Personal Data Processing Policy

1. General Provisions

This personal data processing policy has been prepared in accordance with Federal Law No. 152-FZ “On Personal Data” dated July 27, 2006 (hereinafter referred to as the Personal Data Law) and defines the procedure for processing personal data and the personal data security measures taken by Individual Entrepreneur Danilov (hereinafter referred to as the Operator).

1.1. The Operator considers the observance of human and civil rights and freedoms when processing personal data, including the protection of privacy, personal and family secrets, to be its most important objective and a key condition of its activities.

1.2. This Operator policy regarding personal data processing (hereinafter referred to as the Policy) applies to all information that the Operator may receive about visitors to the website https://true.toys.

2. Main Terms Used in This Policy

2.1. Automated processing of personal data means processing personal data using computer technology.

2.2. Blocking of personal data means the temporary suspension of personal data processing, except where processing is necessary to clarify personal data.

2.3. Website means a set of graphic and informational materials, as well as computer programs and databases, made available on the internet at https://true.toys.

2.4. Personal data information system means a set of personal data contained in databases, together with information technologies and technical means used to process such data.

2.5. Depersonalization of personal data means actions after which it is impossible, without additional information, to determine whether personal data belongs to a specific User or another personal data subject.

2.6. Processing of personal data means any action or set of actions performed with personal data, with or without automation tools, including collection, recording, systematization, accumulation, storage, clarification (updating or modification), retrieval, use, transfer (distribution, provision or 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 other persons organizes and/or carries out personal data processing, and determines the purposes of processing, the scope of personal data to be processed and the actions performed with personal data.

2.8. Personal data means any information relating directly or indirectly to an identified or identifiable User of the website https://true.toys.

2.9. Personal data permitted by the personal data subject for distribution means personal data made available to an unlimited number of persons by the personal data subject through consent to the processing of personal data permitted for distribution in accordance with the procedure established by the Personal Data Law.

2.10. User means any visitor to the website https://true.toys.

2.11. Provision of personal data means actions aimed at disclosing personal data to a specific person or a specific group of persons.

2.12. Distribution of personal data means any actions aimed at disclosing personal data to an indefinite group of persons or making personal data available to an unlimited number of persons, including publication in mass media, placement in information and telecommunications networks or providing access to personal data by any other means.

2.13. Cross-border transfer of personal data means the transfer of personal data to the territory of a foreign state, to a foreign government authority, foreign individual or foreign legal entity.

2.14. Destruction of personal data means any actions resulting in the irreversible destruction of personal data, making it impossible to restore the content of personal data in the personal data information system, and/or the destruction of physical media containing personal data.

3. Main Rights and Obligations of the Operator

3.1. The Operator has the right to:

— receive accurate information and/or documents containing personal data from the personal data subject;

— continue processing personal data without the consent of the personal data subject where the subject withdraws consent or submits a request to stop processing, provided there are grounds specified in the Personal Data Law;

— independently determine the scope and list of measures necessary and sufficient to ensure compliance with obligations under 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 is obliged to:

— provide the personal data subject, upon request, with information concerning the processing of their personal data;

— organize personal data processing in accordance with the procedure 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;

— provide the authorized body for the protection of personal data subjects’ rights with the necessary information within 10 days of receiving such a request;

— publish or otherwise provide unrestricted access to this Personal Data Processing Policy;

— take legal, organizational and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision, distribution and other unlawful actions involving personal data;

— stop transferring, distributing, providing and granting access to personal data, stop processing it and destroy personal data in the manner and cases provided for by the Personal Data Law;

— perform other obligations provided for by the Personal Data Law.

4. Main 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 cases provided for by federal laws. Such information is provided 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 data. The list of information and the procedure for obtaining it are established by the Personal Data Law;

— require the Operator to clarify, block or destroy their personal data if it is incomplete, outdated, inaccurate, unlawfully obtained or not necessary for the stated purpose of processing, and to take measures provided by law to protect their rights;

— require prior consent for the processing of personal data for the purpose of promoting goods, works and services on the market;

— withdraw consent to personal data processing and submit a request to stop the processing of personal data;

— appeal unlawful actions or inaction by the Operator in the processing of personal data to the authorized body for the protection of personal data subjects’ rights or in court;

— 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;

— inform the Operator of any clarification, update or change to their personal data.

4.3. Persons who provide the Operator with inaccurate information about themselves or information about another personal data subject without that subject’s consent are liable in accordance with the legislation of the Russian Federation.

5. Principles of Personal Data Processing

5.1. Personal data is processed on a lawful and fair basis.

5.2. Personal data processing is limited to achieving specific, predetermined and lawful purposes. Processing personal data in a manner incompatible with the purposes for which it was collected is not permitted.

5.3. It is not permitted to combine databases containing personal data processed for mutually incompatible purposes.

5.4. Only personal data that corresponds to the purposes of its processing may be processed.

5.5. The content and scope of the processed personal data correspond to the stated purposes of processing. Excessive personal data processing in relation to the stated purposes is not permitted.

5.6. When processing personal data, the Operator ensures its accuracy, sufficiency and, where necessary, relevance to the purposes of processing. The Operator takes or ensures the necessary measures to delete or clarify incomplete or inaccurate data.

5.7. Personal data is stored in a form that allows the personal data subject to be identified for no longer than required by the purposes of processing, unless a storage period is established by federal law or by an agreement to which the personal data subject is a party, beneficiary or guarantor. Processed personal data is destroyed or depersonalized once the processing purposes have been achieved or the need to achieve them is lost, unless otherwise provided by federal law.

6. Purposes of Personal Data Processing

7. Conditions for Personal Data Processing

7.1. Personal data is processed with the consent of the personal data subject.

7.2. Personal data processing is necessary to achieve purposes provided for by an international treaty of the Russian Federation or by law, and to perform the functions, powers and duties imposed on the Operator by Russian legislation.

7.3. Personal data processing is necessary for the administration of justice or the execution of a judicial act, act of another body or official subject to execution under the legislation of the Russian Federation on enforcement proceedings.

7.4. Personal data processing is necessary for the performance of an agreement to which the personal data subject is a party, beneficiary or guarantor, or for entering into an agreement at the initiative of the personal data subject or an agreement under which the personal data subject will be a beneficiary or guarantor.

7.5. Personal data processing is necessary for exercising the rights and legitimate interests of the Operator or third parties, or for achieving socially significant purposes, provided that the rights and freedoms of the personal data subject are not violated.

7.6. Personal data made available to an unlimited number of persons by the personal data subject or at their request is processed (hereinafter, publicly available personal data).

7.7. Personal data subject to publication or mandatory disclosure in accordance with federal law is processed.

8. Procedure for Collecting, Storing, Transferring and Otherwise Processing Personal Data

The security of personal data processed by the Operator is ensured through the implementation of legal, organizational and technical measures necessary to fully comply with the requirements of 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 prevent unauthorized persons from accessing personal data.

8.2. The User’s personal data will never be transferred to third parties under any circumstances, except where required by current legislation or where the personal data subject has consented to the transfer of data to a third party for the performance of obligations under a civil-law agreement.

8.3. If inaccuracies are found in personal data, the User may update it independently by sending a notice to the Operator at kr@true.toys with the subject “Personal data update”.

8.4. The period of personal data processing is determined by the achievement of the purposes for which the personal data was collected, unless another period is provided for by an agreement or current legislation.
The User may withdraw consent to personal data processing at any time by sending the Operator a notice by email to kr@true.toys with the subject “Withdrawal of consent to personal data processing”.

8.5. All information collected by third-party services, including payment systems, communication tools and other service providers, is stored and processed by those persons (operators) in accordance with their user agreement and privacy policy. The personal data subject should review those documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.

8.6. Prohibitions established by the personal data subject on the transfer, processing or processing conditions of personal data permitted for distribution do not apply in cases where personal data is processed in state, public or other public interests defined by the legislation of the Russian Federation.

8.7. When processing personal data, the Operator ensures the confidentiality of 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, unless a storage period is established by federal law or by an agreement to which the personal data subject is a party, beneficiary or guarantor.

8.9. Grounds for terminating personal data processing may include achievement of the processing purposes, expiration of the personal data subject’s consent, withdrawal of consent or a request to stop processing personal data, as well as the discovery of unlawful personal data processing.

9. List of Actions Performed by the Operator with Received Personal Data

9.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates or modifies), retrieves, uses, transfers (distributes, provides or grants access to), depersonalizes, blocks, deletes and destroys personal data.

9.2. The Operator carries out automated processing of personal data with or without receiving and/or transferring the obtained information through information and telecommunications networks.

10. Cross-Border Transfer of Personal Data

10.1. Before starting cross-border transfer of personal data, the Operator must notify the authorized body for the protection of personal data subjects’ rights of its intention to carry out such transfer. This notice is sent separately from the notice of intent to process personal data.

10.2. Before submitting the above notice, the Operator must obtain the relevant information from the foreign government authorities, foreign individuals or foreign legal entities to whom the cross-border transfer of personal data is planned.

11. Confidentiality of Personal Data

The Operator and other persons who have obtained access to personal data must not disclose it to third parties or 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 receive clarification on any questions concerning the processing of their personal data by contacting the Operator by email at kr@true.toys.

12.2. Any changes to the Operator’s personal data processing policy will be reflected in this document. The Policy remains in effect indefinitely until replaced by a new version.

12.3. The current version of the Policy is publicly available on the internet at https://true.toys/privacy-policy.