Personal Data Processing Policy

Version of 1 August 2026

Scautex service (website: https://scautex.com)

1. General provisions

1.1. This Personal Data Processing Policy (hereinafter — the “Policy”) has been drawn up in accordance with Federal Law No. 152-FZ of 27 July 2006 “On Personal Data” (hereinafter — “152-FZ”) and sets out the procedure for processing personal data and the measures taken by the Operator to ensure their security.

1.2. Personal data Operator:

Individual Entrepreneur Vladimir Mikhailovich Smetannikov

OGRNIP: 326300000036325

INN: 131502783359

Address: 414057, Russia, Astrakhan Region, Astrakhan, Kosmonavtov St., 2, bldg. 1, apt. 30

Email address for enquiries: hello@scautex.com

(hereinafter — the “Operator”).

1.3. The Operator regards observance of human and civil rights and freedoms in the processing of personal data as its paramount objective, including protection of the rights to privacy and to personal and family confidentiality.

1.4. This Policy applies to all information that the Operator may obtain about visitors and users of the website https://scautex.com (hereinafter — the “Website”) and its associated Telegram bot.

2. Key definitions

— Personal data — any information relating directly or indirectly to an identified or identifiable individual (the personal data subject).

— Processing of personal data — any operation with personal data: collection, recording, systematisation, accumulation, storage, updating, use, transfer, anonymisation, blocking, deletion, destruction.

— Operator — the person organising and carrying out the processing of personal data (see clause 1.2).

— User — a visitor of the Website. The service has two roles: Talent (candidate) and Company (employer).

— Website — the set of pages at https://scautex.com and the service's Telegram bot.

3. Categories of subjects and personal data processed

The Operator processes the following data:

3.1. Talent users (candidates):

— surname and first name (or display name);

— email address;

— Telegram identifier/account, LinkedIn profile link (contact details);

— city and country;

— information about professional experience: specialisation, seniority, platforms, verticals, years of experience, budgets managed;

— CV (the uploaded file and its contents).

3.2. Company users (employers):

— company name;

— name and role of the contact person;

— email address and Telegram identifier of the contact person;

— information about payment for services (the fact and status of a payment).

3.3. Data collected automatically from all users:

— technical data: IP address, browser type and version, data on pages visited, date and time of access;

— cookies and similar technologies (see section 9).

3.4. Payment data. Payment for services is made through the payment provider YooKassa (JSC “TBank” / LLC “YuMani”). Full bank card details are not passed to the Operator and are not stored by the Operator — they are processed by the payment provider. The Operator receives only the payment identifier and status.

3.5. The Operator does not process special categories of personal data (health, racial or ethnic origin, political or religious views) or biometric personal data.

4. Purposes of processing personal data

The Operator processes personal data for the following purposes:

— registration and authentication of the user (including sign-in by a one-time email code and linking Telegram);

— providing access to the service's features: creating and moderating a Talent profile, publishing vacancies by Companies, matching and disclosing Talent contact details at Companies' request;

— settlements and payment for the service;

— sending service notifications (about profile status, applications, contact disclosure, payments);

— maintaining the operability and security of the service and preventing fraud;

— compliance with the requirements of the laws of the Russian Federation;

— with separate consent — sending informational and advertising messages.

5. Legal grounds for processing

The Operator processes personal data on the following grounds:

— consent of the personal data subject to the processing of their personal data (Article 6(1)(1) of 152-FZ);

— conclusion and performance of an agreement (offer) to which the subject is a party (Article 6(1)(5));

— Federal Law No. 152-FZ and other regulations in the field of personal data protection.

6. Procedure and conditions of processing

6.1. Personal data are processed with the subject's consent, given upon registration on the Website by ticking the box confirming consent and acknowledgement of this Policy.

6.2. Personal data are processed both by automated means and without them.

6.3. Personal data are stored in databases located in the territory of the Russian Federation in accordance with Article 18(5) of 152-FZ. Collection, recording, systematisation, accumulation and storage of the personal data of citizens of the Russian Federation are carried out using databases located in the territory of the Russian Federation.

6.4. Personal data are stored for the term of the user's account and until consent is withdrawn, unless another term is established by law. Thereafter, personal data are deleted or anonymised.

6.5. Transfer to third parties. The Operator transfers personal data to third parties only to the extent necessary to render the services:

— to the payment provider YooKassa — for settlements;

— to the hosting provider — for hosting and operating the service;

— upon a lawful request from authorised state authorities.

Personal data are not transferred or sold to any other third parties.

6.6. The Operator does not carry out cross-border transfer of personal data. (Should this change, this section will be supplemented.)

7. Rights of the personal data subject

The subject has the right to:

— obtain information concerning the processing of their personal data;

— demand that personal data be updated, blocked or destroyed if they are incomplete, outdated, inaccurate or unlawfully obtained;

— withdraw consent to the processing of personal data at any time;

— appeal against the Operator's actions to Roskomnadzor or in court.

To exercise these rights, the subject sends an enquiry to: hello@scautex.com. The Operator considers the enquiry within the period established by law.

8. Personal data protection measures

The Operator takes legal, organisational and technical measures to protect personal data against unlawful access, destruction, alteration, blocking, copying and distribution, including:

— encryption of the data transmission channel (HTTPS/TLS);

— separation of access rights to data;

— storage of passwords and one-time codes as hashes;

— Talents' contact details are hidden and disclosed to a Company only after the corresponding operation in the service;

— regular backups.

9. Cookies and analytics

9.1. The Website uses cookies to operate authentication, store preferences and analyse traffic. The user may disable cookies in their browser settings, although this may limit how the Website works.

9.2. Yandex.Metrica (LLC “Yandex”) is used to analyse Website traffic. The service collects anonymised data about visits (pages viewed, referral source, device and browser type, IP address) using cookies. The service's data processing terms: https://yandex.ru/legal/confidential.

10. Final provisions

10.1. The Operator may amend this Policy. The current version is permanently available at https://scautex.com/privacy.

10.2. Continued use of the Website after the Policy has been amended constitutes agreement with the new version.

10.3. For any questions regarding personal data processing: hello@scautex.com.