Privacy Policy

Version 2026-09 (September 2026).

The Ten2Ten Privacy Policy (hereinafter, the “Policy”) contains information about how Ten2Ten processes and protects personal data.

1. General provisions of the policy

1.1. This Policy is an integral part of the Terms of Use, as well as of other agreements concluded with the User in the course of using the Ten2Ten Sites, where their terms expressly provide for this.

1.2. This Policy applies to all personal data that Ten2Ten may receive from the User during the use of the Ten2Ten Sites and mobile applications.

1.3. Ten2Ten does not control and is not responsible for third-party websites to which the User may navigate via links available on the Ten2Ten sites. Third-party sites may have their own privacy policy, and other personal data may be collected from or requested of the User there.

For specific services, Ten2Ten may publish additional terms that supplement this Policy.

2. Categories and purposes of personal data processing

2.1. The primary purpose of personal data processing is to perform the obligations to the User provided for by the Ten2Ten Terms of Use and other agreements on the use of the services of the Ten2Ten Sites and mobile applications. More detailed information about the purposes of personal data processing and the categories of processed data is set out in the Ten2Ten Terms of Use and the relevant agreements with the User.

2.2. By using the Site, mobile applications, and individual Ten2Ten Services (hereinafter collectively, the Services), the personal data subject (an individual or a representative of a legal entity) thereby freely, by their own will and in their own interest, provides their personal data to Ten2Ten for processing.

2.3. Personal data processing means the actions or set of actions provided for by Federal Law No. 152-FZ of 27 July 2006 “On Personal Data” performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, updating (renewal, alteration), extraction, use, transfer (distribution, provision, access), removal, and destruction of personal data.

2.4. Processing of the personal data of a User who is an individual may be carried out for purposes including:

2.4.1. Registration and subsequent authorization of the User (including through additional authorization functions via external services or data exchange with them, for example, Sber ID, T ID, VK ID, mobile operator services), provision of services to the User, and enabling the User to make contact regarding the listings submitted. To achieve this purpose, the following are processed: full name, User identifier, email address, phone number, place of residence address, registration address, date of birth, place of birth, identity document details (passport data), User’s photograph, sex, INN, and information about a concluded contract for mobile radiotelephone communication services.

Personal data is processed using automation tools. Personal data is processed for the term of the Terms of Use and/or the Ten2Ten site usage rules and until the expiry of the applicable retention periods determined in accordance with the current legislation of the Russian Federation. Personal data is destroyed upon achievement of the purposes of its processing or upon other lawful grounds by deleting the information.

2.4.1.1. Registration and subsequent authorization of the User (including through additional authorization functions via external services or data exchange with them, for example, Sber ID, T ID, VK ID, mobile operator services), provision of services to the User, and enabling the User to make contact and exchange numbers for the purposes of analyzing and selecting real estate properties solely for personal and family needs unrelated to carrying out commercial activity to promote information, consulting, or other services or to distribute any advertising information. To achieve this purpose, the following are processed: full name, User identifier, email address, phone number, place of residence address, registration address, date of birth, place of birth, identity document details (passport data), User’s photograph, user id (Telegram), sex, INN, and information about a concluded contract for mobile radiotelephone communication services.

2.4.2. Provision of customer support. To achieve this purpose, the following are processed: full name, email address, mobile phone number, audio recordings of telephone conversations concerning the listings submitted, User identifier, and purchases.

2.4.3. Quality control of the listings presented on the ten2ten.ru website. To achieve this purpose, the following are processed: full name, phone number, audio recordings of telephone conversations concerning the listings submitted, passport data, date and place of birth, registration address, information about family composition, INN, photograph, cadastral number of the real estate property, and the surname, first name, and patronymic of the property owner.

2.4.4. Processing of requests received from government authorities. To achieve this purpose, the following are processed: full name, phone number, email address, and IP.

2.4.5. Organization of targeted advertising and mailings, as well as other means of promoting the goods, works, and services of Ten2Ten and/or Ten2Ten’s partners, including by making direct contact through means of communication. To achieve this purpose, the following are processed: full name, email address, phone number, and User identifier.

2.4.6. Providing access to the Site’s Services, use of their functional capabilities, and maintaining their security. Depending on the Service used, the following are processed: full name (including former names, if previously changed), email address, phone number, User identifier, phone book contact details (when contact details are created in the Site’s personal account), citizenship, sex, identity document details, date of birth, place of birth, registration/residence address (including city), marital status, employment information (including type of employment, position, length of service), taxpayer identification number, number of the mandatory pension insurance certificate, information about the property status and real estate properties belonging to the User (including from documents provided by the User confirming ownership or the grounds for acquiring the real estate), information about financial status, income, and credit burden, payment data, information about the location of the user’s device, photo, audio recording of a telephone call, video image (except for biometric personal data), information about actions on the Site (including attendance (time of day, day of the week, month, time at which actions were performed), views, number and frequency of visits, time spent on the site), as well as the ID/type of the operating system of the device used by the User and IP address, including through the use of metric software.

2.4.7. Identifying reviews of the services rendered and assessing the work of employees in order to obtain information about the performance of the contract concluded with the User for the use of the Site’s Services. To achieve this purpose, the following are processed: User identifier, email address, mobile phone number, and the User’s surname and first name.

2.4.8. Conducting research into the needs, motivation, and preferences of Users, their actions, and their use of the functions of the Site’s Services in order to improve the quality and functionality of the Site’s Services and to prevent fraudulent actions. To achieve this purpose, the following are processed: User identifier, phone number, email address, surname, first name, patronymic, sex, age, region, city of residence, occupation, information about the listings presented on the Site, segment (user category), and information about actions on the Company’s website/mobile application (about the User’s views, including taking into account their preferences in searching for real estate, for example, the city/region of the search, term, method of financing the purchase, category and class of real estate, promotional offers, price range, and other search filters).

2.4.9. Organizing communication between the User and Ten2Ten’s partners (developers, real estate agencies, etc.). To achieve this purpose, the following are processed: surname, first name, patronymic, User identifier, email address, and mobile phone number.

2.4.10. Conducting analytics of the use of the Site’s Services, including analysis of Users’ actions on the Site, in order to adapt the Services to the needs of Users. To achieve this purpose, the following are processed: User identifier, phone number, and information about the User’s actions on the Site.

2.4.11. Enabling participation in consultations, webinars, broadcasts, and other similar events held by real estate professionals on matters of searching for and selecting real estate, and collecting feedback following such events. To achieve this purpose, the following are processed: full name, User identifier, email address, phone number, information about participation in events (including topic, date, time of the event), and a photo and/or video image not used for identification purposes.

2.4.12. Ensuring Users’ compliance with the Terms of Use and achieving Ten2Ten’s other legitimate interests in connection with the use of the Site’s Services (storing information about Users during the limitation periods, information about facts of violation of the Terms of Use, etc.). To achieve this purpose, the following are processed: full name, User identifier, email address, and mobile phone number.

2.5. Processing of the personal data of the representatives of a User that is a legal entity may be carried out for purposes including:

2.5.1. Recording partner representatives for subsequent communication and conducting sales department analytics. To achieve this purpose, the following are processed: full name, User identifier, email address, phone number, purchases, and other metrics.

2.5.2. Provision of customer support. To achieve this purpose, the following are processed: full name, User identifier, audio recordings of telephone conversations concerning the listings submitted, place of work, email address, and phone number.

2.5.3. Quality control of the listings presented on the ten2ten.ru Site. To achieve this purpose, the following are processed: full name, place of work and office address, email address, phone number, audio recordings of telephone conversations concerning the listings submitted, and photograph.

2.5.4. Providing access to the Site’s Services, use of their functional capabilities, and maintaining their security. Depending on the Service used, the following are processed: full name, email address, phone number, User identifier, phone book contact details (when contact details are created in the Site’s personal account), information about the location of the user’s device, photo, audio recording of a telephone call, video image (except for biometric personal data), information about actions on the Site (including attendance (time of day, day of the week, month, time at which actions were performed), views, number and frequency of visits, time spent on the site), as well as the ID/type of the operating system of the device used by the User and IP address.

2.5.5. Conducting research to understand the needs, motivation, and preferences of Users, their actions, and their use of the functions of the Site’s Services in order to improve the quality and functionality of the Site’s Services. To achieve this purpose, the following are processed: User identifier, phone number, email address, surname, first name, patronymic, sex, age, region, city of residence, occupation, information about the listings presented on the Site, and the name of the legal entity (agency, realtor, realtor’s partner).

2.5.6. Identifying reviews of the services rendered and assessing the work of employees in order to obtain information about the performance of the contract concluded with the User for the use of the Site’s Services. To achieve this purpose, the following are processed: User identifier, email address, mobile phone number, and the User’s surname and first name.

2.5.7. Organizing communication between the User and Ten2Ten’s partners (developers, real estate agencies, etc.). To achieve this purpose, the following are processed: full name, User identifier, email address, mobile phone number, place of work, and position.

2.5.8. Enabling the holding of consultations, webinars, broadcasts, and other similar events by real estate professionals on matters of searching for and selecting real estate, and collecting feedback following such events. To achieve this purpose, the following are processed: full name, User identifier, email address, phone number, place of work, position, profession, information about participation in events (including topic, date, time of the event), and a photo and/or video image not used for identification purposes.

2.5.9. Organizing client events and meetings. To achieve this purpose, the following are processed: full name, User identifier, email address, mobile phone number, place of work, position, and a photo/video image not used for identification purposes (as part of recording online meetings).

2.5.10. Ensuring Users’ compliance with the Terms of Use and achieving Ten2Ten’s other legitimate interests in connection with the use of the Site’s Services (storing information about Users during the limitation periods, information about facts of violation of the Terms of Use, etc.). To achieve this purpose, the following are processed: full name, User identifier, email address, and mobile phone number.

2.6. To achieve the purposes defined in this Policy, Ten2Ten may transfer the User’s personal data to third parties. The transfer of personal data to third parties is carried out to the extent necessary for the purposes of its processing. The third parties to whom Ten2Ten may transfer the User’s personal data include: real estate agencies (when using the realtor search service), communication service providers, providers of services for mailing informational and advertising materials (if the User subscribes to such mailings), partners providing Ten2Ten with services for the use of information and intermediary services (including when transferring applications to credit institutions at the User’s initiative), as well as services for verifying the reliability of a transaction carried out by the User, Ten2Ten’s affiliated persons, persons acting on Ten2Ten’s behalf, and other third parties to whom the transfer of data is necessary to perform Ten2Ten’s obligations to the User in accordance with this Policy. The transfer of personal data to third parties is carried out under contracts concluded with third parties that include obligations to maintain the confidentiality of the data received. The transfer of personal data may also be carried out in the territory of foreign states.

2.7. When publishing listings, reviews, comments, or questions on the Site, as well as when posting other information in their profile, the personal data contained in such information becomes available to an indefinite range of persons. The User is notified that they disclose such data independently without providing Ten2Ten, as the personal data operator, with separate consent. Ten2Ten processes such personal data for the purpose of performing the contract (for the use of the Site’s functional capabilities) with the User, concluded at the User’s initiative.

2.8. Processing of the User’s personal data is carried out during the terms provided for in the Terms of Use, as well as in other agreements concluded with the User in the course of using the Ten2Ten Sites and/or mobile application. To terminate the processing of personal data by Ten2Ten, the User must perform the actions provided for by the documents referred to above; at the same time, the User’s personal data may continue to be processed thereafter for the period necessary to perform the obligations imposed on Ten2Ten in accordance with the legislation of the Russian Federation. In such a case, personal data processing will be carried out to the extent necessary to comply with the said obligations.

3. Principles and methods of personal data processing

3.1. When processing personal data, Ten2Ten is guided by the following principles:

ensuring the lawfulness of the purposes and methods of personal data processing;
conformity of the purposes of personal data processing with the purposes determined and stated in advance at the time of collecting personal data;
conformity of the volume and nature of the processed personal data, as well as the methods of personal data processing, with the purposes of personal data processing;
the absence of personal data excessive in relation to the purposes stated at the time of collection;
ensuring the accuracy of the processed personal data;
the use of separate databases for incompatible purposes of personal data processing.

3.2. Ten2Ten processes personal data both with and without the use of automation tools.

4. Rules of personal data processing

4.1. Personal data is obtained directly from Users in the course of using the Ten2Ten Sites and mobile applications, except in the cases provided for by the Policy, as well as in other agreements concluded with the User in the course of using the Ten2Ten Sites, where their terms expressly provide for this.

4.2. The collection of personal data is carried out using the Ten2Ten Sites located in the territory of the Russian Federation.

4.3. In the cases provided for by Ten2Ten’s personal data processing procedures, personal data may be transferred to third parties. The transfer of personal data to third parties may be carried out with the User’s consent, as well as in the cases provided for by the legislation of the Russian Federation and on the basis of the requirements of federal laws. More detailed information about the third parties to whom personal data may be transferred, as well as about the conditions under which personal data is transferred to third parties, is set out in the Terms of Use, offer agreements, and other agreements that the User accepts when applying for services on the Ten2Ten Sites.

4.4. Personal data processing is carried out during the term of the Terms of Use, another agreement, or agreement on the use of the services of the Ten2Ten Sites and mobile applications, and for the periods established by the legislation of the Russian Federation.

5. Ensuring the security of personal data

5.1. Ten2Ten takes all necessary protective measures, including those provided for by the legislation of the Russian Federation, aimed at ensuring the confidentiality and security of personal data. The personal data protection measures applied by Ten2Ten include, among others:

a person responsible for ensuring the security of personal data at Ten2Ten has been appointed;
current threats to the security of personal data have been identified;
a set of protective measures has been developed and implemented to neutralize current security threats;
rules for ensuring the security of personal data during its processing have been defined;
periodic monitoring and assessment of the effectiveness of the personal data protection measures taken is carried out.

6. Users’ rights in respect of their personal data

6.1. In accordance with Federal Law No. 152-FZ of 27 July 2006 “On Personal Data”, Users have the right to:

6.1.1. request information about their personal data processed by Ten2Ten, including:

confirmation of the fact of personal data processing;
the legal grounds and purposes of personal data processing;
the methods of personal data processing applied;
the full name and location of Ten2Ten, information about third parties who have access to personal data or to whom personal data may be disclosed on the basis of a contract with Ten2Ten or on the basis of federal law;
the categories of processed personal data and the source from which they were obtained;
the periods of personal data processing, including the periods of their storage;
the procedure for exercising the rights of the personal data subject provided for by law;
information about any cross-border transfer of data carried out or intended;
the name and address of the person processing personal data on Ten2Ten’s behalf, if the processing is or will be entrusted to such a person;
other information provided for by law;

6.1.2. demand to be acquainted with the processed personal data;

6.1.3. demand the clarification of personal data if it is incomplete, outdated, or inaccurate;

6.1.4. demand the blocking of personal data if it is incomplete, outdated, or inaccurate, or if its processing by Ten2Ten is unlawful;

6.1.5. demand the destruction of personal data if it was obtained unlawfully or is not necessary for the stated purpose of processing, or in the event of withdrawal of consent to the processing of personal data;

6.1.6. demand that Ten2Ten notify all persons to whom incorrect or incomplete personal data was previously communicated of all exclusions, corrections, or additions made to it;

6.1.7. appeal, to the authorized body for the protection of the rights of personal data subjects or in court, against unlawful actions or inaction of Ten2Ten in the processing and protection of their personal data.

7. Clarification and destruction of personal data

7.1. Clarification of personal data is carried out by the User independently using the functions of the Sites and mobile applications.

7.2. Personal data processed by Ten2Ten is subject to destruction in the following cases:

upon achievement of the purposes of its processing or in the event that the need to achieve them is lost, within a period not exceeding thirty days from the moment the purpose of personal data processing is achieved, unless otherwise provided by a contract to which the personal data subject is a party, beneficiary, or guarantor, or by another agreement between Ten2Ten and the personal data subject;
in the event that unlawful processing of personal data by Ten2Ten is identified, within a period not exceeding ten business days from the moment the unlawful processing of personal data is identified;
in the event that the personal data subject withdraws consent to the processing of their personal data, if the retention of the personal data is no longer required for the purposes of personal data processing, within a period not exceeding thirty days from the date of receipt of the said withdrawal, unless otherwise provided by a contract to which the personal data subject is a party, beneficiary, or guarantor, or by another agreement between Ten2Ten and the personal data subject;
in the event of the expiry of the personal data retention period, determined in accordance with the legislation of the Russian Federation and Ten2Ten’s organizational and administrative documents;
in the event of an order from the authorized body for the protection of the rights of personal data subjects, the Prosecutor’s Office of Russia, or a court decision.

7.3. Consent to the processing of personal data may be withdrawn by the User at any time. To exercise the right of withdrawal, the User must send the corresponding request to support@ten2ten.ru.

7.4. The withdrawal of the User’s consent to the processing of personal data cannot serve as grounds for the termination of processing where Ten2Ten has the grounds provided for by clauses 2, 7, and 10 of part 1 of article 6 of Federal Law No. 152-FZ of 27 July 2006 “On Personal Data”.

8. Contact information

For matters concerning the processing of personal data: Ten2Ten LLC (ООО «Тен2Тен»), INN 9715532264, OGRN 1267700290989, 127015, г. Москва, вн.тер.г. муниципальный округ Бутырский, ул. Новодмитровская, д. 2Б, email support@ten2ten.ru.