Personal Data Processing Policy

Approved by Order No. 3 of the General Director of ENEF TECH LLC dated 20 October 2026. Revision of 21 October 2026. The Russian version prevails.

1. General

This Policy sets out how Energy-Efficient Technologies LLC (ENEF TECH LLC), OGRN 1267800076829, INN 7804722947, address: 195197, Saint Petersburg, Kondratyevsky prospekt 26, lit. A, apt. 15 (the Operator), processes and protects personal data in accordance with Federal Law No. 152-FZ "On Personal Data". It applies to all personal data the Operator receives from visitors of https://enef.tech, clients, representatives of counterparties, employees and job applicants.

2. Data we process

Website visitors and clients: full name, phone number, e-mail address, company and position, content of the request, and technical data sent by the browser (IP address, device and browser type, page of the request). Counterparty representatives: name, position, business phone and e-mail, data required to conclude and perform contracts. Employees and applicants: data required by labour, tax and pension legislation. The Operator does not process special categories of personal data or biometric data.

3. Purposes

Receiving and handling requests submitted through the website, by phone or e-mail; preparing commercial proposals and estimates; concluding, performing and terminating contracts; informing about the status of a request; HR, accounting and tax records; compliance with the laws of the Russian Federation; operation and security of the website.

4. Legal grounds

Articles 23 and 24 of the Constitution of the Russian Federation; Federal Law No. 152-FZ (items 1, 2 and 5 of part 1 of Article 6); the Civil, Labour and Tax Codes of the Russian Federation; Federal Laws No. 402-FZ and No. 14-FZ; Model Charter No. 20; contracts with data subjects; consents of data subjects.

5. How data is processed

Personal data is processed only to the extent necessary for the stated purposes, by automated and non-automated means, with transmission via the Internet (website, e-mail) and the Operator's internal network. Website requests are received only after the visitor has filled in the form and confirmed consent; the request is stored in the Operator's records and sent to info@enef.tech. Recording, systematisation, accumulation, storage, updating and retrieval of personal data of Russian citizens are performed using databases located in the Russian Federation (Saint Petersburg). Requests are stored until the purpose is achieved and no longer than three years after the last interaction unless a longer period is required by contract or law.

6. Disclosure and cross-border transfer

The Operator does not disclose personal data to third parties except where required to perform a contract with the data subject, required by law, or with a separate consent. Technical processing is performed on the Operator's servers and at a hosting provider located in the Russian Federation. No cross-border transfer of personal data is carried out.

7. Rights of data subjects

A data subject may obtain information about the processing of their data, request correction, blocking or destruction of incomplete, outdated, inaccurate or unlawfully obtained data, withdraw consent, and appeal to Roskomnadzor or a court. Requests are sent to info@enef.tech or by post to the Operator's address and are answered within 10 business days.

8. Security measures

The Operator has appointed a person responsible for organising personal data processing, approved this Policy and internal regulations, identified threats and the protection level of its information systems, restricts and logs access to personal data, uses password and antivirus protection, backups and recovery, access logging and HTTPS, and performs internal compliance checks.

9. Technical data and cookies

Server logs record the IP address, date and time of the request, page address and browser details solely to keep the website operational and secure; they are kept for no more than one year. The website uses only technical cookies (theme and language). No third-party analytics trackers are used.

10. Final provisions

The Operator may amend this Policy; the current version is published at https://enef.tech/en/privacy.html. Contact: info@enef.tech, 8 800 100 0 646. Person responsible for organising personal data processing: General Director Roman Vasilyev.