Privacy Policy

1. General Provisions

This Privacy Policy (hereinafter — the "Policy") has been developed in accordance with Federal Law No. 152-FZ of 27 July 2006 "On Personal Data" (hereinafter — "152-FZ"). The Policy defines the procedure for processing personal data and the measures taken to ensure its security by Underwater Communication and Navigation Laboratory, LLC (hereinafter — the "Operator").

The Operator regards respect for the rights and freedoms of the individual and citizen in the processing of their personal data, including protection of the rights to privacy, personal and family secrecy, as the most important goal and condition of its activity.

This Policy applies to all information the Operator may obtain about visitors to the unavlab.com website, customers, counterparties, prospective clients, job candidates, and employees of the Operator.

2. Key Definitions

For the purposes of this Policy, the following key definitions apply:

• Personal data — any information relating to a directly or indirectly identified or identifiable natural person (data subject).
• Operator — a government body, municipal body, legal entity, or natural person that, independently or jointly with others, organizes and/or carries out the processing of personal data.
• Processing of personal data — any action (operation) or set of actions (operations) performed on personal data, whether or not by automated means, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (dissemination, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
• Data subject — a natural person whose personal data is processed by the Operator.
• Website — the combined graphical and informational materials, as well as computer programs and databases, that ensure their availability on the Internet at the network address https://unavlab.com/ and its subdomains.

3. Information About the Operator

Full name: Underwater Communication and Navigation Laboratory, LLC (Limited Liability Company).
Taxpayer Identification Number (INN): 7705391349.
Tax Registration Reason Code (KPP): 773101001.
Primary State Registration Number (OGRN): 1157746070041.
Registered address: 121205, Moscow, Bolshoy Boulevard (Skolkovo Innovation Center territory), bldg. 42, structure 1, floor 3, room 1098, workspace 10.
Actual address: Moscow, Skolkovo Innovation Center territory, Bolshoy Boulevard 42c1.
Phone: +7 (499) 322-25-37.
Email: hello@unavlab.com.

4. Purposes of Personal Data Processing

The Operator processes personal data for the following purposes:

• Concluding, performing, amending, and terminating contracts (civil-law, employment, or other).
• Providing consultations, responding to inquiries, sending commercial proposals and other information requested by the subject.
• Informing about new products, company news, and special offers — subject to the subject's consent.
• Personnel recruitment and consideration of job applicants.
• Compliance with the legislation of the Russian Federation, including tax and labor legislation.
• Collecting anonymized statistics on Website visits in order to improve its operation and develop the business — subject to the visitor's consent (Section 13).

5. Legal Grounds for Personal Data Processing

The legal grounds for the Operator's processing of personal data are:

• The Constitution of the Russian Federation.
• Federal Law No. 152-FZ of 27 July 2006 "On Personal Data".
• The Civil Code of the Russian Federation.
• The Labor Code of the Russian Federation.
• The Tax Code of the Russian Federation.
• Other federal laws and regulatory legal acts governing relations connected with the processing of personal data.
• Contracts concluded between the Operator and the data subject.
• The data subject's consent to the processing of their personal data.

6. Categories of Subjects and Data Processed

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

• Website visitors who fill in feedback forms.
• Counterparties and customers — representatives of legal entities and individual entrepreneurs.
• Candidates for vacant positions.
• Employees of the Operator.

Depending on the category of subject and the purpose of processing, the Operator may process the following categories of personal data:

• Last name, first name, patronymic.
• Contact phone number.
• Email address.
• Name of organization and job title.
• City of residence.
• Other data voluntarily provided by the subject in free form when contacting the Operator.

When using the Website, and only after the visitor's consent, the Operator may collect technical and behavioral data about visitors using the Yandex Metrica web analytics service. This includes:

• cookies, visitor and session identifiers;
• IP address, information about the browser and operating system;
• referral source;
• cursor movements, clicks, scrolling, and navigation between pages.

Details are provided in Section 13 of this Policy.

The Operator does not process, without the subject's separate written consent, biometric personal data or special categories of personal data. Special categories are information concerning racial and ethnic origin, political, religious, and philosophical beliefs, state of health, and intimate life.

7. Conditions for Personal Data Processing

The Operator processes personal data subject to compliance with one of the following conditions:

• The processing of personal data is carried out with the consent of the data subject.
• The processing of personal data is necessary for the performance of a contract to which the data subject is a party or beneficiary.
• The processing of personal data is necessary for the exercise of the rights and legitimate interests of the Operator or third parties.
• The processing of personal data is carried out for purposes provided for by the legislation of the Russian Federation.

8. Methods of Personal Data Processing

The Operator processes personal data using the following methods:

• Using automation tools (in the Operator's information systems).
• Without the use of automation tools (on paper media).
• Using a mixed method.

9. Measures to Ensure the Security of Personal Data

The Operator takes the necessary legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision, dissemination, and other unlawful actions with respect to it, including:

• Appointing a person responsible for organizing the processing of personal data.
• Approving local acts governing the processing and protection of personal data.
• Applying organizational and technical measures to ensure the security of personal data in information systems in accordance with the level of protection established in the prescribed manner.
• Monitoring and assessing the effectiveness of the measures applied.
• Restricting access to personal data to the circle of persons for whom such access is necessary to perform their job duties.

10. Personal Data Retention Periods

The retention period for personal data is determined based on the purposes of processing, the requirements of the legislation of the Russian Federation, and the terms of contracts concluded with subjects.

Personal data is subject to destruction:

• upon achievement of the purposes of processing or in the event the need to achieve them ceases;
• upon withdrawal by the subject of consent to processing.

Exceptions apply in cases otherwise provided for by the legislation of the Russian Federation.

11. Transfer of Personal Data to Third Parties

The Operator does not transfer personal data to third parties, except in the following cases:

• The subject's consent to such transfer has been obtained.
• The transfer is necessary for the performance of a contract to which the subject is a party.
• The transfer is provided for by the legislation of the Russian Federation (including transfer to government bodies pursuant to their lawful requests).
• Engagement of contractors and service providers (hosting, email distribution, accounting services) under a contract containing an obligation to ensure the confidentiality and security of personal data.

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

12. Rights of the Data Subject

The data subject has the right to:

• Receive information concerning the processing of their personal data, including: confirmation of the fact of processing, the legal grounds and purposes of processing, the methods of processing, information on the persons who have access to the data, the list of data processed and the source of its receipt, and the periods of processing and storage.
• Demand the clarification of their personal data, its blocking or destruction, if it is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing.
• Withdraw their consent to the processing of personal data.
• Appeal the actions or omissions of the Operator to the authorized body for the protection of the rights of personal data subjects (Roskomnadzor — the Federal Service for Supervision of Communications, Information Technology and Mass Media) or in court.

To exercise these rights, the subject may send a written request to the Operator:

• by email to hello@unavlab.com;
• by mail to: 121205, Moscow, Bolshoy Boulevard (Skolkovo Innovation Center territory), bldg. 42, structure 1, Underwater Communication and Navigation Laboratory, LLC.

13. Cookies and Web Analytics Services

The Website uses cookies and the Yandex Metrica web analytics service. The service operator is YANDEX LLC (OGRN 1027700229193, address: 119021, Moscow, Lva Tolstogo St., 16).

How a visitor gives or withholds consent. On the first visit to the Website, a notice about the use of cookies is displayed with two buttons:

• "Accept". By clicking this button, the visitor consents to the processing of the data specified in this section. Only after this does the Yandex Metrica counter load and begin operating. Before the button is clicked, the counter does not load, and no data is transmitted to Yandex Metrica.
• "Decline and leave the site". By clicking this button, the visitor leaves the Website, the counter does not load, and no data is transmitted to Yandex Metrica.

The visitor's decision is stored in their browser's storage. This is necessary so that the notice does not appear again.

Withdrawal of consent. The visitor may withdraw consent at any time:

• using the "Withdraw consent to use cookies" button on this page;
• by deleting the Website's data (cookies and local storage) in the browser settings.

After consent is withdrawn, the counter does not load until consent is given again.

The legal basis for processing is the visitor's consent (clause 1, part 1, article 6 of 152-FZ), expressed by clicking the "Accept" button.

Within the Yandex Metrica service, the "Webvisor" function may be enabled on the Website. It records the visitor's actions on the page (cursor movements, scrolling, clicks, navigation between pages) in the form of a replayable session recording. Recording of form field contents is disabled by technical means (see below).

Categories of data transmitted to Yandex Metrica:

• technical identifiers (the visitor identifier set by the counter in a cookie, session identifier);
• IP address, information on browser, operating system, device type, screen resolution, and language;
• referral source, search query (if applicable), URLs of visited Website pages, time and duration of the visit;
• behavioral data: cursor movements, clicks, scrolling, navigation between pages within the Website;
• the fact of submitting feedback forms (without the field contents) — for conversion counting purposes.

Form contents (name, phone number, email, etc.) are not transmitted to Yandex Metrica:

• form fields on the Website are marked with the CSS classes ym-hide-content and ym-disable-keys, which block the recording of field contents and keystrokes in Webvisor;
• the "Record all fields" option is disabled in the Metrica counter settings.

Data is transmitted to Yandex Metrica under the terms published at: https://yandex.ru/legal/confidential/ and https://yandex.ru/legal/metrica_termsofuse/.

In addition to the decline button in the notice, the visitor may restrict the use of cookies and data collection by Metrica by:

• changing browser settings (disabling cookies, incognito mode);
• installing the official "Metrica Blocker" extension from YANDEX LLC;
• configuring blocking extensions such as uBlock Origin or AdGuard.

14. Functional Language Cookie and Country Determination by IP Address

In addition to the web analytics service cookies (Section 13), the Website uses a technically necessary (functional) cookie to store the interface language selected by the visitor:

• Name: ucnl_lang.
• Value: the code of the selected language (for example, ru or en).
• Retention period: 1 year.
• When it is set: only upon explicit language selection via the switcher in the Website header.
• Purpose: on repeat visits, the Website immediately displays the language version chosen by the visitor, without re-determining it by IP address.

This cookie is technically necessary for the operation of the Website (it provides a basic function — storing the interface language) and is not used for web analytics or advertising, and is therefore set without the visitor's separate consent.

Country determination by IP address. If the visitor has not explicitly selected a language (the ucnl_lang cookie is absent), the Website determines the visitor's likely country from their IP address in order to automatically display the appropriate language version (for example, the English version — for visitors outside Russia). Country determination is performed on the Website's server using a local database; in doing so, the visitor's IP address:

• is not stored or logged in connection with this function;
• is not transmitted to any third parties.

The DB-IP "IP to Country Lite" database is used, attribution: IP Geolocation by DB-IP (db-ip.com), distributed under the terms of the Creative Commons Attribution 4.0 International license (CC BY 4.0).

15. Final Provisions

This Policy is a publicly available document and is published on the Website at https://unavlab.com/policy/.

The Operator has the right to amend this Policy. When amendments are made, the heading of the Policy indicates the date of its most recent revision. The new revision takes effect from the moment it is posted on the Website.

For all questions related to the Operator's processing of personal data, the data subject may contact the following email address: hello@unavlab.com.