Policy on personal data processing
1. General Provisions
This personal data processing policy is drafted in accordance with the requirements of Federal Law No. 152-FZ “On Personal Data” dated July 27, 2006 (hereinafter referred to as the “Personal Data Law”) and defines the procedure for processing personal data and measures to ensure the security of personal data undertaken by LLC “COSMIRA” (hereinafter referred to as the “Operator”).
1.1. The Operator considers the protection of human and civil rights and freedoms when processing personal data, including protecting the right to privacy, personal, and family secrets, as its most important goal and condition for conducting its activities.
1.2. This policy on personal data processing (hereinafter referred to as the “Policy”) applies to all information the Operator may obtain about visitors to the website https://leoetmadeleine.com.
This personal data processing policy is drafted in accordance with the requirements of Federal Law No. 152-FZ “On Personal Data” dated July 27, 2006 (hereinafter referred to as the “Personal Data Law”) and defines the procedure for processing personal data and measures to ensure the security of personal data undertaken by LLC “COSMIRA” (hereinafter referred to as the “Operator”).
1.1. The Operator considers the protection of human and civil rights and freedoms when processing personal data, including protecting the right to privacy, personal, and family secrets, as its most important goal and condition for conducting its activities.
1.2. This policy on personal data processing (hereinafter referred to as the “Policy”) applies to all information the Operator may obtain about visitors to the website https://leoetmadeleine.com.
2. Key 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 in cases where processing is necessary to clarify personal data).
2.3. Website — a collection of graphical and informational materials, as well as computer programs and databases, ensuring their availability on the Internet at https://leoetmadeleine.com.
2.4. Information system of personal data — a set of databases containing personal data and the information technologies and technical means that process them.
2.5. Anonymization of personal data — actions that make it impossible to determine, without additional information, the personal data’s affiliation with a specific User or another subject of personal data.
2.6. Processing of personal data — any action (operation) or set of actions (operations) performed using automated tools or without them concerning personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), anonymization, 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 performs the processing of personal data, as well as defines 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 an identified or identifiable User of the website https://leoetmadeleine.com.
2.9. Personal data authorized by the subject for distribution — personal data to which an unlimited number of persons have been granted access by the subject by providing consent to process personal data authorized for distribution, as per the procedure stipulated by the Personal Data Law (hereinafter referred to as “personal data authorized for distribution”).
2.10. User — any visitor to the website https://leoetmadeleine.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 granting access to personal data to an unlimited number of persons, including making personal data public in the media, posting in 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 state authority, a foreign individual, or a foreign legal entity.
2.14. Destruction of personal data — any actions resulting in the permanent destruction of personal data with no possibility of restoring the personal data content in the personal data information system and/or resulting in the destruction of personal data’s physical media.
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 in cases where processing is necessary to clarify personal data).
2.3. Website — a collection of graphical and informational materials, as well as computer programs and databases, ensuring their availability on the Internet at https://leoetmadeleine.com.
2.4. Information system of personal data — a set of databases containing personal data and the information technologies and technical means that process them.
2.5. Anonymization of personal data — actions that make it impossible to determine, without additional information, the personal data’s affiliation with a specific User or another subject of personal data.
2.6. Processing of personal data — any action (operation) or set of actions (operations) performed using automated tools or without them concerning personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), anonymization, 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 performs the processing of personal data, as well as defines 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 an identified or identifiable User of the website https://leoetmadeleine.com.
2.9. Personal data authorized by the subject for distribution — personal data to which an unlimited number of persons have been granted access by the subject by providing consent to process personal data authorized for distribution, as per the procedure stipulated by the Personal Data Law (hereinafter referred to as “personal data authorized for distribution”).
2.10. User — any visitor to the website https://leoetmadeleine.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 granting access to personal data to an unlimited number of persons, including making personal data public in the media, posting in 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 state authority, a foreign individual, or a foreign legal entity.
2.14. Destruction of personal data — any actions resulting in the permanent destruction of personal data with no possibility of restoring the personal data content in the personal data information system and/or resulting in the destruction of personal data’s physical media.
3. Operator’s Key Rights and Obligations
3.1. The Operator has the right to:
• Obtain reliable information and/or documents containing personal data from the subject of personal data;
• Continue processing personal data without the consent of the subject of personal data if the subject withdraws consent for personal data processing or submits a request to terminate the processing, provided there are grounds specified in the Personal Data Law;
• Independently determine the composition and list of measures necessary and sufficient to ensure compliance with obligations under the Personal Data Law and its associated regulations unless otherwise stipulated by the Personal Data Law or other federal laws.
3.2. The Operator is obligated to:
• Provide the subject of personal data with information regarding the processing of their personal data upon request;
• Organize the processing of personal data in compliance with applicable laws 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 subjects’ rights regarding personal data upon request within 10 days of receiving 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, dissemination, and other unlawful actions concerning personal data;
• Cease dissemination, provision, or access to personal data, terminate processing, and destroy personal data as stipulated by the Personal Data Law;
• Fulfill other obligations stipulated by the Personal Data Law.
3.1. The Operator has the right to:
• Obtain reliable information and/or documents containing personal data from the subject of personal data;
• Continue processing personal data without the consent of the subject of personal data if the subject withdraws consent for personal data processing or submits a request to terminate the processing, provided there are grounds specified in the Personal Data Law;
• Independently determine the composition and list of measures necessary and sufficient to ensure compliance with obligations under the Personal Data Law and its associated regulations unless otherwise stipulated by the Personal Data Law or other federal laws.
3.2. The Operator is obligated to:
• Provide the subject of personal data with information regarding the processing of their personal data upon request;
• Organize the processing of personal data in compliance with applicable laws 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 subjects’ rights regarding personal data upon request within 10 days of receiving 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, dissemination, and other unlawful actions concerning personal data;
• Cease dissemination, provision, or access to personal data, terminate processing, and destroy personal data as stipulated by the Personal Data Law;
• Fulfill other obligations stipulated by the Personal Data Law.
4.1. Personal data subjects have the right to:
• Receive information concerning the processing of their personal data, except in cases provided by federal laws. Information must be provided to the personal data subject by the Operator in an accessible form and must not contain personal data related to other subjects, unless there are legal grounds for disclosing such data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
• Request that the Operator clarify their personal data, block, or destroy it if the data is incomplete, outdated, inaccurate, unlawfully obtained, or is not necessary for the stated purpose of processing. They may also take legal measures to protect their rights as provided by law;
• Set conditions of prior consent for processing personal data for the purpose of marketing goods, works, or services;
• Withdraw consent to the processing of personal data and demand that the Operator cease processing their personal data;
• File complaints with the authorized body for the protection of personal data subjects’ rights or take legal action against unlawful acts or omissions by the Operator during personal data processing;
• Exercise other rights provided by Russian Federation law.
4.2. Personal data subjects are obligated to:
• Provide the Operator with accurate personal data;
• Inform the Operator of updates or changes to their personal data.
4.3. Individuals who provide the Operator with inaccurate information about themselves or information about another subject of personal data without their consent are liable under Russian Federation law.
• Receive information concerning the processing of their personal data, except in cases provided by federal laws. Information must be provided to the personal data subject by the Operator in an accessible form and must not contain personal data related to other subjects, unless there are legal grounds for disclosing such data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
• Request that the Operator clarify their personal data, block, or destroy it if the data is incomplete, outdated, inaccurate, unlawfully obtained, or is not necessary for the stated purpose of processing. They may also take legal measures to protect their rights as provided by law;
• Set conditions of prior consent for processing personal data for the purpose of marketing goods, works, or services;
• Withdraw consent to the processing of personal data and demand that the Operator cease processing their personal data;
• File complaints with the authorized body for the protection of personal data subjects’ rights or take legal action against unlawful acts or omissions by the Operator during personal data processing;
• Exercise other rights provided by Russian Federation law.
4.2. Personal data subjects are obligated to:
• Provide the Operator with accurate personal data;
• Inform the Operator of updates or changes to their personal data.
4.3. Individuals who provide the Operator with inaccurate information about themselves or information about another subject of personal data without their consent are liable under Russian Federation law.
5. Principles of Personal Data Processing
5.1. Personal data processing is carried out on a lawful and fair basis.
5.2. Personal data processing is limited to the achievement of specific, predefined, and lawful purposes. Processing of personal data incompatible with the purposes for which it was collected is not permitted.
5.3. Combining databases containing personal data, which are processed for incompatible purposes, is prohibited.
5.4. Only personal data necessary for the processing purposes is processed.
5.5. The content and scope of personal data processed correspond to the stated processing purposes. Excessive personal data in relation to the stated purposes of processing is not permitted.
5.6. Personal data processing ensures the accuracy, sufficiency, and, where necessary, relevance of the data with respect to the processing purposes. The Operator takes necessary measures or ensures such measures are taken to delete or clarify incomplete or inaccurate data.
5.7. Personal data is stored in a form that allows for the identification of the personal data subject, no longer than required for the processing purposes, unless otherwise stipulated by federal law, contract, or agreement where the data subject is a party or beneficiary. Processed personal data is deleted or anonymized upon achieving the processing purposes or when there is no further need for processing, unless otherwise provided by federal law.
5.1. Personal data processing is carried out on a lawful and fair basis.
5.2. Personal data processing is limited to the achievement of specific, predefined, and lawful purposes. Processing of personal data incompatible with the purposes for which it was collected is not permitted.
5.3. Combining databases containing personal data, which are processed for incompatible purposes, is prohibited.
5.4. Only personal data necessary for the processing purposes is processed.
5.5. The content and scope of personal data processed correspond to the stated processing purposes. Excessive personal data in relation to the stated purposes of processing is not permitted.
5.6. Personal data processing ensures the accuracy, sufficiency, and, where necessary, relevance of the data with respect to the processing purposes. The Operator takes necessary measures or ensures such measures are taken to delete or clarify incomplete or inaccurate data.
5.7. Personal data is stored in a form that allows for the identification of the personal data subject, no longer than required for the processing purposes, unless otherwise stipulated by federal law, contract, or agreement where the data subject is a party or beneficiary. Processed personal data is deleted or anonymized upon achieving the processing purposes or when there is no further need for processing, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing
Informing the User by sending emails
Personal Data
Legal Grounds
Contracts concluded between the Operator and the personal data subject.
Types of Personal Data Processing
Sending informational emails to the email address.
Informing the User by sending emails
Personal Data
- last name, first name, patronymic;
- email address;
- phone numbers;
- date of birth;
- place of birth.
Legal Grounds
Contracts concluded between the Operator and the personal data subject.
Types of Personal Data Processing
Sending informational emails to the email address.
6. Purposes of Personal Data Processing
Informing the User by sending emails
Personal Data
Legal Grounds
Contracts concluded between the Operator and the personal data subject.
Types of Personal Data Processing
Sending informational emails to the email address.
Informing the User by sending emails
Personal Data
- last name, first name, patronymic;
- email address;
- phone numbers;
- date of birth;
- place of birth&
Legal Grounds
Contracts concluded between the Operator and the personal data subject.
Types of Personal Data Processing
Sending informational emails to the email address.
7. Conditions for Personal Data Processing
7.1. Personal data is processed with the consent of the personal data subject for the processing of their personal data.
7.2. Personal data processing is necessary for the achievement of the purposes provided by international treaties of the Russian Federation or laws, for the performance of the functions, powers, and duties assigned to the operator by the legislation of the Russian Federation.
7.3. Personal data processing is necessary for the administration of justice, execution of a judicial act, or an act of another authority or official subject to enforcement according to the legislation of the Russian Federation on enforcement proceedings.
7.4. Personal data processing is necessary for the performance of a contract in which the personal data subject is a party or a beneficiary, or for entering into a contract at the initiative of the personal data subject or the contract under which the personal data subject will be a beneficiary.
7.5. Personal data processing is necessary for the protection of the rights and lawful interests of the operator or third parties, or for achieving socially significant goals, provided that the rights and freedoms of the personal data subject are not violated.
7.6. Personal data processing is carried out where the personal data subject has provided public access to their personal data or upon their request (hereinafter referred to as publicly available personal data).
7.7. Personal data processing is carried out in accordance with federal laws when personal data is required to be published or disclosed.
7.1. Personal data is processed with the consent of the personal data subject for the processing of their personal data.
7.2. Personal data processing is necessary for the achievement of the purposes provided by international treaties of the Russian Federation or laws, for the performance of the functions, powers, and duties assigned to the operator by the legislation of the Russian Federation.
7.3. Personal data processing is necessary for the administration of justice, execution of a judicial act, or an act of another authority or official subject to enforcement according to the legislation of the Russian Federation on enforcement proceedings.
7.4. Personal data processing is necessary for the performance of a contract in which the personal data subject is a party or a beneficiary, or for entering into a contract at the initiative of the personal data subject or the contract under which the personal data subject will be a beneficiary.
7.5. Personal data processing is necessary for the protection of the rights and lawful interests of the operator or third parties, or for achieving socially significant goals, provided that the rights and freedoms of the personal data subject are not violated.
7.6. Personal data processing is carried out where the personal data subject has provided public access to their personal data or upon their request (hereinafter referred to as publicly available personal data).
7.7. Personal data processing is carried out in accordance with federal laws when personal data is required to be published or disclosed.
8. Procedure for the Collection, Storage, Transfer, and Other Types of Personal Data Processing
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 the applicable legislation on personal data protection.
8.1. The Operator ensures the safety of personal data and takes all possible measures to prevent unauthorized access to personal data.
8.2. Personal data of the User will never be transferred to third parties, except in cases related to the enforcement of applicable laws or if the personal data subject has consented to the transfer of data to a third party to fulfill civil law obligations.
8.3. If inaccuracies in personal data are identified, the User can update them independently by sending a notification to the Operator’s email address: i.andreeva@cosmira.ru with the subject “Personal Data Update.”
8.4. The processing period for personal data is determined by the achievement of the purposes for which the personal data were collected, unless a different period is specified by a contract or applicable law.
The User may withdraw their consent to the processing of personal data at any time by sending a notification to the Operator via email at i.andreeva@cosmira.ru with the subject “Withdrawal of Consent to Process 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 entities (Operators) in accordance with their User Agreement and Privacy Policy. The Operator is not responsible for the actions of third parties, including those mentioned in this paragraph.
8.6. Restrictions imposed by the personal data subject on the transfer (other than granting access), processing, or conditions of processing (other than granting access) of personal data permitted for distribution do not apply in cases of personal data processing in state, public, and other public interests defined by the legislation of the Russian Federation.
8.7. The Operator ensures the confidentiality of personal data during processing.
8.8. The Operator stores personal data in a form that allows identification of the personal data subject for no longer than necessary to achieve the purposes of personal data processing unless a longer storage period is specified by federal law, contract, or where the personal data subject is a party to the contract, a beneficiary, or guarantor.
8.9. The termination of personal data processing may occur upon the achievement of the purposes of processing, expiration of the personal data subject’s consent, withdrawal of consent by the personal data subject, a request to stop processing personal data, or upon discovery of unlawful 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 the applicable legislation on personal data protection.
8.1. The Operator ensures the safety of personal data and takes all possible measures to prevent unauthorized access to personal data.
8.2. Personal data of the User will never be transferred to third parties, except in cases related to the enforcement of applicable laws or if the personal data subject has consented to the transfer of data to a third party to fulfill civil law obligations.
8.3. If inaccuracies in personal data are identified, the User can update them independently by sending a notification to the Operator’s email address: i.andreeva@cosmira.ru with the subject “Personal Data Update.”
8.4. The processing period for personal data is determined by the achievement of the purposes for which the personal data were collected, unless a different period is specified by a contract or applicable law.
The User may withdraw their consent to the processing of personal data at any time by sending a notification to the Operator via email at i.andreeva@cosmira.ru with the subject “Withdrawal of Consent to Process 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 entities (Operators) in accordance with their User Agreement and Privacy Policy. The Operator is not responsible for the actions of third parties, including those mentioned in this paragraph.
8.6. Restrictions imposed by the personal data subject on the transfer (other than granting access), processing, or conditions of processing (other than granting access) of personal data permitted for distribution do not apply in cases of personal data processing in state, public, and other public interests defined by the legislation of the Russian Federation.
8.7. The Operator ensures the confidentiality of personal data during processing.
8.8. The Operator stores personal data in a form that allows identification of the personal data subject for no longer than necessary to achieve the purposes of personal data processing unless a longer storage period is specified by federal law, contract, or where the personal data subject is a party to the contract, a beneficiary, or guarantor.
8.9. The termination of personal data processing may occur upon the achievement of the purposes of processing, expiration of the personal data subject’s consent, withdrawal of consent by the personal data subject, a request to stop processing personal data, or upon discovery of unlawful processing of personal data.
9. Actions Performed by the Operator with Received Personal Data
9.1. The Operator performs the following actions with personal data: collection, recording, systematization, accumulation, storage, clarification (updating, modifying), extraction, use, transmission (dissemination, provision, access), anonymization, blocking, deletion, and destruction of personal data.
9.2. The Operator performs automated processing of personal data, receiving and/or transmitting the received information over information and telecommunication networks or without such transmission.
9.1. The Operator performs the following actions with personal data: collection, recording, systematization, accumulation, storage, clarification (updating, modifying), extraction, use, transmission (dissemination, provision, access), anonymization, blocking, deletion, and destruction of personal data.
9.2. The Operator performs automated processing of personal data, receiving and/or transmitting the received information over information and telecommunication networks or without such transmission.
10. Cross-Border Transfer of Personal Data
10.1. Before starting activities related to the cross-border transfer of personal data, the Operator must notify the authorized body for the protection of personal data subjects’ rights about its intention to carry out the cross-border transfer of personal data (such notification must be submitted separately from the notification about the intention to process personal data).
10.2. Before submitting the above-mentioned notification, the Operator must obtain relevant information from the authorities of a foreign country, foreign individuals, and foreign legal entities to whom the personal data is intended to be transferred.
10.1. Before starting activities related to the cross-border transfer of personal data, the Operator must notify the authorized body for the protection of personal data subjects’ rights about its intention to carry out the cross-border transfer of personal data (such notification must be submitted separately from the notification about the intention to process personal data).
10.2. Before submitting the above-mentioned notification, the Operator must obtain relevant information from the authorities of a foreign country, foreign individuals, and foreign legal entities to whom the personal data is intended to be transferred.
11. Confidentiality of Personal Data
The Operator and other individuals who have access to personal data are obliged not to disclose or distribute personal data to third parties without the consent of the data subject, unless otherwise required by federal law.
The Operator and other individuals who have access to personal data are obliged not to disclose or distribute personal data to third parties without the consent of the data subject, unless otherwise required by federal law.
11. Confidentiality of Personal Data
The Operator and other individuals who have access to personal data are obliged not to disclose or distribute personal data to third parties without the consent of the data subject, unless otherwise required by federal law.
The Operator and other individuals who have access to personal data are obliged not to disclose or distribute personal data to third parties without the consent of the data subject, unless otherwise required by federal law.