Private policy

Personal Data Processing Policy

Version dated May 11, 2026

1. General Provisions

1.1. This Personal Data Processing Policy defines the procedure for processing and protecting personal data that WELL ENGINEERING LLC receives through the website https://wellpro.ru/, including the documentation request page https://wellpro.ru/documents/.

1.2. This Policy has been developed in accordance with Federal Law No. 152-FZ “On Personal Data” dated July 27, 2006, and other applicable regulatory legal acts of the Russian Federation.

1.3. The website https://wellpro.ru/ is used by WELL ENGINEERING LLC to provide information about the WellPRO software product, provide access to documentation upon request, process user inquiries and communicate on product-related matters.

1.4. This Policy applies to personal data of website users who submit a request to receive the WellPRO user manual, documentation, technical information, or ask a question about the WellPRO product.

1.5. WELL ENGINEERING LLC does not use personal data received through the forms on the website https://wellpro.ru/ for advertising newsletters, mass email newsletters, SMS mailings, messenger mailings, automated marketing, retargeting, or sending special offers unrelated to a specific user request.

2. Personal Data Operator

2.1. The personal data operator is:

WELL ENGINEERING LLC
Russian name: ООО «ВЭЛ ИНЖИНИРИНГ»
TIN: 7727344381
OGRN: 1187746434380
Legal address: room 2/1, 3, Admiral Ushakov Boulevard, Yuzhnoye Butovo District, Moscow, 117624, Russia
E-mail for personal data inquiries: wellpro@wellengineering.ru
Additional e-mail: mail@wellengineering.ru
Website: https://wellpro.ru/

3. Key Terms

3.1. Personal data means any information relating directly or indirectly to an identified or identifiable individual.

3.2. User means a visitor of the website https://wellpro.ru/ who submits a request to receive the user manual, documentation, or asks a question about the WellPRO product.

3.3. Operator means WELL ENGINEERING LLC, which independently or jointly with other persons organizes and performs the processing of personal data and determines the purposes of personal data processing, the scope of personal data and the actions performed with personal data.

3.4. Personal data processing means any action or set of actions performed with personal data, including collection, recording, systematization, accumulation, storage, clarification, use, transfer, blocking, deletion and destruction.

3.5. Website means the website located on the Internet at https://wellpro.ru/.

4. Categories of Personal Data Subjects

4.1. The Operator processes personal data of the following categories of data subjects:

— website users requesting the WellPRO user manual or documentation;
— users asking questions about the WellPRO product;
— representatives of organizations interested in the WellPRO software product;
— potential customers, partners and product users;
— other persons whose data are voluntarily provided by the user in the inquiry.

4.2. The website is intended for business communication in the B2B format. The Operator does not intentionally collect personal data of minors.

5. Scope of Processed Personal Data

5.1. When a user submits a request through the website form, the Operator processes the following mandatory personal data of the user:

— full name;
— main activity of the user or the organization represented by the user;
— e-mail address;
— phone number.

5.2. The user may also voluntarily provide additional information required to process the request:

— company name;
— position;
— content of the question about the WellPRO product;
— requested documentation or section of the user manual;
— information about the intended scenario of product use;
— other information that the user independently provides in the form or communicates to the Operator.

5.3. The Operator does not request through the documentation request form and does not process within this form the following categories of data:

— passport data;
— bank card data;
— information about education;
— information about qualifications and educational documents;
— special categories of personal data, including information about health, racial or ethnic origin, political opinions, religious or philosophical beliefs, intimate life;
— biometric personal data.

5.4. If the user voluntarily provides excessive personal data in the inquiry, the Operator processes such data only to the extent necessary to consider the request or deletes them if there is no need for processing.

6. Purposes of Personal Data Processing

6.1. The Operator processes personal data exclusively for the following purposes:

— receiving and processing the user’s request;
— identifying the recipient in order to prepare a response;
— providing the WellPRO user manual or other documentation upon request;
— answering the user’s question about the WellPRO product;
— communicating with the user regarding a specific request;
— clarifying technical, organizational or commercial parameters of the request;
— providing information about the functionality, capabilities, requirements and procedure for using the WellPRO product;
— preparing to conclude an agreement at the initiative of the user or the organization represented by the user;
— concluding and performing an agreement if an agreement is concluded following the request;
— fulfilling obligations provided for by the legislation of the Russian Federation;
— protecting the rights and legitimate interests of the Operator in case of disputes.

6.2. The Operator does not use personal data received through the documentation request form for advertising newsletters, mass notifications, automated marketing, user profiling, retargeting or transfer to third parties for advertising purposes.

7. Legal Grounds for Personal Data Processing

7.1. The legal grounds for personal data processing are:

— consent of the personal data subject to the processing of personal data;
— processing necessary to prepare for the conclusion of an agreement at the initiative of the user or the organization represented by the user;
— processing necessary for the conclusion and performance of an agreement;
— fulfillment of the Operator’s obligations provided for by the legislation of the Russian Federation;
— protection of the rights and legitimate interests of the Operator, provided that the rights and freedoms of the personal data subject are not violated.

7.2. Consent to personal data processing is given separately from this Policy and other documents confirmed by the user.

7.3. The user independently decides whether to provide personal data and gives consent freely, voluntarily and in the user’s own interest.

8. Procedure and Conditions of Personal Data Processing

8.1. Personal data processing is carried out both with and without the use of automation tools.

8.2. The Operator may perform the following actions with personal data:

— collection;
— recording;
— systematization;
— accumulation;
— storage;
— clarification;
— use;
— transfer in cases provided for by this Policy;
— blocking;
— deletion;
— destruction.

8.3. The Operator processes only those personal data that correspond to the declared purposes of processing.

8.4. The Operator does not combine databases containing personal data processed for incompatible purposes.

8.5. The Operator ensures the confidentiality of personal data and takes the necessary legal, organizational and technical measures to protect them.

9. Transfer of Personal Data to Third Parties

9.1. The Operator does not sell, exchange, publish or disseminate users’ personal data.

9.2. Personal data may be transferred to third parties only in the following cases:

— if the transfer is necessary to process the user’s request and provide documentation for the WellPRO product;
— if the transfer is necessary to answer the user’s question about the product;
— if the transfer is necessary for the conclusion or performance of an agreement;
— if the transfer is required under the legislation of the Russian Federation;
— if the user has given separate consent to such transfer.

9.3. Access to personal data may be granted to authorized employees of the Operator, as well as to persons ensuring the technical operation of the website, hosting, mail services, CRM system, WellPRO portal and other information systems of the Operator, provided that they comply with confidentiality and personal data protection requirements.

9.4. Persons who gain access to personal data on behalf of the Operator undertake to process personal data only for the purposes determined by the Operator and to ensure their confidentiality.

10. Technical Data and Cookies

10.1. The website may process technical data required for the proper operation of the website, protection against unlawful actions, ensuring security and functioning of the documentation request form.

10.2. Such technical data may include:

— IP address;
— browser and device information;
— date and time of access to the website;
— technical information about the operation of the website;
— server log data;
— technical cookies, if they are necessary for the operation of the website.

10.3. The website may use technical cookies required for the correct operation of the website, feedback form, protection against unlawful actions and ensuring security.

10.4. The Operator does not use web analytics services, advertising pixels, retargeting services, end-to-end analytics systems or other similar tools for tracking user behavior on the website.

10.5. The Operator does not use technical data and cookies for advertising profiling, retargeting, sending advertising messages or transferring data to third parties for advertising purposes.

10.6. If in the future the Operator decides to use web analytics services, advertising pixels, retargeting services, end-to-end analytics systems or other similar tools for tracking user behavior, the Operator will update this Policy and, where necessary, obtain separate consent from the user before using such tools.

11. Cross-Border Transfer of Personal Data

11.1. The Operator does not carry out cross-border transfer of personal data of users of the website https://wellpro.ru/, unless otherwise expressly stated in this Policy or in the user’s separate consent.

11.2. If cross-border transfer of personal data becomes necessary in the future, the Operator will comply with the requirements of the legislation of the Russian Federation before starting such transfer.

12. Personal Data Processing and Storage Periods

12.1. Personal data are processed until the purposes of processing are achieved.

12.2. Personal data received through the documentation request form or product inquiry form are stored:

— during the period required to review the request;
— during the period of business communication regarding the specific request;
— during the period required to provide documentation or answer the user’s question;
— during the term of the agreement, if the request results in the conclusion of an agreement;
— during the periods established by the legislation of the Russian Federation, if such periods apply.

12.3. If the request does not result in the conclusion of an agreement, the Operator may store personal data for 12 months from the date of the last communication regarding the request, unless a longer period is required to protect the rights and legitimate interests of the Operator or to comply with legal requirements.

12.4. Upon achievement of the processing purposes, expiration of the storage period or withdrawal of consent, personal data shall be deleted, destroyed or anonymized, unless otherwise provided by the legislation of the Russian Federation.

13. Rights of the Personal Data Subject

13.1. The user has the right to:

— receive information about the processing of personal data;
— request clarification of personal data;
— request blocking or destruction of personal data if they are incomplete, outdated, inaccurate, unlawfully obtained or no longer necessary for the declared purpose of processing;
— withdraw consent to personal data processing;
— request termination of personal data processing;
— appeal against actions or omissions of the Operator to the authorized body for the protection of the rights of personal data subjects or to a court;
— exercise other rights provided for by the legislation of the Russian Federation.

13.2. To exercise these rights, the user may send a request to the following e-mail address:

wellpro@wellengineering.ru

13.3. It is recommended to indicate “Personal Data Request” or “Withdrawal of Consent to Personal Data Processing” in the subject line of the e-mail.

13.4. The Operator has the right to request additional information necessary to identify the applicant and confirm the fact of processing of the applicant’s personal data.

14. Withdrawal of Consent to Personal Data Processing

14.1. The user has the right to withdraw consent to personal data processing at any time.

14.2. The withdrawal of consent shall be sent to:

wellpro@wellengineering.ru

14.3. After receiving the withdrawal, the Operator shall terminate the processing of personal data and destroy them, unless there are other legal grounds for continuing the processing.

14.4. Withdrawal of consent may make it impossible to provide the user manual, documentation or answer the product-related question if the request cannot be processed without the relevant data.

15. Measures to Protect Personal Data

15.1. The Operator takes the necessary legal, organizational and technical measures to protect personal data, including:

— restriction of access to personal data;
— determination of persons having access to personal data;
— appointment of persons responsible for organizing personal data processing;
— application of organizational and technical protection measures;
— access control to information systems;
— backup and restoration of information where necessary;
— recording and review of requests from personal data subjects;
— familiarization of employees having access to personal data with personal data protection requirements;
— destruction or anonymization of personal data after the purposes of processing have been achieved.

15.2. The Operator takes measures to prevent unauthorized or accidental access to personal data, their destruction, modification, blocking, copying, provision, dissemination and other unlawful actions.

16. Final Provisions

16.1. This Policy is effective from the date of its publication on the website https://wellpro.ru/.

16.2. The Operator has the right to amend this Policy. The new version of the Policy becomes effective from the moment it is published on the website, unless otherwise provided by the new version.

16.3. The current version of the Policy is freely available on the website at: https://wellpro.ru/privacy/.

16.4. For any questions related to personal data processing, the user may contact the Operator at:

wellpro@wellengineering.ru