PRIVACY AND PERSONAL DATA PROTECTION POLICY

Saint Petersburg
 «18» October 2025

Limited Liability Company "Rotepak" (LLC "Rotepak"), operating under the NV GRAUP brand, represented by General Director Nikolay Leonidovich Stepanov, acting on the basis of the Articles of Association, hereinafter referred to as the "Operator", guided by Federal Law No. 152-FZ of 27.07.2006 "On Personal Data", hereby establishes this Privacy and Personal Data Protection Policy (hereinafter — the Policy).
1. BASIC CONCEPTS
1.1. Operator — Limited Liability Company "Rotepak" (PSRN 1257800025790, TIN 7802963143, KPP 780201001), independently organizing and carrying out the processing of personal data, as well as determining the purposes of their processing.
1.2. Personal data — any information relating to a directly or indirectly identified or identifiable natural person (User).
1.3. Processing of personal data — any action (operation) or set of actions (operations) performed with personal data.
1.4. User — any person providing their personal data to the Operator through the website https://nvgraup.demo.mtfy.xyz/en or by other means.
1.5. Cookies — small data files that are sent by a web server and stored on the User's device.
1.6. IP address — a unique network address of a node in a computer network.

2. GENERAL PROVISIONS
2.1. Use of the website https://nvgraup.demo.mtfy.xyz/en by the User implies unconditional consent to this Policy.
2.2. This Policy applies exclusively to the website https://nvgraup.demo.mtfy.xyz/en. The Operator does not control and is not responsible for third-party websites.
2.3. The site administration does not verify the accuracy of the personal data provided by the User.

3. PURPOSES OF COLLECTING AND PROCESSING PERSONAL DATA
3.1. The Operator processes Users' personal data for the following purposes:
• Conclusion and execution of contracts for the provision of international logistics services, production organization, and branding;
• Implementation of customs clearance of goods;
• Interaction with transport companies and production partners;
• Sending commercial offers and information materials to the User;
• Consulting Users on the services of NV GRAUP;
• Registering the User on the website to gain access to personalized services;
• Ensuring security and preventing fraudulent activities.

4. COMPOSITION OF PROCESSED PERSONAL DATA
4.1. The Operator processes the following personal data:
• Surname, first name, patronymic;
• Contact phone number;
• Email address;
• Company name and position;
• Company details;
• Data required for customs clearance;
• Other information provided by the User voluntarily.
4.2. Technical data collected automatically:
• IP address;
• information from cookies;
• browser and operating system data;
• access time;
• addresses of visited pages.

5. CONDITIONS FOR PROCESSING PERSONAL DATA
5.1. Processing of personal data is carried out on a legal and fair basis.
5.2. The Operator ensures the accuracy of the processed personal data.
5.3. Storage of personal data is carried out no longer than required for the processing purposes.
5.4. When processing personal data, its security and confidentiality are ensured.

6. TRANSFER OF PERSONAL DATA TO THIRD PARTIES
6.1. The Operator may transfer personal data to the following categories of third parties:
• Transport and logistics companies;
• Customs authorities and brokers;
• Manufacturing partners in China and other Asian countries;
• Banks and payment systems;
• Government authorities in cases provided for by law.

7. USER RIGHTS
7.1. The User has the right:
• To access their personal data;
• To clarify and destroy personal data;
• To withdraw consent for the processing of personal data;
• To protect their rights and legitimate interests.

8. PROTECTION OF PERSONAL DATA
8.1. The Operator takes the necessary organizational and technical measures to protect personal data from unauthorized access and distribution.

9. CONTACT INFORMATION
9.1. All suggestions and questions regarding this Policy should be sent to the address: 194352, St. Petersburg, VN.TER.G. MUNICIPAL DISTRICT SERGIEVSKOE, PRIDOROZHNAYA ALLEY, 8, LETTER A, OFFICE 427
LLC "Rotepak" General Director Stepanov Nikolay Leonidovich
Email: nvgraup@mail.ru
9.2. The current version of the Policy is available on the page at: https://nvgraup.demo.mtfy.xyz/en/pol

10. FINAL PROVISIONS
10.1. The Operator has the right to make changes to this Policy unilaterally.
10.2. The new version of the Policy comes into force from the moment it is posted on the website.