Personal Data Processing Policy

Website: www.10-c.com
Contact: contact@10-c.com
Effective date: November 3, 2026
Last updated: November 3, 2026

1. Introduction and Scope
This Privacy Policy explains how the operator of www.10-c.com ("we," "us," "our," or the "Operator") collects, uses, shares, stores, and protects personal data of visitors and users of the website ("you" or "User"), and describes the rights you have under applicable data protection laws, including:

• the EU General Data Protection Regulation (EU) 2016/679 ("GDPR") and, where applicable, the UK GDPR and the Swiss Federal Act on Data Protection.

This Policy applies to all personal data we obtain through the website and related email communications. By using the website you acknowledge that you have read this Policy. Where the law requires your consent, we will ask for it separately.

2. Definitions

• Personal data — any information relating to an identified or identifiable natural person.
• Processing — any operation performed on personal data, including collection, recording, organization, storage, adaptation, retrieval, use, disclosure, restriction, erasure, or destruction.
• Controller — the party that determines the purposes and means of processing; in this Policy, the Operator.
• Processor — a party that processes personal data on behalf of the Operator.
• Cookies and similar technologies — small files and technologies (such as pixels and local storage) that store or access information on your device.

3. Who Is Responsible for Your Data
The Operator is the controller (GDPR) in respect of personal data processed through www.10-c.com. You can contact us at any time at contact@10-c.com for any question about this Policy or to exercise your rights.
If we are required to appoint an EU/UK representative or a Data Protection Officer under applicable law, their contact details will be published on this page.

4. Personal Data We Collect
4.1. Data you provide to us

• full name;
• email address;
• telephone number(s);
• organization name, industry, and job title;
• the content of messages you send us and records of your communications with us.

4.2. Data collected automatically
When you visit the website, we and our analytics providers may automatically collect:

• IP address (which may be truncated or anonymized) and approximate location derived from it;
• device, browser, operating system, language, and screen settings;
• pages visited, links clicked, time spent, referring and exit pages, and date and time of visits;
• unique online identifiers, cookie IDs, and similar identifiers.

4.3. Sensitive data
We do not intentionally collect special categories of personal data (GDPR Art. 9), and we ask that you not send us such information. If you do, we will delete it unless we are legally required to retain it.

4.4. Children
The website is not directed at children under 16 (or the higher minimum age set by local law), and we do not knowingly collect their personal data. If you believe a child has provided us with personal data, contact us at contact@10-c.com and we will delete it.


Where we rely on legitimate interests, we balance them against your rights and freedoms. You may request details of that assessment. Where we rely on consent, you may withdraw it at any time, without affecting the lawfulness of processing before withdrawal.
We do not use your personal data for solely automated decision-making that produces legal or similarly significant effects, including profiling of that kind.

6. Cookies, Analytics, and Similar Technologies
6.1. Google Analytics and other analytics services
We use Google Analytics and may use other international analytics services to understand how visitors use the website. These tools use cookies and similar technologies to collect usage data and transmit it to the provider, which acts as our processor/service provider (and, to the extent defined by its own terms, as an independent controller for certain purposes). Google's processing is described in its privacy policy at policies.google.com/privacy, and you can learn how Google uses data from sites that use its services at policies.google.com/technologies/partner-sites.
We configure analytics, where available, to shorten IP addresses, to limit data retention, and to disable advertising features and data sharing that we do not need.

6.2. Categories of cookies

• Strictly necessary cookies — required for the website to function and security; they do not require consent.
• Analytics/performance cookies — measure traffic and usage; used only with your consent where required by law (e.g., EU/UK).
• Marketing/advertising cookies — used only if we enable them, and only with your consent where required.

6.3. Managing cookies
Where required, we display a cookie banner that lets you accept, reject, or customize non-essential cookies, and you can change your choice at any time via the cookie settings link on the website. You can also block or delete cookies in your browser settings, or opt out of Google Analytics using Google's browser add-on at tools.google.com/dlpage/gaoptout. Blocking some cookies may affect website functionality.

7. How We Share Personal Data
We do not sell your personal data for money. We will not disclose your personal data to third parties except as described below:

• Service providers/processors that help us operate the website and communications, such as hosting, email delivery, customer-relationship, and analytics providers (including Google). They may process data only on our instructions and under data processing agreements or equivalent terms.
• Legal and safety reasons — where required by law, court order, or a lawful request from authorities, or to establish, exercise, or defend legal claims and protect our rights, users, or others.
• Business transfers — in connection with a merger, acquisition, or sale of assets, in which case we will ensure the recipient honors this Policy or notify you of changes.
• With your consent — where you ask us or authorize us to share your data.

8. International Data Transfers
The Operator is based in the Russian Federation. All personal data collected through the website is transferred to, stored, and processed in the Russian Federation, regardless of the country from which you access the website. Our service providers (for example, Google for analytics) may also process data in other countries, including the United States. The Russian Federation has not been recognized by the European Commission as providing an adequate level of data protection. Where the GDPR applies, we therefore transfer personal data from the EEA, the UK, or Switzerland only on the basis of one of the following:

• Standard Contractual Clauses approved by the European Commission (and the UK Addendum/IDTA), together with supplementary measures where necessary;
• your explicit consent under Art. 49(1)(a) GDPR, given after we have informed you of the possible risks of a transfer to a country without an adequacy decision and without appropriate safeguards;
• another derogation permitted by Art. 49 GDPR, such as a transfer necessary to perform a contract with you or to take steps at your request before entering into a contract;
• the EU–U.S. Data Privacy Framework, for onward transfers to certified providers such as Google LLC.

Processing in the Russian Federation is carried out in compliance with Russian Federal Law No. 152-FZ "On Personal Data." You may request a copy of the safeguards we use by contacting contact@10-c.com.

9. Data Retention
We keep personal data only as long as necessary for the purposes for which it was collected, or as required by law:

• Email marketing/information data — until you unsubscribe or withdraw consent, and then for a short period necessary to honor your opt-out and defend legal claims;
• Inquiry correspondence — generally up to 3 years after the last communication, unless a longer period is needed for legal reasons;
• Analytics data — in line with the retention settings we configure in the analytics service (generally no more than 14 months);
• Records required by law — for the statutory period.

When data is no longer needed, we delete it or irreversibly anonymize it.

10. Security
We implement appropriate technical and organizational measures to protect personal data against unauthorized or unlawful access, loss, destruction, alteration, and disclosure, including encryption in transit (HTTPS), access controls, the principle of least privilege, and vendor due diligence. No method of transmission or storage is completely secure, so we cannot guarantee absolute security. In the event of a personal data breach that is likely to put your rights at risk, we will notify the competent supervisory authority and affected individuals as required by law.
11. Your Rights Under the GDPR (EEA, UK, and Switzerland)
If the GDPR applies to you, you have the right to:

• Access your personal data and obtain a copy and information about how it is processed;
• Rectification of inaccurate or incomplete data;
• Erasure ("right to be forgotten") in the circumstances provided by law;
• Restriction of processing in the circumstances provided by law;
• Data portability — to receive data you provided in a structured, commonly used, machine-readable format and have it transmitted to another controller where technically feasible;
• Object to processing based on legitimate interests, and to direct marketing at any time and free of charge;
• Withdraw consent at any time, without affecting prior processing;
• Not be subject to solely automated decisions with legal or similarly significant effects;
• Lodge a complaint with your local supervisory authority (for the EU, a list is available at edpb.europa.eu; in the UK, the Information Commissioner's Office).

We will respond to verified requests within one month (extendable by up to two further months for complex or numerous requests, with notice to you). We may need to verify your identity before acting on a request.

12. Email Communications and Unsubscribing
We send informational emails only in accordance with applicable law (including the GDPR, ePrivacy rules, CAN-SPAM, and CASL, where applicable). Every marketing email includes an unsubscribe link, and you can also opt out at any time by emailing contact@10-c.com. We will process opt-outs promptly and no later than 10 business days. Even after you opt out, we may send non-promotional messages related to a request you made.

13. Third-Party Websites and Services
The website may contain links to third-party websites or services. We are not responsible for their privacy practices and encourage you to read their privacy policies. Information collected by third-party services, such as analytics, communication, and payment providers, is processed under their own terms and privacy policies.

14. Changes to This Policy
We may update this Policy from time to time to reflect changes in our practices, technology, or legal requirements. The current version is always available at www.10-c.com/privacy. If changes are material, we will give you appropriate notice and, where required by law, obtain your consent. Your continued use of the website after the effective date of changes constitutes acceptance of the updated Policy, except where consent is required.

15. Contact Us
For questions about this Policy, to exercise your rights, or to make a complaint, contact us at:
Email: contact@10-c.com
Website: www.10-c.com


Addendum
1. General Provisions
This personal data processing policy has been drawn up in accordance with the requirements of Federal Law No. 152-FZ of 27 July 2006 "On Personal Data" (hereinafter, the "Personal Data Law") and sets out the procedure for processing personal data and the measures to ensure the security of personal data taken by Vladimirov Maxim Vladimirovich (hereinafter, the "Operator").
1.1. The Operator's paramount aim and condition for carrying out its activities is to respect the rights and freedoms of individuals and citizens when processing their personal data, including the protection of the right to privacy and to personal and family confidentiality.
1.2. This Operator's personal data processing policy (hereinafter, the "Policy") applies to all information that the Operator may obtain about visitors to the website https://10-c.com.

2. Basic 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 suspension of the processing of personal data (except where processing is necessary to clarify the personal data).
2.3. Website — a set of graphic and informational materials, as well as computer programs and databases, ensuring their availability on the Internet at the network address https://10-c.com.
2.4. Personal data information system — the set of personal data contained in databases, and the information technologies and technical means that ensure its processing.
2.5. Depersonalization of personal data — actions as a result of which it is impossible, without the use of additional information, to determine whether personal data belongs to a specific User or other personal data subject.
2.6. Processing of personal data — any action (operation) or set of actions (operations) performed with personal data, with or without the use of automation tools, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (dissemination, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
2.7. Operator — a state body, municipal body, legal entity or individual that, independently or jointly with others, organizes and/or carries out the processing of personal data, and determines the purposes of processing, the composition of the personal data to be processed, and the actions (operations) performed with personal data.
2.8. Personal data — any information relating directly or indirectly to an identified or identifiable User of the website https://10-c.com.
2.9. Personal data permitted by the personal data subject for dissemination — personal data to which the personal data subject has granted access to an unlimited number of persons by giving consent to the processing of personal data permitted by the subject for dissemination, in the manner provided by the Personal Data Law (hereinafter, "personal data permitted for dissemination").
2.10. User — any visitor to the website https://10-c.com.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Dissemination of personal data — any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or at making an unlimited number of persons familiar with personal data, including publication in the mass media, posting in information and telecommunication networks, or providing access to personal data in any other way.
2.13. Cross-border transfer of personal data — transfer of personal data to the territory of a foreign state to a foreign state authority, a foreign individual, or a foreign legal entity.
2.14. Destruction of personal data — any actions as a result of which personal data is destroyed irrevocably, making it impossible to restore the content of the personal data in the personal data information system, and/or as a result of which the physical media of personal data are destroyed.

3. Basic Rights and Obligations of the Operator
3.1. The Operator has the right to:
— receive from the personal data subject reliable information and/or documents containing personal data;
— if the personal data subject withdraws consent to the processing of personal data, or submits a request to stop the processing of personal data, continue processing personal data without the subject's consent where there are grounds specified in the Personal Data Law;
— independently determine the composition and list of measures necessary and sufficient to ensure compliance with the obligations provided for by the Personal Data Law and the regulatory legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.
3.2. The Operator is obliged to:
— provide the personal data subject, at their request, with information concerning the processing of their personal data;
— organize the processing of personal data in the manner established by the current legislation of the Russian Federation;
— respond to inquiries and requests from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
— provide the authorized body for the protection of the rights of personal data subjects, at that body's request, with the necessary information within 10 days of receiving such a request;
— publish this Policy on personal data processing or otherwise ensure unrestricted access to it;
— take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision, or dissemination, as well as from other unlawful actions with respect to personal data;
— cease the transfer (dissemination, provision, access) of personal data, cease processing, and destroy personal data in the manner and in the cases provided for by the Personal Data Law;
— perform other obligations provided for by the Personal Data Law.

4. Basic Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects have the right to:
— receive information concerning the processing of their personal data, except in cases provided for by federal laws. The information is provided to the personal data subject by the Operator in an accessible form and must not contain personal data relating to other personal data subjects, except where there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
— require the Operator to clarify their personal data, block it, or destroy it if the personal data is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, and take measures provided by law to protect their rights;
— set a condition of prior consent for the processing of personal data for the purpose of promoting goods, works, and services on the market;
— withdraw consent to the processing of personal data, and submit a request to stop the processing of personal data;
— appeal to the authorized body for the protection of the rights of personal data subjects, or in court, against unlawful actions or inaction of the Operator in the processing of their personal data;
— exercise other rights provided for by the legislation of the Russian Federation.
4.2. Personal data subjects are obliged to:
— provide the Operator with reliable information about themselves;
— notify the Operator of any clarification (update, modification) of their personal data.
4.3. Persons who have provided the Operator with false information about themselves, or information about another personal data subject without that subject's consent, bear liability in accordance with the legislation of the Russian Federation.

5. Principles of Personal Data Processing
5.1. Personal data is processed on a lawful and fair basis.
5.2. Processing of personal data is limited to the achievement of specific, predetermined, and lawful purposes. Processing of personal data that is incompatible with the purposes of its collection is not permitted.
5.3. It is not permitted to merge databases containing personal data that is processed for purposes that are incompatible with each other.
5.4. Only personal data that meets the purposes of its processing is subject to processing.
5.5. The content and volume of the personal data processed correspond to the stated purposes of processing. Excessiveness of the personal data processed in relation to the stated purposes of processing is not permitted.
5.6. When processing personal data, the accuracy of the personal data, its sufficiency, and, where necessary, its relevance in relation to the purposes of processing are ensured. The Operator takes the necessary measures and/or ensures that they are taken to delete or clarify incomplete or inaccurate data.
5.7. Personal data is stored in a form that allows the personal data subject to be identified for no longer than the purposes of processing require, unless the storage period is established by federal law or by a contract to which the personal data subject is a party, beneficiary, or guarantor. Processed personal data is destroyed or depersonalized upon achievement of the purposes of processing or when the need to achieve those purposes is lost, unless otherwise provided by federal law.

6. Purposes of Personal Data Processing
Purpose of processing: informing the User by sending emails.
Personal data:

• surname, first name, patronymic
• email address
• telephone numbers
• name of organization, field of activity, position
• the content of messages and records of communications with the User

Legal grounds:

• the Operator's charter (constituent) documents
• contracts concluded between the Operator and the personal data subject

Types of personal data processing:

• Collection, recording, systematization, accumulation, storage, destruction, and depersonalization of personal data
• Sending informational emails to an email address

7. Conditions of Personal Data Processing
7.1. Personal data is processed with the consent of the personal data subject to the processing of their personal data.
7.2. Processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, and to perform the functions, powers, and obligations imposed on the operator by the legislation of the Russian Federation.
7.3. Processing of personal data is necessary for the administration of justice, the execution of a judicial act, or an act of another body or official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. Processing of personal data is necessary for the performance of a contract to which the personal data subject is a party, beneficiary, or guarantor, as well as for the conclusion of a contract at the initiative of the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor.
7.5. Processing of personal data is necessary for the exercise of the rights and legitimate interests of the operator or third parties, or for the achievement of socially significant purposes, provided that the rights and freedoms of the personal data subject are not violated.
7.6. Personal data is processed to which access by an unlimited number of persons has been granted by the personal data subject or at their request (hereinafter, "publicly available personal data").
7.7. Personal data is processed that is subject to publication or mandatory disclosure in accordance with federal law.

8. Procedure for Collection, Storage, Transfer, and Other Types of Personal Data Processing
The security of personal data processed by the Operator is ensured by implementing the legal, organizational, and technical measures necessary to fully comply with the requirements of current legislation on personal data protection.
8.1. The Operator ensures the safety of personal data and takes all possible measures to prevent unauthorized persons from accessing personal data.
8.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to compliance with current legislation, or where the personal data subject has given the Operator consent to transfer the data to a third party for the performance of obligations under a civil law contract.
8.3. If inaccuracies in personal data are identified, the User may update them independently by sending the Operator a notice to the Operator's email address contact@10-c.com marked "Updating personal data."
8.4. The period of personal data processing is determined by the achievement of the purposes for which the personal data was collected, unless a different period is provided for by a contract or current legislation.
The User may withdraw their consent to the processing of personal data at any time by sending the Operator a notice by email to the Operator's email address contact@10-c.com marked "Withdrawal of consent to the processing of personal data."
8.5. All information collected by third-party services, including payment systems, communication services, and other service providers, is stored and processed by those persons (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject should review the said documents on their own. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.
8.6. Prohibitions established by the personal data subject on the transfer (other than the provision of access) of personal data permitted for dissemination, as well as on the processing of such data or conditions of its processing (other than obtaining access), do not apply in cases where personal data is processed in the state, public, and other public interests defined by the legislation of the Russian Federation.
8.7. When processing personal data, the Operator ensures the confidentiality of personal data.
8.8. The Operator stores personal data in a form that allows the personal data subject to be identified for no longer than the purposes of processing require, unless the storage period is established by federal law or by a contract to which the personal data subject is a party, beneficiary, or guarantor.
8.9. A condition for terminating the processing of personal data may be the achievement of the purposes of processing, the expiry of the personal data subject's consent, the withdrawal of consent by the personal data subject or a request to stop processing, as well as the identification of unlawful processing of personal data.

9. List of Actions Performed by the Operator with Personal Data Received
9.1. The Operator carries out the collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (dissemination, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
9.2. The Operator carries out automated processing of personal data, with or without receiving and/or transmitting the information obtained via information and telecommunication networks.

10. Cross-Border Transfer of Personal Data
10.1. Before commencing any cross-border transfer of personal data, the Operator is obliged to notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out cross-border transfer of personal data (such notification is submitted separately from the notification of the intention to process personal data).
10.2. Before submitting the above notification, the Operator is obliged to obtain from the foreign state authorities, foreign individuals, or foreign legal entities to which cross-border transfer of personal data is planned, the relevant information.

11. Confidentiality of Personal Data
The Operator and other persons who have gained access to personal data are obliged not to disclose personal data to third parties and not to disseminate it without the consent of the personal data subject, unless otherwise provided by federal law.

12. Final Provisions
12.1. The User may obtain any clarification on questions concerning the processing of their personal data by contacting the Operator by email at contact@10-c.com.
12.2. Any changes to the personal data processing policy made by the Operator will be reflected in this document. The Policy is valid indefinitely until replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet at http://10-c.com/privacy/.