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Privacy Policy

Regarding the Processing of Personal Data
December 19, 2025
1. General Provisions
1.1. This Personal Data Processing Policy (hereinafter referred to as the "Policy") is issued and applied by PADELAPP.CLUB LIMITED LIABILITY COMPANY, Taxpayer Identification Number (INN): 9705251602, Primary State Registration Number (OGRN): 1257700568322, located at Rostov Region, Rostov-on-Don city district, Rostov-on-Don, Vernaya Street, 47, email: info@padelapp.club (hereinafter referred to as the "Operator"), in accordance with Federal Law No. 152-FZ of July 27, 2006, "On Personal Data" (hereinafter referred to as the "Law").
1.2. All matters related to the processing of personal data not regulated by this Policy shall be resolved in accordance with the current legislation of the Russian Federation in the field of personal data.
1.3. This Policy:
1.3.1. establishes the rules for the Operator's processing of personal data provided by individuals who have entered into contractual and other civil law relationships (hereinafter referred to as the "Data Subject") with the Operator;
1.3.2. defines the purposes, legal grounds, procedure, and scope of processed personal data;
1.3.3. contains information on the implemented requirements for the protection of processed personal data;
1.3.4. defines the procedure for interacting with Data Subjects upon receiving requests from them;
1.3.5. outlines the methods and timeframes for processing personal data;
1.3.6. establishes the procedure for the destruction of personal data.
1.4. Lack of awareness of the conditions set forth in this Policy does not constitute grounds for the Data Subject to make any claims against the Operator.
1.5. The Data Subject accepts the terms of this Policy and provides the Operator with informed and conscious consent to the processing of their personal data under the conditions provided for by this Policy and the Law:
1.5.1. When filling out a feedback form — for personal data that the Data Subject provides to the Operator when filling out a feedback form on the Internet website, in the padelapp.club mobile application, and in electronic services (Telegram, etc.).
1.5.2. During any use of the website and application — for personal data that is automatically transmitted to the Operator during the use of the website via software installed on the Data Subject's device. The Data Subject is considered to have provided consent to the processing of their personal data at the moment they start using the website and application.
1.6. The Data Subject's consent to the Operator's processing of their personal data is effective from the day consent is granted for their processing, and for the period necessary to achieve the purposes of the personal data processing, or until its withdrawal, or for 3 (three) years from the date of termination of service provision.
1.7. The Operator considers the observance of human and civil rights and freedoms when processing their personal data, including the protection of rights to privacy, personal and family secrets, as its highest priority and a condition for conducting its activities.
1.8. This Policy of the Operator regarding the processing of personal data (hereinafter referred to as the "Policy") applies to all information that the Operator may obtain about users of its website and mobile application.
1.9. The Operator processes the personal data of individuals who have not reached full legal capacity. In case an individual has not reached such age, consent to their processing is provided by their legal representatives. If it is discovered that an individual who provided their personal data lacks legal capacity and did so without the permission of their legal representative, the Operator will immediately block the processing of such personal data pending clarification of the circumstances.
2. Key Terms Used in the Policy
2.1. Automated Processing of Personal Data – processing of personal data using computer technology.
2.2. Blocking of Personal Data – temporary cessation of personal data processing (except for cases where processing is necessary to clarify personal data).
2.3. Website – a collection of graphical and informational materials, as well as computer programs and databases that make them accessible on the internet at the network address Padelapp.club (hereinafter referred to as the Website/Mobile Application).
2.4. Mobile Application "Padelapp.club" (also hereinafter referred to as the "Mobile Application") – a collection of interconnected texts, graphic elements, photos and videos, computer programs, including software modules, databases, cross-module components, and other elements, algorithmically combined by thematic, technical, and functional features into a single software complex under the search name "Padelapp.club", designed for installation on Android and iOS devices, enabling Customers as application users to utilize the user functionality.
2.5. Personal Data Information System – a collection of personal data contained in databases and the information technologies and technical means ensuring their processing.
2.6. Anonymization of Personal Data – actions resulting in the inability to determine, without the use of additional information, the belonging of personal data to a specific User or other subject of personal data.
2.7. Processing of Personal Data – any action (operation) or a set of actions (operations) performed with or without the use of automation tools on personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), anonymization, blocking, deletion, destruction of personal data.
2.8. Operator – a legal entity, individual entrepreneur, or individual who, independently or jointly with others, organizes and/or carries out the processing of personal data, and determines the purposes of personal data processing, the composition of personal data to be processed, and the actions (operations) performed with personal data.
2.9. Personal Data – any information relating directly or indirectly to a specific or identifiable User.
2.10. Personal Data Permitted by the Data Subject for Dissemination – personal data, access to which by an unlimited number of persons has been provided by the data subject by giving consent to the processing of personal data permitted by the data subject for dissemination in the manner prescribed by the Law on Personal Data (hereinafter – personal data permitted for dissemination).
2.11. User – any visitor to the Website or Mobile Application.
2.12. Destruction of Personal Data – any actions resulting in the irreversible destruction of personal data with the impossibility of further recovery of the content of personal data in the personal data information system and/or the destruction of material carriers of personal data.
3. Conditions for Providing Personal Data by the Data Subject
3.1. The Operator does not verify the accuracy of personal information provided by Data Subjects and does not monitor their legal capacity. The risk of providing inaccurate personal data, including providing third-party data as one's own, is borne solely by the Data Subject.
3.2. The Operator assumes that:
3.2.1. The Data Subject provides accurate and sufficient personal information regarding the questions presented in the Website forms or by providing consent as stipulated in clause 3.1.1., and keeps this information up to date.
3.2.2. When uploading one's own image via the Website, the Data Subject grants free-of-charge consent to the use of this image (Article 152.1 of the Civil Code) for purposes not related to identifying the Data Subject. The Data Subject undertakes not to provide photographs of third parties as the Data Subject's own image.
3.3. The Data Subject acknowledges that by consenting to the dissemination of personal data permitted by the Data Subject, such data may be posted by the Operator on the Website, where they become accessible to other Data Subjects of the Website and may be copied and disseminated by such Data Subjects, unless restrictions and/or conditions for their dissemination are established in the consent for the dissemination of permitted personal data by the Data Subject.
3.4. By providing this consent, the Data Subject is informed of the right to impose prohibitions on the transfer (except for providing access) of these personal data by the Operator to an unlimited number of persons, as well as prohibitions on the processing or conditions for processing (except for obtaining access) of these personal data by an unlimited number of persons.
3.5. The Data Subject has familiarized themselves with this Policy and expresses their informed and conscious consent to it.
4. Personal Data
4.1. The personal data of the Data Subject, as well as persons who have not reached full legal capacity and whose legal representative is the Data Subject, processed by the Operator include: Surname, first name, patronymic; Mobile phone number; Email address; Residential address; Details of an identity document (for verification); Payment details; Date of birth; Information about the presence of minors (if participating); Video and photographic images containing the Customer's image (with consent). Account data in electronic services (Telegram messenger, etc.), if authorization via these services is provided on the Website or in the mobile application.
4.2. The Operator may access, collect, and use technical and other information related to Data Subjects for the purposes defined in this Policy. Technical information is not personal data; however, the Operator uses cookies that allow for the identification of Data Subjects. Technical information also refers to information automatically transmitted to the Operator during the Data Subject's use of the Website via software installed on the Data Subject's device, namely:
4.2.1. Data on the Data Subject's activity on the Internet, particularly visited pages, date and time of URL transitions, etc.;
4.2.2. Information about the device and browser used by the Data Subject to access the Internet: IP address and (if the Data Subject accesses the Website from a mobile device) device type and its unique identifier;
4.2.3. Cookie files, as well as other data collected via a metrics program.
4.3. The Operator does not process:
4.3.1. biometric personal data (information characterizing a person's physiological and biological features, which can be used to establish their identity),
4.3.2. special categories of personal data (pertaining to race, nationality, political views, religious or philosophical beliefs, health status, intimate life).
4.4. The processing of the Data Subject's personal data by the Operator is carried out using databases located on the territory of the Russian Federation.
4.5. Personal data is processed with and without the use of automated systems (mixed processing).
4.6. The Operator does not carry out cross-border data transfer.
5. Legal Grounds for Processing Personal Data
5.1. The processing of the Data Subject's personal data is carried out on the following legal grounds:
5.1.1. The Constitution of the Russian Federation;
5.1.2. The Civil Code of the Russian Federation;
5.1.3. The Data Subject's consent to the processing of personal data.
6. Legal Grounds for Processing Personal Data
6.1. The legal grounds for the processing of personal data by the Operator are: the legislation of the Russian Federation; agreements concluded between the Operator and the personal data subject; federal laws, other regulatory legal acts in the field of personal data protection; the Users' consent to the processing of their personal data.
6.2. The Operator processes the User's personal data only if they are filled in and/or sent by the User independently through special forms located on the Website or sent to the Operator via email. By filling out the relevant forms and/or sending their personal data to the Operator and marking their acknowledgment of the Consent to the processing of personal data, the User expresses their consent to the processing of their personal data in accordance with the text of the Consent and this Policy.
6.3. The Operator processes anonymized data about the User if this is allowed in the User's browser settings (saving "cookies" and using JavaScript technology is enabled).
6.4. The subject of personal data independently decides to provide their personal data and gives consent freely, by their own will and in their own interest.
6.5. The processing of the Data Subject's personal data includes the following actions performed by the Operator: collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), anonymization, blocking, deletion, destruction.
7. Methods of Personal Data Processing:
7.1. The collection of the Data Subject's personal data is carried out in cases and for the purposes specified in this Policy.
7.2. The storage of personal data is carried out (depending on which event occurs first):
7.2.1. until their deletion by the Data Subject in the relevant section of the Website;
7.2.2. until their destruction by the Operator — in case of receipt from the Data Subject of a withdrawal of consent to the processing of personal data or a demand for the destruction of personal data;
7.2.3. until the expiration of the consent term or the achievement of the purposes of personal data processing.
7.3. The Operator has the right to transfer personal data to third parties. Such transfer does not constitute the dissemination of the Data Subject's personal data to an indefinite circle of persons.
7.4. Purposes of transferring personal data: The Customer's personal data are processed for the purposes of: Concluding and executing a service agreement; Identifying the Customer and verifying their identity; Providing services and technical support; Processing payments and monitoring their receipt; Sending information about booked facilities; Sending informational and promotional materials (only with consent); Improving service quality and preventing fraud; Complying with the requirements of the legislation of the Russian Federation; Handling claims and resolving disputes. Fulfilling the terms of the agreement with the Data Subjects of the Website with the involvement of third parties.
7.5. The list of permitted methods for processing personal data: collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (provision, access), anonymization, blocking, deletion, destruction. The third party is prohibited from transferring and disseminating the personal data.
7.6. The destruction of personal data is carried out by the Operator in the following cases:
7.6.1. receipt from the Data Subject of a withdrawal of consent to the processing of personal data;
7.6.2. receipt from the Data Subject of a demand for the destruction of personal data;
7.6.3. expiration of the consent term;
7.6.4. expiration of the storage period for personal data according to the agreements between the Operator and the Data Subject.
8. Measures Applied by the Operator to Protect Personal Data
8.1. The Operator takes necessary and sufficient legal, organizational, and technical measures to protect the information provided by Data Subjects from unlawful or accidental access, destruction, alteration, blocking, copying, dissemination, as well as from other unlawful actions by third parties. Such measures include, in particular:
8.1.1. Appointment of a person responsible for the processing of personal data;
8.1.2. Implementation of organizational and technical measures to ensure the security of personal data during their processing in information systems;
8.1.3. Monitoring instances of unauthorized access to personal data and taking measures to prevent such incidents in the future;
8.1.4. Monitoring the implemented measures for ensuring the security of personal data and the level of protection of personal data information systems.
9. Procedure for Destruction of Personal Data
9.1. The responsible person of the Operator destroys information containing the personal data of the Data Subject in accordance with clause 9.6. of this Policy, no later than 10 days from the date of the Data Subject's request, expiration of the storage period, expiration of the validity period, achievement of the purpose of processing personal data, or loss of necessity for achieving it.
9.2. Destruction is carried out in one of the following ways:
9.2.1. destruction of the medium containing the information with the Data Subject's personal data;
9.2.2. complete formatting of the information containing the Data Subject's personal data;
9.2.3. complete formatting of the information containing the Data Subject's personal data using a special auxiliary program within the Operator's Software (utility).
9.2.4. Compilation of an Act of Destruction of the Data Subject's Personal Data. The act shall specify: — the date, place, and time of destruction; — the type and quantity of destroyed media containing the personal data of data subjects (if media are being destroyed); — the basis for destruction; — the method of destruction.
9.3. The fact of destruction of media containing the personal data of Data Subjects is recorded in the logbook of documents submitted for destruction. This document is confidential and, together with the acts, is stored on electronic media at the Operator's registered address.
10. Limitation of Liability
10.1. The Operator shall not be liable for any possible misuse of personal data and any damage caused to the Data Subject resulting from:
10.1.1. technical failures in software, technical means, and networks beyond the Operator's control;
10.1.2. intentional or unintentional use of the Website not for its intended purpose by third parties;
10.1.3. failure to maintain the confidentiality of access passwords or intentional transfer of access passwords, other information from the Website by the Data Subject themselves to other persons who do not have access to such information, when receiving the Operator's services or using the Website;
10.1.4. unlawful actions by third parties to access the Website's data, including personal data.
10.2. The Operator is not responsible for the manner in which third parties, with whom the Data Subject interacts while using the Website, use the Data Subject's personal data.
10.3. The Operator does not verify the existence of a special regime for processing the personal data of Data Subjects. If the Data Subject is a citizen of the European Union or a citizen of other states temporarily or permanently residing in the territory of EU countries and accesses the Website from Europe, the Operator takes all reasonable measures to ensure compliance with such personal data protection legislation requirements. For this purpose, the Data Subject is obliged to notify the Operator about the existence of a special regime for the protection of their personal data by contacting the Operator's email address.
11. Rights of Data Subjects
11.1. The Data Subject has the right to:
11.1.1. At their discretion, provide the Operator with personal data for processing under the terms specified in this Policy;
11.1.2. Submit requests to the Operator, including for the clarification of personal data; for the blocking or destruction of personal data, if such data is incomplete, outdated, inaccurate, unlawfully obtained, or is not necessary for the stated purpose of processing. The request shall be submitted in the manner provided for in Section 14 of this Policy;
11.1.3. Receive from the Operator, based on a request, information relating to the processing of their personal data as provided for in Clause 7, Article 14 of Federal Law No. 152-FZ of July 27, 2006, "On Personal Data."
11.1.4. Withdraw consent to the processing of personal data at any time in accordance with Article 9 of Federal Law No. 152-FZ of July 27, 2006, "On Personal Data";
11.1.5. Establish restrictions on the dissemination of personal data in accordance with Article 10.1 of Federal Law No. 152-FZ of July 27, 2006, "On Personal Data";
11.1.6. Protect their rights, including through judicial means.
12. Inquiries from Data Subjects
12.1. The Data Subject has the right to submit inquiries and demands to the Operator (hereinafter referred to as an "Inquiry"), including regarding the use of their personal data, as well as to withdraw consent to the processing of personal data and consent to the processing of personal data permitted by the data subject for dissemination. An Inquiry may be submitted in the following ways:
12.1.1. In written form to the Operator's address (Section 16 of the Policy);
12.1.2. In the form of an electronic document (scan, photo copy of the document). The document must be sent from the Data Subject's email address specified by them during registration on the Website or in the agreement as the authorized email address, to the Operator's email address.
12.2. An Inquiry submitted by the Data Subject must contain the following information:
12.2.1. The surname and first name of the Data Subject;
12.2.2. Information confirming the Data Subject's participation in relations with the Operator (in particular, the Data Subject's login and password on the Website);
12.2.3. The essence of the Inquiry;
12.2.4. The signature of the Data Subject or their legal representative.
12.3. The Operator considers the Data Subject's Inquiry in the following order:
12.3.1. The Inquiry is registered in the Log of Inquiries from Data Subjects;
12.3.2. The presence of all mandatory details of the Inquiry is verified;
12.3.3. The validity of the Inquiry is verified;
12.3.4. A response to the Inquiry is provided.
12.4. Depending on the essence of the Inquiry, the response to it must contain:
12.4.1. The information requested by the Data Subject about the processed personal data;
12.4.2. A reasoned refusal to provide the requested information about the processed personal data;
12.4.3. A notification about the actions taken with the Data Subject's personal data based on their Inquiry.
12.4.4. A response to the Inquiry is sent within 10 (ten) days from the date the Operator receives the Inquiry, in a form corresponding to the form of the Data Subject's Inquiry, unless the provision of a response to the Inquiry in a different form is specified in the Inquiry (clause 14.1 of the Policy).
13. Amendments to the Policy
13.1. The Operator reserves the right to make changes to this Policy. The Data Subject is obliged to review the text of the Policy each time they use the Website.
13.2. The new version of the Policy comes into force from the moment it is posted in the relevant section of the Operator's Website. Continued use of the Website or its services after the publication of a new version of the Policy signifies the Data Subject's acceptance of the Policy and its terms. In case of disagreement with the terms of the Policy, the Data Subject must immediately cease using the Website and its services.
13.3. We undertake not to make material changes, impose additional burdens, or restrict your rights established by this Policy without notifying you.
13.4. In case of amendments to the Policy, we will notify you by posting the new version of the Policy on our Website. Such notification will be considered proper.
14. Operator's Details and the Person Responsible for Personal Data Processing:

PADELAPP.CLUB LIMITED LIABILITY COMPANY
Taxpayer Identification Number (INN): 9705251602
Primary State Registration Number (OGRN): 1257700568322
Address: Rostov Region, Rostov-on-Don city district, Rostov-on-Don, Vernaya Street, 47
Email: info@padelapp.club
This version is effective from December 19, 2025.