Privacy Policy

PERSONAL DATA PROCESSING POLICY

POLICY OF SPECTRUM LLC REGARDING THE PROCESSING OF PERSONAL DATA

GENERAL PROVISIONS

When carrying out its activities, SPECTRUM LLC, location address: Russian Federation, Moscow, 101000, Moscow, ext. ter. Basmanny Municipal District, Lubyansky proezd, 27/1, building 1, floor 4, room 109 (hereinafter referred to as the Company) enters into relationships related to the processing of personal data and is, therefore, an operator of personal data. The policy regulates the procedure and conditions for processing personal data of personal data subjects, the rights and obligations of personal data subjects.

The terms used in this Policy are used in the meanings established by the Federal Law of the Russian Federation “On Personal Data” and the norms of the current legislation of the Russian Federation.
The policy was developed based on the requirements of regulatory and legal documents in the field of protection and processing of personal data: the Constitution of the Russian Federation; Civil Code, Federal Laws of the Russian Federation “On Personal Data”, “On Security”, “On Information, Information Technologies and Information Protection”, “On Trade Secrets”, “On Communications”, “On Limited Liability Companies”, “On Technical regulation", Resolutions of the Government of the Russian Federation, Orders of the FSTEC of Russia and other regulatory legal acts of the Russian Federation.

The basis for the processing of personal data is Consent to the processing of personal data in the form of Appendix No. 1 to this Policy.

OBJECTIVES AND PRINCIPLES OF PROCESSING PERSONAL DATA
The Company processes personal data for the following purposes:
— for registration/authorization on the website vitaccishop.ru;
— for the execution of an agreement to which the subject of personal data is a party or beneficiary or guarantor;
— to evaluate and analyze the Company’s work in the process of fulfilling its obligations under the Agreement;
— to determine the winner in incentive events conducted by the Company;
— carrying out advertising and marketing campaigns, including advertising and marketing campaigns of third parties;
— identification of users of the Company’s website on the Internet;
— fulfillment of other requirements of the legislation of the Russian Federation.
- the company has the right to send advertising and informational messages to the Buyer via e-mail with information about discounts, promotions, new arrivals only if the Buyer subscribes to the newsletter in the “Subscribe to our newsletter and get a 10% discount” section. The frequency of mailings is determined by the Seller independently, unilaterally.

CATEGORIES OF PERSONAL DATA SUBJECTS, THEIR RIGHTS AND CATEGORIES OF PROCESSED PERSONAL DATA
The company processes personal data of the following categories of subjects:
— individuals – clients of the Company who have consented to the processing of personal data by the Company;
— visitors to the Company’s website on the Internet who have consented to the processing of personal data by the Company;
— users of the Company’s applications/services who have consented to the processing of personal data by the Company;
- individuals who contacted the Company with requests (including claims, letters), including through the contact center, chat, social networks, who consented to the processing of personal data by the Company;
— representatives of the above-mentioned entities authorized on the basis of a power of attorney who have given consent to the processing of personal data by the Company.

Rights of personal data subjects
— receive complete information about their personal data processed by the Company;
— clarify your personal data, demand their blocking or destruction if the personal data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated purpose of processing;
— revoke consent to the processing of personal data in the manner and manner established in section 5 of this Policy;
— exercise other rights provided for by the legislation of the Russian Federation;
— the buyer has the right to refuse to receive advertising and other information without explaining the reasons for the refusal at any time. Service messages informing the Buyer about the order and the stages of its processing are sent automatically and cannot be rejected by the Buyer.

Categories of personal data
The company has the right to process the following categories of personal data: Last name, first name, patronymic (including previous ones); floor; Date of Birth; address of residence, passport details or data of another identification document (type, series and number of the document, date of issue of the document, name of the authority that issued the document, department code (if any)); contact information (phone number, email address); photographs and other specified information.

PROCEDURE AND CONDITIONS FOR PROCESSING PERSONAL DATA
Processing of personal data is carried out both using automation tools and without the use of such tools. Processing of personal data includes, but is not limited to: collection; recording; systematization; accumulation; storage; clarification (update, change); extraction; usage; transmission (distribution, provision, access); depersonalization; blocking; deletion; destruction.

Conditions for processing personal data Consent to the processing of personal data by the Company can be given by the subject of personal data or his representative in any form that allows confirmation of its receipt, unless otherwise provided by law.

Terms for processing personal data The period for processing personal data of the Company's clients, consent to the processing of personal data and other above-mentioned actions is provided by the subject of personal data without limitation of validity. The period for processing personal data of other personal data subjects is determined by the Company as the period necessary to achieve the purposes of processing, unless otherwise specified in the consent to the processing of personal data provided by the personal data subject.

Personal data is collected in the following ways:
- entering or otherwise communicating personal data directly by the subject of personal data on the Company’s website on the Internet, through the Mobile application, contact center or social networks;
— collection via e-mail or other electronic communication channels, questionnaires and other documents in the form established by the Company, containing personal data of subjects;
— collection of questionnaires and other documents personally signed by the subject of personal data in the form established by the Company, containing the personal data of the subjects;
— The company has the right to use “cookies” technology. "Cookies" do not contain confidential information and are not transferred to third parties. The policy regarding cookies is governed by the Cookies Policy;
— The Company receives information about the IP address of the Site visitor. This information is not used to identify the visitor to the Site;
— Make recordings of telephone conversations (with notification that a recording is being made), as well as save records of correspondence in written communication channels (email, SMS messages and instant messenger messages with the Buyer. In accordance with paragraph 4 of Article 16 of the Federal Law “On Information , information technology and information protection" The Seller undertakes to: prevent attempts of unauthorized access to information and/or transfer it to persons not directly related to the execution of orders; to promptly detect and suppress such facts;
— The fact of checking the box that you have read and agree with this Policy on the website vitaccishop.ru, taking into account prior reading of this Policy, is a sufficient form of consent to the processing of personal data of the site user. Thus, the Buyer confirms that his consent is specific, informed and conscious. The subject is obliged to provide reliable information about himself and promptly report changes in his personal data. The Company has the right to verify the accuracy of the data provided by the subject, comparing this data with documents already available to the Company.

Personal data is stored in the following ways:
— on paper; in the form of questionnaires and other documents signed by the subject of personal data in the form established by the Company on paper; on electronic media; on electronic media located on the Company’s servers, as well as backup systems; on electronic media hosted on servers leased by the Company from hosting providers. In the process of storing personal data, the Company ensures their safety and access to personal data only by authorized persons.

Confidentiality and security of personal data
The company does not disclose or distribute personal data to third parties without the consent of the subject of personal data, unless otherwise provided by the legislation of the Russian Federation. The company takes all necessary measures to ensure the security of personal data established by the legislation of the Russian Federation, including:
— identifies threats to the security of personal data during their processing;
— adopts local regulations and other documents regulating relations in the field of processing and protection of personal data;
— appoints persons responsible for ensuring the security of personal data in the structural divisions and information systems of the Operator;
— creates the necessary conditions for working with personal data;
— organizes records of documents containing personal data;
— organizes work with information systems in which personal data is processed;
— stores personal data under conditions that ensure their safety and prevent unauthorized access to them;
— organizes training for the Operator’s employees processing personal data.

Transfer of personal data
When carrying out its activities, the Company may transfer personal data of subjects in strict accordance with the requirements of the legislation of the Russian Federation, local regulations and with proper security of this data. The transfer of personal data can be carried out either using automation tools or without the use of such tools.

Processing of personal data for the purpose of promoting goods, works, services
Processing of personal data for the purpose of promoting goods, works, services on the market by making direct contacts with potential consumers via communication means can be carried out by the Company only with the prior consent of the subject of personal data and is terminated upon his request.

Blocking of personal data The company blocks personal data in the following cases:
— when the subject of personal data requests compliance with their legal rights. The choice of method for blocking personal data is determined by the responsible employee based on the specific conditions for processing personal data, including the capabilities of the software used in processing.

Termination of processing and destruction of personal data
The processing of personal data is terminated or its termination is ensured if the processing of personal data is carried out by another person acting on behalf of the Company, and the collected personal data is destroyed within the time limits established by the legislation of the Russian Federation, in the following cases, unless otherwise established by the legislation of the Russian Federation:
- upon expiration of the established period for processing personal data;
— upon achieving the processing goals or when there is no longer a need to achieve them;
- at the request of the subject of personal data or the authorized body for the protection of the rights of subjects of personal data - if the personal data is incomplete, outdated, unreliable, illegally obtained or is not necessary for the stated purpose of processing;
— when the subject of personal data withdraws consent to the processing of his personal data, if such consent is required in accordance with federal law;
— if it is impossible for the Company to eliminate violations committed when processing personal data.

APPEALS AND INQUIRIES REGARDING ISSUES OF PROCESSING PERSONAL DATA
General provisions
The subject of personal data has the right to receive information about the Company, its location, whether the Company has personal data related to the relevant subject of personal data, as well as to become familiar with such personal data. The subject of personal data has the right to demand from the Company clarification of his personal data, blocking or destruction of it if the personal data is incomplete, outdated, unreliable, illegally obtained or is not necessary for the stated purpose of processing, as well as take measures provided by law to protect his rights . Information about the availability of personal data is provided to the subject of personal data in an accessible form and free of charge. In addition, they should not contain personal data relating to other subjects of personal data.

The subject of personal data has the right to receive information regarding the processing of his personal data, including containing: confirmation of the fact of processing of personal data by the Company, as well as the purpose of such processing; methods of processing personal data used by the Company; information about persons who have access to personal data or who may be granted such access; list of personal data processed and the source of its receipt; terms of processing of personal data, including periods of their storage.

The procedure for accessing your personal data is provided to the subject of personal data or his legal representative by the Company upon application or upon receipt of a request from the subject of personal data or his legal representative (hereinafter referred to as the Appeal). Applications from subjects are accepted by the Company during business hours.

The application must contain the number of the main document identifying the subject of personal data or his legal representative, information about the date of issue of the specified document and the issuing authority and the handwritten signature of the subject of personal data or his legal representative. An application for revocation of personal data can be sent at any time to the following address: Russian Federation, Moscow, 101000, Moscow, ext. ter. Basmanny Municipal District, Lubyansky proezd, 27/1, building 1, floor 4, room 109

The Company is obliged to send a response to the Personal Data Subject’s Application within a period not exceeding thirty working days from the date of receipt of the Application. In case of revocation of Personal Data, you will have to re-consent to the processing of Personal Data if the client again decides to use the services or products of SPECTRUM LLC, which require filling out questionnaires, applications, etc., containing Personal Data.

LIABILITY FOR VIOLATION OF STANDARDS GOVERNING THE PROCESSING AND PROTECTION OF PERSONAL DATA
Persons guilty of violating the rules governing the processing and protection of personal data processed in the Company’s personal data information systems bear civil, criminal, administrative, disciplinary and other liability provided for by the legislation of the Russian Federation. There is no breach of obligation to disclose information in accordance with reasonable and applicable legal requirements. The Seller is not responsible for the information provided by the Buyer on the Site in a publicly accessible form.

Appendix No. 1
to the Personal Data Processing Policy at SPECTRUM LLC
By my own will and in my own interest, I consent to processing, incl. to collect, systematize, accumulate, store (clarify, update, change), use, transfer to third parties (depersonalize, block, destroy, my personal data, which, depending on the document (form, application, etc.) includes, but not limited to the following Personal data: Last name, first name, patronymic (including previous ones); date of birth; address of residence, passport data or data of another identification document (type, series and number of the document, date of issue of the document, name). authority that issued the document, department code (if available)); contact information (phone number, email address); photographs and other specified information, Limited Liability Company "SPECTR", OGRN 1217700207449 (RF, Moscow, 101000, Moscow, ex. not limited to: identification of the participant in the loyalty program, ensuring the procedure for accounting for the accumulation and use of discounts, delivery, provision of services, distribution of advertising messages (including about ongoing promotions and special offers through any communication channels, including by mail, SMS, e-mail, telephone, other means of communication), collecting opinions on the operation of the online store SPECTRUM LLC. I agree that my personal data will be processed in ways that are consistent with the purposes of processing personal data, incl. with or without the use of automation tools. I also agree that the consent given by me in electronic form on the site is a consent that fully complies with the requirements of the legislation on personal data and allows us to confirm the fact of its receipt by SPECTRUM LLC. Consent is given by me for the entire duration of the Program. At the same time, I am informed and agree that withdrawal of this consent will automatically terminate my participation in the Loyalty Program, and I will also have to re-consent to the processing of Personal Data in the event that I decide to use it again services or products of SPECTRUM LLC that require filling out questionnaires, applications, etc., containing my Personal Data.