Personal Data Processing Policy
1. General Provisions
This personal data processing policy has been drawn up in accordance with the requirements of Federal Law No. 152-FZ of 27.07.2006 “On Personal Data” (hereinafter — the Personal Data Law) and defines the procedure for the processing of personal data and the measures to ensure the security of personal data undertaken by Himcolor Rus LLC (hereinafter — the Operator).
1.1. The Operator regards the observance of human and civil rights and freedoms in the processing of personal data, including the protection of the rights to privacy and to personal and family confidentiality, as the most important objective and condition of carrying out its activities.
1.2. This Operator’s policy on the processing of personal data (hereinafter — the Policy) applies to all information that the Operator may obtain about visitors to the website https://himcolor.com.
2. Key Terms Used in the Policy
2.1. Automated processing of personal data — the processing of personal data by means of computing equipment.
2.2. Blocking of personal data — the temporary suspension of the processing of personal data (except in 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 https://himcolor.com.
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. Anonymization of personal data — actions as a result of which it becomes impossible, without the use of additional information, to determine that personal data belong to a specific User or other personal 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 with personal data, including the collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
2.7. Operator — a state body, municipal body, legal entity, or natural person that, independently or jointly with other persons, organizes and/or carries out the processing of personal data, as well as determines the purposes of processing personal data, the composition of the personal data to be processed, and the actions (operations) performed with the personal data.
2.8. Personal data — any information relating directly or indirectly to an identified or identifiable User of the website https://himcolor.com.
2.9. Personal data authorized by the personal data subject for distribution — personal data to which access by an unlimited range of persons has been granted by the personal data subject through the giving of consent to the processing of personal data authorized by the personal data subject for distribution in the manner prescribed by the Personal Data Law (hereinafter — personal data authorized for distribution).
2.10. User — any visitor to the website https://himcolor.com.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific range of persons.
2.12. Distribution of personal data — any actions aimed at disclosing personal data to an indefinite range of persons (transfer of personal data) or at making personal data available to an unlimited range of persons, including the publication of personal data in the mass media, the posting of personal data on information and telecommunications networks, or the provision of access to personal data by any other means.
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 natural person, or a foreign legal entity.
2.14. Destruction of personal data — any actions as a result of which personal data are irretrievably destroyed such that the content of the personal data in the personal data information system cannot be subsequently restored, and/or as a result of which the material carriers of the personal data are destroyed.
3. Principal Rights and Obligations of the Operator
3.1. The Operator has the right to:
- receive from the personal data subject accurate information and/or documents containing personal data;
- in the event that the personal data subject withdraws consent to the processing of personal data, as well as sends a request demanding that the processing of personal data cease, the Operator has the right to continue processing the personal data without the consent of the personal data subject where there are grounds specified in the Personal Data Law;
- independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of the 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 Operator is obliged to:
- provide the personal data subject, at their request, with information concerning the processing of their personal data;
- organize the processing of personal data in the manner established by the applicable legislation of the Russian Federation;
- respond to appeals and requests from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
- provide the authorized body for the protection of the rights of personal data subjects, at that body’s request, with the necessary information within 10 days from the date of receipt of such request;
- publish or otherwise ensure unrestricted access to this Policy on the processing of personal data;
- take legal, organizational, and technical measures to protect personal data against unlawful or accidental access, destruction, modification, blocking, copying, provision, and distribution of personal data, as well as against other unlawful actions with respect to personal data;
- cease the transfer (distribution, provision, access) of personal data, cease the processing, and destroy the personal data in the manner and in the cases provided for by the Personal Data Law;
- fulfill other obligations provided for by the Personal Data Law.
4. Principal Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects have the right to:
- receive information concerning the processing of their personal data, except in the cases provided for by federal laws. Such information is provided to the personal data subject by the Operator in an accessible form, and it must not contain personal data relating to other personal data subjects, except where there are lawful 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 Operator to clarify their personal data, to block it, or to destroy it where the personal data are incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, as well as take the measures provided for by law to protect their rights;
- impose the condition of prior consent to the processing of 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 send a request demanding that the processing of personal data cease;
- appeal, to the authorized body for the protection of the rights of personal data subjects or through the courts, against the unlawful actions or inaction of the Operator in the processing of their personal data;
- exercise other rights provided for by the legislation of the Russian Federation.
4.2. Personal data subjects are obliged to:
- provide the Operator with accurate data about themselves;
- notify the Operator of any clarification (updating, modification) of their personal data.
4.3. Persons who have provided the Operator with inaccurate information about themselves, or information about another personal data subject without the latter’s consent, bear liability 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 the personal data is not permitted.
5.3. The merging of databases containing personal data that are processed for purposes incompatible with one another is not permitted.
5.4. Only personal data that correspond to the purposes of their processing are subject to processing.
5.5. The content and scope of the personal data processed correspond to the stated purposes of processing. The processed personal data must not be excessive in relation to the stated purposes of their processing.
5.6. When processing personal data, the accuracy and sufficiency of the personal data and, where necessary, their currency in relation to the purposes of processing the personal data are ensured. The Operator takes the necessary measures and/or ensures that they are taken to delete or clarify incomplete or inaccurate data.
5.7. Personal data are stored in a form that allows the personal data subject to be identified for no longer than required by the purposes of processing the personal data, unless the storage period for the personal data is established by federal law or by a contract to which the personal data subject is a party, beneficiary, or guarantor. The processed personal data are destroyed or anonymized upon achievement of the purposes of processing, or in the event that the need to achieve those purposes is lost, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing
| Purpose of processing | providing the User with access to the services, information, and/or materials contained on the website |
|---|---|
| Personal data | surname, first name, patronymic email address telephone numbers |
| Legal grounds | Federal Law No. 149-FZ of 27.07.2006 “On Information, Information Technologies and Information Protection” |
| Types of personal data processing | Collection, recording, systematization, accumulation, storage, destruction, and anonymization of personal data |
| Purpose of processing | informing the User by sending emails |
|---|---|
| Personal data | surname, first name, patronymic email address telephone numbers |
| Legal grounds | Federal Law No. 149-FZ of 27.07.2006 “On Information, Information Technologies and Information Protection” |
| Types of personal data processing | Collection, recording, systematization, accumulation, storage, destruction, and anonymization of personal data Sending informational emails to the email address |
7. Conditions for Personal Data Processing
7.1. Personal data are processed with the consent of the personal 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, and to carry out the functions, powers, and duties assigned to the Operator by the legislation of the Russian Federation.
7.3. The processing of personal data is necessary for the administration of justice, the enforcement of a judicial act or an act of another body or official subject to enforcement 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 personal data subject is a party, beneficiary, or guarantor, as well as for the conclusion of a contract at the initiative of the personal data subject or of a contract under which the personal data subject will be a beneficiary or guarantor.
7.5. The processing of personal data is necessary to exercise the rights and legitimate interests of the Operator or of third parties, or to achieve socially significant purposes, provided that in doing so the rights and freedoms of the personal data subject are not violated.
7.6. Personal data are processed to which access by an unlimited range of persons has been granted by the personal data subject or at their request (hereinafter — publicly available personal data).
7.7. Personal data are processed that are subject to publication or mandatory disclosure in accordance with federal law.
8. Procedure for the Collection, Storage, Transfer, and Other Types of Processing of Personal Data
The security of the personal data processed by the Operator is ensured through the implementation of the legal, organizational, and technical measures necessary to fully comply with the requirements of the applicable legislation in the field of personal data protection.
8.1. The Operator ensures the safekeeping of personal data and takes all possible measures to preclude 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 enforcement of applicable legislation or where the personal data subject has given the Operator consent to transfer the data to a third party for the performance of obligations under a civil law contract.
8.3. In the event that inaccuracies in personal data are identified, the User may update them independently by sending the Operator a notice to the Operator’s email address info@himcolor.com marked “Update of personal data”.
8.4. The period of processing of personal data is determined by the achievement of the purposes for which the personal data were collected, unless a different period is provided for by a contract or by applicable legislation.
The User may at any time withdraw their consent to the processing of personal data by sending the Operator a notice by email to the Operator’s email address info@himcolor.com marked “Withdrawal of consent to the processing of personal data”.
8.5. All information collected by third-party services, including payment systems, means of communication, and other service providers, is stored and processed by the said persons (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject and/or with the said documents. The Operator is not responsible for the actions of third parties, including the service providers referred to in this clause.
8.6. The prohibitions established by the personal data subject on the transfer (other than the provision of access), as well as on the processing or the conditions of processing (other than the obtaining of access) of personal data authorized for distribution, do not apply in cases of the processing of personal data in the state, public, and other public interests defined by the legislation of the Russian Federation.
8.7. When processing personal data, the Operator ensures the confidentiality of the personal data.
8.8. The Operator stores personal data in a form that allows the personal data subject to be identified for no longer than required by the purposes of processing the personal data, unless the storage period for the personal data is established by federal law or by a contract to which the personal data subject is a party, beneficiary, or guarantor.
8.9. The grounds for ceasing the processing of personal data may be the achievement of the purposes of processing the personal data, the expiry of the personal data subject’s consent, the withdrawal of consent by the personal data subject, a request demanding that the processing of personal data cease, as well as the detection of unlawful processing of personal data.
9. List of Actions Performed by the Operator with the Personal Data Received
9.1. The Operator carries out the collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
9.2. The Operator carries out the automated processing of personal data, with or without the receipt and/or transfer of the information obtained via information and telecommunications networks.
10. Cross-Border Transfer of Personal Data
10.1. Before commencing activities involving the cross-border transfer of personal data, the Operator is obliged to notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out the cross-border transfer of personal data (such notification is sent separately from the notification of the intention to process personal data).
10.2. Before submitting the aforementioned notification, the Operator is obliged to obtain the relevant information from the foreign state authorities, foreign natural persons, and foreign legal entities to which the cross-border transfer of personal data is planned.
11. Confidentiality of Personal Data
The Operator and other persons who have gained access to personal data are obliged not to disclose personal data to third parties and not to distribute personal data without the consent of the personal data subject, unless otherwise provided by federal law.
12. Final Provisions
12.1. The User may obtain any clarifications on questions of interest concerning the processing of their personal data by contacting the Operator via email at info@himcolor.com.
12.2. This document will reflect any changes to the Operator’s personal data processing policy. The Policy is valid indefinitely until it is replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet at https://himcolor.com/privacy.