

2.12. Cross-border transfer of personal data – transfer of personal data to the territory of a foreign state to a foreign state authority, a foreign individual, or a foreign legal entity;

2.13. Destruction of personal data – any actions as a result of which personal data are destroyed irretrievably with the impossibility of further restoration of the content of personal data in the personal data information system and (or) material carriers of personal data are destroyed.

3. The Operator May Process the Following Personal Data of the User

3.1. Personal information provided by you during registration (account creation);

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

3.3. Date and time of access to the Website;

3.4. Information about your activity while using the Website (for example, clicks on hyperlinks, time spent on the site, etc.);

3.5. Geolocation information;

3.6. Information about you that we receive from our Partners in accordance with the terms of agreements concluded between you and the relevant Partner, and agreements concluded between the Administration and the Partner (for example, Yandex.Metrica and/or Google Analytics counters).

4. Purposes of Personal Data Processing

4.1. The purpose of processing the User's personal data is the conclusion, execution, and termination of civil law contracts; providing the User with access to services, information, and/or materials contained on the website https://surfe.be.

4.2. The Operator also has the right to send the User notifications about new products and services, special offers, and various events. The User can always refuse to receive informational messages by sending the Operator an email to info@surfe.be with the note "Refusal of notifications about new products and services and special offers".

4.3. Anonymized User data collected by the Operator independently and/or through internet statistics services is used to collect information about User actions on the site, improve the quality of the site and its content.

5. Legal Grounds for Personal Data Processing

5.1. The Operator processes the User's personal data only if they are filled in and/or sent by the User independently through forms on the website https://surfe.be/, including during registration. Checking the box in the relevant form field means the User's consent to this Personal Data Processing Policy.

5.2. The Operator processes anonymized data about the User if this is allowed in the User's browser settings (enabled saving of "cookie" files and use of JavaScript technology).

6. Procedure for Collection, Storage, Transfer, and Other Types of Personal Data Processing

The security of personal data processed by the Operator is ensured by the implementation of legal, organizational, and technical measures necessary to fully comply with the requirements of current legislation in the field of personal data protection.

6.1. The Operator ensures the safety of personal data and takes all possible measures to exclude access to personal data by unauthorized persons.

6.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to the execution of current legislation.

6.3. In case of inaccuracies in personal data, the User can update them independently by sending the Operator a notification to the Operator's email address info@surfe.be with the note "Updating personal data".

6.4. The period of personal data processing is unlimited. The User may at any time withdraw their consent to the processing of personal data by sending the Operator a notification via email to the Operator's email address info@surfe.be with the note "Withdrawal of consent to the processing of personal data".

6.5. The Operator is appointed as the person responsible for organizing the processing of personal data.

6.6. Storage and processing of personal data of citizens of the Russian Federation is carried out on the territory of the Russian Federation using servers located within the Russian Federation, in accordance with the requirements of the legislation on the localization of personal data.

6.7. The User has the right to receive information regarding the processing of their personal data, including:

• confirmation of the fact of processing of personal data by the Operator;
• legal grounds and purposes of processing;
• purposes and methods of processing used;
• information about third parties to whom personal data is transferred;
• list of processed personal data;
• processing periods, including storage periods;
• information about the performed or intended cross-border data transfer.

To exercise these rights, the User may send a request via the feedback form on the website or to the Operator's email address: info@surfe.be.

6.8. The Operator uses cookies, as well as web analytics tools, including Yandex.Metrica and Google Analytics, for the purpose of analyzing User behavior, improving the quality of the website, and providing personalized content. The User's use of the website constitutes their consent to the processing of data collected using these technologies.

The User can independently configure the parameters for the use of cookies in their browser. If necessary, the Operator reserves the right to implement a mechanism for obtaining separate consent for the use of cookies and other tracking technologies.

7. Cross-Border Transfer of Personal Data

7.1. Before starting the cross-border transfer of personal data, the Operator must ensure that the foreign state to whose territory the transfer of personal data is intended provides reliable protection of the rights of personal data subjects.

7.2. Cross-border transfer of personal data to countries that do not provide adequate protection of the rights of personal data subjects is allowed only with the written consent of the personal data subject and/or in the execution of a contract to which the subject is a party.

7.3. The User, taking into account the terms of this Policy and continuing to use the website, shall comply with the agreement on the cross-border transfer of their digital data, including anonymized data, in a state that does not provide adequate protection of the rights of subjects of historical data, in particular, in the United States of America, where US servers and resources of Google LLC and other analytical and technical solutions.

Such an agreement applies to the use of web analytics services, data storage, technical functionality of the site, as well as the fulfillment of the terms of the user agreement. The User may revoke their consent at any time by sending a notice to the Operator's e-mail address.

8. Use of Cookies and Analytical Technologies

8.1. The Operator uses cookies and similar technologies (web beacons, pixels, device identifiers, and other technical means) in order to: — ensure the functioning of the website and its individual components; — remember the User’s preferences; — analyze the behavior and activity of Users on the website; — improve the convenience and quality of the provided services; — deliver personalized content and advertising.

8.2. Cookies are small text files that are stored on the User’s device when visiting the website. They may be persistent or session-based and can store various information, including IP address, browser data, operating system, time and duration of visit, page navigation, and other technical data.

8.3. The Operator may use third-party web analytics services, including but not limited to: — Yandex.Metrica (LLC “Yandex”); — Google Analytics (Google LLC).

The collected information is processed by these services in anonymized form and is used to analyze the website’s performance and User preferences. These services may carry out cross-border data transfers to other jurisdictions in accordance with their own policies.

8.4. Continued use of the website by the User is considered consent to the use of cookies and the specified analytical tools. The User has the right to refuse the processing of cookies by changing their browser settings, and may also use the opt-out interface provided on the website.

8.5. The Operator reserves the right to implement a separate mechanism for obtaining consent to the use of cookies, including by means of a pop-up notification (banner).

9. Final Provisions

9.1. The User may obtain any clarifications on issues of interest regarding the processing of their personal data by contacting the Operator via email at info@surfe.be.

9.2. Any changes to the Operator's personal data processing policy will be reflected in this document. The new version of the Policy comes into force from the moment it is posted on the website, unless otherwise provided by the new version of the Policy.

9.3. The current version of the Policy is freely available on the Internet at https://surfe.be/site/privacy-policy.

9.4. Effective date of this version of the Policy: "29" May 2025.

10. Operator Details

IE Safiyulin Albert Radikovich
INN 331108567690
+74994907126, info@surfe.be