PRIVACY AND COOKIE POLICY

Limited Liability Company “Evolution of Marine Digital Technologies” (LLC “EMCT”), hereinafter referred to as the “Operator,” “we,” “us,” or “our,” Taxpayer Identification Number (TIN) 7813663695, registered at: Building 3, No. 4 Aleksandrovsky Park, St. Petersburg, 197198, Russia, has adopted this Privacy and Cookie Policy (the “Policy”).

This Policy applies to all information that the Evolution of Marine Digital Technologies website, available at evomarine.ru (the “Website”), may collect about a user while the user accesses or uses the Website, its software, and its products.

We collect, process, and protect personal data for the purposes specified in this Policy.

The Website forms through which personal data may be processed are listed in Section 4, “Purposes of Collecting the User’s Personal Data.”

We comply with the requirements of Russian legislation on personal data. When processing personal data, we follow the principles set out in Article 5 of Federal Law No. 152-FZ dated 27 July 2006 “On Personal Data” (the “Personal Data Law”).

The Website is not intended for the processing of personal data of minors. If you believe that a minor has provided us with personal data through the Website, please notify us at evomarine@evomarine.ru.

Please read this Policy carefully to understand the purposes for which we process your personal data and how you may exercise your rights in relation to that data.

If you have any questions regarding the processing or protection of your personal data, please contact us using the details provided in the “Contacts” section.

1. Definitions

1.1. The following terms are used in this Policy:

1.1.1. Personal Data Officer means the person acting on behalf of the Operator who organizes and/or carries out the collection and processing of personal data, determines the purposes of processing and the categories of personal data to be processed, and determines the operations performed on personal data.

1.1.2. “Personal data” means any information relating directly or indirectly to an identified or identifiable individual — the data subject.

1.1.3. “Processing of personal data” means any operation or set of operations performed on personal data, whether or not by automated means, including collection, recording, systematization, accumulation, storage, updating, modification, retrieval, use, transfer, disclosure, provision of access, depersonalization, blocking, deletion, and destruction.

1.1.4. “Confidentiality of personal data” means the obligation of the Operator and any other person with access to personal data not to disclose such data without the data subject’s consent or another lawful basis.

1.1.5. “Automated processing of personal data” means the processing of personal data using computer technology.

1.1.6. “Disclosure of personal data” means actions intended to make personal data available to an unrestricted number of persons.

1.1.7. “Destruction of personal data” means actions that make it impossible to restore the content of personal data in a personal data information system and/or result in the destruction of the physical media containing such data.

1.1.8. “Website User” or “User” means any person who accesses and uses the Website via the Internet.

1.1.9. “Cookies” means small data files sent by a web server and stored on the User’s computer, which a web client or browser sends back to the web server in an HTTP request when the User attempts to open a page of the relevant website.

1.1.10. “IP address” means a unique network address assigned to a device or node in a computer network operating under the Internet Protocol.

2. General Provisions

2.1. By using the Website, the User confirms acceptance of this Policy and consents to the processing of the User’s personal data, whether by automated means or otherwise, in accordance with applicable law and this Policy.

2.2. If the User does not agree with this Policy, the User must discontinue use of the Website.

2.3. This Policy applies only to the Website available at evomarine.ru. The Website does not control and is not responsible for third-party websites that the User may access through links available on the Website.

2.4. The Personal Data Officer does not verify the accuracy of the personal data provided by the User.

3. Scope of the Privacy Policy

3.1. This Policy establishes the rules for the collection, processing, storage, protection, and confidentiality of personal data provided by the User at the request of the Website, including when the User submits a form through the Website.

3.2. The Website may automatically collect and protect the following information when the User views advertising content or visits pages containing a statistical tracking script or pixel:

- IP address;
- cookie information;
- browser information or information about another software application used to access advertising content — currently not used;
- access time;
- the address of the page containing the advertising content — currently not used;
- referrer information, meaning the address of the previous page.

3.3. The Website collects statistical information about visitors’ IP addresses. This information is used to identify and resolve technical issues and to monitor the legitimacy of financial transactions conducted through the Website.

3.4. Any other information that is not expressly specified above, including information about the browser and operating system used, is stored securely and is not disclosed, except as provided for in this Policy or required by applicable law.

4. Purposes of Collecting the User’s Personal Data

We process personal data to establish and maintain contact with the User, respond to requests, provide consultations, and communicate with the User in connection with technical support.

Personal data may be collected through the following Website features:

- “Contact Us” form;
- “Learn More” button;
- “Request Technical Support” form.

The categories of personal data processed for these purposes may include:

- name;
- telephone number;
- email address.

The Operator may perform the following operations with personal data:

- collection;
- recording;
- systematization;
- accumulation;
- storage;
- updating and modification;
- retrieval;
- use;
- transfer, including provision and access;
- blocking;
- deletion;
- destruction.

The legal basis for processing personal data is the User’s consent to the processing of personal data.

Personal data is processed from the date on which it is provided until the relevant processing purposes have been achieved or until the User withdraws consent, whichever occurs first, unless a longer retention period is required by law or is otherwise permitted by law.

5. Cookie Processing

5.1. General Information

Cookies are one of the technologies we use to collect information automatically and improve the quality and functionality of the Website.

The Website may automatically collect the following information when the User views advertising content or visits pages containing a statistical tracking script or pixel:

Disabling cookies may prevent the User from accessing certain parts or functions of the Website.

The Website may collect statistical information about Users’ IP addresses to identify and resolve technical issues.

Other information, including browsing history, the browser used, and the operating system, is stored securely and is not disclosed, except as provided for in this Policy or required by applicable law.

When visiting the Website for the first time, the User may refuse the use of cookies by changing the relevant browser settings. If the User does not agree to the processing of cookies or personal data, the User should discontinue use of the Website.

5.2. Cookie Settings and Analytics Providers

Detailed information about the purposes of data processing and the providers whose services are used on the Website is set out below.

5.2.1. Analytics Cookies

Google Analytics

Google Analytics enables us to collect and analyze information about how Users interact with the Website. The information is used for statistical and analytical purposes and is not intended to identify the User directly.

For more information, please refer to Google’s documentation on the types of cookies used by Google and Google Analytics’ privacy practices.

Yandex Metrica

The Website uses the Yandex Metrica web analytics service provided by Yandex LLC, 16 L. Tolstoy Street, Moscow, 119021, Russia (“Yandex”).

Yandex Metrica uses cookies — small text files stored on Users’ devices — to analyze User activity on the Website.

Information collected through cookies is not intended to identify the User directly but may help us improve the operation and functionality of the Website.

Information about the User’s use of the Website collected through cookies may be transferred to Yandex and stored on Yandex servers located in the European Union and the Russian Federation. Yandex may process this information to evaluate the use of the Website, prepare reports on Website activity, and provide other related services.

Yandex processes this information in accordance with the terms of use of the Yandex Metrica service and its applicable privacy policy.

The User may refuse the use of cookies by selecting the relevant settings in the browser. The User may also use an available cookie-management tool. Disabling cookies may affect the operation of certain Website functions.

By continuing to use the Website, the User consents to the processing of relevant data by Yandex for the purposes and in the manner described above, to the extent permitted by applicable law.

For further information, please refer to:

- the rules for protecting information about Website users;
- the Yandex Metrica privacy policy;
- the Yandex cookie policy.

6. User Rights

6.1. General Information about User Rights

Under Federal Law No. 152-FZ, the User has the following rights in relation to the processing of personal data:

- the right to access personal data;
- the right to request correction or updating of personal data;
- the right to request blocking or deletion of personal data;
- the right to challenge the Operator’s actions or omissions;
- the right to challenge decisions based solely on automated processing of personal data;
- the right to withdraw consent to the processing of personal data.

6.2. Provision of Information Concerning User Rights

Information related to the exercise of the User’s rights is provided free of charge.

If a request is manifestly unfounded or excessive, in particular because of its repetitive nature, the Operator may refuse to act on the request or may charge a reasonable fee, to the extent permitted by applicable law.

6.3. Right of Access to Personal Data

The User has the right to receive reliable information about the processing of the User’s personal data and, where applicable, access to such data and to the following information:

- confirmation of whether the Operator processes the User’s personal data;
- the legal grounds and purposes of processing;
- the purposes and methods of processing used by the Operator;
- the name and address of the Operator;
- information about persons, other than the Operator’s employees, who have access to personal data or to whom personal data may be disclosed under an agreement with the Operator or under federal law;
- the personal data being processed and the source from which it was obtained;
- the processing and retention periods;
- the procedure for exercising the User’s rights under Federal Law No. 152-FZ;
- information about any completed or intended cross-border transfer of personal data;
- the name, surname, first name, patronymic, and address of a person processing personal data on behalf of the Operator, if such processing has been or will be entrusted to that person.

6.4. How to Exercise Your Rights

The User may submit a written request to:

Limited Liability Company “Evolution of Marine Digital Technologies”
Building 3, No. 4 Aleksandrovsky Park
St. Petersburg, 197198
Russia

The request should include:

- information about the identity document of the User or the User’s representative, including the document type, series and number, issuing authority, and issue date;
- the User’s full name or the full name of the User’s representative;
- information confirming the relationship between the User and the Operator and the fact that the Operator processes the User’s personal data;
- the User’s signature or the signature of the User’s representative.

A request may also be sent electronically if it is signed in accordance with the requirements of Russian legislation on electronic signatures.

The User may contact the Operator directly at evomarine@evomarine.ru.

6.5. Additional Information for Identification

When exercising the User’s rights, the Operator may request additional information necessary to reliably identify the User. Such information will be requested only where reasonably necessary.

We seek to request the minimum amount of additional information required for identification.

The Operator may be unable to exercise the User’s rights if the User fails to provide the requested information.

6.6. Right to Challenge the Operator’s Actions or Omissions

The User has the right to object to the processing of personal data and to challenge the Operator’s actions or omissions.

The User may also contact the relevant territorial office of the Federal Service for Supervision of Communications, Information Technology and Mass Media (Roskomnadzor) in the User’s region.

6.7. Automated Decision-Making

The User has the right not to be subject to a decision based solely on automated processing, including profiling, if that decision produces legal effects concerning the User or similarly significantly affects the User.

If such decisions are made, the User may contact the Operator to challenge the relevant actions in accordance with applicable law.

6.8. Right to Withdraw Consent

If the processing of the User’s personal data is based on consent, the User has the right to withdraw that consent.

Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal. The Operator may continue processing personal data where another lawful basis exists or where continued processing is required or permitted by law.

6.9. Circumstances in Which User Rights May Be Restricted

The scope of the Operator’s obligations and the User’s rights, including rights of access, correction, blocking, and deletion, may be restricted in the following cases:

- personal data is processed, including data obtained through operational-search, counterintelligence, or intelligence activities, for the purposes of national defense, state security, or law enforcement;
- personal data is processed by authorities that detained the data subject on suspicion of committing a crime, charged the data subject in a criminal case, or imposed a preventive measure before charges were brought, except where Russian criminal procedure law permits access to such data;
- personal data is processed in accordance with legislation on preventing the legalization or laundering of proceeds of crime and the financing of terrorism;
- access to the data subject’s personal data would infringe the rights and legitimate interests of third parties;
- personal data is processed under Russian transport security legislation for the purposes of ensuring the sustainable and safe operation of the transport system and protecting individuals, society, and the state against unlawful interference;
- the Operator has lawful grounds to continue processing the User’s personal data.

Certain rights may be subject to specific statutory conditions. If the Operator is unable to satisfy a User’s request, the Operator will provide a reasoned refusal, to the extent required by applicable law.

7. Obligations of the Parties

7.1. User Obligations

The User must:

7.1.1. Provide accurate and complete personal data necessary for using the Website.

7.1.2. Promptly update the personal data provided to the Operator if it changes.

7.2. Operator Obligations

The Personal Data Officer must:

7.2.1. Use the personal data received exclusively for the purposes specified in Section 4 of this Policy.

7.2.2. Keep personal data confidential and not disclose, sell, exchange, publish, or otherwise disclose the User’s personal data without the User’s prior written consent, except where disclosure is permitted or required by this Policy or applicable law.

7.2.3. Take reasonable organizational and technical measures to protect the confidentiality and security of personal data in accordance with generally accepted business practices and applicable law.

7.2.4. Block personal data relating to the relevant User upon receiving a request from the User, the User’s legal representative, or an authorized data-protection authority during an investigation if inaccurate personal data or unlawful processing is identified.

If the Operator cannot immediately delete the User’s personal data, the Operator may block the data for a period of up to six months while determining how the data may lawfully be deleted or otherwise handled. Where permitted by law, the Operator may depersonalize the data instead of deleting it so that the User cannot be identified.

After blocking, deleting, or depersonalizing the User’s personal data, the Operator will notify the User where required by applicable law.

8. Liability

8.1. The Operator that fails to perform its obligations is liable for losses incurred by the User as a result of unlawful use of personal data, in accordance with Russian law and subject to the limitations and exceptions established by this Policy and applicable law.

8.2. The Operator is not liable for the loss or disclosure of confidential information if that information:

8.2.1. Had become publicly available before it was lost or disclosed;

8.2.2. Was lawfully obtained from a third party before it was received by the Operator; or

8.2.3. Was disclosed with the User’s consent.

9. Dispute Resolution

9.1. Before filing a claim with a court in connection with a dispute arising between the User and the Operator, the claimant must submit a written pre-trial complaint proposing voluntary settlement of the dispute, unless a different procedure is established by applicable law.

9.2. The recipient of the complaint must notify the claimant in writing of the outcome of the complaint review within 30 calendar days of receiving the complaint, unless another period is established by law.

9.3. If the parties fail to reach an agreement, the dispute may be submitted to a competent court in accordance with applicable Russian law.

9.4. This Policy and the relationship between the User and the Operator are governed by the laws of the Russian Federation.

10. Additional Terms

10.1. The Operator may amend this Policy without obtaining the User’s prior consent, unless such consent is required by applicable law.

10.2. The amended Policy becomes effective when it is posted on the Website, unless otherwise provided in the amended version.

10.3. Any questions or comments concerning this Policy should be sent to evomarine@evomarine.ru.

10.4. The current version of this Policy is available at:
https://evomarine.ru/privacy-policy/

11. Additional Provisions

11.1. The User’s personal data may be transferred to authorized state authorities of the Russian Federation only on the grounds and in accordance with the procedure established by Russian law.

11.2. If personal data is lost or disclosed, the Operator will notify the User where required by applicable law.

11.3. The Personal Data Officer takes the necessary organizational and technical measures to protect the User’s personal data against unlawful or accidental access, destruction, modification, blocking, copying, disclosure, dissemination, and other unlawful actions by third parties.

11.4. The Personal Data Officer and the User will take all reasonable measures to prevent losses or other adverse consequences resulting from the loss or disclosure of the User’s personal data.

11.5. Contacts

The contact details specified in this section are intended solely for matters relating to the processing and protection of personal data.

Requests sent to the contact details specified in this Policy that are unrelated to personal data protection will not be processed under this Policy.

For questions concerning the processing and protection of personal data, please contact the person responsible for organizing the processing of personal data:

Name: [to be completed]
Email: evomarine@evomarine.ru

11.6. Term of Consent

The User’s personal data is retained from the date of receipt until:

- the User exercises the right to request blocking or deletion and the relevant actions are completed;
- the User’s request or application is no longer being considered; or
- a contract for the provision of relevant works or services is concluded,

whichever occurs first, unless a longer retention period is required or permitted by applicable law.

Last updated: 19 February 2026

Consent to the Processing of Personal Data

To operate the Website, we collect certain technical data, including cookies, IP address information, and location data where available. If you do not agree to the processing of such data, please discontinue use of the Website.

In accordance with Article 9 of Federal Law No. 152-FZ dated 27 July 2006 “On Personal Data,” and for the purpose of providing services to you, you consent to the processing by the Operator of the personal data specified in this Policy.

You confirm that the personal data you provide is complete and accurate and undertake to update it promptly if it changes.

In accordance with Article 10 of Federal Law No. 152-FZ, you consent to the processing of your personal data by the Operator, provided that such processing is carried out by authorized persons.

When providing assistance and services to you, the Operator’s employees may transfer your personal data to other employees of the Operator where this is necessary to provide the services specified in this Policy.

The Operator may:

- enter your personal data into registers and databases of automated information systems in order to prepare reports and other information required under agreements or other documents governing the Operator’s interaction with other organizations;
- provide or transfer your personal data to other organizations where necessary to perform obligations established by law or contract;
- transfer personal data using physical media or communication channels, provided that appropriate measures are taken to protect the data against unauthorized access; and
- transfer personal data only to persons or organizations legally required to maintain professional or other legally protected confidentiality, where applicable.

The retention period for your personal data corresponds to the period specified in this Policy.

You consent to the following operations involving your personal data:

- processing in properly protected automated personal data information systems;
- processing by non-automated means in accordance with applicable data-protection requirements.

You have the right to withdraw your consent, in whole or in part, by submitting a written request. You may also withdraw consent if you become aware of facts indicating that your rights have been violated in connection with the processing of your personal data.

Upon receiving your written withdrawal of consent, the Operator will stop processing your personal data unless the Operator has another lawful basis for continuing such processing or is required or permitted to retain the data under applicable law.