Personal Data Processing Policy

1. General Provisions
This Privacy Policy has been drafted in accordance with the requirements of Federal Law No. 152-FZ dated July 27, 2006 "On Personal Data" (hereinafter referred to as the "Personal Data Law") and defines the procedure for processing personal data and the measures to ensure the security of personal data undertaken by Individual Entrepreneur Savvina Lidia Sergeevna (hereinafter referred to as the "Operator").
1.1. The Operator’s primary goal and condition for carrying out its activities is to uphold the rights and freedoms of individuals and citizens when processing their personal data, including the protection of the rights to privacy, personal, and family secrets.
1.2. This Policy of the Operator regarding the processing of personal data (hereinafter referred to as the "Policy") applies to all information that the Operator may obtain about visitors to the website https://lidasava.com/.
2. Basic Terms Used in the Policy
2.1. Automated processing of personal data – processing of personal data using computer technology.
2.2. Blocking of personal data – temporary suspension of personal data processing (except when processing is necessary to clarify personal data).
2.3. Website – a collection of graphic and informational materials, as well as computer software and databases, ensuring their availability on the internet at the network address https://lidasava.com/.
2.4. Personal data information system – a set of personal data contained in databases, and information technologies and technical means ensuring their processing.
2.5. Anonymization of personal data – actions as a result of which it is impossible to determine, without using additional information, the ownership of personal data to a specific User or other subject of personal data.
2.6. 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, changing), retrieval, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
2.7. Operator – a state body, municipal body, legal entity or individual, organizing and/or carrying out the processing of personal data independently or jointly with others, as well as determining the purposes of processing personal data, the composition of personal data to be processed, and the actions (operations) performed with personal data.
2.8. Personal data – any information relating directly or indirectly to a specific or identifiable User of the website https://lidasava.com/.
2.9. Personal data permitted for dissemination by the subject of personal data – personal data to which an unlimited circle of persons has been granted access by the subject of personal data by giving consent to the processing of personal data permitted for dissemination in accordance with the procedure provided for by the Personal Data Law (hereinafter referred to as "personal data permitted for dissemination").
2.10. User – any visitor to the website https://lidasava.com/.
2.11. Provision of personal data – actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Dissemination 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 circle of persons, including publishing 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 – transfer of personal data to the territory of a foreign state to a foreign state authority, a foreign individual, or a foreign legal entity.
2.14. Destruction of personal data – any actions as a result of which personal data are permanently destroyed without the possibility of further restoration of the content of personal data in the personal data information system and/or the physical media of personal data are destroyed.
3. Basic Rights and Obligations of the Operator
3.1. The Operator has the right to:
— receive from the subject of personal data accurate information and/or documents containing personal data;
— in the event that the subject of personal data withdraws consent to the processing of personal data or submits a request to cease processing of personal data, the Operator has the right to continue processing personal data without the consent of the subject of personal data if there are grounds specified in the Personal Data Law;
— independently determine the composition and list of measures necessary and sufficient to ensure compliance with the obligations provided for by the 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. The Operator is obliged to:
— provide the subject of personal data, upon their request, with information regarding the processing of their personal data;
— organize the processing of personal data in accordance with the procedure established by the current legislation of the Russian Federation;
— respond to requests and inquiries from subjects of personal data and their legal representatives in accordance with the requirements of the Personal Data Law;
— notify the authorized body for the protection of the rights of subjects of personal data, upon request from that body, of the necessary information within 10 days from the date of receipt of such request;
— publish or otherwise provide unlimited access to this Policy regarding the processing of personal data;
— take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, alteration, blocking, copying, provision, distribution of personal data, as well as from other unlawful actions with respect to personal data;
— cease the transfer (distribution, provision, access) of personal data, cease processing, and destroy personal data in the manner and cases provided for by the Personal Data Law;
— perform other duties provided for by the Personal Data Law.
4. Basic Rights and Obligations of Subjects of Personal Data
4.1. Subjects of personal data have the right to:
— receive information regarding the processing of their personal data, except in cases provided for by federal laws. The information is provided by the Operator to the subject of personal data in an accessible form and must not contain personal data relating to other subjects of personal data, unless there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
— require the Operator to clarify their personal data, block or destroy them if the personal data is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, as well as take measures provided for by law to protect their rights;
— impose a condition of prior consent when processing personal data for the purpose of marketing goods, works, and services;
— withdraw consent to the processing of personal data and submit a request to cease processing of personal data;
— appeal against unlawful actions or inaction of the Operator in the processing of their personal data to the authorized body for the protection of the rights of subjects of personal data or in court;
— exercise other rights provided for by the legislation of the Russian Federation.
4.2. Subjects of personal data are obliged to:
— provide the Operator with accurate data about themselves;
— inform the Operator of any clarification (updating, change) of their personal data.
4.3. Persons who provide the Operator with false information about themselves or information about another subject of personal data without the latter's consent shall be liable in accordance with the legislation of the Russian Federation.
5. Principles of Processing Personal Data
5.1. Processing of personal data is carried out on a lawful and fair basis.
5.2. Processing of personal data is limited to achieving specific, pre-determined, and lawful purposes. Processing of personal data that is incompatible with the purposes of collecting personal data is not allowed.
5.3. Merging of databases containing personal data processed for incompatible purposes is not allowed.
5.4. Only personal data that meets the purposes of their processing may be processed.
5.5. The content and scope of the processed personal data correspond to the stated purposes of processing. Redundancy of the processed personal data in relation to the stated purposes of their processing is not allowed.
5.6. When processing personal data, the accuracy of personal data, their sufficiency, and, where necessary, their relevance to the purposes of processing personal data are ensured. The Operator takes necessary measures and/or ensures that they are taken to remove or clarify incomplete or inaccurate data.
5.7. Personal data is stored in a form that allows the identification of the subject of personal data for no longer than required by the purposes of processing personal data, unless the storage period for personal data is established by federal law or a contract to which the subject of personal data is a party, beneficiary, or guarantor. Processed personal data is destroyed or anonymized upon achievement of the processing purposes or in the event that the need to achieve these purposes is lost, unless otherwise provided for by federal law.

6. Purposes of Processing Personal Data

Purpose of Processing
Informing the User by sending emails
Personal Data

• Surname, first name, patronymic
• email address
• phone numbers

Legal Basis

• The Operator conducting an informational newsletter to the User's email address

Types of Processing of Personal Data

• Sending informational emails to the email address

7. Conditions for Processing Personal Data
7.1. Processing of personal data is carried out with the consent of the subject of personal data to the processing of their personal data.
7.2. Processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, and to carry out the functions, powers, and duties assigned to the operator by the legislation of the Russian Federation.
7.3. Processing of personal data is necessary for the administration of justice, the execution of a judicial act, an act of another body or official, subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. Processing of personal data is necessary for the performance of a contract to which the subject of personal data is a party, beneficiary, or guarantor, as well as for concluding a contract at the initiative of the subject of personal data or a contract under which the subject of personal data will be the beneficiary or guarantor.
7.5. Processing of personal data 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 subject of personal data are not violated.
7.6. Processing of personal data to which access by an unlimited circle of persons is provided by the subject of personal data or at their request (hereinafter referred to as "publicly available personal data") is carried out.
7.7. Processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.
8. Procedure for Collection, Storage, Transfer, and Other Types of Processing of Personal Data
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 current legislation in the field of personal data protection.
8.1. The Operator ensures the safety of personal data and takes all possible measures to prevent access to personal data by unauthorized persons.
8.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to the implementation of current legislation, or where the subject of personal data has given consent to the Operator to transfer data to a third party to fulfill obligations under a civil law contract.
8.3. If inaccuracies in the personal data are identified, the User may update them independently by sending a notification to the Operator's email address assist@lidasava.com marked "Updating Personal Data."
8.4. The period for processing personal data is determined by the achievement of the purposes for which the personal data was collected, unless another period is provided for by contract or current legislation. The User may at any time withdraw their consent to the processing of personal data by sending a notification to the Operator via email to the Operator's email address assist@lidasava.com marked "Withdrawal of Consent to the Processing of Personal Data."
8.5. All information collected by third-party services, including payment systems, communication services, and other service providers, is stored and processed by these persons (Operators) in accordance with their User Agreements and Privacy Policies. The subject of personal data should familiarize themselves with these documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.
8.6. Prohibitions established by the subject of personal data on transfer (except for granting access), as well as on processing or conditions of processing (except for obtaining access) of personal data permitted for dissemination, do not apply in cases of processing personal data in state, public, and other public interests determined by the legislation of the Russian Federation.
8.7. When processing personal data, the Operator ensures the confidentiality of personal data.
8.8. The Operator stores personal data in a form that allows the identification of the subject of personal data for no longer than required by the purposes of processing personal data, unless the storage period for personal data is established by federal law, a contract to which the subject of personal data is a party, beneficiary, or guarantor.
8.9. The conditions for terminating the processing of personal data may be the achievement of the purposes of processing personal data, the expiration of the consent of the subject of personal data, the withdrawal of consent by the subject of personal data or a request to cease processing of personal data, as well as the detection of unlawful processing of personal data.
9. List of Actions Performed by the Operator with Obtained Personal Data
9.1. The Operator carries out the collection, recording, systematization, accumulation, storage, clarification (updating, changing), retrieval, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
9.2. The Operator carries out automated processing of personal data with or without the receipt and/or transfer of the obtained information via information and telecommunications networks.
10. Cross-Border Transfer of Personal Data
10.1. Before commencing activities related to the cross-border transfer of personal data, the Operator is obliged to notify the authorized body for the protection of the rights of subjects of personal data of its intention to carry out the cross-border transfer of personal data (such notification is sent separately from the notification of intention to process personal data).
10.2. Before submitting the aforementioned notification, the Operator is obliged to obtain relevant information from the foreign state authorities, foreign individuals, and foreign legal entities to whom the cross-border transfer of personal data is planned.
11. Confidentiality of Personal Data
The Operator and other persons who have gained access to personal data are obliged not to disclose or disseminate personal data to third parties without the consent of the subject of personal data, unless otherwise provided for by federal law.
12. Final Provisions
12.1. The User may obtain any clarification regarding issues related to the processing of their personal data by contacting the Operator via email at assist@lidasava.com.
12.2. Any changes to the Operator's privacy policy will be reflected in this document. The Policy is valid indefinitely until replaced by a new version.
12.3. The current version of the Policy is freely available on the internet at https://lidasava.com/.