Personal Data Processing Policy

1. General Provisions

This personal data processing policy is drawn up in accordance with the requirements of the Personal Data Law and defines the personal data processing procedure and personal data security measures to be taken by Polostores (hereinafter referred to as the "Operator").
1.1. The Operator's main goal and a prerequisite for its activity is observance of human and citizen's rights and freedoms when processing personal data, including protection of rights to privacy, personal and family secrets.
1.2. This Operator's policy regarding personal data processing (hereinafter — the "Policy") applies to all information that the Operator may receive about visitors of the website;
2. Basic concepts used in the Policy
2.1. Automated personal data processing is processing of personal data by means of computer technology;
2.2. Blocking of personal data is temporary termination of personal data processing (except when processing is necessary to clarify personal data);
2.3. Website is a set of graphic and informational materials, as well as programs for computers and databases, making them available at URL;
2.4. Personal data information system is a set of personal data contained in databases, as well as information technology and technical means providing their processing;
2.5. Anonymization of personal data is an action rendering it impossible to determine pertinence of the personal data to a particular User or other owner without additional information;

2.6. Personal data processing is any action (operation) or a set of actions (operations) performed with regard to personal data with or without the use of automation, including the collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), anonymization, blocking, removal, destruction of personal data;
2.7. Operator is a state body, municipal authority, legal or natural person, independently or together with other persons organizing and (or) carrying out the personal data processing, as well as determining the purpose of personal data processing, the composition of personal data to be processed, actions (operations) performed with personal data;
2.8. Personal Data are any information relating directly or indirectly to a specific or identifiable User of the website;
2.9. User is any visitor of the website;
2.10. Personal data provision is actions aimed at disclosure of personal data to a certain person or a certain group of persons;
2.11. Dissemination of personal data is any action aimed at disclosure of personal data to an indefinite range of persons (transfer of personal data) or familiarizing general public with personal data, including the publication of personal data in the media, placing them in information and telecommunications networks or providing access to personal data in any other way;
2.12. Transborder transfer of personal data is transfer of personal data to a foreign country to a foreign authority, a foreign individual or a foreign legal entity;
2.13. Destruction of personal data is any action resulting in irretrievable destruction of personal data with the inability to further restore the content of personal data in the personal data information system and (or) destruction of the personal data carrier.

3. The Operator can process the following personal data of the User
3.1. Surname, first name, patronymic;
3.2. E-mail;
3.3. Phone numbers;
3.4. The site also collects and processes anonymized visitor data (including cookies) using Internet statistical services (Google Analytics and others).
3.5. The above data further in the text of the Policy are combined under the general term "Personal Data".

4. Purposes of personal data processing
4.1. The purpose of processing the User's personal data is to conclude, execute and terminate civil law contracts; provide the User with access to services, information and/or materials contained on the httpsː// website; clarify order details.
4.2. The Operator also has the right to send the User notifications about new products and services, special offers and different events. The User can always refuse to receive information messages by sending a letter to the Operator's e-mail marked with "Waiver of notifications of new products and services and special offers"..
4.3. Anonymized User data collected through Internet statistical services are used to collect information about the Users' actions on the website, to improve the quality of the website and its content.

5. Legal basis for personal data processing
5.1. The Operator processes the User's personal data only in case the User fills them in and/or sends them by themselves using the special forms on the website By filling in the relevant forms and/or sending his/her personal data to the Operator the User expresses his/her consent with the Policy.
5.2. The Operator processes anonymized data about the User in case it is allowed in the User's browser settings (cookies saving and JavaScript technology are enabled).

6. Procedure for the collection, storage, transfer and other processing of personal data

The safety of personal data, which are processed by the Operator, is provided by implementing legal, organizational and technical measures, necessary to fulfill the requirements of applicable legislation in the field of personal data protection in full.
6.1. The operator ensures the safety of personal data and takes all possible measures to exclude access to personal data by unauthorized persons.
6.2. Personal data of the User shall never, under no circumstances be transferred to third parties, except in cases related to the execution of the current legislation.
6.3. In case of incorrect personal data, the User can update them independently, by sending a notice to the Operator's e-mail with a note "Updating personal data".
6.4. The period of personal data processing is unlimited. The User may withdraw their consent to personal data processing at any time by sending a notice to the Operator's e-mail marked with "Withdrawal of consent to personal data processing ".

7. Transborder transfer of personal data
7.1. Prior to transborder transfer of personal data, the operator shall ensure that the foreign country, to the territory of which the personal data is supposed to be transferred, provides reliable protection of the rights of personal data owners.
7.2. Transborder transfer of personal data to foreign countries that do not meet the above requirements may be carried out only subject to the written consent of personal data owner to the transborder transfer of their personal data and/or for performance of the contract whereto the personal data owner is a party.

8. Final provisions
8.1. The User can get any clarifications on issues of interest concerning their personal data processing by contacting the Operator via e-mail
8.2. The document will reflect any changes in the Operator's personal data processing policy. The Policy shall have an infinite validity period until superseded by a new version.
8.3. The current version of the Policy is freely available at URL:
Konstantin Tsyutsyura
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