Version 001-2023, date: 20th June 2023.
1.General provisions.
This Privacy Policy, or Personal Data Processing Policy, (hereinafter referred to as the Policy) is compiled in accordance with the requirements of the Russian Federation Law 152-FZ, dated 27th July 2006 “About Personal Data” (hereinafter referred to as the Personal Data Law) and defines the procedure for processing personal data and measures to ensure the security of all personal data collected by Private Entrepreneur Polina Mircheva (hereinafter referred to as the Operator).
1.1. The Operator sets as its most important goal and condition for the implementation of its activities the respect of the rights and freedoms of every man or woman, and every citizen in the processing of his/her personal data, including the protection of their rights to privacy, personal and family secrets.
1.2. This Policy applies to all information that the Operator can obtain about the people who visit the Operator’s website https://polinamircheva.com . Basic terms used in this Policy.
2. Basic terms used in this Policy.
2.1. Automated processing of personal data – means processing of personal data using computer technology and special software.
2.2. Blocking of personal data – means a temporary suspension of processing of personal data (except in cases where processing is necessary to clarify personal data).
2.3. Website – means a set of graphic and informational materials, as well as computer software and databases that ensure their availability on the Internet at the website address (URL – Uniform Resource Locator) https://polinamircheva.com/ .
2.4. Personal Data Information System means a set of personal data contained in databases, information technologies and technical means that ensure data processing.
2.5. Depersonalization of personal data — means actions as a result of which it is impossible to determine without using additional information whether personal data belongs to a specific User or another subject of personal data.
2.6. Personal data processing – means any action (operation) or a 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), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
2.7. Operator – means Private Entrepreneur Polina Mircheva and her authorized employees, who independently or jointly organize and process personal data, as well as determine the purposes of personal data processing, the composition of personal data to be processed, actions (operations) performed with personal data.
2.8. Personal data – means any information related directly or indirectly to a specific or identifiable User of the Website https://polinamircheva.com/ .
2.9. Personal data which has been authorized to be disclosed by the subject of personal data – means personal data which the subject of has given its consent to be disclosed in accordance with the procedure provided for by the Personal Data Law (hereinafter – personal data authorized for distribution).
2.10. User – means any visitor of the website https://polinamircheva.com/ .
2.11. Provision of personal data – means actions aimed at disclosure of personal data to a certain person or a certain circle of persons.
2.12. Dissemination of personal data – means any actions aimed at disclosure of personal data to an indefinite circle of persons (transfer of personal data) or familiarization with personal data of an unlimited number of persons, including the publication of personal data in the media, posting in information and telecommunications networks, or providing access to personal data in any other way.
2.13. Cross–border transfer of personal data means the transfer of personal data to the territory of a foreign state to an authority of a foreign state, a foreign individual, or a foreign legal entity.
2.14. Destruction of personal data – means any actions as a result of which personal data is irrevocably destroyed with the inability to further restore the content of personal data in the personal data information system and (or) the material carriers of personal data are destroyed.
3. Operator’s basic rights and obligations.
3.1. Operator’s rights:
– receive reliable and true information and/or documents containing personal data from the subject of personal data;
– if the personal data subject withdraws his/her consent to the processing of personal data, the Operator has the right to continue processing his/her personal data further if it is in line with the provisions of the Personal Data Law;
– determine at will the composition and list of measures necessary and sufficient to ensure the fulfillment of its obligations stipulated by the Personal Data Law and by other regulatory legal acts adopted in accordance with it, unless otherwise provided by the Russian Federation legislation.
3.2. Operator’s rights:
– receive reliable and true information and/or documents containing personal data from the subject of personal data;
– if the personal data subject withdraws his/her consent to the processing of personal data, the Operator has the right to continue processing his/her personal data further if it is in line with the provisions of the Personal Data Law;
– respond to inquiries and requests from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
– upon request provide the authorized state body in charge of personal data protection rights all necessary information within 30 (thirty) days from the date of receipt of such a request;
– publish or otherwise provide unrestricted access to this Policy;
– take legal, organizational and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, dissemination of personal data, as well as from other illegal actions with respect to personal data;
– suspend the transfer (distribution, provision, access) of personal data, stop processing and destroy personal data in the manner and in cases provided for by the Personal Data Law;
– perform other duties stipulated by the Personal Data Law.
4. Personal data subjects’ basic rights and obligations.
4.1. Personal data subjects’ basic rights:
– receive information concerning the processing of his/her personal data, except in cases provided for by Federal laws. The information shall be provided to the personal data subject by the Operator in an accessible form, and it should not contain personal data related to other personal data subjects, except in cases where there are legitimate grounds for disclosure of such personal data. The list of information and the procedure for obtaining it is established by the Personal Data Law;
– require that the Operator clarifies his/her personal data, block or destroy them if the personal data are incomplete, outdated, inaccurate, illegally obtained or are not necessary for the stated purpose of processing, as well as take measures provided by law to protect their rights;
– demand a prior consent when processing personal data in order to promote goods, works and services on the market;
– revoke consent to the processing of personal data;
– appeal to the state body authorized to oversee personal data rights or in court against illegal actions or inaction of the Operator when processing his/her personal data;
– exercise other rights provided for by the legislation of the Russian Federation.
4.2. Personal data subjects’ obligations:
– provide the Operator with reliable and true personal data;
– timely notify the Operator about any changes in his/her personal data
4.3. Natural persons who have provided the Operator with false information about themselves or information about another natural person(s) without the latter’s consent shall bear responsibility in accordance with the legislation of the Russian Federation.
5. The Operator may process the following personal data of the User:
5.1. Given (first) name, father’s name, surname.
5.2. Email.
5.3. Phone numbers, including mobile ones.
5.4. Delivery address.
5.5. Sex
5.6. Date of birth.
5.7. Additional collection of anonymous data takes place on the website about Users (including cookies), applying Internet statistics (Yandex Metric and Google Analytics and others).
5.8. The above data (5.1. – 5.7.) hereinafter shall be referred to as «Personal Data».
5.9. The Operator shall not process under any circumstances special categories of personal data concerning race, nationality, political views, religious or philosophical beliefs, intimate life.
5.10. Processing of personal data permitted for distribution from among the special categories of personal data specified in Part 1 of Article 10 of the Personal Data Law is allowed only if prescriptions of Article 10.1 of the Personal Data Law are strictly followed.
5.11. The User’s consent to the processing of his/her personal data permitted for distribution is issued separately from other consents to the processing of his/her personal data. At the same time, all conditions stipulated in Article 10.1. of the Personal Data Law must be observed. The requirements for the content of such consent are established by the authorized state body for the protection of the rights of personal data subjects.
5.11.1. The User gives directly to the Operator his/her consent to the processing of personal data which may be distributed.
5.11.2. The Operator is obliged to publish exhaustive information about the terms and conditions of data processing including any restrictions and special requirements within three working days from the date of receipt of the User’s consent to have his/her personal data allowed for distribution processed by an unlimited number of persons.
5.11.3. The transfer (distribution, provision, access) of personal data authorized by the personal data subject for distribution must be terminated immediately upon receipt of a formal request of the personal data subject. This formal request must include User’s surname, first name, patronymic (if any), contact information (phone number, email address or postal address), as well as a list of personal data processing of which is subject to termination. The personal data specified in this request can only be processed by the Operator to whom it is sent.
5.11.4. The consent to the processing of personal data permitted for distribution becomes invalid from the moment the Operator receives the request specified in clause 5.11.3 of this Policy.
6. Principles of personal data processing.
6.1. The processing of personal data shall be carried out on a legal and fair basis.
6.2. The processing of personal data shall be limited to the achievement of specific, predetermined, and legitimate goals. Processing of personal data incompatible with the purposes of personal data collection is not allowed.
6.3. It is not allowed to combine databases containing personal data, the processing of which is carried out for purposes incompatible with each other.
6.4. Only personal data that meets the purposes of their processing shall be subject to processing.
6.5. The content and volume of the processed personal data shall correspond to the stated purposes of processing. Excessive processing of personal data if not in line with the stated purposes is not allowed.
6.6. Accuracy and adequacy of personal data must be ensured, and, if necessary, data updates must be provided in order to meet data processing goals. The Operator shall take all necessary measures and/or shall ensure that such measures are taken to delete or clarify incomplete or inaccurate data.
6.7. The storage of personal data is carried out in a form that allows you to determine the subject of personal data, no longer than the purposes of personal data processing require, unless the storage period of personal data is established by a federal law, an agreement to which the party, beneficiary or guarantor is the subject of personal data. The processed personal data shall be destroyed or depersonalized upon achievement of the processing goals or in case of loss of the need to achieve these goals, unless otherwise provided by a federal law.
7. Personal data processing goals.
7.1. User’s personal data processing goals:
– Providing the User with useful information by sending emails;
– Providing the User with access to the goods, services, information and/or materials contained on the website https://polinamircheva.com/.
– Study Users’ preferences to improve the Operator’s product line and the product offer to the User.
7.2. The Operator also has the right to send notifications to the User about new products and services, special offers and various events. The User can always reject to receive information messages by sending an email to the Operator using dedicated Operators email address Customer.feedback@polinamircheva.com and Subject: “Rejection of notifications about new products, services and special offers”.
7.3. Depersonalized Users’ data acquired using Internet statistics services are used to accumulate information about Users’ actions on the website, improve the quality of the website and its content.
8. Legal grounds for personal data processing.
8.1. The following documents shall from legal grounds for personal data processing:
– Russian Federation Laws, other regulatory legal acts in the field of personal data protection;
– Operator’s charter documents;
– Users’ consent to the processing of their personal data, to the processing of personal data which may be distributed.
– This Policy.
8.2. The Operator processes the Users’ personal data only if they are filled in and/or sent by the Users independently through special forms located on the website https://polinamircheva.com/ or sent to the Operator via e-mail. By filling out the appropriate forms and/or by sending their personal data to the Operator, the User agrees with this Policy.
8.3. The Operator processes depersonalized data about the User if this is allowed in the User’s browser settings (saving cookies and the use of JavaScript technology enabled).
8.4. The User takes an independent decision to provide or not his/her personal data and gives his/her personal consent at will and in his/her best interests.
9. Personal data processing terms and conditions.
9.1. Personal data processing is carried out only if a relevant User’s consent has been duly received.
9.2. Personal data processing is required for the execution of a sale contract between the User and the Operator.
9.3. Personal data processing is necessary to exercise the rights and legitimate interests of the Operator or third parties or to achieve socially significant goals, provided that the rights and freedoms of the personal data subject are not violated.
10. Порядок сбора, хранения, передачи и других видов обработки персональных данных.
Безопасность персональных данных, которые обрабатываются Оператором, обеспечивается путем реализации правовых, организационных и технических мер, необходимых для выполнения в полном объеме требований действующего законодательства в области защиты персональных данных.
10.1. Procedure for collection, storage, transfer and other types of personal data processing.The security of Users’ 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 Russian federal legislation in the field of personal data protection.
10.2. The Users’ personal data will never, under any circumstances, be transferred to third parties, except in cases related to the implementation of Russian Federal legislation or if the subject of personal data has given his/her consent to the Operator to transfer data to a third party to fulfill obligations under a civil contract.
10.3.In case of inaccuracies in personal data, the User can update them independently by sending a notification to the Operator using dedicated Operator’s email address Customer.feedback@polinamircheva.com and Subject: “Update of personal data” or by making appropriate changes himself/herself to his/her Personal Account on the website https://polinamircheva.com/.
10.4. The timeframe of personal data processing is determined by the achievement of the goals for which personal data has been collected unless another term is stipulated by a contract or Russian legislation. The User can withdraw his/her consent to the personal data processing at any time by sending a notification to the Operator using dedicated Operator’s email address Customer.feedback@polinamircheva.com and Subject: “Withdrawal of consent to the personal data processing”.
10.5. All information collected by third-party services, including payment systems, communication facilities and other service providers, is stored and processed by these third-party independent bodies (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data and/or the User is obliged to familiarize himself/herself with these documents in a timely manner. The Operator (Private Entrepreneur Polina Mircheva) shall not bear any responsibility for the actions of these third-party independent bodies (Operators.
10.6. The restrictions established by the subject of personal data on the transfer (other than granting access), as well as on the processing or processing conditions (other than obtaining access) of personal data permitted for distribution, do not apply in cases of personal data processing in the state and/or public interests defined by the Russian Federation legislation.
10.7. The Operator shall always ensure the confidentiality of personal data while processing it.
10.8. The Operator shall store personal data in a form that allows to determine the subject of personal data, no longer than the purposes of personal data processing require, unless the period of personal data storage is established by a Federal Law, an agreement to which the party, beneficiary or guarantor is the subject of personal data.
10.9. Personal data processing shall be terminated upon achievement of the purposes/goals of personal data processing, or upon expiration of the consent of the personal data subject, or upon withdrawal of consent by the personal data subject, as well as upon identification of unlawful processing of personal data.
11. List of actions performed by the Operator with the received personal data.
11.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), extracts, uses, transfers (distribution, provision, access), depersonalizes, blocks, deletes and destroys personal data.
11.2. The Operator performs automated processing of personal data with or without receiving and/or transmitting the received information via information and telecommunication networks.
12. The Operator shall not carry out any cross-border transfer of personal data.
13. Confidentiality of personal data.
The Operator, her employees and other persons who have gained access to personal data must not disclose it to third parties and must not distribute personal data without the consent of the subject of personal data, unless otherwise provided by the Russian Federal laws.
14. Final provisions
14.1. The User has the right to receive any clarifications about questions of interest regarding the processing of his personal data. Any such questions should be addressed to the Operator by e-mail Customer.feedback@polinamircheva.com .
14.2. This document will reflect any changes to the Operator’s personal data processing Policy. The Policy is valid indefinitely until it is replaced by a new version.
14.3. The current version of the Policy is published on the Internet at: https://polinamircheva.com/ with free unlimited access.
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