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Personal Data Processing Policy

Revision of December 30, 2025

AURORA FASHION GROUP Limited Liability Company

TAX ID 7813464410 KPP 781301001

OGRN 1107847035922

Legal address: 197198, St. Petersburg, Bolshaya Morskaya str., 14, letter A, room 12-N, part 46

General provisions

The policy of AURORA FASHION GROUP Limited Liability Company (hereinafter referred to as the Company) regarding the processing of personal data (hereinafter referred to as the Policy) regulates relations related to the processing of personal data carried out by the Company, including on the Internet information and telecommunications network. The purpose of this Policy is to ensure the protection of human and civil rights and freedoms when processing personal data, including the protection of the rights to privacy, personal and family secrets.

For the purposes of this Policy, the concepts established by Federal Law No. 152-FZ of 27.07.2006 “On Personal Data” are used. The legal bases for the processing of personal data by the Company are the Civil Code of the Russian Federation, the Law of the Russian Federation dated 07.02.1992 No. 2300-1 “On Consumer Rights Protection”, Federal Law No. 152-FZ dated 27.07.2006 “On Personal Data”, other regulatory legal acts of the Russian Federation, this Policy, as well as contracts concluded by the Company with subjects of personal data.

The processing of personal data in the Company is carried out in compliance with the principles and rules provided for by the legislation of the Russian Federation in the field of personal data.

Purposes of personal data processing

Personal data is processed by the Company for the following purposes: conclusion and execution of contracts for the retail sale of goods remotely, including making orders, delivering goods, making payments and refunding funds; providing information about goods, promotions and special offers (subject to the consent of the personal data subject); processing customer requests and requests; ensuring the functioning of the website and the user’s personal account; improvement of the quality of service and analysis of customer preferences; prevention and investigation of illegal actions; compliance with the requirements of the legislation of the Russian Federation.

Scope and categories of personal data processed

The Company processes the following categories of personal data of clients and users
of the website: last name, first name, patronymic;
Contact phone number;
email address;
delivery address;
date of birth (if voluntarily provided);
the history of orders and product views;
technical data (IP address, browser and device information, cookies).

The categories of personal data subjects are clients, potential clients, and users of the Company’s website.

Procedure and conditions of personal data processing

Personal data processing includes collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (provision, access), depersonalization, blocking, deletion and destruction of personal data.

The processing is carried out both with and without automation tools.

The Company transfers personal data to third parties only to the extent necessary to achieve these goals, including courier services, payment systems, and technical support contractors (subject to confidentiality). There is no cross-border transfer of personal data.

The terms of storage of personal data are determined in accordance with the requirements of the legislation of the Russian Federation. Upon achieving the processing objectives or upon withdrawal of consent, personal data is destroyed or depersonalized.

The Company takes the necessary organizational and technical measures to protect personal data from unauthorized access, destruction, modification, blocking, copying and distribution.

Rights of personal data subjects

Personal data subjects have the right to receive information about the processing of their personal data, to clarify, block or destroy the data, as well as to revoke consent to the processing.

Requests are sent to: Info@aurora.luxe or by mail to the Company’s legal address.

Using the website means that the user agrees to this Policy.

The Company has the right to make changes to the Policy with the publication of a new version on the website.

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