Personal Data Processing Policy

1. General Provisions
This Personal Data Processing Policy is drafted in accordance with the requirements of Federal Law No. 152-FZ dated July 27, 2006, "On Personal Data" (hereinafter referred to as the "Personal Data Law") and defines the procedure for processing personal data and measures to ensure the security of personal data taken by Globaris Estate (hereinafter referred to as the "Operator").
1.1. The Operator’s primary goal and condition for its activities is the observance of human and civil rights and freedoms during the processing of personal data, including the protection of the rights to privacy, personal, and family secrets.
1.2. This Policy regarding the processing of personal data (hereinafter referred to as the "Policy") applies to all information that the Operator may obtain about visitors to the website: https://phuket-investment.com/en
2. Basic Concepts Used in the Policy

• 2.1. Automated processing of personal data: Processing of personal data using computer equipment.
• 2.2. Blocking of personal data: Temporary termination of the processing of personal data (unless processing is necessary to clarify personal data).
• 2.3. Website: A collection of graphic and information materials, as well as computer programs and databases, ensuring their availability on the Internet at the network address https://phuket-investment.com/en.
• 2.4. Personal data information system: A set of personal data contained in databases and the information technologies and technical means ensuring their processing.
• 2.5. Depersonalization of personal data: Actions as a result of which it is impossible to determine, without the use of additional information, the ownership of personal data to a specific User or other subject of personal data.
• 2.6. Processing of personal data: Any action (operation) or set of actions (operations) performed with or without the use of automation tools, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
• 2.7. Operator: A state body, municipal body, legal entity, or individual, independently or jointly with others, organizing and/or carrying out the processing of personal data, as well as determining the purposes of processing, the composition of data, and the actions performed with it.
• 2.8. Personal data: Any information relating directly or indirectly to a specific or identifiable User of the website https://phuket-investment.com/en.
• 2.9. Personal data authorized by the subject for distribution: Personal data to which the subject has provided access to an unrestricted circle of persons by giving consent in the manner prescribed by the Personal Data Law.
• 2.10. User: Any visitor to the website https://phuket-investment.com/en.
• 2.11. Provision of personal data: Actions aimed at disclosing personal data to a specific person or a specific circle of persons.
• 2.12. Distribution of personal data: Any actions aimed at disclosing personal data to an indefinite circle of persons (transfer) or familiarizing an unlimited circle of persons with personal data (publication, etc.).
• 2.13. Cross-border transfer of personal data: Transfer of personal data to the territory of a foreign state to an authority of a foreign state, a foreign individual, or a foreign legal entity.
• 2.14. Destruction of personal data: Any actions as a result of which personal data are destroyed irrevocably with the impossibility of further restoration in the information system and/or the destruction of material carriers.

3. Basic Rights and Obligations of the Operator
3.1. The Operator has the right to:

• Receive reliable information and/or documents containing personal data from the subject.
• Continue processing personal data without the subject's consent if the subject withdraws consent or requests termination, provided there are legal grounds specified in the Personal Data Law.
• Independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations provided by law.

3.2. The Operator is obliged to:

• Provide the subject, upon request, with information regarding the processing of their personal data.
• Organize the processing of personal data in the manner prescribed by the current legislation of the Russian Federation.
• Respond to requests from subjects and their legal representatives within the timeframe required by law.
• Inform the authorized body for the protection of the rights of personal data subjects within 10 days of a request.
• Publish or otherwise provide unrestricted access to this Policy.
• Take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, or other unlawful actions.

4. Basic Rights and Obligations of Personal Data Subjects
4.1. Subjects have the right to:

• Receive information regarding the processing of their personal data, except in cases provided by federal laws.
• Demand clarification, blocking, or destruction of their data if it is incomplete, outdated, inaccurate, illegally obtained, or unnecessary for the stated purpose.
• Set a condition of prior consent when processing data for marketing goods or services.
• Withdraw consent to processing and/or demand the termination of processing.
• Appeal unlawful actions or omissions of the Operator to the authorized body or a court.

4.2. Subjects are obliged to:

• Provide the Operator with accurate data about themselves.
• Inform the Operator about any updates or changes to their personal data.

4.3. Persons who provide the Operator with false information or information about another subject without their consent are liable under the laws of the Russian Federation.
5. Principles of Personal Data Processing

• Processing is carried out on a legal and fair basis.
• Processing is limited to achieving specific, predetermined, and legitimate goals.
• Databases containing personal data processed for incompatible purposes shall not be merged.
• Only personal data that meets the purposes of their processing shall be processed.
• The content and volume of processed data must correspond to the stated purposes (no redundancy).
• Accuracy, sufficiency, and relevance of data are ensured.
• Storage is carried out in a form that allows identifying the subject for no longer than required by the purposes of processing or the law.

7. Conditions for Personal Data Processing
Processing is carried out only:

• With the consent of the subject.
• To achieve goals provided by international treaties or the law.
• For the administration of justice or execution of judicial acts.
• For the execution of a contract to which the subject is a party, beneficiary, or guarantor.
• To protect the rights and legitimate interests of the Operator or third parties, provided the subject's rights are not violated.

8. Procedure for Collection, Storage, and Transfer
8.1. The Operator ensures the safety of data and takes all possible measures to exclude access by unauthorized persons.
8.2. User data will never, under any circumstances, be transferred to third parties, except for cases related to compliance with current legislation or if the subject has given consent.
8.3. Users may update their data by sending an email to info@phuket-investment.com with the subject "Personal Data Update."
8.4. Consent may be withdrawn at any time via email to info@phuket-investment.com with the subject "Withdrawal of consent to personal data processing."
8.5. Information collected by third-party services (payment systems, etc.) is stored and processed by those entities according to their own policies. The Operator is not responsible for the actions of these third parties.
9. List of Actions Performed by the Operator
The Operator collects, records, systematizes, accumulates, stores, clarifies, extracts, uses, transfers (distributes, provides, accesses), depersonalizes, blocks, deletes, and destroys personal data via automated and non-automated means.
10. Cross-border Transfer of Personal Data
Prior to the start of cross-border transfer, the Operator must notify the authorized body of its intention and ensure that the foreign authorities or entities involved provide adequate protection for the rights of personal data subjects.
11. Confidentiality
The Operator and other persons who have gained access to personal data are obliged not to disclose them to third parties without the consent of the subject, unless otherwise provided by federal law.
12. Final Provisions
12.1. The User can receive any clarification on issues of interest by contacting the Operator at info@phuket-investment.com.
12.2. This document reflects any changes to the policy. The policy is valid indefinitely until replaced by a new version.