Policy on personal data processing (version of September 6, 2024)
This Policy is a document defining the policy of the Limited Liability Company “Eternal Youth”, OGRN 1197847190826, TIN 7841086351 (hereinafter referred to as the “Company”) in relation to the processing of personal data that the Company may receive from personal data subjects who in one way or another use the website on the Internet at https://vsh25.net/ (hereinafter referred to as the “Site”) and / or any services available through the Site (hereinafter referred to as the “Service(s)”). Hereinafter, the respective personal data subjects are collectively referred to as “users” and individually as “user”.
The use of the Site (in particular, any of its pages) and / or the use of any Services means that the user unconditionally agrees with this Policy and the terms of processing of his/her personal data specified herein; in case of disagreement with these terms, the user must refrain from using the Site and / or Services.
1. GENERAL PROVISIONS
1.1 For the purposes of this Policy, the user’s personal data shall mean:
1.1.1 Personal data (name, surname, patronymic, phone number, e-mail address, etc.), which the user provides about himself/herself when going through the registration procedure on the Site, as a result of which a unique account (personal account) is created for the user, or in any other way;
1.1.2. Data that is automatically transmitted by the user’s device, through which he/she accesses the Site and / or Services, including IP-address, cookie data, information about the user’s browser (or similar program), technical characteristics of equipment and software used by the user, date and time of access to the Site and / or Services, addresses of requested pages and other similar information.
1.2 This Policy applies solely to the Site and the Services available through the Site. The Company does not control and is not responsible for third party websites, to which the user can go through the links available on the Site.
2. PURPOSES OF PROCESSING PERSONAL DATA OF USERS
2.1 The Company shall process users’ personal data solely for the following purposes:
- provision of services by the Company to users in accordance with the contract (user agreement) concluded with users, in particular, ensuring availability of the Services for users (including by sending information digests (news selections), analytical materials to users’ e-mail addresses);
- creation of unique accounts (personal accounts) on the Website for users;
- sending reference and marketing information to users, including marketing information of third party partners of the Company;
- providing users with an opportunity to provide feedback to the Company, including for the purposes of user support;
- providing users with consultations on issues related to the services provided by the Company.
- CONDITIONS OF PROCESSING OF USERS’ PERSONAL DATA AND ITS TRANSFER TO THIRD PARTIES
3.1 The legal basis for the processing of personal data of users by the Company is a contract concluded between users and the Company (user agreement, the current version of which is always publicly available on the Website at: https://vsh25.net/user-agreement and / or the user’s consent to the processing of personal data by the Company. In the absence of a contract between the Company and the user, when sending any information to the Company, including by filling in the feedback form on the Website, the user gives the Company consent to the processing of all personal data provided by the user.
3.2 The Company shall process only those personal data of users, the content and scope of which corresponds to the processing purposes specified in Section 2 of this Policy. To achieve the purposes specified in Section 2 of this Policy, the Company processes the following user’s personal data: name, surname, patronymic, telephone number, e-mail address, and other data that the user independently wishes to provide to the Company, as well as, due to technical peculiarities of the Internet functioning, the data specified in Section 1.1.2 of this Policy.
3.3 In certain cases, in particular, for the purpose of refunding the money paid by the user in case of circumstances specified in the User Agreement, the Company may process the user’s personal data, which are additionally provided (sent) by the user. Submission (sending) of the respective personal data by the user to the Company means the user’s consent to the processing of the said personal data by the Company.
3.4 In the course of personal data processing, the Company shall have the right to collect, record, systematize, accumulate, store, clarify (update, change), extract, use, transfer (provide, access), depersonalize, block, delete, destroy personal data of users.
3.5 Processing of users’ personal data is generally carried out with the use of means of automation. In exceptional cases, the processing of personal data of users may be carried out without the use of such means, subject to mandatory compliance with all requirements stipulated by applicable law.
3.6 Processing of users’ personal data shall be carried out for the period necessary to achieve the purposes specified in Section 2 of this Policy and / or during the period provided for by the contract (user agreement) with users and / or during the period provided for by applicable law.
3.7 User’s personal data shall be kept confidential, except for cases when the User voluntarily provides information about himself/herself for public access to an unlimited number of persons.
3.8 The user hereby fully consents to the possibility of cross-border transfer by the Company of any of his/her personal data to third parties located in foreign countries that are parties to the Council of Europe Convention for the Protection of Individuals with regard to Automatic Processing of Personal Data, as well as other foreign countries that provide adequate protection of the rights of personal data subjects outside the Russian Federation (the names of such third parties will be communicated by the Company to the user additionally).
The transfer of users’ personal data in accordance with this clause shall be carried out for the purposes of provision of marketing information to users by the relevant third parties who are partners of the Company, i.e. information on goods, services, works, property rights, etc. offered by such third parties. Relevant third parties have the right to process users’ personal data in compliance with the requirements for the protection of processed personal data established by the laws of incorporation in such ways as: systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (provision, access), depersonalization, blocking, deletion, destruction of user’s personal data.
3.9 Upon achievement of the purposes / upon expiration of the period for processing of personal data / upon withdrawal of the user’s consent to the processing of personal data, the user’s personal data shall be irretrievably destroyed.
3.10. The Company shall take the necessary organizational and technical measures to protect users’ personal data from unlawful or accidental access, destruction, modification, blocking, copying, distribution, as well as from other unlawful actions of third parties. When personal data of users are processed by the Company’s employees, the relevant data shall be processed only by authorized employees of the Company who have undertaken to keep such data confidential and who have been familiarized with the provisions of the legislation of the Russian Federation on personal data, including the requirements to the protection of personal data, as well as with the local acts of the Company on the issues of personal data processing. The Company processes users’ personal data using databases located in the Russian Federation.
- RIGHTS AND OBLIGATIONS OF THE WEBSITE USER
4.1 Users have the right:
4.1.1. to demand clarification of their personal data, their updating, blocking or destruction;
4.1.2. to receive a list of their personal data processed by the Company, the source of their receipt, information on the terms of processing their personal data, including the terms of their storage, and other information on the processing of their personal data, as provided for by applicable law;
4.1.3. demand notification of all persons to whom his/her incorrect or incomplete personal data were previously disclosed about all corrections or additions made;
4.1.4. to appeal in accordance with the established procedure against unlawful acts or omissions in the processing of their personal data.
4.2 Users undertake to provide only true data about themselves.
4.3 If the Company processes personal data on the basis of consent to the processing of personal data, such consent shall be given by the user for the entire period necessary for the Company to achieve the processing purposes specified in Section 2 of this Policy.
- OBLIGATIONS OF THE COMPANY
5.1 The Company undertakes to:
5.1.1. use the received personal data exclusively for the purposes specified in Section 2 of this Policy;
5.1.2. to keep the data confidential, not to disclose them without prior written authorization of the user, as well as not to sell, exchange, publish or disclose by other possible means the personal data of the user, except for the cases stipulated by this Policy and applicable law;
5.1.3. take measures provided for by the legislation and local acts of the Company to protect the confidentiality of the user’s personal data;
5.1.4. block personal data related to the respective user from the moment of receiving a request from the user or his/her legal representative or the authorized body for the protection of the rights of personal data subjects for the period of verification in case of revealing unreliable personal data or unlawful actions;
5.1.5. to provide the user, upon receipt of a request from the user or his/her legal representative that complies with legal requirements, with a list of personal data processed by the Company, the source of their receipt, information on the terms of personal data processing, including the terms of their storage, and other information on the processing of his/her personal data as provided for by applicable law;
5.1.6. to carry out clarification of the user’s personal data, their updating, blocking, destruction, as well as to eliminate any violations of the law committed during the processing of personal data in the manner prescribed by applicable law.
- ADDITIONAL CONDITIONS
6.1 Any requests / appeals of users / legal representatives of users / authorized state authorities regarding the Company’s processing of personal data, including those concerning inaccuracy of processed personal data, unlawfulness of their processing, withdrawal of consent, as well as the user’s access to his/her data shall be sent in writing (by registered and / or valuable letter, express mail) to the Company’s address: Russia, 191186, St. Petersburg, Nevsky Prospekt, 38/4, liter a, part of room 2-n, room 213 or by sending the relevant request / appeal to the following e-mail address of the Company: . 2-n, room 213 or by sending a relevant request / appeal to the following e-mail address of the Company: info@vsh25.net. The request / appeal must contain at least: the user’s surname, first name, patronymic, e-mail address, and in cases stipulated by the current legislation, other data.
6.2 The Company has the right to make changes to this Policy without the consent of the user.
6.3 The new edition of the Policy comes into effect from the moment of its posting on the Website, unless otherwise provided by the new edition of the Policy.
6.4 The current version of this Policy is always publicly available on the Website at the following address: https://vsh25.net/private-policy/.