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Roomy

Personal Data Processing Policy

Version dated 22 June 2026

1. General Provisions

This Policy on the processing of personal data (hereinafter the "Policy") has been developed pursuant to the requirements of Federal Law No. 152-FZ "On Personal Data" of 27.07.2006 (hereinafter "152-FZ") and sets out the procedure for processing personal data and the measures taken by the operator to ensure their security.

The operator regards the observance of the rights and freedoms of the individual and the citizen in the processing of their personal data, including the protection of the rights to privacy and to personal and family confidentiality, as its paramount objective.

The Policy applies to all information that the operator may obtain about visitors to the website located on the Internet and about users of the Roomy software.

2. Key Terms

Personal data — any information relating to a directly or indirectly identified or identifiable natural person (the subject of personal data).

Operator — an organisation that, independently or jointly with other persons, organises and (or) carries out the processing of personal data, and also determines the purposes and scope of the personal data being processed.

Processing of personal data — any action or set of actions performed on personal data, with or without the use of automation tools, including collection, recording, systematisation, accumulation, storage, rectification, use, transfer, blocking, deletion and destruction.

Website — the collection of Roomy web pages. User — a visitor to the website or a user of the Roomy software.

3. Operator of Personal Data

The operator is OXTECH LLC (the Roomy brand), TIN 9721254914, PSRN 1257700343845, address: Russia, Moscow, Nekrasovka municipal district, Rozhdestvenskaya St. 37, apt. 101. Contact email: robot@oxteam.me.

4. What Personal Data Are Processed

The operator processes personal data that the user provides voluntarily when completing feedback forms or when corresponding with the operator, in particular: surname, first name; the name of the hotel or company; email address; telephone number; the content of the enquiry. When visiting the website, anonymised technical data may be collected automatically (IP address, information about the browser and device, cookie data and web analytics system data).

The operator does not process special categories of personal data (concerning racial or ethnic origin, political opinions, religious or other beliefs, health, intimate life) or biometric personal data.

5. Purposes of Processing Personal Data

Personal data are processed for the following purposes: handling users' enquiries and requests; feedback, preparation and submission of commercial proposals; informing about the product and the terms of its implementation; improving the operation of the website and the quality of service.

6. Legal Grounds for Processing

The legal grounds for processing are: the consent of the personal data subject to the processing of their personal data; agreements concluded with the operator; Federal Law No. 152-FZ and other regulatory legal acts in the field of personal data protection. Processing is carried out on the basis of the consent that the user gives when submitting a form on the website.

7. Procedure and Conditions of Processing

The processing of personal data is carried out with the consent of the subject to the processing of their personal data, in compliance with the principles and rules provided for by 152-FZ. The operator processes personal data both with and without the use of automation tools.

The operator does not disclose or transfer personal data to third parties, except in cases expressly provided for by the legislation of the Russian Federation, or where the consent of the personal data subject is present. Cross-border transfer of personal data is not carried out by the operator.

The conditions for storing data in the Roomy system are determined by the agreement with the hotel: data may be stored in a secure cloud in compliance with the requirements of 152-FZ or on the hotel's local server.

8. Storage Periods

Personal data are stored no longer than required by the purposes of their processing, or until the subject withdraws their consent to processing. Upon achievement of the processing purposes or upon withdrawal of consent, the personal data are subject to destruction or anonymisation within the time limits established by law.

9. Rights of the Personal Data Subject

The personal data subject has the right to: obtain information about the processing of their personal data; demand the rectification, blocking or destruction of personal data if they are incomplete, outdated, inaccurate, unlawfully obtained or not necessary for the stated purpose of processing; withdraw consent to the processing of personal data; appeal against the actions or inaction of the operator to the authorised body for the protection of the rights of personal data subjects (Roskomnadzor) or in court.

To exercise their rights, as well as to withdraw consent, the subject may send a request to the address robot@oxteam.me.

10. Cookies and Web Analytics

The website may use cookies and web analytics systems to ensure the operation of the website and to analyse anonymised visit statistics. The user may restrict or prohibit the use of cookies in their browser settings; this may affect the operation of certain functions of the website.

11. Measures for the Protection of Personal Data

The operator takes the necessary legal, organisational and technical measures to protect personal data against unlawful or accidental access, destruction, modification, blocking, copying, dissemination, as well as against other unlawful actions, including: identifying security threats, applying information protection tools, restricting access to personal data and monitoring the measures taken.

12. Amendments to the Policy

The operator has the right to make amendments to this Policy. The new version takes effect from the moment of its placement on the website, unless otherwise provided by the new version. The current version is always available on this page.

13. Contacts

For all matters relating to the processing of personal data, please contact the operator at the address robot@oxteam.me.

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