PERSONAL DATA PROCESSING POLICY
1. GENERAL PROVISIONS
This Personal Data Processing Policy (hereinafter referred to as the “Policy”) is drawn up in accordance with the requirements of Federal Law No. 152-FZ dated July 27, 2006 “On Personal Data” and defines the procedure for processing personal data and the measures to ensure the security of personal data that Self-Employed Individual Saaryan Anastasia Leonidovna, Tax ID (INN): 503 228 710 110 (hereinafter referred to as the “Operator”), may receive about the User while using the website https://sorry-retouch.ru (hereinafter referred to as the “Website”).
By registering on the Website and/or using the Website, the User expresses full consent to the terms of this Policy.
The User may obtain any clarifications regarding issues related to the processing of their personal data by contacting the Operator via email at Saaryan.nastya@gmail.com (hereinafter referred to as the “Operator’s Email”).
2. KEY TERMS USED IN THE POLICY
Personal Data — any information relating directly or indirectly to an identified or identifiable natural person (the subject of personal data).
User — a natural person, the subject of personal data, using the Website for its functional purpose.
Cookies — small data fragments related to personal data that are stored in the browser of a computer, mobile phone, or other device after the User visits the Website.
Automated Processing of Personal Data — processing of personal data using computing equipment.
Blocking of Personal Data — temporary suspension of the processing of personal data (except where processing is necessary to clarify personal data).
Personal Data Information System — a set of personal data contained in databases, as well as information technologies and technical means ensuring their processing.
Depersonalization of Personal Data — actions as a result of which it is impossible to determine, without the use of additional information, the ownership of personal data by a specific User or another subject of personal data.
Processing of Personal Data — any action (operation) or set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
Provision of Personal Data — actions aimed at disclosing personal data to a specific person or an indefinite circle of persons.
Distribution of Personal Data — any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or making personal data available to an unlimited number of persons, including publication in mass media, placement in information and telecommunication networks, or providing access to personal data by any other means.
Destruction of Personal Data — any actions as a result of which personal data are irreversibly destroyed, making it impossible to restore the content of personal data in the personal data information system and/or resulting in the destruction of physical media containing personal data.
3. SUBJECT OF THE POLICY
3.1. The User’s use of the Website signifies agreement with this Policy and the terms of processing the User’s personal data. Consent to this Policy constitutes the personal data subject’s consent to the processing of their personal data.
3.2. If the User disagrees with the terms of this Policy, the User must cease using the Website.
3.3. Personal data permitted for processing under this Policy are provided by the User voluntarily by filling in the User data forms on the Website.
3.4. Personal data permitted for processing under this Privacy Policy are provided by the User by filling in forms on the Operator’s Website and include the following information:
- User’s first and last name;
- User’s contact phone number;
- User’s email address;
- links to the User’s social media profiles;
- cookies.
The above data are hereinafter collectively referred to as “Personal Data”.
4. PURPOSES OF PERSONAL DATA PROCESSING
4.1. The processing of the User’s personal data is carried out in accordance with the legislation of the Russian Federation. The Operator processes the User’s personal data for the following purposes:
- identification of a party within the framework of agreements and contracts concluded with the Operator;
- provision of services to the User, access to the Website and services;
- communication with the User, sending emails to the User at the time of registration on the Website and/or at the time of receiving payment from the User, sending notifications and requests in connection with the performance of concluded agreements;
- settlements with the User within the framework of concluded contracts;
- confirmation of the accuracy and completeness of the personal data provided by the User;
- providing the User with access to the websites or services of the Operator’s partners in order to receive products, updates, and services;
- carrying out advertising activities with the User’s consent;
- providing effective customer and technical support to the User in case of issues related to the use of the Website.
4.2. The User may opt out of receiving informational messages at any time by sending an email to the Operator’s Email with the subject line “Refusal of notifications”.
5. RIGHTS AND OBLIGATIONS OF THE PARTIES
5.1. The Operator has the right to:
- receive reliable information from the User containing personal data.
5.2. The Operator is obliged to:
- process personal data in accordance with the procedure established by the legislation of the Russian Federation;
- ensure the confidentiality of personal data, not disclose them without the User’s prior written consent, and not sell, exchange, publish, or disclose the User’s personal data by other means, except as provided for by this Policy;
- use the obtained information exclusively for the purposes specified in this Privacy Policy;
- consider the User’s requests regarding personal data processing and provide reasoned responses;
- take measures to clarify or destroy the User’s personal data upon lawful and justified requests from the User (or their legal representative);
- organize the protection of personal data in accordance with the requirements of the legislation of the Russian Federation.
5.3. The User has the right to:
- receive full information about their personal data processed by the Operator;
- request clarification, blocking, or destruction of their personal data if such data are incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated processing purpose;
- submit a request to the Operator for clarification, modification, or blocking of personal data by sending a notification to the Operator’s Email;
- withdraw consent to the processing of personal data;
- take measures provided by law to protect their rights;
- exercise other rights provided for by the legislation of the Russian Federation.
5.4. The User is obliged to:
- provide the Operator with only accurate personal data about themselves.
6. PROCEDURE FOR COLLECTION, STORAGE, TRANSFER, AND OTHER TYPES OF PERSONAL DATA PROCESSING
6.1. The processing of the User’s personal data is carried out without time limitation by any lawful means, including in personal data information systems using automated and non-automated processing tools.
6.2. The Operator grants access to the User’s personal data only to contractors and affiliated persons who require this information to ensure the operation of the Website and the provision of services under concluded agreements.
6.3. The security of personal data processed by the Operator is ensured through the implementation of legal, organizational, and technical measures necessary to fully comply with the requirements of applicable personal data protection legislation.
6.4. The Operator ensures the safety of personal data and takes all possible measures to prevent unauthorized access to personal data.
6.5. If inaccuracies in personal data are identified, the User may update them independently by sending a notification to the Operator’s Email with the subject line “Personal data update”.
6.6. The Operator has the right to store (archive) and compile documents and personal data.
6.7. The User may withdraw their consent to the processing of personal data at any time by sending a notification to the Operator’s Email with the subject line “Withdrawal of consent to personal data processing”.
6.8. The Operator has the right to transfer the User’s personal data to third parties in the following cases:
6.8.1. the User has given consent to such actions;
6.8.2. the transfer is necessary for the User to use a specific service or to perform a specific agreement or contract with the User;
6.8.3. the transfer is provided for by Russian or other applicable legislation within the framework of the procedure established by law.
7. COOKIES
7.1. The following cookies are collected on the Website:
7.1.1. Technical cookies — the collection of these cookies cannot be disabled during visits, as they are necessary for the proper operation and full functionality of the Website.
7.1.2. Analytical cookies — collected through web analytics tools for the purpose of general analysis of Website usage and obtaining data on User actions to improve functionality.
7.2. Purposes of cookie collection:
- authentication of Website Users;
- as part of security measures used to protect user accounts, including prevention of fraudulent use of login credentials, as well as protection of the Website as a whole;
- data analytics purposes.
7.3. If the User does not wish cookies to be stored on their device, this option can be disabled in browser settings. Stored cookies can also be deleted at any time via browser system settings. The User may configure the browser to accept or reject all cookies by default or only cookies from the Website. Disabling cookies may result in limited access to certain functions and tools of the Website.
8. DISPUTE RESOLUTION
8.1. Prior to filing a lawsuit regarding disputes arising from relations between the Website User and the Operator, it is mandatory to submit a claim (a written proposal for voluntary dispute resolution).
8.2. The recipient of the claim shall notify the claimant in writing of the results of the claim review within 30 (thirty) calendar days from the date of receipt of the claim.
8.3. If no agreement is reached, the dispute shall be referred to the court in accordance with the current legislation of the Russian Federation.
8.4. The applicable law governing this Policy and relations between the User and the Operator shall be the legislation of the Russian Federation.
9. FINAL PROVISIONS
9.1. The Operator has the right to make changes to this Policy without the User’s consent.
9.2. The new version of the Personal Data Processing Policy shall enter into force from the moment it is published on the Website, unless otherwise provided by the new version of the Privacy Policy.
9.3. The current version of the Policy is freely available on the Internet at: https://site/legal-privacy