Personal Data Processing Policy

1. Consent to Personal Data Processing

By filling out the form on the CAPITOLINE website, you consent to the processing of your personal data in accordance with Federal Law No. 152-FZ "On Personal Data".

2. Personal Data Subject

The personal data subject is a natural person who provides their data through the contact form on the website.

3. Personal Data Operator

Operator: CAPITOLINE Family Office

Purpose of processing: Processing user requests, providing Family Office services, client communication

4. List of Processed Data

We process the following categories of personal data:

• Surname, name, patronymic
• Contact phone
• Telegram username
• Request or application content
• Requested service category

5. Actions with Personal Data

The following actions are performed with personal data:

• Collection and recording
• Systematization
• Accumulation
• Storage
• Clarification (updating, modification)
• Use
• Deletion and destruction

6. Data Processing Methods

Personal data processing is carried out using automation tools and without such tools, including:

• Processing in information systems
• Manual document processing
• Transmission via secure communication channels

7. Consent Validity Period

Consent to personal data processing is valid until the subject revokes it. Consent revocation can be made by sending a written notice to the Operator.

8. Data Protection Requirements

When processing personal data, the Operator takes necessary legal, organizational, and technical measures to protect personal data from unauthorized access, destruction, modification, blocking, copying, provision, distribution, as well as from other unlawful actions.

9. Data Transfer to Third Parties

Personal data is not transferred to third parties, except in cases of:

• Obtaining consent from the personal data subject
• Requirements of Russian legislation
• Necessity for fulfilling obligations to the user

10. Rights of Personal Data Subject

The personal data subject has the right to:

• Receive information concerning the processing of their data
• Require clarification or deletion of data
• Withdraw consent to data processing at any time
• Challenge the Operator's actions (inaction) in the authorized body
• Receive a copy of their personal data

11. Consent Withdrawal

The personal data subject may withdraw consent to personal data processing by sending a written notice to the Operator at info@capitoline.ru. After consent withdrawal, the Operator ceases data processing and deletes it within legally established timeframes, except when processing is necessary to fulfill contractual obligations or legal requirements.

12. Liability for Legislation Violation

Persons guilty of violating the provisions of Russian legislation in the field of personal data bear civil, administrative, and criminal liability in accordance with Russian legislation.

13. Data Retention Period

Personal data is stored for 3 years from the last interaction with the personal data subject, unless a different period is established by Russian legislation. After the retention period expires, data is subject to destruction or anonymization.

14. Contact Information

For all questions related to personal data processing:

Phone: +7 (966) 867-80-90

Email: info@capitoline.ru