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Privacy Policy for Personal Data Processing
  1. General Provisions
This Personal Data Processing Policy has been prepared in accordance with the requirements of Federal Law No. 152-FZ of 27.07.2006 “On Personal Data” (the Personal Data Law) and defines the procedure for processing personal data and the measures taken to ensure the security of personal data by Yulia Udalova (the Operator).
1.1. The Operator’s primary objective and condition for conducting its activities is the observance of the rights and freedoms of individuals and citizens in the processing of their personal data, including the protection of the rights to privacy, personal and family secrecy.
1.2. This Policy of the Operator regarding the processing of personal data (the Policy) applies to all information that the Operator may obtain about visitors to the website http://mjb-jewelry.com.
  1. Key Terms Used in the Policy
2.1. Automated processing of personal data means the processing of personal data using computing equipment.
2.2. Blocking of personal data means the temporary suspension of the processing of personal data (except where processing is necessary to clarify personal data).
2.3. Website means a set of graphical and informational materials, as well as software and databases, which ensure their availability on the internet at the network address http://mjb-jewelry.com.
2.4. Personal data information system means a set of personal data contained in databases and information technologies and technical tools that ensure their processing.
2.5. Depersonalization of personal data means actions that make it impossible, without the use of additional information, to determine whether personal data belong to a specific User or another personal data subject.
2.6. Processing of personal data means any action (operation) or set of actions (operations) performed with or without the use of automation tools with 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. Operator means a state body, municipal body, legal entity, or individual that independently or jointly with others organizes and/or carries out the processing of personal data, and also 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 means any information relating directly or indirectly to an identified or identifiable User of the website http://mjb-jewelry.com.
2.9. Personal data made publicly available by the personal data subject means personal data to which the personal data subject has granted access to an unlimited number of persons by giving consent to the processing of personal data made publicly available by the personal data subject in the manner prescribed by the Personal Data Law (personal data permitted for distribution).
2.10. User means any visitor to the website http://mjb-jewelry.com.
2.11. Provision of personal data means actions aimed at disclosing personal data to a specific person or a specific circle of persons.
2.12. Distribution of personal data means any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or at familiarization with personal data by an unlimited circle of persons, including the disclosure of personal data in the mass media, placement in information and telecommunication networks, or providing access to personal data in any other way.
2.13. Cross-border transfer of personal data means the transfer of personal data to the territory of a foreign state to an authority of a foreign state, a foreign individual, or a foreign legal entity.
2.14. Destruction of personal data means any actions resulting in the irrevocable destruction of personal data with no possibility of further restoration of the personal data content in the personal data information system and/or the destruction of the physical media on which personal data are stored.
  1. Basic Rights and Obligations of the Operator
3.1. The Operator has the right to:
— receive from the personal data subject reliable information and/or documents containing personal data;
— in the event that the personal data subject withdraws consent to the processing of personal data, or sends a request to terminate the processing of personal data, continue processing personal data without the consent of the personal data subject if 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 obligations provided for by the Personal Data Law and regulations adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.
3.2. The Operator must:
— provide the personal data subject, upon request, with information regarding the processing of his/her personal data;
— organize the processing of personal data in the manner established by the current legislation of the Russian Federation;
— respond to requests and inquiries from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
— report to the authorized body for the protection of the rights of personal data subjects, upon request of that body, the required information within 10 days from the date of receipt of such request;
— publish or otherwise ensure unrestricted access to this Personal Data Processing Policy;
— take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, alteration, blocking, copying, provision, distribution, as well as from other unlawful actions with respect to personal data;
— cease the transfer (distribution, provision, access) of personal data, cease processing, and destroy 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.
  1. Basic Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects have the right to:
— receive information relating to the processing of their personal data, except in cases provided for by federal laws. Information is provided to the personal data subject by the Operator in an accessible form and must not contain personal data relating to other personal data subjects, except where there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it is established by the Personal Data Law;
— demand that the operator clarify their personal data, block or destroy them if the personal data are incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, as well as take measures provided by law to protect their rights;
— stipulate a condition of prior consent when processing personal data for the purposes of marketing goods, works, and services;
— withdraw consent to the processing of personal data and send a demand to cease processing of personal data;
— appeal to the authorized body for the protection of the rights of personal data subjects or to a court against unlawful actions or inaction of the Operator in processing their personal data;
— exercise other rights provided by the legislation of the Russian Federation.
4.2. Personal data subjects must:
— provide the Operator with accurate information about themselves;
— notify the Operator of the 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 that person’s consent, bear liability in accordance with the legislation of the Russian Federation.
  1. Principles of Personal Data Processing
5.1. Personal data are processed on a lawful and fair basis.
5.2. Personal data processing is limited to achieving specific, predetermined, and lawful purposes. 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 purposes that are incompatible with each other, is not permitted.
5.4. Only personal data that meet the purposes of their processing are subject to processing.
5.5. The content and volume of personal data being processed correspond to the stated purposes of processing. Excessive processing of 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 personal data in relation to the purposes of personal data processing are ensured. The Operator takes the necessary measures and/or ensures that incomplete or inaccurate data are removed or clarified.
5.7. Personal data are stored in a form that allows the identification of the personal data subject for no longer than required by the purposes of personal data processing, unless the period for storing 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 depersonalized upon achievement of the purposes of processing or if the necessity to achieve these purposes is lost, unless otherwise provided by federal law.
  1. Purposes of Personal Data Processing
Purpose of processing
Providing the User with access to the services, information, and/or materials contained on the website; conclusion, performance, and termination of civil-law contracts; informing the User by sending emails; processing applications for masterclasses and related communications; receiving and processing requests for repair/expert assessment of items; customer relationship management (CRM), including registration and support of inquiries, communications, planning and execution of deals, invoicing, and analysis of interaction effectiveness.
Personal data
surname, first name, patronymic (middle name)
email address
phone numbers
year, month, date, and place of birth
Legal grounds
contracts concluded between the Operator and the personal data subject; Federal Law “On Information, Information Technologies and Information Protection” No. 149-FZ of 27.07.2006; Federal Law No. 152-FZ of 27 July 2006 “On Personal Data”.
Types of personal data processing
collection, recording, systematization, accumulation, storage, destruction, and depersonalization of personal data; sending informational emails to the email address; processing of personal data using CRM systems to automate client interactions, including transfer, organization, analysis, and management of user requests, storage and updating of data, as well as fulfillment of requests and contractual obligations, analytics, and automated notifications. Granting access to personal data of personal data subjects to third-party services, such as Tilda CRM, AMO CRM, Bitrix CRM, exclusively for organizing the processing of applications, user communications, analytics, process automation, and the performance of contractual obligations. Access to data is provided on the basis of a contract and in accordance with the requirements of the legislation of the Russian Federation.
  1. Conditions for Personal Data Processing
7.1. Personal data are processed with the consent of the personal data subject to the processing of his/her personal data.
7.2. 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 Operator’s functions, powers, and duties imposed by the legislation of the Russian Federation.
7.3. Processing of personal data is necessary for the administration of justice, the execution of a judicial act, or an act of another body or official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. 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 a contract under which the personal data subject will be a beneficiary or guarantor.
7.5. Processing of personal data is necessary for the exercise of the rights and legitimate interests of the Operator or third parties or for achieving socially significant goals, provided that this does not violate the rights and freedoms of the personal data subject.
7.6. Processing is carried out of personal data to which an unlimited number of persons have been granted access by the personal data subject or at his/her request (publicly available personal data).
7.7. Processing is carried out of personal data subject to publication or mandatory disclosure in accordance with federal law.
  1. Procedure for Collection, Storage, Transfer, and Other Types of Personal Data Processing
The security of personal data processed by the Operator is ensured by implementing legal, organizational, and technical measures necessary to fully comply with the requirements of the current legislation in the field of personal data protection.
8.1. The Operator ensures the safekeeping of personal data and takes all possible measures to exclude 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 compliance with applicable law or if the personal data subject has given the Operator consent to transfer the data to a third party for the fulfillment of obligations under a civil-law contract.
8.3. If inaccuracies in personal data are identified, the User may update them independently by sending the Operator a notice to the Operator’s email address UliaMJB@yandex.ru with the note “Personal data update.”
8.4. The period of personal data processing is determined by the achievement of the purposes for which the personal data were collected, unless a different period is provided by a contract or applicable law. The User may withdraw his/her consent to the processing of personal data at any time by sending the Operator a notice by email to the Operator’s email address UliaMJB@yandex.ru with the note “Withdrawal of consent to personal data processing.”
8.5. All information collected by third-party services, including payment systems, communication providers, and other service providers, is stored and processed by such parties (Operators) in accordance with their User Agreements and Privacy Policies. The personal data subject must familiarize himself/herself with such documents. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this clause.
8.6. Restrictions established by the personal data subject on transfer (other than granting access), as well as on processing or conditions of processing (other than obtaining access) of personal data permitted for distribution, do not apply in cases of processing personal data 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 when processing personal data.
8.8. The Operator stores personal data in a form that allows the identification of the personal data subject for no longer than required by the purposes of personal data processing, unless the period for storing 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 conditions for terminating personal data processing may include the achievement of the purposes of personal data processing, expiration of the consent’s validity period, withdrawal of consent by the personal data subject, or a demand to cease personal data processing, as well as the identification of unlawful processing of personal data.
  1. List of Actions Performed by the Operator with the Personal Data Received
9.1. The Operator carries out 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 Operator carries out automated processing of personal data with the receipt and/or transfer of the obtained information via information and telecommunication networks or without such networks.
  1. Cross-Border Transfer of Personal Data
10.1. Before commencing the cross-border transfer of personal data, the Operator must notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out cross-border transfer of personal data (such notification is sent separately from the notification of intention to carry out personal data processing).
10.2. Before submitting the above notification, the Operator must obtain from the public authorities of the foreign state, foreign individuals, or foreign legal entities to whom the cross-border transfer of personal data is planned, the relevant information.
  1. Confidentiality of Personal Data
The Operator and other persons who have obtained access to personal data are obliged not to disclose to third parties and not to distribute personal data without the consent of the personal data subject, unless otherwise provided by federal law.
  1. Final Provisions
12.1. The User may obtain any clarifications on any issues concerning the processing of his/her personal data by contacting the Operator at the email address UliaMJB@yandex.ru.
12.2. Any changes to the Operator’s personal data processing policy will be reflected in this document. The Policy is valid indefinitely until replaced by a new version.
12.3. The current version of the Policy is publicly available on the internet at http://mjb-jewelry.com/privacy.