Personal data processing policy
1. General Provisions
This Personal Data Processing Policy has been prepared in accordance with the requirements of the Federal Law No. 152-FZ of 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 implemented by "Yabloki i Yabloni" LLC (hereinafter referred to as the "Data Controller" or "Controller") to ensure the security of personal data.
1.1. The Controller’s paramount goal and a fundamental condition for its operations is the observance of human and civil rights and freedoms when processing their personal data, including the protection of the rights to privacy, personal and family secrets.
1.2. This Policy of the Controller regarding the processing of personal data (hereinafter referred to as the "Policy") applies to all information that the Controller may obtain about visitors to the website at http://titocco.ru.
2. Key Terms Used in the Policy
2.1. Automated Processing of Personal Data — processing of personal data by means of computer technology.
2.2. Blocking of Personal Data — temporary cessation of personal data processing (except for cases where processing is necessary to clarify personal data).
2.3. Website — a collection of graphic and informational materials, as well as computer programs and databases that ensure their availability on the Internet at the network address http://titocco.ru.
2.4. Personal Data Information System — a set of personal data contained in databases and the information technologies and technical means that ensure their processing.
2.5. Depersonalization of Personal Data — actions as a result of which it is impossible to determine, without the use of additional information, the ownership of personal data to a specific User or another data subject.
2.6. Processing of Personal Data — any action (operation) or set of actions (operations) performed with or without the use of automation tools on personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
2.7. Controller (Operator) — a state body, municipal body, legal entity, or individual who independently or jointly with others organizes and/or carries out the processing of personal data, and determines 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 http://titocco.ru.
2.9. Personal Data Authorized by the Data Subject for Distribution — personal data to which access by an unlimited number of persons has been granted by the data subject by giving consent to the processing of personal data authorized for distribution in the manner prescribed by the Personal Data Law (hereinafter referred to as "personal data authorized for distribution").
2.10. User — any visitor to the website http://titocco.ru.
2.11. Provision of Personal Data — actions aimed at disclosing personal data to a specific person or a specific circle of persons.
2.12. Distribution of Personal Data — any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or at making personal data known to an unlimited number of persons, including the publication of personal data 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 — the 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 irreversible destruction of personal data with the impossibility of further restoration of the content of personal data in the personal data information system and/or the destruction of the material carriers of personal data.
3. Key Rights and Obligations of the Controller
3.1. The Controller has the right to:
— Receive accurate information and/or documents containing personal data from the data subject;
— In the event that the data subject withdraws consent to the processing of personal data or submits a request to cease processing of personal data, the Controller has the right to continue processing personal data without the data subject’s consent on the grounds stipulated by the Personal Data Law;
— Independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations provided for by the Personal Data Law and the regulatory legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.
3.2. The Controller is obliged to:
— Provide the data subject, upon their request, with information concerning the processing of their personal data;
— Organize the processing of personal data in the manner established by the current legislation of the Russian Federation;
— Respond to inquiries and requests from data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
— Provide the authorized data protection supervisory authority, upon its request, with the necessary information within 10 days from the date of receipt of such a request;
— Publish or otherwise ensure unrestricted access to this Policy regarding the processing of personal data;
— Implement legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision, distribution, as well as from other unlawful actions in relation 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;
— Fulfill other obligations stipulated by the Personal Data Law.
4. Key Rights and Obligations of Data Subjects
4.1. Data subjects 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 to the data subject by the Controller in an accessible form and shall not contain personal data relating to other data subjects, except in cases where 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 Controller to clarify, block, or destroy their personal data if the data is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, as well as to take statutory measures to protect their rights;
— Impose a condition of prior consent when processing personal data for the purpose of promoting goods, works, and services on the market;
— Withdraw consent to the processing of personal data, as well as to submit a demand to cease the processing of personal data;
— Lodge a complaint with the authorized data protection supervisory authority or in a court of law against unlawful actions or inaction of the Controller in processing their personal data;
— Exercise other rights provided for by the legislation of the Russian Federation.
4.2. Data subjects are obliged to:
— Provide the Controller with accurate data about themselves;
— Notify the Controller about the clarification (updating, modification) of their personal data.
4.3. Persons who have provided the Controller with inaccurate information about themselves or information about another data subject without the latter’s consent shall be liable in accordance with the legislation of the Russian Federation.
5. Principles of Personal Data Processing
5.1. The processing of personal data is carried out on a lawful and fair basis.
5.2. The processing of personal data is limited to the achievement of specific, predetermined, and lawful purposes. The processing of personal data that is incompatible with the purposes of collecting personal data is not permitted.
5.3. The merging of databases containing personal data, the processing of which is carried out for incompatible purposes, is not permitted.
5.4. Only personal data that meets the purposes of its processing is subject to processing.
5.5. The content and volume of the processed personal data correspond to the stated purposes of processing. The redundancy of the processed personal data in relation to the stated purposes of their processing is not permitted.
5.6. When processing personal data, the accuracy, sufficiency, and, where necessary, relevance of the personal data in relation to the purposes of processing are ensured. The Controller takes the necessary measures and/or ensures their adoption to delete or clarify incomplete or inaccurate data.
5.7. The storage of personal data is carried out in a form that allows the identification of the data subject for no longer than required by the purposes of processing personal data, unless the storage period for personal data is established by federal law, an agreement to which the data subject is a party, beneficiary, or guarantor. The processed personal data shall be destroyed or depersonalized upon achieving the purposes of processing or in the event of the loss of necessity to achieve these purposes, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing
Purpose of ProcessingInforming the User by sending emails
Personal Data
Last name, first name, patronymic name; email address; phone numbers; year, month, date, and place of birth; passport details
Legal Basis
Charter (foundation) documents of the Controller
Types of Processing
Collection, recording, systematization, accumulation, storage, destruction, and depersonalization of personal data; Sending informational emails to the email address
7. Conditions for Processing Personal Data
7.1. The processing of personal data is carried out with the consent of the data subject to the processing of their personal data.
7.2. The processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, for the performance of the functions, powers, and duties imposed on the Controller by the legislation of the Russian Federation.
7.3. The processing of personal data is necessary for the administration of justice, the execution of a judicial act, an act of another body, or an official, subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. The processing of personal data is necessary for the performance of a contract to which the data subject is a party, beneficiary, or guarantor, as well as for the conclusion of a contract on the initiative of the data subject or a contract under which the data subject will be a beneficiary or guarantor.
7.5. The processing of personal data is necessary for the exercise of the rights and legitimate interests of the Controller or third parties, or for the achievement of socially significant goals, provided that the rights and freedoms of the data subject are not violated.
7.6. Processing is carried out of personal data to which access by an unlimited number of persons has been provided by the data subject or at their request (hereinafter referred to as "publicly available personal data").
7.7. Processing is carried out of personal data subject to publication or mandatory disclosure in accordance with federal law.
8. Procedure for Collection, Storage, Transfer, and Other Types of Processing of Personal Data
The security of personal data processed by the Controller is ensured by implementing legal, organizational, and technical measures necessary to ensure full compliance with the requirements of the current legislation in the field of personal data protection.
8.1. The Controller 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 execution of applicable legislation or where the data subject has given consent to the Controller to transfer data to a third party to fulfill obligations under a civil law contract.
8.3. In the event of inaccuracies in personal data, the User may update them independently by sending a notification to the Controller’s email address at contactapple7@mail.ru with the note "Update of personal data."
8.4. The period for processing personal data is determined by the achievement of the purposes for which the personal data were collected, unless another period is stipulated by the contract or applicable legislation.
The User may at any time withdraw their consent to the processing of personal data by sending a notification to the Controller via email to contactapple7@mail.ru with the note "Withdrawal of consent to the processing of personal data."
8.5. All information collected by third-party services, including payment systems, communication means, and other service providers, is stored and processed by the said persons (Controllers/Processors) in accordance with their User Agreement and Privacy Policy. The data subject is obliged to familiarize themselves with the said documents. The Controller is not responsible for the actions of third parties, including the service providers specified in this clause.
8.6. Prohibitions established by the data subject on the transfer (except for granting access), as well as on the processing or conditions of processing (except for obtaining access) of personal data authorized for distribution, do not apply in cases of processing personal data in state, public, and other public interests as defined by the legislation of the Russian Federation.
8.7. The Controller, when processing personal data, ensures their confidentiality.
8.8. The Controller stores personal data in a form that allows the identification of the data subject for no longer than required by the purposes of processing personal data, unless the storage period for personal data is established by federal law, an agreement to which the data subject is a party, beneficiary, or guarantor.
8.9. The processing of personal data may be terminated upon achieving the purposes of processing, the expiration of the data subject’s consent, the withdrawal of consent by the data subject or a demand to cease processing, as well as upon the detection of unlawful processing of personal data.
9. List of Actions Performed by the Controller with the Received Personal Data
9.1. The Controller performs collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
9.2. The Controller performs automated processing of personal data with the receipt and/or transmission of the received information via information and telecommunication networks or without it.
10. Cross-Border Transfer of Personal Data
10.1. The Controller, prior to commencing activities related to the cross-border transfer of personal data, is obliged to notify the authorized data protection supervisory authority of its intention to carry out cross-border transfer of personal data (such notification is sent separately from the notification of intention to process personal data).
10.2. The Controller, prior to submitting the aforementioned notification, is obliged to obtain from the authorities of the foreign state, foreign individuals, and foreign legal entities to whom the cross-border transfer of personal data is planned, the relevant information.
11. Confidentiality of Personal Data
The Controller and other persons who have gained access to personal data are obliged not to disclose to third parties and not to distribute personal data without the consent of the data subject, unless otherwise provided by federal law.
12. Final Provisions
12.1. The User can obtain any clarifications on questions of interest regarding the processing of their personal data by contacting the Controller via email at contactapple7@mail.ru.
12.2. This document will reflect any changes to the Controller’s personal data processing policy. 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 http://titocco.ru/privacy.
This Personal Data Processing Policy has been prepared in accordance with the requirements of the Federal Law No. 152-FZ of 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 implemented by "Yabloki i Yabloni" LLC (hereinafter referred to as the "Data Controller" or "Controller") to ensure the security of personal data.
1.1. The Controller’s paramount goal and a fundamental condition for its operations is the observance of human and civil rights and freedoms when processing their personal data, including the protection of the rights to privacy, personal and family secrets.
1.2. This Policy of the Controller regarding the processing of personal data (hereinafter referred to as the "Policy") applies to all information that the Controller may obtain about visitors to the website at http://titocco.ru.
2. Key Terms Used in the Policy
2.1. Automated Processing of Personal Data — processing of personal data by means of computer technology.
2.2. Blocking of Personal Data — temporary cessation of personal data processing (except for cases where processing is necessary to clarify personal data).
2.3. Website — a collection of graphic and informational materials, as well as computer programs and databases that ensure their availability on the Internet at the network address http://titocco.ru.
2.4. Personal Data Information System — a set of personal data contained in databases and the information technologies and technical means that ensure their processing.
2.5. Depersonalization of Personal Data — actions as a result of which it is impossible to determine, without the use of additional information, the ownership of personal data to a specific User or another data subject.
2.6. Processing of Personal Data — any action (operation) or set of actions (operations) performed with or without the use of automation tools on personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
2.7. Controller (Operator) — a state body, municipal body, legal entity, or individual who independently or jointly with others organizes and/or carries out the processing of personal data, and determines 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 http://titocco.ru.
2.9. Personal Data Authorized by the Data Subject for Distribution — personal data to which access by an unlimited number of persons has been granted by the data subject by giving consent to the processing of personal data authorized for distribution in the manner prescribed by the Personal Data Law (hereinafter referred to as "personal data authorized for distribution").
2.10. User — any visitor to the website http://titocco.ru.
2.11. Provision of Personal Data — actions aimed at disclosing personal data to a specific person or a specific circle of persons.
2.12. Distribution of Personal Data — any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or at making personal data known to an unlimited number of persons, including the publication of personal data 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 — the 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 irreversible destruction of personal data with the impossibility of further restoration of the content of personal data in the personal data information system and/or the destruction of the material carriers of personal data.
3. Key Rights and Obligations of the Controller
3.1. The Controller has the right to:
— Receive accurate information and/or documents containing personal data from the data subject;
— In the event that the data subject withdraws consent to the processing of personal data or submits a request to cease processing of personal data, the Controller has the right to continue processing personal data without the data subject’s consent on the grounds stipulated by the Personal Data Law;
— Independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations provided for by the Personal Data Law and the regulatory legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.
3.2. The Controller is obliged to:
— Provide the data subject, upon their request, with information concerning the processing of their personal data;
— Organize the processing of personal data in the manner established by the current legislation of the Russian Federation;
— Respond to inquiries and requests from data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
— Provide the authorized data protection supervisory authority, upon its request, with the necessary information within 10 days from the date of receipt of such a request;
— Publish or otherwise ensure unrestricted access to this Policy regarding the processing of personal data;
— Implement legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision, distribution, as well as from other unlawful actions in relation 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;
— Fulfill other obligations stipulated by the Personal Data Law.
4. Key Rights and Obligations of Data Subjects
4.1. Data subjects 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 to the data subject by the Controller in an accessible form and shall not contain personal data relating to other data subjects, except in cases where 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 Controller to clarify, block, or destroy their personal data if the data is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, as well as to take statutory measures to protect their rights;
— Impose a condition of prior consent when processing personal data for the purpose of promoting goods, works, and services on the market;
— Withdraw consent to the processing of personal data, as well as to submit a demand to cease the processing of personal data;
— Lodge a complaint with the authorized data protection supervisory authority or in a court of law against unlawful actions or inaction of the Controller in processing their personal data;
— Exercise other rights provided for by the legislation of the Russian Federation.
4.2. Data subjects are obliged to:
— Provide the Controller with accurate data about themselves;
— Notify the Controller about the clarification (updating, modification) of their personal data.
4.3. Persons who have provided the Controller with inaccurate information about themselves or information about another data subject without the latter’s consent shall be liable in accordance with the legislation of the Russian Federation.
5. Principles of Personal Data Processing
5.1. The processing of personal data is carried out on a lawful and fair basis.
5.2. The processing of personal data is limited to the achievement of specific, predetermined, and lawful purposes. The processing of personal data that is incompatible with the purposes of collecting personal data is not permitted.
5.3. The merging of databases containing personal data, the processing of which is carried out for incompatible purposes, is not permitted.
5.4. Only personal data that meets the purposes of its processing is subject to processing.
5.5. The content and volume of the processed personal data correspond to the stated purposes of processing. The redundancy of the processed personal data in relation to the stated purposes of their processing is not permitted.
5.6. When processing personal data, the accuracy, sufficiency, and, where necessary, relevance of the personal data in relation to the purposes of processing are ensured. The Controller takes the necessary measures and/or ensures their adoption to delete or clarify incomplete or inaccurate data.
5.7. The storage of personal data is carried out in a form that allows the identification of the data subject for no longer than required by the purposes of processing personal data, unless the storage period for personal data is established by federal law, an agreement to which the data subject is a party, beneficiary, or guarantor. The processed personal data shall be destroyed or depersonalized upon achieving the purposes of processing or in the event of the loss of necessity to achieve these purposes, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing
Purpose of ProcessingInforming the User by sending emails
Personal Data
Last name, first name, patronymic name; email address; phone numbers; year, month, date, and place of birth; passport details
Legal Basis
Charter (foundation) documents of the Controller
Types of Processing
Collection, recording, systematization, accumulation, storage, destruction, and depersonalization of personal data; Sending informational emails to the email address
7. Conditions for Processing Personal Data
7.1. The processing of personal data is carried out with the consent of the data subject to the processing of their personal data.
7.2. The processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, for the performance of the functions, powers, and duties imposed on the Controller by the legislation of the Russian Federation.
7.3. The processing of personal data is necessary for the administration of justice, the execution of a judicial act, an act of another body, or an official, subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. The processing of personal data is necessary for the performance of a contract to which the data subject is a party, beneficiary, or guarantor, as well as for the conclusion of a contract on the initiative of the data subject or a contract under which the data subject will be a beneficiary or guarantor.
7.5. The processing of personal data is necessary for the exercise of the rights and legitimate interests of the Controller or third parties, or for the achievement of socially significant goals, provided that the rights and freedoms of the data subject are not violated.
7.6. Processing is carried out of personal data to which access by an unlimited number of persons has been provided by the data subject or at their request (hereinafter referred to as "publicly available personal data").
7.7. Processing is carried out of personal data subject to publication or mandatory disclosure in accordance with federal law.
8. Procedure for Collection, Storage, Transfer, and Other Types of Processing of Personal Data
The security of personal data processed by the Controller is ensured by implementing legal, organizational, and technical measures necessary to ensure full compliance with the requirements of the current legislation in the field of personal data protection.
8.1. The Controller 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 execution of applicable legislation or where the data subject has given consent to the Controller to transfer data to a third party to fulfill obligations under a civil law contract.
8.3. In the event of inaccuracies in personal data, the User may update them independently by sending a notification to the Controller’s email address at contactapple7@mail.ru with the note "Update of personal data."
8.4. The period for processing personal data is determined by the achievement of the purposes for which the personal data were collected, unless another period is stipulated by the contract or applicable legislation.
The User may at any time withdraw their consent to the processing of personal data by sending a notification to the Controller via email to contactapple7@mail.ru with the note "Withdrawal of consent to the processing of personal data."
8.5. All information collected by third-party services, including payment systems, communication means, and other service providers, is stored and processed by the said persons (Controllers/Processors) in accordance with their User Agreement and Privacy Policy. The data subject is obliged to familiarize themselves with the said documents. The Controller is not responsible for the actions of third parties, including the service providers specified in this clause.
8.6. Prohibitions established by the data subject on the transfer (except for granting access), as well as on the processing or conditions of processing (except for obtaining access) of personal data authorized for distribution, do not apply in cases of processing personal data in state, public, and other public interests as defined by the legislation of the Russian Federation.
8.7. The Controller, when processing personal data, ensures their confidentiality.
8.8. The Controller stores personal data in a form that allows the identification of the data subject for no longer than required by the purposes of processing personal data, unless the storage period for personal data is established by federal law, an agreement to which the data subject is a party, beneficiary, or guarantor.
8.9. The processing of personal data may be terminated upon achieving the purposes of processing, the expiration of the data subject’s consent, the withdrawal of consent by the data subject or a demand to cease processing, as well as upon the detection of unlawful processing of personal data.
9. List of Actions Performed by the Controller with the Received Personal Data
9.1. The Controller performs collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
9.2. The Controller performs automated processing of personal data with the receipt and/or transmission of the received information via information and telecommunication networks or without it.
10. Cross-Border Transfer of Personal Data
10.1. The Controller, prior to commencing activities related to the cross-border transfer of personal data, is obliged to notify the authorized data protection supervisory authority of its intention to carry out cross-border transfer of personal data (such notification is sent separately from the notification of intention to process personal data).
10.2. The Controller, prior to submitting the aforementioned notification, is obliged to obtain from the authorities of the foreign state, foreign individuals, and foreign legal entities to whom the cross-border transfer of personal data is planned, the relevant information.
11. Confidentiality of Personal Data
The Controller and other persons who have gained access to personal data are obliged not to disclose to third parties and not to distribute personal data without the consent of the data subject, unless otherwise provided by federal law.
12. Final Provisions
12.1. The User can obtain any clarifications on questions of interest regarding the processing of their personal data by contacting the Controller via email at contactapple7@mail.ru.
12.2. This document will reflect any changes to the Controller’s personal data processing policy. 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 http://titocco.ru/privacy.