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Personal data processing policy

Version of 1 August 2026. This is a courtesy translation. In case of any discrepancy, the Russian version of this document prevails and is the legally binding one. This Personal Data Processing Policy is adopted by FREGAT BLAGODAT LLC pursuant to Article 18.1(1)(2) of Federal Law No. 152-FZ of 27 July 2006 “On Personal Data”.

1. General provisions

1.1. The data controller (operator) is FREGAT BLAGODAT LLC, PSRN (OGRN) 1217800152195, TIN (INN) 7801704643, TRRC (KPP) 780101001, registered address: 199106, г. Санкт-Петербург, вн.тер.г. муниципальный округ Гавань, пл. Морской Славы, д. 1, литера А, помещ. 3-Н, часть пом. 304; place of business: 197046, г. Санкт-Петербург, Петровская набережная, д. 2.

1.2. Contact for data protection matters: banket@fregat-blagodat.ru, phone +7 (921) 999-95-75.

1.3. The Policy applies to all information about individuals obtained by the Operator, including through the website https://fregat-blagodat.ru and its sections, such as the QR menu page https://fregat-blagodat.ru/eng-menu.

1.4. Consent to the processing of personal data is given separately, by ticking the dedicated checkbox in a form on the website.

2. Categories of data subjects and data processed

2.1. Persons submitting a banquet request: name, phone number, e-mail address, and optionally the type of event, expected number of guests, preferred hall and free-text comments.

2.2. Guests reserving a table: name, phone number, date and time of the visit, number of guests, seating preferences.

2.3. Persons contacting the Operator by e-mail or phone: contact details and the content of the enquiry.

2.4. Website visitors: IP address, cookies, browser and device information, pages viewed and referral source — processed mainly in anonymised form for statistics.

2.5. The Operator does not process special categories of personal data or biometric data, and does not process data of minors. The forms are intended for persons aged 18 and over.

3. Purposes of processing

  • handling banquet requests, preparing and sending commercial proposals;
  • concluding and performing a contract for the provision of catering services;
  • processing table reservations and confirming them;
  • responding to enquiries, questions and complaints;
  • complying with the Operator’s statutory duties under consumer protection, accounting and tax law;
  • maintaining and improving the website and collecting anonymised traffic statistics.

4. Legal grounds

  • consent of the data subject — Article 6(1)(1) of Federal Law No. 152-FZ;
  • performance of a contract to which the data subject is a party, or its conclusion at the subject’s initiative — Article 6(1)(5) of Federal Law No. 152-FZ;
  • the Civil Code of the Russian Federation, Articles 779–783;
  • Law of the Russian Federation No. 2300-1 “On Consumer Rights Protection”;
  • Rules for the Provision of Catering Services (Government Decree No. 1515 of 21 September 2020);
  • Federal Law No. 402-FZ “On Accounting” and the Tax Code — for retention of primary documents.

5. Procedure and conditions of processing

5.1. Processing is carried out both with and without the use of automation and includes collection, recording, systematisation, accumulation, storage, updating, retrieval, use, transfer, blocking, erasure and destruction.

5.2. Databases containing personal data of Russian citizens are located in the Russian Federation, as required by Article 18(5) of Federal Law No. 152-FZ. The website and its database are hosted with a Russian hosting provider.

5.3. The Operator does not carry out cross-border transfers of personal data.

5.4. Processing may be entrusted to third parties acting under a contract with the Operator: the hosting provider, the table reservation service and the e-mail provider. They are bound by confidentiality and data protection obligations.

5.5. The website uses Yandex.Metrica web analytics, which processes anonymised visit data. You may opt out by disabling cookies in your browser.

5.6. Retention periods:

  • banquet request that did not result in a contract — 1 year from the date of the request;
  • data related to the performance of a contract — 5 years from completion (as part of primary accounting records);
  • table reservation data — until the service is provided and 6 months thereafter;
  • enquiries and complaints — 3 years;
  • cookies and analytics data — up to 1 year.

5.7. Once the purposes are achieved or consent is withdrawn, personal data is destroyed within 30 days, unless a different retention period is required by law.

6. Security measures

6.1. The Operator applies legal, organisational and technical measures required by Articles 18.1 and 19 of Federal Law No. 152-FZ, including the appointment of a person responsible for organising the processing, internal regulations, access control, encrypted connections (HTTPS), backups and logging.

6.2. In the event of an unlawful transfer of personal data, the Operator notifies Roskomnadzor within 24 hours of detecting the incident and reports the results of the internal investigation within 72 hours.

7. Rights of the data subject

7.1. You have the right to obtain information about the processing of your personal data, to request rectification, blocking or destruction of data that is incomplete, outdated, inaccurate or unlawfully obtained, to withdraw consent, and to lodge a complaint with Roskomnadzor or the courts.

7.2. Requests should be sent to banket@fregat-blagodat.ru or in writing to 197046, г. Санкт-Петербург, Петровская набережная, д. 2. The Operator responds within 10 working days; this period may be extended by up to 5 working days with a reasoned notice.

7.3. Consent may be withdrawn at any time. Upon withdrawal, processing ceases and the data is destroyed within 30 days, save where the law permits processing without consent.

8. Cookies

8.1. The use of cookies is described in a separate document available at https://fregat-blagodat.ru/docs/cookies. Optional analytics cookies are set only after you accept them in the cookie notice.

9. Final provisions

9.1. The current version of the Policy is published at https://fregat-blagodat.ru/docs/privacy. The Operator may amend the Policy; a new version takes effect upon publication on the website.

9.2. Russian law applies to this Policy and to the relations it governs.