PERSONAL DATA PROCESSING POLICY

Publication Date: 15 December 2025

1. GENERAL PROVISIONS

1.1. This Personal Data Processing Policy (hereinafter referred to as the “Policy”) defines the procedures and conditions for processing personal data on the website of the international forum “Trans-Siberian Cultural Dialogue” (hereinafter referred to as the “Forum”, the “Website”) and applies to all personal data collected by the FOUNDATION FOR THE SUPPORT OF THE TRANS-SIBERIAN ART FESTIVAL / TRANS-SIBARTFEST FOUNDATION, Tax ID (INN) 7707363026 (hereinafter referred to as the “Operator”, the “Organizer”) from Website users, applicants, and Forum participants.

1.2. This Policy has been developed in accordance with Clause 2, Part 1, Article 18.1 of Federal Law No. 152-FZ dated 27 July 2006 (as amended on 24 June 2025) “On Personal Data”, as well as other applicable regulatory legal acts of the Russian Federation governing personal data.

1.3. This Policy applies to any information relating to an identified or identifiable individual (hereinafter referred to as “Personal Data”, “PD”) obtained by the Operator when using the Website, completing registration forms, submitting applications, subscribing to newsletters, participating in Forum events, or communicating with the Organizer.

1.4. Use of the Website, submission of any form (application, registration, feedback), or provision of Personal Data in any other manner constitutes the User’s consent to this Policy and to the processing of Personal Data under the terms set forth herein.

2. OPERATOR AND CONTACT DETAILS

2.1. The personal data operator is:

FOUNDATION FOR THE SUPPORT OF THE TRANS-SIBERIAN ART FESTIVAL / TRANS-SIBARTFEST FOUNDATION

Registered address: Room 2, Building 2, 3 Likhov Lane, Moscow, 127051, Russian Federation.

Tax ID (INN): 7707363026.

2.2. For matters related to personal data processing and the exercise of data subject rights, inquiries may be sent:

— by email: info@tsaf-tscd.ru;

— by post: Room 2, Building 2, 3 Likhov Lane, Moscow, 127051, Russian Federation.

3. CATEGORIES OF DATA SUBJECTS AND TYPES OF PERSONAL DATA PROCESSED

3.1. The Operator may process Personal Data of the following categories of data subjects:

— Website users;

— individuals applying for participation in the Forum (applicants, participants);

— speakers, moderators, experts, invited guests;

— representatives of partner organizations and contractors;

— other persons contacting the Organizer regarding Forum-related matters.

3.2. Depending on the form and purpose of interaction, the Operator may process the following Personal Data:

— full name (last name, first name, patronymic);

— date of birth;

— country and city of residence;

— citizenship (where required);

— contact details: email address, phone number, messenger accounts;

— information about organization and position, professional status, field of activity;

— information related to Forum participation (role, participation format, sections, applications, abstracts, etc.);

— links to social media profiles and personal websites (if available and voluntarily provided);

— payment details necessary for organizing registration fees or other services (without storing full payment card details in the Operator’s systems);

— other information voluntarily provided by the data subject via Website forms or during communication.

3.3. When visiting the Website, technical data may be processed automatically, including:

— IP address, browser and device information;

— date and time of access, requested page address;

— cookie files and similar technologies;

— statistical data on Website usage.

3.4. The Operator does not process special categories of Personal Data (data concerning race or ethnicity, political opinions, religious or philosophical beliefs, health status, or intimate life) or biometric Personal Data, except in the following cases:

— publication of photo and video materials from Forum events;

— where such data are explicitly and voluntarily provided by the data subject and are necessary for Forum purposes (e.g., special participation requirements, visa support).

In such cases, processing is carried out based on separate consent executed in accordance with the requirements of Russian legislation.

4. PURPOSES OF PERSONAL DATA PROCESSING

4.1. The Operator processes Personal Data strictly for specific purposes, including:

— receiving and reviewing applications for Forum participation;

— registering participants, speakers, partners, and volunteers;

— organizing and conducting Forum events (program formation, participant lists, badges, seating arrangements, distribution of materials, etc.);

— communication with data subjects (program updates, organizational information, service notifications);

— creation and maintenance of personal accounts (if applicable);

— preparation of reports and analytical materials following Forum results;

— ensuring Website functionality and improving its performance;

— sending informational and promotional materials related to the Forum and associated projects, subject to separate consent;

— compliance with Russian legislation, including accounting, tax reporting, and reporting to grant providers and partners (if applicable);

— handling inquiries, claims, and requests from data subjects.

4.2. Use of Personal Data for purposes not specified in this Policy is permitted only with the separate consent of the data subject or on another lawful basis.

5. LEGAL GROUNDS FOR PERSONAL DATA PROCESSING

5.1. The Operator processes Personal Data on the following legal grounds:

— Federal Law No. 152-FZ dated 27 July 2006 (as amended on 24 June 2025) “On Personal Data”;

— Federal Law No. 149-FZ dated 27 July 2006 “On Information, Information Technologies and Information Protection”;

— other applicable regulatory legal acts of the Russian Federation;

— the Operator’s charter and internal regulations;

— contracts, agreements, and offers concluded with data subjects (including the Forum participation agreement);

— consent of the personal data subject to the processing of their Personal Data.

5.2. Depending on the specific situation, the legal basis for processing may include:

— conclusion and performance of a contract/offer (e.g., the Forum participation agreement);

— fulfillment of statutory obligations of the Operator;

— consent of the data subject, including consent expressed by checking a box and submitting a Website form;

— legitimate interests of the Operator, provided such interests do not violate the rights and freedoms of the data subject (e.g., protection of the Operator’s rights, ensuring the security of the Website and Forum events).

6. PROCEDURE, METHODS, AND RETENTION PERIODS OF PERSONAL DATA PROCESSING

6.1. Personal Data processing is carried out using automated and/or non-automated means and includes collection, recording, systematization, accumulation, storage, clarification, use, transfer (provision, access), anonymization, blocking, deletion, and destruction.

6.2. The Operator ensures that Personal Data are stored in a form that allows identification of the data subject no longer than required for processing purposes or as required by Russian legislation or data subject consents.

6.3. Retention periods are determined with regard to:

— the duration of the Forum and related programs;

— requirements of civil, tax, accounting, and other legislation of the Russian Federation;

— retention periods specified in data subject consents;

— limitation periods for potential legal protection of the Operator’s rights.

6.4. Personal Data processing is terminated and data are destroyed or anonymized in the following cases:

— achievement of processing purposes;

— expiration of retention periods;

— withdrawal of consent by the data subject (unless other legal grounds exist);

— identification of unlawful processing.

7. TRANSFER OF PERSONAL DATA TO THIRD PARTIES AND CROSS-BORDER TRANSFERS

7.1. The Operator may transfer Personal Data to third parties to the extent necessary to achieve the purposes specified in Section 4, including:

— technical service providers (hosting providers, mailing services, online form services, payment aggregators, etc.);

— Forum partners and co-organizers involved in event preparation and execution;

— consultants, carriers, visa and other services where necessary to ensure participation;

— public authorities in cases and in the manner stipulated by Russian legislation.

7.2. If Personal Data are transferred to or become accessible to organizations located outside the Russian Federation, such cross-border transfers are carried out in accordance with Russian legislation and subject to appropriate consent or other lawful grounds.

7.3. The Operator does not transfer Personal Data to third parties for purposes unrelated to the Forum or the Operator’s activities without separate consent, except where required by law.

8. COOKIES AND TECHNICAL DATA

8.1. Cookies and similar technologies may be used when visiting the Website for the following purposes:

— ensuring proper operation of the Website and its functions;

— saving user settings and preferences;

— analyzing traffic statistics and improving Website content and structure.

8.2. Users may independently restrict or disable cookies through browser settings; however, some Website functions may not operate correctly as a result.

8.3. Information obtained through cookies and technical means is processed in aggregated form for statistical and analytical purposes and may also be used to protect the Website from attacks and unlawful actions.

9. RIGHTS OF PERSONAL DATA SUBJECTS

9.1. Personal data subjects have the right to:

— obtain information regarding the existence and scope of their Personal Data held by the Operator;

— request clarification, blocking, or destruction of Personal Data in cases provided by Russian legislation;

— withdraw consent to Personal Data processing;

— restrict processing in cases stipulated by law;

— appeal actions or inaction of the Operator to the authorized data protection authority or to a court.

9.2. To exercise their rights, data subjects may submit a written request or electronic inquiry to the contact details specified in Section 2 of this Policy. Requests are recommended to include full name, contact details, request description, and, if necessary, documents confirming the applicant’s status or authority.

9.3. The Operator reviews data subject requests within the timeframes and in the manner prescribed by Russian legislation and provides a reasoned response.

10. MEASURES TO ENSURE PERSONAL DATA SECURITY

10.1. The Operator implements necessary and sufficient legal, organizational, and technical measures to protect Personal Data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, dissemination, and other unlawful actions.

10.2. Such measures include, in particular:

— adoption of internal policies governing Personal Data processing and protection;

— restriction of access to Personal Data to authorized personnel only;

— use of information security tools and antivirus software;

— data backup and recovery;

— regular monitoring of compliance with Russian legislation and internal regulations.

10.3. The Operator ensures training of employees with access to Personal Data regarding legal requirements and internal data protection procedures.

11. POLICY AMENDMENTS

11.1. The Operator reserves the right to amend this Policy. The revised version enters into force upon publication on the Website unless otherwise specified in the revised version.

11.2. In the event of material changes affecting the scope, purposes, or methods of Personal Data processing, the Operator may additionally notify users by posting information on the Website or by email (if provided by the data subject).

12. FINAL PROVISIONS

12.1. All matters related to Personal Data processing not regulated by this Policy are governed by the legislation of the Russian Federation.

12.2. The current version of the Policy is permanently available on the Website at: https://tsaf-tscd.ru/personal-data/.

12.3. In the event of discrepancies between the terms of consents provided by data subjects and this Policy, the consent terms shall prevail to the extent they do not contradict Russian legislation.

FOUNDATION FOR THE SUPPORT OF THE TRANS-SIBERIAN ART FESTIVAL /

TRANS-SIBARTFEST FOUNDATION

Publication Date: 15 December 2025