Privacy Policy

Last updated: December 12, 2026

1. General Provisions

This personal data processing policy is drafted in accordance with the requirements of international data protection regulations and determines the procedure for processing personal data and the measures to ensure the security of personal data undertaken by SurepassAI (hereinafter – the Operator).

1.1. The Operator sets as its most important goal and condition for its activities the observance of human and civil rights and freedoms when processing their personal data, including the protection of the rights to privacy, personal and family secrets.

1.2. This Operator's policy regarding the processing of personal data (hereinafter – the Policy) applies to all information that the Operator can obtain about visitors to the website https://surepass.tech.

2. Key Concepts 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 cessation of personal data processing (except when processing is necessary to clarify 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://surepass.tech.
2.4. Personal data information system – a set of personal data contained in databases, and the information technologies and technical means ensuring their processing.
2.5. Anonymization of personal data – actions as a result of which it is impossible to determine, without the use of additional information, the belonging of personal data to a specific User or other subject of personal data.
2.6. Processing of personal data – any action (operation) or a set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, destruction of personal data.
2.7. Operator – a state body, municipal body, legal or natural person, independently or jointly with other persons organizing and/or carrying out the processing of personal data, as well as determining the purposes of processing personal data, the composition of personal data to be processed, actions (operations) performed with personal data.
2.8. Personal data – any information relating directly or indirectly to a specific or identifiable User of the website https://surepass.tech.
2.9. User – any visitor to the website https://surepass.tech.
2.10. Provision of personal data – actions aimed at disclosing personal data to a certain person or a certain circle of persons.
2.11. Dissemination of personal data – any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or at familiarizing an unlimited circle of persons with personal data, including the publication of personal data in the media, placement in information and telecommunication networks, or providing access to personal data in any other way.
2.12. Cross-border transfer of personal data – transfer of personal data to the territory of a foreign state to an authority of a foreign state, a foreign individual, or a foreign legal entity.
2.13. Destruction of personal data – any actions as a result of which personal data are irretrievably destroyed with the impossibility of further restoring the content of personal data in the personal data information system and/or material carriers of personal data are destroyed.

3. Basic Rights and Obligations of the Operator

3.1. The Operator has the right:

— to receive reliable information and/or documents containing personal data from the subject of personal data;
— in case the subject of personal data withdraws consent to the processing of personal data, as well as sends a request to stop processing personal data, the Operator has the right to continue processing personal data without the consent of the subject of personal data if there are grounds specified in data protection laws;
— to independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations provided for by data protection laws and regulations adopted in accordance with them, unless otherwise provided by law.

3.2. The Operator is obliged:

— to provide the subject of personal data, upon their request, with information regarding the processing of their personal data;
— to organize the processing of personal data in the manner established by current legislation;
— to respond to requests and inquiries from subjects of personal data and their legal representatives in accordance with the requirements of data protection laws;
— to report the necessary information to the authorized body for the protection of the rights of subjects of personal data upon request of this body within a reasonable time;
— to publish or otherwise ensure unrestricted access to this Policy regarding the processing of personal data;
— to take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other illegal actions in relation to personal data;
— to stop the transfer (distribution, provision, access) of personal data, stop processing and destroy personal data in the manner and cases provided for by data protection laws;
— to fulfill other obligations stipulated by data protection laws.

4. Basic Rights and Obligations of Personal Data Subjects

4.1. Personal data subjects have the right:

— to receive information regarding the processing of their personal data, except in cases provided for by federal laws. The information is provided to the subject of personal data by the Operator in an accessible form, and it should not contain personal data relating to other subjects of personal data, except when there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it is established by data protection laws;
— to require the operator to clarify their personal data, block or destroy them if the personal data are incomplete, outdated, inaccurate, illegally obtained, or are not necessary for the stated purpose of processing, as well as to take measures provided by law to protect their rights;
— to demand prior consent for the processing of personal data for the purpose of promoting goods, works, and services on the market;
— to withdraw consent to the processing of personal data, as well as to send a request to stop processing personal data;
— to appeal to the authorized body for the protection of the rights of subjects of personal data or in court against illegal actions or inaction of the Operator when processing their personal data;
— to exercise other rights provided for by legislation.

4.2. Personal data subjects are obliged:

— to provide the Operator with reliable data about themselves;
— to inform the Operator about the clarification (update, change) of their personal data.

4.3. Persons who have provided the Operator with false information about themselves, or information about another subject of personal data without the latter's consent, are liable in accordance with the legislation.

5. Principles of Personal Data Processing

5.1. The processing of personal data is carried out on a legal and fair basis.
5.2. The processing of personal data is limited to the achievement of specific, predetermined, and legitimate purposes. Processing of personal data incompatible with the purposes of collecting personal data is not allowed.
5.3. It is not allowed to combine databases containing personal data, the processing of which is carried out for purposes incompatible with each other.
5.4. Only personal data that meet the purposes of their processing are subject to processing.
5.5. The content and volume of the processed personal data correspond to the stated purposes of processing. The redundancy of processed personal data in relation to the stated purposes of their processing is not allowed.
5.6. When processing personal data, the accuracy of personal data, their sufficiency, and, where necessary, their relevance to the purposes of processing personal data are ensured. The Operator takes the necessary measures and/or ensures their adoption to delete or clarify incomplete or inaccurate data.
5.7. The storage of personal data is carried out in a form that allows identifying the subject of personal data, no longer than the purposes of processing personal data require, unless the storage period for personal data is established by federal law, a contract to which the subject of personal data is a party, beneficiary, or guarantor. The processed personal data are destroyed or anonymized upon achievement of the processing purposes or in case of loss of the need to achieve these purposes, unless otherwise provided by federal law.

6. Purposes of Personal Data Processing

Purpose of processing: providing the User with access to the services, information and/or materials contained on the website

Personal data: email address

Legal basis: constituent documents of the Operator

Types of personal data processing: Collection, recording, systematization, accumulation, storage, destruction, and anonymization of personal data; Sending informational emails to the email address

7. Conditions for Personal Data Processing

7.1. The processing of personal data is carried out with the consent of the subject of personal data to the processing of their personal data.
7.2. The processing of personal data is necessary to achieve the purposes provided for by an international treaty or law, for the performance of the functions, powers, and duties imposed on the operator by legislation.
7.3. The processing of personal data is necessary for the administration of justice, the execution of a judicial act, an act of another body or official, subject to execution in accordance with the legislation on enforcement proceedings.
7.4. The processing of personal data is necessary for the performance of a contract to which the subject of personal data is a party or beneficiary or guarantor, as well as for the conclusion of a contract on the initiative of the subject of personal data or a contract under which the subject of personal data will be the beneficiary or guarantor.
7.5. The 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 goals, provided that this does not violate the rights and freedoms of the subject of personal data.
7.6. The processing of personal data is carried out, access to which is provided by the subject of personal data to an unlimited circle of persons or at their request (hereinafter – publicly available personal data).
7.7. The processing of personal data is subject to publication or mandatory disclosure in accordance with federal law.

8. Procedure for Collecting, Storing, Transferring and Other Types of Personal Data Processing

The security of personal data processed by the Operator is ensured by implementing legal, organizational, and technical measures necessary to fully comply with the requirements of current legislation in the field of personal data protection.

8.1. The Operator ensures the safety of personal data and takes all possible measures to exclude access to personal data by unauthorized persons.

8.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to the execution of current legislation or if the subject of personal data has given consent to the Operator to transfer data to a third party to fulfill obligations under a civil law contract.

8.3. In case of inaccuracies in personal data, the User can update them independently by sending a notification to the Operator's email address support@surepass.tech with the subject "Personal data update".

8.4. The period for processing personal data is determined by the achievement of the purposes for which the personal data were collected, unless a different period is provided for by the contract or current legislation. The user can at any time withdraw their consent to the processing of personal data by sending a notification to the Operator via email to the Operator's email address support@surepass.tech with the subject "Withdrawal of consent to the processing of personal data".

8.5. All information collected by third-party services, including payment systems, means of communication, and other service providers, is stored and processed by these persons (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data is obliged to familiarize themselves with these documents. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this paragraph.

8.6. The prohibitions established by the subject of personal data on the transfer (except for providing access), as well as on the processing or processing conditions (except for obtaining access) of personal data permitted for distribution, do not apply in cases of processing personal data in the state, public, and other public interests determined by legislation.

8.7. The Operator ensures the confidentiality of personal data when processing them.

8.8. The Operator stores personal data in a form that allows identifying the subject of personal data, no longer than the purposes of processing personal data require, unless the storage period for personal data is established by federal law, a contract to which the subject of personal data is a party, beneficiary, or guarantor.

8.9. The condition for terminating the processing of personal data may be the achievement of the purposes of processing personal data, the expiration of the consent of the subject of personal data, the withdrawal of consent by the subject of personal data or a request to stop processing personal data, as well as the detection of illegal processing of personal data.

9. List of Actions Performed by the Operator with the Received Personal Data

9.1. The Operator carries out the collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.

9.2. The Operator carries out automated processing of personal data with the receipt and/or transfer of the information received via information and telecommunication networks or without it.

10. Cross-border Transfer of Personal Data

10.1. Before starting the cross-border transfer of personal data, the Operator is obliged to notify the authorized body for the protection of the rights of subjects of personal data of its intention to carry out the cross-border transfer of personal data (such notification is sent separately from the notification of the intention to process personal data).

10.2. Before submitting the above notification, the Operator is obliged to obtain relevant information from the authorities of the foreign state, foreign individuals, foreign legal entities to whom the cross-border transfer of personal data is planned.

11. Confidentiality of Personal Data

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

12. Final Provisions

12.1. The User can receive any clarifications on issues of interest concerning the processing of their personal data by contacting the Operator via email at support@surepass.tech.

12.2. Any changes to the personal data processing policy by the Operator will be reflected in this document. The policy is valid indefinitely until it is replaced by a new version.

12.3. The current version of the Policy is freely available on the Internet at https://surepass.tech/privacy-policy.