Last Updated:
«27» July 2023

1. GENERAL PROVISIONS

1.1. The Privacy Policy (hereinafter – the Policy) is published to inform about the policy implemented by the Operator regarding the processing of personal data of the Operator's website users – subjects of personal data (hereinafter – the User).

1.2. The Policy is developed and published by the Operator in accordance with Clause 2 Part 1 Article 18.1 of the Federal Law of July 27, 2006 No. 152-FZ "On Personal Data" (hereinafter – the Federal Law "On Personal Data").

1.3. The Policy is developed to implement the requirements of legislation in the field of processing and protecting personal data and aims to ensure the protection of the rights and freedoms of individuals during the processing of their personal data, including the protection of privacy, personal, and family secrets.

1.4. The Policy contains information subject to disclosure in accordance with Part 1 Article 14 of the Federal Law "On Personal Data", is a public document, and is located at: https://minkychic.com/.

1.5. To keep the documents defining the Operator's policy regarding the processing of personal data up to date, the Operator may amend this Policy at any time by publishing the relevant changes. This Policy can only be changed by publishing an amended document on the Website.

2. BASIC TERMS

2.1. Personal Data – any information relating to an identified or identifiable individual (subject of personal data).

2.2. Processing of Personal Data – any action (operation) or a set of actions (operations) performed using automated means or without such means with personal data, including collection, recording, systematization, accumulation, storage, updating (modification), extraction, use, anonymization, blocking, deletion, destruction of personal data.

2.3. Personal Data Operator – a person or entity that, individually or jointly with other persons, organizes and (or) performs the processing of personal data, as well as determines the purposes of processing personal data, the composition of personal data to be processed, and actions (operations) performed with personal data of Users.

2.4. Confidentiality of Personal Data – the obligation of the Operator and other persons who have access to personal data not to disclose or distribute them to third parties without the consent of the personal data subject unless otherwise provided by federal law.

2.5. Website – a set of software for electronic computers and other information contained in an information system, access to which is provided through the information and telecommunication network of the Internet and located at: https://minkychic.com/. The Website may contain links to other internet resources. The Operator is not responsible for the confidentiality of information posted by the User on such resources.

3. USER RIGHTS

3.1. The User has the right:

3.1.1. To receive personal data related to the User and information regarding their processing;

3.1.2. To clarify, block, or destroy their personal data if they are incomplete, outdated, inaccurate, illegally obtained, or are not necessary for the stated purpose of processing;

3.1.3. To withdraw their consent to the processing of personal data;

3.1.4. To protect their rights and legitimate interests, including compensation for damages and moral harm in court;

3.1.5. To appeal actions or inactions of the Operator to the authorized body for the protection of the rights of subjects of personal data or in court.

4. GROUNDS FOR PROCESSING PERSONAL DATA

4.1 The Operator processes personal data on a lawful and fair basis to perform functions, powers, and duties assigned by legislation, to exercise the rights and legitimate interests of the Operator and the User.

4.2 The Operator receives personal data directly from the User and processes them exclusively with the User's consent. The Operator receives personal data of the User during their interaction with certain functions of the Website.

5. PROCESSING OF USERS' PERSONAL DATA

5.1. This Policy establishes the obligations of the Operator to maintain the confidentiality and protect the personal data provided by the User while using the Website.

5.2. The Operator processes Users' personal data in compliance with the laws of the Russian Federation and for the following purposes:

5.2.1. Conclusion and execution of contracts.

5.2.2. Informing about new products and services.

5.2.3. Preparation of personalized offers.

5.2.4. Conducting advertising activities.

5.3. The Operator processes Users' personal data with their consent, obtained by checking the box indicating their agreement with the terms of this Agreement.

5.4. Categories of personal data collected by the Operator to achieve the purposes specified in Clause 5.2 of the Policy:

5.4.1. Last name, first name, patronymic.

5.4.2. Contact phone number.

5.4.3. Email address.

5.4.4. User identifier stored in cookies.

5.5. The Operator does not process special categories of Users' personal data.

5.6. The Operator does not process biometric categories of Users' personal data.

5.7. This Policy applies only to information processed during the use of the Website. The Operator does not control and is not responsible for the processing of information by third-party websites and services to which Users may go via links available on the Website.

5.8. The Operator does not verify the accuracy of the personal data provided by the User and cannot assess their legal capacity. However, the Operator assumes that the User provides accurate and sufficient personal data and keeps them up to date.

6. PROCESSING OF USERS' PERSONAL DATA USING COOKIE FILES

6.1. Cookies transmitted to Users' technical devices may be used to provide personalized functions of the Website, for personalized advertising shown to Users, for statistical and research purposes, as well as to improve the Website.

6.2. Users acknowledge that the equipment and software they use to visit websites on the Internet may have the function of prohibiting operations with cookies (for any sites or for certain sites), as well as deleting previously received cookies.

6.3. The Operator may stipulate that providing certain functions of the Website is possible only if Users allow the acceptance and receipt of cookies.

6.4. The structure of the cookie, its content and technical parameters are determined by the Operator and may be changed without prior notice to Users.

6.5. Counters placed on the site or the Site application can be used to analyze User cookies, to collect and process statistical information about the use of the Site, as well as to ensure the performance of the Site as a whole or its individual functions in particular. Technical parameters of the meters are determined by the Operator and may be changed without prior notice to Users.

7. CONDITIONS FOR PROCESSING USERS' PERSONAL DATA

7.1. The processing of Users’ personal data is limited to the period for achieving the purposes of processing.

7.2. The Operator processes Users’ personal data in an automated manner using computer technology.

7.3. Actions for processing personal data include collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion and destruction.

7.4. With regard to the personal data of Users, their confidentiality is maintained, except in cases where Users voluntarily provide information about themselves for general access to an unlimited number of persons.

7.5. The Operator has the right to transfer the User’s personal data to third parties in the following cases:

7.5.1. Users have expressed consent to such actions;

7.5.2. The transfer is necessary for Users to use certain functions of the Site or for the execution of a certain agreement or contract;

7.5.3. The transfer is provided for by Russian or other applicable legislation within the framework of the procedure established by law;

7.5.4. Such a transfer occurs as part of the sale or other transfer of a business (in whole or in part), and all obligations to comply with the terms of this Policy in relation to the personal data received by it are transferred to the acquirer;

7.5.5. As a result of processing the personal data of Users by depersonalizing them, anonymized statistical data was obtained, which is transferred to a third party to conduct research, perform work or provide services on behalf of the Operator;

7.5.6. Personal data of Users may be transferred to authorized government bodies of the Russian Federation on the grounds and in the manner established by the current legislation of the Russian Federation.

7.6. When processing personal data of Users, the Operator is guided by:

7.6.1. Federal Law of July 27, 2006 No. 152-FZ “On Personal Data”;

7.6.2. Decree of the Government of the Russian Federation dated November 1, 2012 No. 1119 “On approval of requirements for the protection of personal data during their processing in personal data information systems”;

7.6.3. Order of the FSTEC of Russia dated February 18, 2013 No. 21 “On approval of the composition and content of organizational and technical measures to ensure the security of personal data when processed in personal data information systems”;

7.6.4 Order of the FSB of Russia dated July 10, 2014 No. 378 “On approval of the composition and content of organizational and technical measures to ensure the security of personal data during their processing in personal data information systems using cryptographic information protection tools necessary to fulfill those established by the Government Russian Federation requirements for the protection of personal data for each level of security.”

7.6.5. The Operator takes the necessary organizational and technical measures to protect the User’s personal data from unauthorized or accidental access, destruction, modification, blocking, copying, distribution, as well as from other unlawful actions of third parties.

7.6.6. The Operator, together with the User, takes all necessary measures to prevent losses or other negative consequences caused by the loss or disclosure of personal data.

8. Mandatory data storage

8.1. The rights of Users provided for in this Policy may be limited in accordance with the requirements of current legislation. In particular, such restrictions may provide for the obligation of the Operator to retain information changed or deleted by Users for a period established by law, and/or transfer such information in accordance with the legally established procedure to a government agency.

9. INFORMATION ABOUT ENSURING THE SECURITY OF PERSONAL DATA

9.1. The operator appoints a person responsible for organizing the processing of personal data to fulfill the duties provided for by the Federal Law “On Personal Data” and the regulatory legal acts adopted in accordance with it.

9.2. The operator applies a set of legal, organizational and technical measures to ensure the security of personal data to ensure the confidentiality of personal data and their protection from unlawful actions:

9.2.1. Establishes rules for access to personal data processed in the Operator’s information system, and also ensures registration and accounting of all actions with it;

9.2.2. Assesses the harm that may be caused to Users in case of violation of the Federal Law