AVEROL –
Engineering Design and Industrial Technologies

PERSONAL DATA PROCESSING POLICY
Publication date: November 3, 2026
1. General Provisions
This Policy establishes the procedures for processing and protecting the personal data of users of the AVEROL website.
Data Controller:
Individual Entrepreneur Mirko Evangelisti.
Tax Identification Number (INN): 616518140240.
Registered address: 105A Kirova Street, Azov, Rostov Region, 346780, Russia.
Email: info@averol.ru
Website: https://averol.ru
2. Personal Data Subject to Processing
When users complete contact forms on the website, the Data Controller may collect the following personal data:

• Name;
• Email address;
• Telephone number;
• Content of the message or enquiry.

When the website is used, the following technical data may also be collected automatically:

• IP address;
• Browser and device information;
• Date and time of the visit;
• Addresses of pages visited;
• Website referral source;
• Cookie data and visitor identifiers.

The Data Controller does not request special categories of personal data or biometric personal data.
3. Purposes of Personal Data Processing
Personal data is processed for the following purposes:

• Receiving and handling enquiries submitted through the AVEROL website;
• Contacting users to provide information and consultations;
• Preparing commercial proposals;
• Discussing potential cooperation and project implementation;
• Maintaining records of enquiries and business correspondence with prospective and existing customers;
• Analysing website traffic and improving website performance using Yandex Metrica, subject to the user's relevant consent.

4. Legal Grounds for Processing
Personal data is processed on the following legal grounds:

• Consent of the personal data subject;
• The necessity of processing data to conclude a contract at the initiative of the personal data subject;
• Other legal grounds provided for by the legislation of the Russian Federation.

Consent to the processing of personal data is obtained separately from this Policy.
The use of analytical cookies is subject to the user's choice in the cookie settings on the website.
5. Operations and Methods of Personal Data Processing
The Data Controller may perform the following operations involving personal data:
Collection, recording, systematization, accumulation, storage, updating, extraction, use, transfer, access provision, blocking, deletion and destruction.
Processing is carried out both by automated means and without the use of automated systems.
6. Services Used and Data Transfers
To receive, process and store enquiries, the Data Controller uses the following services:
Tilda — website platform and processing of enquiries submitted through contact forms.
Yandex 360 — email services and storage of business correspondence.
Yandex Metrica — collection of website traffic statistics and analysis of visitor activity, subject to consent to the use of analytical cookies.
MAX — notifications about incoming enquiries delivered to the Data Controller's personal account and work group.
Access to enquiries in the MAX work group is granted only to authorized employees and representatives of the Data Controller who need this information to perform their work duties.
These services are used in accordance with their terms of service and documents governing data processing.
The Data Controller does not use the personal data collected for mass marketing communications without a separate lawful basis.
7. Personal Data Retention Periods
The Data Controller retains personal data only for as long as necessary to achieve the purposes of processing, subject to the following retention periods:
Enquiries in Tilda: the retention period in the enquiry interface is determined by the service settings and, as of the publication date of this Policy, is 30 calendar days.
Business correspondence in Yandex 360: retained for no longer than three years from the date of the last interaction with the user.
Notifications and enquiries in MAX: retained for no longer than three years from the date of the last interaction with the user.
After the three-year period, the Data Controller ensures that the relevant enquiries and correspondence are deleted from the email accounts and MAX work groups used, unless other lawful grounds for continued retention exist.
Data collected by Yandex Metrica is retained in accordance with the service settings and applicable terms of use.
Once the purposes of processing have been achieved, consent has been withdrawn, or further storage is no longer necessary, personal data shall be deleted or destroyed within the time limits established by the legislation of the Russian Federation, unless other lawful grounds for processing exist.
8. Personal Data Protection Measures
The Data Controller takes the necessary organizational and technical measures to protect personal data against unauthorized or accidental access, destruction, alteration, blocking, copying, disclosure and distribution.
Access to enquiries is granted only to persons who need it to perform their official duties.
9. Rights of Personal Data Subjects
Users have the right to:

• Obtain information about the processing of their personal data;
• Request the correction, blocking or deletion of personal data in the cases provided for by law;
• Withdraw previously granted consent;
• Contact the Data Controller with questions and requests concerning the processing of their personal data.

To exercise these rights, users may send a request to the following email address:
info@averol.ru
10. Final Provisions
This Policy comes into force upon its publication on the AVEROL website.
The Data Controller may amend this Policy in the event of changes to the legislation of the Russian Federation or to the procedures for processing personal data.
The current version of the Policy is permanently available on the website:
https://averol.ru

Personal Data Processing Policy
Consent to the Processing of Personal Data