Personal Data Processing Policy

1. General Provisions

This Personal Data Processing Policy has been drawn up in accordance with the requirements of Federal Law of 27.07.2006. No. 152-FZ "On Personal Data" (hereinafter - the Personal Data Bill) and establishes the procedure for personal data processing and measures to ensure the security of personal data taken by Entrepreneur Cherneykina Irina Aleksandrovna (hereinafter referred to as the Operator).

1.1. Observance of human and civil rights and freedoms during personal data processing, including the protection of the rights to privacy, personal and family secrets is the Operator's key goal and necessary condition for its operations.

1.2. This Operator's policy regarding personal data processing (hereinafter - the Policy) applies to all information that the Operator can obtain about visitors to the website

2. Basic Concepts Used in the Policy

2.1. Automated Personal Data Processing refers to processing of personal data using computer technology.

2.2. Blocking of Personal Data refers to temporary suspension of personal data processing (unless processing is necessary to clarify personal data).

2.3. Website refers to a set of graphic and information materials, as well as computer programs and databases, ensuring their availability on the Internet at the web address

2.4. Personal Data Information System refers to a set of personal data contained in databases, information technologies and technical means ensuring their processing.

2.5. Personal Data Anonymization refers to 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. Personal Data Processing - any action (transaction) or a set of actions (transactions) performed with personal data using automation tools or without using such tools, including collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.

2.7. Operator refers to government agency, municipal authority, legal entity or individual, independently or jointly with other persons organizing and (or) performing personal data processing, as well as determining the purposes of personal data processing, personal data contents to be processed, actions (transactions) performed with personal data.

2.8. Personal Data refers to any information relating directly or indirectly to a specific or identifiable User of the website

2.9. Personal Data Permitted for Dissemination by the Data Subject refers to personal data, access of an unlimited number of persons to which is provided by the data subject by giving consent to personal data process permitted by the data subject for dissemination in the manner prescribed by the Personal Data Law (hereinafter - Personal Data Permitted for Dissemination).

2.10. User refers to any visitor to the website

2.11. Personal Data Provision refers to actions aimed at disclosing personal data to a certain person or a certain number of persons.

2.12. Personal Data Dissemination refers to any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or at acquaintance with the personal data of an unlimited number of persons, including the disclosure of personal data in the media, posting on information and telecommunication networks or providing access to personal data in any other way.

2.13. Cross-Border Transfer of Personal Data refers to the transfer of personal data to the territory of a foreign state to the authority of a foreign state, to a foreign individual or foreign legal entity.

2.14. Personal Data Destruction refers to any actions as a result of which personal data is destroyed irrevocably and it is impossible to restore the content of personal data in the personal data information system and (or) material carriers of personal data are destroyed.

3. Operator's Basic Rights and Duties

3.1. Operator has the right to:

- receive reliable information and / or documents containing personal data from the data subject;

- if the Data Subjects withdraws consent to personal data processing, the Operator has the right to continue personal data processing without the data subject's consent if there are grounds specified in the Personal Data Law;

- independently determine the contents and list of measures necessary and sufficient to ensure fulfillment of the obligations provided for by Personal Data Law and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.

3.2. Operator shall:

- provide the data subject, upon his request, with information regarding his/her personal data processing;

- arrange personal data processing in the manner prescribed by the current legislation of the Russian Federation;

- respond to requests and inquiries from data subjects and their legal representatives in accordance with the requirements of Personal Data Law;

- inform the authorized body for the protection of the rights of data subjects at the request of this body the necessary information within 30 days from the date of receipt of such a request;

- publish or otherwise provide unrestricted access to this Policy in relation to personal data processing;

- take legal, organizational and technical measures to protect personal data from unauthorized or accidental access, destruction, alteration, blocking, copying, provision, dissemination of personal data, as well as from other illegal actions in relation to personal data;

- stop transfer (distribution, provision, access) of personal data, stop processing and destroy personal data in the manner and in cases provided for Personal Data Law;

- perform other duties provided for by Personal Data Law.

4. Data Subject's Basic Rights and Duties

4.1. Data subjects have the right to:

- receive information regarding his/her personal data, with the exception of cases provided for by federal laws. The information is provided to the data subject by the Operator in an accessible form, and it should not contain personal data relating to other data subjects, unless there are legal grounds for disclosing such personal data. The list of information and the procedure for its obtaining is established by Personal Data Law;

- require the Operator to clarify his/her personal data, block or destroy them if the personal data is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing, as well as take measures to protect their rights provided by law;

- set a condition of prior consent when processing personal data in order to promote goods, works and services on the market;

- withdraw consent to personal data processing;

- appeal to the authorized body for the protection of the rights of subjects of personal data or in court the illegal actions or inaction of the Operator when processing his personal data;

- to exercise other rights provided by the legislation of the Russian Federation.

4.2. Data subjects shall:

- provide the Operator with reliable data about themselves;

- 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 data subject without his/her consent are liable in accordance with the legislation of the Russian Federation.

5. The Operator can process the following personal data of the User

5.1. Full Name.

5.2. Email address.

5.3. Phone numbers.

5.4. Also, the site collects and processes anonymized data about visitors (including cookies) using Internet statistics services (Yandex Metrica and Google Analytics and others).

5.5. The above data - hereinafter "the Policy" – is united by the general concept of Personal data.

5.6. Processing of special categories of personal data concerning race, nationality, political views, religious or philosophical beliefs, intimate life is not carried out by the Operator.

5.7. Processing of personal data permitted for dissemination from among the special categories of personal data specified in Part 1 of Art. 10 of Personal Data Law is allowed if the prohibitions and conditions provided for in Art. 10.1 of Personal Data Law are observed.

5.8. The User's consent to personal data processing permitted for dissemination is drawn up separately from other consents to his/her personal data processing. In this case, the conditions provided for, in particular, Art. 10.1 of Personal Data shall be observed.

The requirements for the approval of such consent are established by the authority for data subjects' rights protection.

5.8.1 Consent to personal data processing permitted for dissemination shall be provided by the User directly to the Operator.

5.8.2 The Operator shall provide information on processing conditions, on current prohibitions and conditions on processing of data permitted for dissemination by an unlimited number of persons no later than three (3) days after receipt of such User's consent.

5.8.3 The transfer (distribution, provision, access) of personal data permitted by the data subject for dissemination should be cancelled any time at the request of the data subject. The request shall contain the last name, first name, patronymic (if any), contact information (telephone number, e-mail address or postal address) of the data subject, as well as a list of data, the processing of which is subject to termination. The personal data specified in this request can be processed only by the Operator to whom it is sent.

5.8.4 Consent to the processing of data permitted for dissemination, termination of the moment the Operator receives a request, termination in clause 5.8.3 of this Policy in relation to data processing.

6. Data Processing Principles

6.1. Personal data processing is carried out on a legal and fair basis.

6.2. Data processing is limited to the achievement of specific, defined and legitimate purposes. Data processing incompatible with the purposes of data collection is not permitted.

6.3. Combination of data bases containing personal data to be processed in incompatible purposes is not permitted.

6.4. Only personal data that correspond to the purposes of their processing is subject to processing.

6.5. Content and scope of the processed data correspond to the stated purposes of processing. Excessive processed data for the stated purposes of processing is not permitted.

6.6. When processing data, accuracy and reliability of personal data shall be secured, and if necessary, relevance in relation to the purposes of data processing shall be secured as well. The Operator takes measures and ensures their implementation to remove or clarify incomplete inaccurate data.

6.7. Data storage is carried out in a form that allows determining internal data, no longer than this period of the purpose of data processing, if the data storage period is not established by federal law, an agreement to which the data subject is a party, beneficiary or guarantor. The processed personal data is destroyed or depersonalized upon achievement of the processing purposes or if there is no longer need to achieve such purposes, unless otherwise provided by the federal law.

7. Purposes of Personal Data Processing

7.1. Purpose of the User's Personal Data Processing:

- informing the User by sending emails;

- entering into, execution and termination of agreements.

7.2. The Operator also has the right to send the User notifications about new products and services, special offers and various events. The User can always refuse to receive informational messages by sending an email to the Operator at with the note "Refusal of notifications about new products, services and special offers".

7.3. Depersonalized User data collected using Internet statistics services are used to collect information about the Users' activity on the site, improve the quality of the site and its content.

8. Legal Grounds for Personal Data Processing

8.1. Legal grounds for personal data processing by the Operator are:

- Operator's documents of incorporation;

- federal laws, other regulations in personal data protection;

- Users' consent to process their personal data, to process personal data permitted for dissemination.

8.2. The Operator processes the User's personal data only if it is filled in and/or sent by the User on his own through special forms on the website or sent to the Operator via e-mail. By filling out the appropriate forms and/or sending his/her personal data to the Operator, the User agrees with this Policy.

8.3. The Operator processes depersonalized User's data it is allowed in the settings of the User's browser (the storage of cookies and the use of JavaScript technology are enabled).

8.4. The data subject makes his/her own decision to provide his/her personal data and gives consent freely, on his free will and in his interest.

9. Terms of Personal Data Processing

9.1. Personal data processing is carried out with the consent of the data subject to process his/her personal data.

9.2. Personal data processing is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, to exercise the functions, powers and duties imposed by the legislation of the Russian Federation on the Operator.

9.3. Personal data processing is necessary to delivery justice, to execute the court order, the decision of another authority or official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.

9.4. Personal data processing is necessary to execute an agreement, to which the data subject is a party or beneficiary or guarantor, as well as to enter into an agreement initiated by the data subject or an agreement under which the data subject will be the beneficiary or guarantor.

9.5. Personal data processing is necessary to exercise the rights and legitimate interests of the Operator or third parties, or to achieve socially significant goals without violation rights and freedoms of the data subject.

9.6. The data subject provides access to an unlimited number of persons in respect of data to be processed or upon his/ her request (hereinafter - Publicly Available Personal Data).

9.7. Personal data subject to publication or mandatory disclosure in accordance with federal law is processed.

10. Procedure for Collection, Storage, Transfer and Other Mode of Personal Data Processing

Safety of the personal data processed by the Operator is ensured by the execution of legal, organizational and technical measures necessary to comply in full with the requirements of the current legislation in personal data protection.

10.1. The Operator shall ensure the safety of personal data and take all possible measures to exclude access to personal data of unauthorized persons.

10.2. The User's personal data shall under no circumstances be transferred to third parties, except in cases related to the execution of current legislation or if the data subject has given consent to the Operator to transfer data to a third party to fulfill obligations under any agreement.

10.3. In case of revealing inaccuracies in personal data, the User can update them on his own by sending a notification to the Operator's e-mail address with the subject "Personal Data Update".

10.4. The period for personal data processing is determined by the achievement of the purposes for which the personal data has been collected, unless another period is provided for by the agreement or current legislation.

The user can revoke his consent to personal data processing anytime by sending a notification to the Operator's email address with the subject "Withdrawal of Personal Data Processing Consent".

10.5. All information collected by third-party services, including payment systems, communication facilities and other service providers, is stored and processed by the specified persons (Operators) in accordance with their User Agreement and Privacy Policy. The data subject and/or the User shall review these documents in a timely manner on his/her own. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.

10.6. The prohibitions established by the data subject on transfer (except for granting access), as well as on processing or processing terms (except for gaining access) for personal data permitted for dissemination do not apply in cases of personal data processing in the state, government and other public interests determined by law of the Russian Federation.

10.7. When processing personal data, the Operator ensures the confidentiality of personal data.

10.8. The Operator stores the personal data in a form that makes it possible to determine the data subject no longer than the purpose of personal data processing requires, unless the personal data storage period is established by federal law, an agreement to which the data subject is a party, beneficiary or guarantor.

10.9. A condition for terminating personal data processing may be achievement of personal data processing purposes, expiration of the data subject's consent or withdrawal of consent by the data subject, as well as the identification of illegal personal data processing.

11. List of Measures Taken by the Operator with the Personal Data Received

11.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), extracts, uses, transfers (distributes, provides, accesses), depersonalizes, blocks, deletes and destroys personal data.

11.2. The Operator processes the personal data automatically with the receipt and/or transfer of the information received via telecommunication networks or without it.

12. Personal Data Cross-Border Transfer

12.1. Before personal data cross-border transfer, the Operator shall make sure that the foreign state, where it is supposed to transfer personal data, provides reliable protection of the data subject's rights.

12.2. Personal data cross-border transfer to the territory of foreign states that do not meet the above requirements can be carried out only if there is a written consent of the data subject for the cross-border transfer of his/her personal data and/or execution of an agreement to which the data subject is a party.

13. Personal Data Privacy

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

14. Final Provisions

14.1. The User can receive any clarifications on issues of interest regarding his/her personal data processing by contacting the Operator via e-mail

14.2. This document will reflect any changes in the personal data processing policy by the Operator. The policy is valid indefinitely until it is replaced by a new version.

14.3. The current version of the Policy is publicly available on the Internet at