PERSONAL DATA PROCESSING POLICY
FASHION TECHNOLOGIES Limited Liability Company (hereinafter referred to as the Company) enters into relations related to the processing of personal data and is, therefore, the operator of personal data. The Policy regulates the procedure and conditions for processing personal data of personal data subjects, the rights and obligations of personal data subjects.
1. GENERAL PROVISIONS
1.1. The terms used in this Policy are used in the meanings established by the Federal Law of the Russian Federation "On Personal Data" and the norms of the current legislation of the Russian Federation.
1.2. The policy was developed based on the requirements of regulatory and legal documents in the field of personal data protection and processing: the Constitution of the Russian Federation; the Civil Code, Federal Laws of the Russian Federation "On Personal Data", "On Security", "On Information, Information Technologies and Information Protection", "On Trade Secrets", "On Communications", "On Limited Liability Companies", "On Technical Regulation", Resolutions of the Government of the Russian Federation, Orders of the FSTEC of Russia and other regulatory legal acts of the Russian Federation.
1.3 The basis for the processing of personal data is Consent to the processing of personal data in the form of Appendix No. 1 to this Policy.
2. PURPOSES AND PRINCIPLES OF PERSONAL DATA PROCESSING
2.1 The Company processes personal data for the purposes of:
to register/authorize a user on the website filisti.com (hereinafter, the Site);
to fulfill a contract to which the personal data subject is a party or beneficiary or guarantor.;
to evaluate and analyze the Company's performance in the process of fulfilling contractual obligations;
to determine the winner in the incentive events held by the Company;
conducting advertising and marketing campaigns, including advertising and marketing campaigns of third parties;
identification of users of the Company's website on the Internet;
compliance with other requirements of the legislation of the Russian Federation.
2.2. The Company has the right, with the consent of the personal data subject, to send informational, including advertising messages, to his e-mail, mobile phone, messengers. The fact that there is a check mark when the user places an Order or on other forms of the Site is a sufficient form of consent to receive the above messages. Service messages informing the user about the order and the stages of its processing are sent automatically and cannot be rejected by the user.
3. CATEGORIES OF PERSONAL DATA SUBJECTS, THEIR RIGHTS AND CATEGORIES OF PERSONAL DATA PROCESSED
3.1. The Company processes personal data of the following categories of subjects:
individuals – clients of the Company who have given their consent to the processing of personal data by the Company;
visitors to the Company's Website on the Internet who have consented to the processing of personal data by the Company;
users of the Company's applications/services who have consented to the processing of personal data by the Company;
individuals who have contacted the Company with requests (including claims, letters), including through the contact center, chat, social networks, who have consented to the processing of personal data by the Company;
authorized on the basis of a power of attorney by representatives of the above-mentioned entities who have consented to the processing of personal data by the Company.
3.2. Rights of personal data subjects:
receive full information about their personal data processed by the Company;
clarify your personal data, request their blocking or destruction if the personal data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated purpose of processing.;
revoke consent to the processing of personal data in the manner and in the manner prescribed in section 5 of this Policy;
to exercise other rights stipulated by the legislation of the Russian Federation;
The subject has the right to refuse to receive advertising and other information at any time without explaining the reasons for the refusal. Service messages informing the subject about the order and the stages of its processing are sent automatically and cannot be rejected by the subject.
3.3. The Company has the right to process the following categories of personal data:
last name, first name, patronymic (including former ones);
gender
date of birth;
address of the place of residence, passport data or data of another identity document (type, series and number of the document, date of issue of the document, name of the issuing authority, unit code (if available));
contact information (phone number, accounts in messengers, social networks, email address);
photos, as well as other specified information.
4. PROCEDURE AND CONDITIONS OF PERSONAL DATA PROCESSING
4.1. The processing of personal data is carried out both with the use of automation tools and without the use of such tools. The processing of personal data includes, among other things: collection; recording; systematization; accumulation; storage; clarification (updating, modification); extraction; use; transfer (distribution, provision, access); depersonalization; blocking; deletion; destruction.
4.2. Personal data processing conditions Consent to the processing of personal data by the Company may be given by the personal data subject or his representative in any form that allows to confirm the fact of its receipt, unless otherwise established by law.
4.3. Terms of processing personal data The term of processing personal data of the Company's clients, consent to the processing of personal data and other above-mentioned actions is provided by the personal data subject without limitation of the validity period. The period of processing of personal data of other personal data subjects is defined by the Company as the period necessary to achieve the purposes of processing, unless otherwise specified in the consent to the processing of personal data provided by the personal data subject.
4.4. Personal data is collected in the following ways:
entering or otherwise communicating personal data directly by the personal data subject on the Company's website on the Internet, through a Mobile Application, contact center or social networks;
collection of personal data by the Company's counterparties when a personal data subject applies to a retail store with the intention of joining a loyalty program;
collection by e-mail or other electronic communication channels, questionnaires and other documents in the form prescribed by the Company containing personal data of subjects;
collection of questionnaires and other documents with the personal signature of the personal data subject in accordance with the form established by the Company, containing the personal data of the subjects.
The Company has the right to use "cookies" technology. "Cookies" do not contain confidential information and are not passed on to third parties. The Cookie Policy is regulated by Appendix No. 1 to this Policy.
The Company receives information about the IP address of the Website user. This information is not used to identify the user.
The Company has the right to record telephone conversations with users. At the same time, the Company undertakes to prevent attempts of unauthorized access to information obtained during telephone conversations and/or its transfer to third parties.
I have read and agree with this Policy on the Website when checking the box. filisti.com taking into account the preliminary review of this Policy, it is a sufficient form of consent to the processing of personal data of the Site user. In this way, the user confirms that his consent is specific, informed and conscious. The subject is obliged to provide reliable information about himself and promptly notify about changes in his personal data. The Company has the right to verify the accuracy of the data provided by the subject, comparing this data with the documents already available to the Company.
4.5. Personal Data is stored in the following ways:
on paper;
in the form of questionnaires and other documents with the personal signature of the personal data subject in the form prescribed by the Company on paper;
on electronic media; on electronic media hosted on the Company's servers, as well as backup systems;
on electronic media hosted in servers rented by the Company from hosting providers. During the storage of personal data, the Company ensures their safety and access to personal data exclusively by authorized persons.
4.6. Confidentiality and security of personal data are not disclosed by the Company to third parties and personal data is not distributed without the consent of the personal data subject, unless otherwise provided by the legislation of the Russian Federation. The Company takes all necessary measures to ensure the security of personal data established by the legislation of the Russian Federation, including:
identifies threats to the security of personal data during their processing;
Adopts local regulations and other documents regulating relations in the field of personal data processing and protection;
appoints persons responsible for ensuring the security of personal data in the structural divisions and information systems of the Operator;
creates the necessary conditions for working with personal data;
organizes the accounting of documents containing personal data;
organizes work with information systems in which personal data is processed;
stores personal data in conditions that ensure their safety and exclude unauthorized access to them.;
organizes the training of the Operator's employees who process personal data.
4.7. In carrying out its activities, the Company may transfer the personal data of subjects in strict accordance with the requirements of the legislation of the Russian Federation, local acts and with proper security of this data. The transfer of personal data can be carried out both with the use of automation tools and without the use of such tools.
4.8. The processing of personal data for the purpose of promoting goods, works, and services on the market through direct contact with a potential consumer by means of communication can be carried out by the Company only with the prior consent of the personal data subject and is terminated upon his request.
4.9. Blocking of personal data The Company blocks personal data in the following cases: — when the subject of personal data applies for compliance with their legal rights. The choice of the method of blocking personal data is determined by the responsible employee based on the specifics of the personal data processing conditions, including the capabilities of the software used in the processing.
4.10. Termination of processing and destruction of personal data The processing of personal data is terminated or terminated if the processing of personal data is carried out by another person acting on behalf of the Company, and the collected personal data is destroyed within the time limits established by the legislation of the Russian Federation, in the following cases, unless otherwise established by the legislation of the Russian Federation:
after the expiration of the established period for processing personal data;
upon achievement of the processing objectives or upon loss of the need to achieve them;
at the request of the personal data subject or the authorized body for the protection of the rights of personal data subjects — if the personal data is incomplete, outdated, unreliable, illegally obtained or is not necessary for the stated purpose of processing;
when a personal data subject withdraws consent to the processing of their personal data, if such consent is required in accordance with federal law;
if it is impossible for the Company to eliminate the violations committed during the processing of personal data.
5. REQUESTS AND INQUIRIES REGARDING THE PROCESSING OF PERSONAL DATA
5.1. The personal data subject has the right to receive information about the Company, about its location, about the Company's availability of personal data related to the relevant personal data subject, as well as to get acquainted with such personal data. The personal data subject has the right to require the Company to clarify their personal data, block or destroy them if the personal data is incomplete, outdated, unreliable, illegally obtained or is not necessary for the stated purpose of processing, as well as to take legal measures to protect their rights.
5.2. Information about the availability of personal data is provided to the personal data subject in an accessible form and free of charge. In addition, they should not contain personal data related to other subjects of personal data. The personal data subject has the right to receive information regarding the processing of his personal data, including information containing:
confirmation of the processing of personal data by the Company, as well as the purpose of such processing;
personal data processing methods used by the Company;
information about persons who have access to personal data or who may be granted such access;
the list of personal data processed and the source of their receipt;
terms of personal data processing, including the terms of their storage.
5.3. Access to their personal data is provided to the personal data subject or his legal representative by the Company upon request or upon receipt of a request from the personal data subject or his legal representative (hereinafter referred to as the Request). The appeals of the subjects are accepted by the Company during the working day. The request must contain the number of the main identity document of the personal data subject or his legal representative, information about the date of issue of the specified document and the issuing authority, and the handwritten signature of the personal data subject or his legal representative. An application for revocation of personal data can be sent at any time to the address: 127276, Moscow, Marfinsky proezd d 4, 1st entrance, 3rd floor, room 2.
5.4 The Company is obliged to send a response to the personal data subject's Request within a period not exceeding thirty working days from the date of receipt of the Request. In case of revocation of Personal Data, participation in the loyalty program will be automatically terminated, the Loyalty Program client's card will be blocked and its blocking will mean that it will be impossible to use the discount, and you will also have to re-consent to the processing of personal data if the client decides to use the Company's services or products again, requiring filling out questionnaires, applications, etc. containing personal data.
6. LIABILITY FOR VIOLATIONS OF THE RULES GOVERNING THE PROCESSING AND PROTECTION OF PERSONAL DATA
6.1. Persons guilty of violating the rules governing the processing and protection of personal data processed in the Company's personal data information systems bear civil, criminal, administrative, disciplinary and other liability provided for by the legislation of the Russian Federation. Disclosure of information in accordance with reasonable and applicable legal requirements is not considered a violation of obligations. The Company is not responsible for the information provided by the user on the Website in a publicly accessible form.
Appendix No. 1 to the Company's Personal Data Processing Policy
By my own will and in my own interest, I consent to the processing, including collection, systematization, accumulation, storage, (clarification, updating, modification), use, transfer to third parties (a list of third parties can be found at the link, depersonalization, blocking, destruction, of my personal data, which, depending on the document (application form, application, etc.) includes, but is not limited to, the following personal data:
surname;
name;
patronymic;
gender;
date of birth;
address of the place of residence;
passport data or data of another identity document (type, series and number of the document, date of issue of the document, name of the issuing authority, unit code (if available));
contact information (phone number, email address, accounts in messengers, social networks);
photos, as well as other specified information, to FASHION TECHNOLOGIES Limited Liability Company, OGRN 1217700186835, in order to provide me with their goods and services (products), including, but not limited to: identification of a participant in the loyalty program, ensuring the accounting procedure for the accumulation and use of discounts, delivery, provision of services, distribution of advertising messages (including about ongoing promotions and special offers through any communication channels, including by mail, SMS, e-mail, telephone, and other means of communication), collecting opinions about the work of FASHION TECHNOLOGIES LLC.
I agree that my personal data will be processed in ways that correspond to the purposes of personal data processing, including with or without the use of automation tools. I also agree that the consent given by me in electronic form on the website is a consent that fully complies with the requirements of the legislation on personal data and allows me to confirm the fact of its receipt by FASHION TECHNOLOGIES LLC. Consent is given by me for the duration of the Program. At the same time, I am informed and agree that the revocation of this consent will automatically terminate my participation in the Loyalty Program, my Loyalty Program customer card will be blocked and its blocking will mean that it will be impossible to use the discount, and I will have to re-consent to the processing of personal data in the event that if I decide to use the services or products of FASHION TECHNOLOGIES LLC again, which require filling out questionnaires, applications, etc. containing my personal data.