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User Agreement

Revision of August 1, 2026

Table of Contents

This User Agreement (hereinafter the «Agreement») governs the use of the Sarafano digital platform (hereinafter the «Platform»), defines the rights and obligations of users, and establishes the terms of interaction between the platform operator, buyers, and sellers.

By using the Platform, creating an account, posting offers, purchasing services, or performing any other actions through the Platform interface, the user confirms full and unconditional acceptance of the terms of this Agreement.

1. General Provisions

1.1. Subject Matter of the Agreement

1.1.1. This Agreement sets out the terms of use of the Sarafano Platform, the procedures for user registration, posting of offers, conclusion of transactions, organization of settlements, processing of information, and interaction between participants.

1.1.2. The Sarafano Platform is a digital information system that provides the technical means for interaction between persons offering services and persons purchasing such services.

1.1.3. The Platform provides users with tools for:

1.1.4. This Agreement is a public document published in electronic form and available for review by all users of the Platform.

1.2. Key Definitions

For the purposes of this Agreement, the following definitions apply:

Operator — the person that ensures the functioning of the Sarafano Platform, provides the technical infrastructure, organizes user interaction, and performs agency functions with respect to settlements in the cases provided for by this Agreement.

Platform — the Sarafano hardware and software system that provides users with access to the functional capabilities of the service.

User — a natural person, individual entrepreneur, or legal entity registered on the Platform and using its functional capabilities.

Buyer — a user who purchases services through the Platform.

Seller (Contractor) — a User of the Platform who is a natural person registered as a payer of the tax on professional income (NPD), an individual entrepreneur, or a legal entity selling Services through the Platform, subject to compliance with the requirements of this Agreement, including the tax status requirements. A Seller may be an individual entrepreneur or a legal entity applying a special tax regime, or applying the general taxation system provided that such person has lawful grounds for exemption from the obligations to calculate and pay VAT on the operations carried out through the Platform. Use of the Platform as a Seller by persons who are actual VAT payers with respect to the sale of Services through the Platform is not permitted. The Seller posts offers to provide services and independently performs its obligations to Buyers.

Service — the result of the Seller’s activity offered for purchase through the Platform.

Listing — an offer to provide a service posted by the Seller, containing information about the terms of its provision.

Transaction — an agreement between the Buyer and the Seller concluded by means of the Platform’s functionality.

Agency Fee — the Operator’s remuneration for performing agency functions related to the organization of settlements and support of transactions.

PRO Package — a standalone paid digital service of the Operator for Sellers that provides extended capabilities of using the Platform for the period specified in the interface. The PRO Package is not an agency fee and is not part of any service purchased by a Buyer from a Seller.

1.3. Status of this Agreement

1.3.1. This User Agreement constitutes a public offer of the Operator addressed to an indefinite range of persons wishing to use the functional capabilities of the Sarafano platform on the terms set out in this Agreement.

1.3.2. Registration of an account, acceptance of the terms of the Agreement, posting of a listing, placing of an order, making of a payment, or use of the Platform’s functionality by the User is deemed full and unconditional acceptance of this offer.

1.3.3. From the moment of acceptance of this Agreement, a contractual relationship arises between the Operator and the User on the terms of this Agreement.

1.3.4. With respect to the relationship between the Buyer and the Seller, this Agreement defines the procedure for using the Platform and does not replace the service agreement, which is concluded directly between the Buyer and the Seller.

2. Legal Status of the Platform and Allocation of Roles

2.1. Role of the Operator

2.1.1. The Operator ensures the operation of the Platform and provides users with the technical means for interaction.

2.1.2. The Operator performs the following functions:

2.1.3. The Operator is not:

2.1.4. The above delineation does not apply to the Operator’s own paid services, including the PRO Package. When providing them, the Operator acts as the provider and is a party to the contract with the relevant User.

2.2. Role of the Seller

2.2.1. The Seller independently determines:

2.2.2. The Seller is responsible for:

2.2.3. By posting an offer on the Platform, the Seller confirms that it has the necessary rights and authority to provide the relevant service.

2.3. Role of the Buyer

2.3.1. The Buyer independently decides whether to purchase a service based on the information posted by the Seller.

2.3.2. The Buyer must:

2.3.3. The Buyer understands that it purchases services directly from the Seller, while the Operator provides the technical infrastructure and organizes the interaction.

3. User Registration and Account

3.1. Creating an Account

3.1.1. To use certain functions of the Platform, the user completes a registration procedure.

3.1.2. During registration, the user must provide accurate and up-to-date information.

3.1.3. The user is responsible for keeping the provided information up to date.

3.1.4. Creating an account constitutes acceptance of the terms of this Agreement.

3.2. User Requirements

3.2.1. The user confirms that they:

3.2.2. The user may not use the Platform:

3.3. Account Security

3.3.1. The user is solely responsible for safeguarding their account access credentials.

3.3.2. All actions performed through a user’s account are deemed to have been performed by that user unless proven otherwise.

3.3.3. The user must immediately notify the Operator upon discovering unauthorized access to their account.

3.4. Acceptance of this Agreement

3.4.1. The terms of this Agreement are accepted when the user performs any of the following actions:

3.4.2. The user confirms that they:

3.5. Tax Status and Mandatory Information of the Seller

3.5.1. Registration and use of the Platform’s functionality as a Seller is permitted only for persons who have no obligation to calculate and pay VAT on the sale of Services through the Platform. Participation as a Seller is permitted for individual entrepreneurs and legal entities applying the general taxation system, provided that such persons have an exemption, provided for by the legislation of the Russian Federation, from the obligations to calculate and pay VAT with respect to the operations carried out through the Platform.

3.5.2. A User who holds none of the statuses listed in clause 3.5.1 may not post Listings, accept orders, or receive payouts as a Seller. Such a User may use the other functions of the Platform available to them, including the Buyer functions.

3.5.3. Before posting their first Listing, the Seller must provide the Operator with: information about their tax status; taxpayer identification number (INN); the full name of the legal entity, the name of the individual entrepreneur, or the surname, first name, and patronymic of the self-employed person; a contact phone number; and any other information required by law for documenting settlements.

3.5.4. The information specified in clause 3.5.3 is used by the Operator to identify the Seller, document settlements, and indicate the Seller’s mandatory details in cash receipts in the cases provided for by the legislation of the Russian Federation.

3.5.5. The Seller guarantees the accuracy and currency of the information provided, including information about the taxation system applied, the existence of an exemption from the obligations of a VAT payer, and the absence of an obligation to calculate and pay VAT on sales made through the Platform. The Seller must notify the Operator immediately, and in any event before entering into the next Transaction, of any change in these circumstances, loss of the VAT exemption, arising of an obligation to calculate and pay VAT, transition to the general taxation system, or loss or termination of any other tax status indicated at registration.

3.5.6. The Operator may, when activating the Seller functions, during their use, and before transferring funds, verify the Seller’s tax status and the information provided by the Seller using the official information services of the Federal Tax Service, the Seller’s documents and representations, and other lawful sources. The Operator may request documents or information confirming the taxation system applied, the exemption from the obligations of a VAT payer, and the absence of an obligation to calculate and pay VAT on sales made through the Platform.

3.5.7. If the Seller’s mandatory tax status is not confirmed or is lost, if the Seller has become obliged to calculate and pay VAT on sales made through the Platform, or if the information provided by the Seller proves inaccurate, the Operator may, without prior notice, refuse to activate or may suspend the Seller functions, hide the Seller’s Listings, prohibit the conclusion of new Transactions and, to the extent permitted by the legislation of the Russian Federation, suspend payouts until the circumstances are clarified, previously arisen obligations are completed, and the violation is remedied. Such measures do not mean that the Operator assumes the Seller’s tax obligations.

3.5.8. Suspension of functions or payouts does not terminate the Seller’s previously arisen obligations to Buyers. Such obligations and the related settlements are completed in the manner provided for by this Agreement and the legislation of the Russian Federation.

3.5.9. Where the Seller holds and maintains one of the statuses listed in clause 3.5.1, the Operator does not act as a tax agent with respect to the Seller’s income, unless expressly required by mandatory provisions of the legislation of the Russian Federation. The Seller independently calculates and pays the applicable taxes and levies, complies with the terms of the chosen taxation system, monitors the existence or loss of the exemption from the obligations of a VAT payer, and files the required reports.

3.5.10. A natural person without individual entrepreneur status may register as a payer of the tax on professional income in the manner prescribed by law, including via the Federal Tax Service application «Moy Nalog».

4. Posting Offers and Content of Listings

4.1. General Provisions

4.1.1. The Seller is given the ability to post offers to provide services on the Platform by creating listings.

4.1.2. A listing is an informational offer by the Seller to potential Buyers and contains the terms of the proposed transaction.

4.1.3. By posting a listing, the Seller confirms that the information in it is accurate, up to date, and does not infringe the rights of third parties.

4.1.4. The Operator provides the technical tools for posting listings but is not the author of, and does not determine, the content of the information posted by Sellers.

4.2. Requirements for the Content of Listings

4.2.1. A listing must contain the information necessary to understand the terms on which the service is provided, including:

4.2.2. The Seller must present information in a way that does not mislead Buyers.

4.2.3. It is prohibited to post listings that:

4.3. Responsibility for Listings

4.3.1. The Seller is solely responsible for the content of the listings they post.

4.3.2. The Operator does not guarantee that listings correspond to the Seller’s actual capabilities and does not vouch for the quality of the services offered.

4.3.3. The posting of a listing on the Platform does not mean that the Operator endorses its content.

4.3.4. Upon discovering violations, the Operator may:

5. Conclusion of Transactions Between the Buyer and the Seller

5.1. General Provisions

5.1.1. A transaction for the purchase of a service is concluded directly between the Buyer and the Seller by means of the Platform’s functionality.

5.1.2. The Operator provides the technical means for concluding the transaction but does not become a party to it.

5.1.3. The terms of the transaction are determined by:

5.1.4. The posting by the Seller of an offer to provide a service on the Platform is deemed a public offer of the Seller if the content of such offer clearly indicates the Seller’s intention to enter into a contract on the stated terms, unless otherwise indicated by the Seller or implied by the nature of the service posted.

5.2. Placing an Order

5.2.1. To purchase a service, the Buyer performs the actions provided for by the Platform interface.

5.2.2. Before confirming the order, the Buyer is given the opportunity to review:

5.2.3. Confirmation of the order by the Buyer expresses their intention to enter into a transaction on the stated terms.

5.2.4. Once the transaction is confirmed, information about it is recorded in the Platform’s information system.

5.3. Performance of the Transaction

5.3.1. The obligations to provide the service are performed directly by the Seller.

5.3.2. The Seller independently determines the methods and manner of performing the service, unless otherwise provided by the terms of the specific transaction.

5.3.3. The Buyer must provide the information and conditions required for performance of the service.

5.3.4. The Operator does not interfere in the process of providing the service and does not determine how it is performed.

5.4. Confirmation of Performance

5.4.1. Completion of the transaction may be confirmed by means of the Platform’s functionality.

5.4.2. Depending on the type of service, confirmation may take the form of:

5.4.3. The recording of the transaction’s completion in the Platform is relevant for accounting for operations and organizing settlements.

6. Settlements and Financial Interaction

6.1. General Provisions

6.1.1. The Platform provides a mechanism for organizing settlements between the Buyer and the Seller.

6.1.2. The manner in which funds move is determined by the operating model chosen for the Platform and the terms of this Agreement.

6.1.3. The Operator may accept funds from Buyers for subsequent transfer to Sellers less the applicable agency fee.

6.2. Agency Settlement Model

6.2.1. Under the agency model, the Seller instructs the Operator to:

6.2.2. By accepting this Agreement, the Seller grants the Operator the right to act in the Seller’s name and at the Seller’s expense with respect to the organization of settlements.

6.2.3. The Operator acts solely within the authority related to the functioning of the Platform and the organization of settlements.

6.2.4. The Operator’s receipt of funds does not mean that the Operator acquires any rights to the service that is the subject of the transaction.

6.3. Agency Fee

6.3.1. For performing the functions of organizing the operation of the Platform and settlements, the Operator is entitled to receive an agency fee.

6.3.2. The amount of the agency fee and the manner of withholding it are indicated:

6.3.3. The Seller confirms their consent to the withholding of the agency fee when using the Platform.

6.4. Responsibility for Settlements

6.4.1. The Operator is responsible only for the correct execution of the operations that directly relate to its functions in organizing settlements.

6.4.2. The Operator is not responsible for:

6.4.3. The Seller is solely responsible for performing its tax and other obligations related to the receipt of income.

7. Delivery of Service Results and Interaction of the Parties

7.1. General Provisions

7.1.1. The result of the service is delivered to the Buyer directly by the Seller, unless a different procedure is expressly provided by the terms of the specific service.

7.1.2. The Operator provides the technical means for the exchange of information between the Buyer and the Seller but does not take part in the actual performance of the service.

7.1.3. The Seller independently determines how to deliver the result of the service, taking into account the nature of the service and the terms of the transaction.

7.1.4. The Buyer must provide the conditions necessary for the performance of the service, including:

7.2. Forms of Delivering the Result

7.2.1. Depending on the nature of the service, the result may be delivered:

7.2.2. The Seller must specify the method of receiving the result if this is a material term of the service.

7.2.3. The Buyer must independently ensure that they are able to receive the result of the service.

7.3. Use of Service Results

7.3.1. The purchase of a service through the Platform does not automatically transfer exclusive rights to any result of intellectual activity, unless expressly provided by the terms of the transaction.

7.3.2. The scope of the rights to use the result is determined by:

7.3.3. The Seller must independently determine whether there are any restrictions on the use of the result of the service.

7.4. Completion of the Transaction

7.4.1. The transaction is deemed performed once the parties have fulfilled their obligations in accordance with the terms of the transaction.

7.4.2. Completion of the transaction may be confirmed by:

7.4.3. The record of the transaction’s completion is used by the Operator for the purposes of accounting, settlements, and confirmation of events in the information system.

8. Refunds, Cancellation of Transactions, and Disputes

8.1. General Provisions

8.1.1. The procedure for cancelling a transaction, refunding funds, and resolving disputes is determined by:

8.1.2. The Operator provides the technical means for the parties to interact but does not assume the Seller’s obligations to refund funds where such obligations arose as a result of improper performance of the service.

8.2. Cancellation of the Transaction by the Buyer

8.2.1. The Buyer may request cancellation of the transaction in the cases provided for by the legislation of the Russian Federation or the terms of the specific service.

8.2.2. A cancellation request is submitted through the tools provided by the Platform or in any other manner indicated by the Operator.

8.2.3. When considering the cancellation of a transaction, the following may be taken into account:

8.3. Refunds

8.3.1. Refunds are made in the cases and in the manner provided for by the legislation of the Russian Federation, the terms of the transaction, or the agreement of the parties.

8.3.2. Where there are grounds for a refund, the Operator may provide technical support for the refund within the payment infrastructure used.

8.3.3. A refund does not mean that the Operator acknowledges responsibility for the Seller’s actions.

8.3.4. The amount to be refunded may be determined taking into account:

8.4. Disputes Between the Buyer and the Seller

8.4.1. Disputes concerning the quality, content, timing, and result of the service are resolved directly between the Buyer and the Seller.

8.4.2. The Operator may provide the parties with:

8.4.3. The provision of such information does not mean that the Operator sides with either party.

9. Moderation, Restrictions, and Safe Use of the Platform

9.1. General Provisions

9.1.1. The Operator takes reasonable measures to ensure the safe and stable functioning of the Platform.

9.1.2. To protect users and the infrastructure, the Operator may apply verification, restriction, and moderation procedures.

9.1.3. Moderation does not constitute a mandatory prior review of all user actions and materials.

9.2. Grounds for Restricting Access

9.2.1. The Operator may temporarily or fully restrict a user’s access to the Platform in the event of:

9.3. Response Measures

9.3.1. Depending on the nature of the violation, the Operator may:

9.3.2. The application of protective measures does not constitute an acknowledgment by the Operator that the user committed a violation until the review of the circumstances is completed.

9.4. Security of the Information System

9.4.1. Users are prohibited from:

9.4.2. The user must immediately report any discovered vulnerabilities, errors, or suspicious activity to the Operator.

10. Agency Model of Interaction and Settlement Procedure

10.1. General Provisions

10.1.1. With respect to settlements under transactions between Buyers and Sellers, the Operator uses an agency model: it acts in its own name but at the Seller’s expense, accepting payments, withholding the agency fee, and transferring the funds due to the Seller.

10.1.2. The agency model applies where the Operator takes part in organizing the flow of funds, including accepting payments, keeping records of operations, withholding the agency fee, and transferring funds to the Seller.

10.1.3. By accepting this Agreement, the Seller confirms their consent to the use of the agency model and instructs the Operator to take the actions necessary to organize settlements.

10.2. Authority of the Operator as Agent

10.2.1. Under the agency model, the Operator may:

10.2.2. The Operator acts solely within the authority granted by this Agreement.

10.2.3. The Operator does not assume any obligation to provide the services that are the subject of the transaction between the Buyer and the Seller.

10.3. Funds and Transfer Procedure

10.3.1. Funds received from Buyers as part of settlements through the Platform are accounted for in accordance with the established operating procedures of the Platform.

10.3.2. Once the conditions required for the transfer of funds have been met, the Operator transfers the funds to the Seller less:

10.3.3. The timing of the transfer of funds may depend on:

10.4. Operator’s Agency Fee

10.4.1. The Operator receives a fee for performing the agency functions.

10.4.2. The amount of the agency fee is determined by:

10.4.3. By taking actions on the Platform after reviewing the amount of the fee, the User confirms their agreement with the stated terms.

10.5. Taxation of Participants

10.5.1. The Operator independently performs the tax obligations arising in connection with its own activities.

10.5.2. The Seller is solely responsible for:

10.5.3. Use of the Platform does not exempt the Seller from complying with the requirements of the tax legislation of the Russian Federation.

10.5.4. The Operator does not determine the Seller’s tax obligations and is not the Seller’s tax representative, unless expressly provided by law.

10.5.5. The provisions of clause 10.5.4 apply provided that the Seller holds and maintains the tax status provided for by clause 3.5.1. This Agreement does not exclude any obligations of the Operator that may arise directly by virtue of mandatory provisions of the legislation of the Russian Federation.

10.5.6. A Seller applying the tax on professional income must, for each payout received from the Operator as part of settlements under Transactions, generate a receipt in the Federal Tax Service application «Moy Nalog» and provide it to the Operator in the manner provided by the Platform’s functionality or indicated by the Operator.

10.5.7. Failure by a self-employed Seller to provide the receipt referred to in clause 10.5.6 constitutes a violation of this Agreement and may result in the suspension of subsequent payouts and Seller functions until the violation is remedied.

10.5.8. The Operator prepares an agent’s report on the instructions performed, Transactions concluded, payments received, agency fees withheld, payouts, and refunds, and posts it in the Seller’s personal account or provides it by another agreed electronic means.

10.5.9. If the Seller does not submit reasoned written objections within 3 (three) calendar days from the date the agent’s report is posted or provided, the report is deemed accepted by the Seller without objections and signed by the parties in electronic form.

10.5.10. Objections to the agent’s report must identify the disputed operations and the grounds for disagreement. The Operator reviews them using the data of the information system and, where necessary, prepares a corrected report.

10.6. PRO Package and the Operator’s Own Services

10.6.1. The Operator may offer Sellers the PRO Package — the Operator’s own paid service. The contract for the provision of the PRO Package is concluded directly between the Operator and the Seller at the moment the purchase is confirmed and paid for through the Platform interface.

10.6.2. The PRO Package is valid for 30 calendar days, unless a different period is expressly indicated in the Platform interface at the time of purchase. The start and end dates of the PRO Package are displayed in the Seller’s personal account.

10.6.3. While a PRO Package is active, the Seller may be provided with the following benefits: (1) an agency fee of 10 percent instead of the standard 15 percent for transactions concluded during the PRO Package period; (2) accelerated transfer of funds within one day after the right to a payout arises, in the absence of technical, banking, legal, or other restrictions; (3) priority display of listings in search results; (4) priority support; (5) a PRO badge in the profile.

10.6.4. Priority display and priority support are provided within the technical capabilities of the Platform and do not guarantee a specific position in search results, a particular sales volume, or a response outside business hours, unless a different support arrangement is indicated in the Platform interface.

10.6.5. The PRO badge confirms only that an active PRO Package exists. It is not a confirmation of the Seller’s identity, a guarantee of the quality of their services, an indicator of reliability, or a recommendation by the Operator.

10.6.6. The price of the PRO Package is indicated before payment. Funds received for the PRO Package are payment for the Operator’s own service and are accounted for separately from the funds accepted by the Operator as agent under transactions between Buyers and Sellers.

10.6.7. Payment for the PRO Package does not change the price of the Seller’s services for Buyers. The reduced agency fee applies only to transactions concluded during the PRO Package period, unless a different arrangement is expressly indicated in the Platform interface before the transaction is entered into.

10.6.8. The terms of cancelling the PRO Package and refunding its price are determined by the legislation of the Russian Federation and the information communicated to the Seller before payment.

10.6.9. Settlements for the Operator’s own services, including the PRO Package, are documented separately from the agency settlements under transactions between Buyers and Sellers. The Operator issues cash receipts and related documents for such services in the cases and in the manner provided for by the legislation of the Russian Federation.

11.1. General Provisions

11.1.1. Intellectual property posted or used on the Platform is protected in accordance with the legislation of the Russian Federation.

11.1.2. Such property includes:

11.2. Rights of the Operator

11.2.1. The exclusive rights to the software and elements of the Platform belong to the Operator or are used by it on lawful grounds.

11.2.2. The user receives a limited right to use the Platform solely for the purposes provided for by this Agreement.

11.2.3. The user may not:

11.3. User Content

11.3.1. The user retains the rights to the materials they post through the Platform.

11.3.2. By posting materials, the user grants the Operator a non-exclusive right to use such materials solely for:

11.3.3. The grant of this right does not transfer any exclusive rights to the Operator.

11.4. Responsibility for Content

11.4.1. The user guarantees that they hold the necessary rights to the materials they post.

11.4.2. The user is solely responsible for any infringement of third-party rights related to the posted content.

11.4.3. Upon receiving substantiated claims, the Operator may:

12. Personal Data and Confidentiality of Information

12.1. General Provisions

12.1.1. The Operator processes users’ personal data for the purposes of operating the Platform, performing this Agreement, and complying with the requirements of the legislation of the Russian Federation.

12.1.2. Personal data is processed in accordance with:

12.2. Categories of Data Processed

12.2.1. The Operator may process the following categories of information:

12.2.2. The scope of the data processed is determined by what is necessary to provide the Platform’s functionality.

12.3. Purposes of Data Processing

12.3.1. Personal data is used for:

12.3.2. The Operator may use anonymized data to analyze and improve the operation of the Platform.

12.4. Data Transfers

12.4.1. The Operator may transfer data to third parties where necessary for:

12.4.2. The Operator does not sell users’ personal data and does not use it for purposes unrelated to the operation of the Platform without an appropriate legal basis.

12.5. Confidentiality

12.5.1. Users undertake to keep confidential the information obtained while using the Platform.

12.5.2. The following information is confidential:

12.5.3. The user must use the information obtained solely for the purposes of interacting through the Platform.

13. Liability of the Parties and Limitation of the Operator’s Liability

13.1. General Provisions

13.1.1. Users and the Operator are liable for the performance of their obligations in accordance with this Agreement and the legislation of the Russian Federation.

13.1.2. Liability is determined by the role of the respective participant:

13.1.3. The Operator is not liable for the obligations arising between the Buyer and the Seller.

13.2. Liability of the Seller

13.2.1. The Seller is solely responsible for:

13.2.2. The Seller must independently settle Buyers’ claims related to the quality and performance of the services.

13.2.3. The Seller is responsible for the consequences of posting inaccurate or unlawful information.

13.3. Liability of the Buyer

13.3.1. The Buyer is responsible for:

13.3.2. The Buyer may not use the Platform for fraudulent activity, abuse of the refund mechanisms, or violation of the rights of other users.

13.4. Liability of the Operator

13.4.1. The Operator is responsible for:

13.4.2. The Operator is not responsible for:

13.4.3. The Operator is not a party to the service agreement between the Buyer and the Seller.

13.5. Limitation of Liability

13.5.1. The user understands that the Platform is a digital tool for interaction between participants.

13.5.2. The Operator does not guarantee:

13.5.3. The Operator is not liable for temporary unavailability of the Platform caused by:

14. Electronic Document Flow and Legal Significance of Actions in the Platform

14.1. Electronic Form of Interaction

14.1.1. Users acknowledge that electronic interaction through the Platform is legally significant.

14.1.2. Actions performed through the personal account and the Platform interface are deemed to have been performed by the respective user unless proven otherwise.

14.2. Electronic Messages

14.2.1. Messages may be legally significant when sent through:

14.2.2. The user must keep their contact details up to date.

14.3. Recording of Events

14.3.1. The Platform’s information system may record:

14.3.2. The data of the information system may be used as evidence that actions were performed by users.

15. Handling of Inquiries and Claims and Dispute Resolution

15.1. General Procedure

15.1.1. Users undertake to first attempt to resolve disputes through negotiation.

15.1.2. The Operator considers inquiries related to the operation of the Platform and its own obligations.

15.1.3. Disputes concerning the quality and performance of services are resolved between the Buyer and the Seller.

15.2. Inquiries to the Operator

15.2.1. An inquiry must contain:

15.2.2. The Operator may request additional information in order to consider the inquiry.

15.3. Evidence

15.3.1. The parties acknowledge the evidentiary value of:

15.4. Applicable Law

15.4.1. The relationship between the Operator and users is governed by the legislation of the Russian Federation.

15.4.2. Disputes are resolved in the manner established by the legislation of the Russian Federation.

16. Amendment of the Agreement and Termination of Use of the Platform

16.1. Amendment of the Agreement

16.1.1. The Operator may amend this Agreement in connection with:

16.1.2. A new revision takes effect from the moment of publication, unless a different date is indicated by the Operator.

16.2. Notification of Users

16.2.1. The Operator may notify users of changes by:

16.2.2. Continued use of the Platform after the changes take effect constitutes the user’s agreement with the new revision.

16.3. Termination of Use

16.3.1. The user may stop using the Platform.

16.3.2. Termination of use does not release the user from their obligations under previously concluded transactions.

16.3.3. The Operator may restrict or terminate the user’s access in the event of violation of this Agreement.

17. Final Provisions

17.1. General Provisions

17.1.1. This Agreement is the principal document governing the use of the Sarafano Platform.

17.1.2. The user confirms that they have read the terms of the Agreement and accept them in full.

17.2. Operating Model of the Platform

17.2.1. The user confirms their understanding that:

17.2.2. The user accepts this model of interaction between the Operator, the Buyer, and the Seller.

17.3. Personal Data Processing Policy

17.3.1. The Personal Data Processing Policy is set out in Appendix No. 3 to this Agreement and forms an integral part of it.

17.3.2. The user confirms that they have read the Personal Data Processing Policy before starting to use the Platform and before providing personal data.

17.4. Appendices to the Agreement

17.4.1. The following are integral parts of this Agreement: Appendix No. 1 — Refund and Order Cancellation Rules; Appendix No. 2 — Cookie Policy; Appendix No. 3 — Personal Data Processing Policy.

17.4.2. The provisions of sections 4, 9, 11, and 15 of this Agreement govern the requirements for publishing content, user conduct, moderation, and dispute resolution; no separate appendices apply to these matters.

17.4.3. In the event of a conflict between an appendix and the main text of the Agreement, the main text prevails, unless otherwise required by mandatory provisions of the legislation of the Russian Federation.

18. Operator Details

Operator of the Sarafano Platform

Full name: Individual Entrepreneur Aleksandr Nikolaevich Tikhanskiy

Short name: IE Tikhanskiy A. N.

Legal form: individual entrepreneur

Taxpayer identification number (INN): 503116570489

OGRNIP: 315502400003172

Registered address: 143421, Moscow Region, Krasnogorsk District, Glukhovo village, Rublevskoe Predmestie St., 8, bldg. 2, apt. 1

Email address: support@sarafano.com

Contact address for inquiries: support@sarafano.com

Platform website: sarafano.com

Effective date of this revision: August 1, 2026

Appendix No. 1 to the User Agreement of the Sarafano Platform

Refund and Order Cancellation Rules

1. General Provisions

1.1. These Rules define the procedure for cancelling Orders and refunding funds on the Platform and apply together with the User Agreement.

1.2. A refund under a Transaction between the Buyer and the Seller does not mean that the Operator becomes a party to the service agreement. The Operator takes part in the settlements and in the review of the inquiry within the authority established by the Agreement.

2. Cancellation of an Order

2.1. The Buyer may cancel an Order before the Seller begins performing it, unless otherwise implied by the nature of the service, the terms of the Listing, or the legislation of the Russian Federation.

2.2. After performance has begun, an Order may be cancelled by agreement of the Buyer and the Seller or following the review of an inquiry in accordance with section 15 of the Agreement.

2.3. The cancellation and its grounds are recorded by means of the Platform. The user must provide the requested information and evidence.

3. Refunds Under a Transaction

3.1. A full refund may be made in the event of the Seller’s refusal to perform, objective impossibility of providing the service, confirmed fraud, cancellation of the Order before performance began, or in other cases provided for by law or the terms of the Transaction.

3.2. A partial refund is allowed by agreement of the Buyer and the Seller or in proportion to the unperformed part of the obligation. For subscription services, partial refunds do not apply; a refund is possible only in full.

3.3. The Operator may request correspondence, files, information about performance, and other materials, temporarily restrict operations with the disputed amount within the limits of the law and technical capabilities, and, where the information is insufficient, deny the claim.

3.4. The refund is credited to the Buyer’s balance on the Platform; a refund to a bank card is made under the procedure for returning the unused balance (section 4 of these Rules), unless otherwise provided by law. The time for crediting a bank card depends on the bank and the payment organization.

3.5. A refund claim under a Transaction may be submitted within 30 calendar days: for subscription services — from the moment of payment for the relevant period; for other services — from the moment the Transaction is completed, unless a longer period is established by law.

4. Return of the Unused Balance

4.1. Where the Platform’s functionality provides for topping up a balance, the User may request the return of the unused balance within 30 calendar days from the date of the relevant top-up, unless a longer period is established by law.

4.2. The return is made after the User has been identified and the source of the funds has been verified. Amounts already used to pay for Orders, fees, or the Operator’s own services do not constitute an unused balance.

4.3. The Operator may suspend the return for the duration of a review where there are signs of fraud, abuse, error, a demand from a state authority, or restrictions imposed by a payment organization.

5. PRO Package and Refund Expenses

5.1. Cancellation of the PRO Package and the refund of its price are governed by the legislation of the Russian Federation, taking into account the status of the purchaser, the moment the service began to be provided, the period actually provided, and the information communicated before payment.

5.2. The fees of banks and payment organizations are withheld or reimbursed only in the cases permitted by law and the rules of the relevant organization. The Operator does not reduce a refund required by law by the amount of its own agency fee.

Appendix No. 2 to the User Agreement of the Sarafano Platform

Cookie Policy

1. General Provisions

1.1. The Platform uses cookies and similar technologies to ensure the operation of the website and applications, security, the saving of settings, and the analysis of the use of the Platform.

1.2. For the purposes of this Policy, the Operator is the person whose details are set out in section 18 of the Agreement.

2. Categories of Cookies

2.1. Essential cookies are necessary for authorization, account protection, session maintenance, load balancing, and the operation of the core functions.

2.2. Functional cookies save the settings chosen by the User and allow the interface to be personalized.

2.3. Analytics cookies help assess traffic, errors, and the use of functions. Advertising cookies are used only where there is an appropriate legal basis and the User has been given a choice.

3. Third-Party Services and Storage Periods

3.1. Third-party services may be used for analytics, security, payments, and other functions; they set their own cookies in accordance with their own documents.

3.2. Session cookies are deleted when the session ends; persistent cookies are stored for the period set in the cookie itself or in the settings of the relevant service, but no longer than necessary for the stated purpose.

4. Managing Cookies

4.1. The User can manage non-essential cookies through the Platform interface, where such a tool is available, and through browser settings.

4.2. Disabling essential cookies may make it impossible to log in and use certain functions. Withdrawal of a choice does not affect the lawfulness of processing performed before the withdrawal.

Appendix No. 3 to the User Agreement of the Sarafano Platform

Personal Data Processing Policy

1. General Provisions

1.1. This Policy defines the procedure and conditions for processing the personal data of users of the Sarafano Platform and the measures taken to ensure its security.

1.2. The personal data operator is the person whose details are set out in section 18 of the Agreement. The Policy applies to all data received through the website, applications, the personal account, the support service, and the related services of the Platform.

1.3. Processing is carried out in accordance with the legislation of the Russian Federation on personal data, including Federal Law No. 152-FZ of July 27, 2006 «On Personal Data».

2. Categories of Data and Data Subjects

2.1. The Operator may process the surname, first name, and patronymic; date of birth where necessary; phone number; email; account information; the Seller’s INN, tax status, and details; information about Orders, settlements, payouts, refunds, receipts, and agent’s reports; inquiries and correspondence; technical data, including IP address, cookies, information about the device, browser, and actions on the Platform; and other data voluntarily provided by the User.

2.2. Full bank card details may be processed by the payment organization without being transferred to the Operator. The Operator processes payment identifiers and other information only to the extent necessary for settlements, refunds, accounting, and fraud prevention.

2.3. Data subjects include visitors, registered Users, Buyers, Sellers, representatives of legal entities and individual entrepreneurs, and persons contacting support.

3. Purposes and Legal Bases of Processing

3.1. Data is processed for registration and authentication; the provision of the Platform’s functions; the conclusion and performance of the Agreement and the Operator’s own services, including the PRO Package; the organization of Transactions and settlements; verification of the Seller’s tax status; the preparation of cash receipts and agent’s reports; the handling of refunds and disputes; support; security; the prevention of violations; the performance of obligations established by law; and the protection of the rights of the Operator and Users.

3.2. The legal bases are the conclusion and performance of a contract, legal requirements, the consent of the data subject, and the legitimate interests of the Operator or third parties, where such processing does not infringe the rights and freedoms of the data subject.

3.3. Advertising and marketing messages are sent where the consent required by law has been given. The User can opt out of them in the manner indicated in the message or the interface.

4. Data Operations and Automation

4.1. The Operator may collect, record, systematize, accumulate, store, update, retrieve, use, transfer, anonymize, block, delete, and destroy data, with or without the use of automation tools.

4.2. Decisions giving rise to legal consequences for the data subject solely on the basis of automated processing are made only in the cases and in the manner permitted by law.

5. Data Transfers and Outsourced Processing

5.1. Data may be transferred to banks and payment organizations; providers of cloud infrastructure, communications, analytics, technical support, tax status verification, and document management; and state authorities — to the extent necessary for the relevant purpose and where there is a legal basis.

5.2. Persons processing data on the Operator’s instructions must maintain confidentiality and ensure the security of the data. The Operator does not sell personal data.

5.3. In the event of cross-border transfers, the Operator complies with the requirements of the legislation of the Russian Federation, including the localization requirements and the prior assessment of transfer conditions, where applicable.

6. Storage Periods and Destruction

6.1. Data is stored no longer than required by the purposes of processing, the contractual relationship, and the mandatory document retention periods. Once the purposes have been achieved or the legal basis has ceased, the data is destroyed or anonymized, unless the law requires further storage.

6.2. Deletion of an account does not entail the immediate deletion of data that the Operator must retain for bookkeeping, tax, and cash accounting purposes, dispute resolution, or compliance with other legal requirements.

7. Rights of the Data Subject

7.1. The data subject may obtain information about the processing; demand the updating, blocking, or destruction of incomplete, outdated, inaccurate, unlawfully obtained, or excessive data; withdraw consent; object to processing in the cases provided for by law; and challenge the Operator’s actions.

7.2. To exercise these rights, the data subject sends an inquiry to the contact address set out in section 18 of the Agreement. The Operator may request the information necessary to confirm the person’s identity and the connection between the inquiry and the subject’s data.

7.3. Withdrawal of consent does not terminate processing carried out on another legal basis and does not affect the lawfulness of processing performed before the withdrawal.

8. Security and Incidents

8.1. The Operator takes the necessary legal, organizational, and technical measures, including access control, activity logging, backups, protection of communication channels, and contractor oversight, taking into account the nature of the data and current threats.

8.2. If an incident is discovered, the Operator acts in accordance with legal requirements, takes measures to remedy the consequences, and sends the required notifications.

9. Changes to the Policy

9.1. The Operator may update the Policy. A new revision applies from the date of publication, unless a different date is specified in it. Material changes are communicated to Users in an accessible manner.

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