Personal Data Processing Policy

1. General Provisions
This Personal Data Processing Policy has been prepared in accordance with the requirements of Federal Law No. 152-FZ dated July 27, 2006 “On Personal Data” (hereinafter — the Personal Data Law) and defines the procedure for processing personal data and the measures to ensure the security of personal data undertaken by Silkin Sergey Sergeyevich (hereinafter — the Operator).
1.1. The Operator considers compliance with the rights and freedoms of individuals and citizens in the processing of their personal data, including the protection of the right to privacy, personal and family confidentiality, to be its most important goal and condition for carrying out its activities.
1.2. This Operator’s Personal Data Processing Policy (hereinafter — the Policy) applies to all information that the Operator may obtain about visitors to the website https://rollin-jade.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 where processing is necessary to clarify personal data).
2.3. Website — a set of graphic and information materials, as well as computer programs and databases, ensuring their availability on the Internet at https://rollin-jade.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. Depersonalization of personal data — actions resulting in the impossibility of determining the ownership of personal data by a specific User or other personal data subject without the use of additional information.
2.6. Processing of personal data — any action (operation) or set of actions (operations) performed with or without automation tools on personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
2.7. Operator — a state authority, municipal authority, legal entity, or individual that independently or jointly with others organizes and/or carries out the processing of personal data, as well as determines the purposes of personal data processing, the composition of personal data subject to processing, and actions (operations) performed on personal data.
2.8. Personal data — any information relating directly or indirectly to an identified or identifiable User of the website https://rollin-jade.com.
2.9. Personal data authorized by the subject for distribution — personal data to which access is granted to an unlimited number of persons by the personal data subject by giving consent to the processing of personal data authorized for distribution in accordance with the procedure established by the Personal Data Law (hereinafter — personal data authorized for distribution).
2.10. User — any visitor to the website https://rollin-jade.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. Distribution of personal data — any actions aimed at disclosing personal data to an indefinite group of persons or making personal data available to an unlimited group of persons, including publication in mass media, posting on information and telecommunication 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 government authority, foreign individual, or foreign legal entity.
2.14. Destruction of personal data — any actions resulting in the irreversible destruction of personal data with no possibility of restoring its content in the personal data information system and/or destruction of physical media containing personal data.

3. Basic Rights and Obligations of the Operator
3.1. The Operator has the right to:
— receive reliable information and/or documents containing personal data from the personal data subject;
— continue processing personal data without the consent of the personal data subject in the event of withdrawal of consent or receipt of a request to terminate processing, provided there are grounds stipulated by 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 federal laws.
3.2. The Operator is obliged to:
— provide the personal data subject, upon request, with information regarding the processing of their personal data;
— organize personal data processing in accordance with the procedure established by the legislation of the Russian Federation;
— respond to requests and inquiries from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
— provide the authorized body for the protection of the rights of personal data subjects with necessary information within 10 days from the date of receipt of the request;
— publish or otherwise ensure unrestricted access to this Personal Data Processing Policy;
— take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, distribution, and other unlawful actions;
— terminate the transfer, processing, and destroy personal data in cases provided for by the Personal Data Law;
— fulfill other obligations stipulated by the Personal Data Law.

4. Basic Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects have the right to:
— receive information regarding the processing of their personal data, except in cases provided for by federal laws;
— require clarification, blocking, or destruction of their personal data if such data is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing;
— require prior consent for the processing of personal data for marketing purposes;
— withdraw consent to the processing of personal data and submit a request to terminate such processing;
— appeal unlawful actions or inaction of the Operator to the authorized body or in court;
— exercise other rights provided for by the legislation of the Russian Federation.
4.2. Personal data subjects are obliged to:
— provide the Operator with accurate personal data;
— inform the Operator of any updates or changes to their personal data.
4.3. Persons who provide inaccurate personal data or personal data of another subject without their consent bear responsibility in accordance with the legislation of the Russian Federation.

5. Principles of Personal Data Processing
5.1. Personal data processing is carried out on a lawful and fair basis.
5.2. Processing is limited to achieving specific, predetermined, and lawful purposes.
5.3. Combining databases containing personal data processed for incompatible purposes is not permitted.
5.4. Only personal data relevant to the processing purposes is processed.
5.5. The content and scope of personal data correspond to the stated processing purposes.
5.6. Accuracy, sufficiency, and relevance of personal data are ensured.
5.7. Personal data is stored no longer than required by the processing purposes, unless otherwise provided by law or contract.

6. Purposes of Personal Data Processing
Purpose of processing:
Informing the User by sending emails
Personal data:

Last name, first name, patronymic
Phone numbers

Legal basis:

Constituent (founding) documents of the Operator

Types of processing:

Collection, recording, systematization, accumulation, storage, destruction, and depersonalization of personal data

7. Conditions for Processing Personal Data
7.1. Processing is carried out with the consent of the personal data subject.
7.2–7.7. Processing may also be carried out in cases provided for by law, contracts, public interest, or where data is publicly available or subject to mandatory disclosure.

8. Procedure for Collection, Storage, Transfer, and Other Types of Processing
The security of personal data is ensured through legal, organizational, and technical measures.
8.1. The Operator ensures the safety of personal data and prevents unauthorized access.
8.2. Personal data is not transferred to third parties except as required by law or with consent.
8.3. Users may update their data by emailing shop@rollin-jade.com with the subject “Personal Data Update”.
8.4. Users may withdraw consent by emailing shop@rollin-jade.com with the subject “Withdrawal of Consent to Personal Data Processing”.
8.5. Data collected by third-party services is processed in accordance with their own policies; the Operator is not responsible for their actions.
8.6–8.9. Processing is terminated upon achievement of purposes, expiration or withdrawal of consent, or unlawful processing.

9. List of Actions Performed with Personal Data
9.1. Collection, recording, systematization, accumulation, storage, clarification, extraction, use, transfer, depersonalization, blocking, deletion, and destruction.
9.2. Automated processing with or without data transmission over information and telecommunication networks.

10. Cross-Border Transfer of Personal Data
10.1. The Operator must notify the authorized body before commencing cross-border data transfer.
10.2. Prior to notification, the Operator must obtain necessary information from foreign recipients.
11. Confidentiality of Personal DataThe Operator and other persons with access to personal data must not disclose or distribute personal data without consent, unless otherwise provided by law.

12. Final Provisions
12.1. Users may contact the Operator at shop@rollin-jade.com for clarification.
12.2. Changes to the Policy will be reflected in this document.
12.3. The current version is available at:
https://rollin-jade.com/privacy