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 July 2006 No. 152-FZ ‘On Personal Data’ and sets out the procedure for the processing of personal data and the measures taken to ensure the security of personal data by Alexander Sergeyevich Larin, TIN 623201055974, ORGNI 323623400034687 (hereinafter referred to as the ‘Controller’).

1.1. The Operator considers the observance of human and civil rights and freedoms when processing personal data, including the protection of the rights to privacy and personal and family confidentiality, to be its primary objective and a prerequisite for carrying out its activities.

1.2. This Operator’s policy regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator may obtain about visitors to the website https://alexandersecret.shop/.


2. Key terms used in the Policy


2.1. Automated processing of personal data – the processing of personal data using computer technology;

2.2. Blocking of personal data – the temporary suspension of the processing of personal data (except where processing is necessary to verify the accuracy of the personal data);

2.3. Website – a collection of graphic and informational materials, as well as computer programs and databases, ensuring their availability on the internet at the web address https://alexandersecret.shop/.

2.4. Personal data information system – a collection of personal data contained in databases, together with the information technologies and technical means ensuring their processing;

2.5. Anonymisation of personal data – actions resulting in the impossibility of determining, without the use of additional information, the attribution of personal data to a specific User or other data subject;

2.6. Processing of personal data — any action (operation) or set of actions (operations) performed with or without the use of automated means on personal data, including the collection, recording, organisation, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), anonymisation, blocking, deletion, and destruction of personal data;

2.7. Controller – a state body, municipal body, legal entity or natural person who, independently or jointly with other persons, organises and/or carries out the processing of personal data, as well as determines the purposes of the processing of personal data, the scope of personal data to be processed, and the actions (operations) performed on personal data;

2.8. Personal data – any information relating directly or indirectly to an identified or identifiable User of the website https://alexandersecret.shop/;

2.9. User – any visitor to the website https://alexandersecret.shop/;

2.10. Provision of personal data – actions aimed at disclosing personal data to a specific person or a specific group of persons;

2.11. Dissemination of personal data – any actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or to enable an unlimited group of persons to access personal data, including the publication of personal data in the media, posting on information and telecommunications networks, or providing access to personal data by any other means;

2.12. Cross-border transfer of personal data – the transfer of personal data to the territory of a foreign state to a public authority of a foreign state, a foreign natural person or a foreign legal entity;

2.13. Destruction of personal data – any actions resulting in the irreversible destruction of personal data, rendering it impossible to subsequently restore the content of the personal data within the personal data information system and/or the destruction of physical media containing personal data.




3. The Operator may process the following personal data of the User


3.1. Surname, first name, patronymic;

3.2. Email address;

3.3. Telephone numbers;

3.4. Address of actual place of residence or current location;

3.5. The website also collects and processes anonymised data about visitors (including ‘cookies’) using web analytics services (Yandex Metrica, Google Analytics and others).

3.6. The data listed above is hereinafter referred to collectively as ‘Personal Data’ in this Policy.



4. Purposes of processing personal data


4.1. The purpose of processing the User’s personal data is to inform the User by sending emails; and to dispatch orders to the User at their place of residence or place of stay.

4.2. The Operator also has the right to send the User notifications about new products and services, special offers and various events. The User may at any time opt out of receiving such communications by sending an email to the Operator at sale.secretstation@mail.ru with the subject line ‘Opt-out of notifications about new products and services and special offers’.

4.3. De-identified User data collected via web analytics services is used to gather information about Users’ activities on the website and to improve the quality of the website and its content.



5. Legal basis for the processing of personal data


5.1. The Operator processes the User’s personal data only if the User fills in and/or submits it themselves via special forms located on the website https://alexandersecret.shop/. By filling in the relevant forms and/or submitting their personal data to the Operator, the User consents to this Policy.



6. Procedures for the collection, storage, transfer and other forms of processing of personal data


The security of personal data processed by the Operator is ensured through the implementation of legal, organisational and technical measures necessary to fully comply with the requirements of current legislation on the protection of personal data.


6.1. The Operator ensures the security of personal data and takes all possible measures to prevent unauthorised persons from accessing personal data.

6.2. The User’s personal data will never, under any circumstances, be transferred to third parties, except in cases related to compliance with applicable legislation.

6.3. Should any inaccuracies be identified in the personal data, the User may update them independently by sending a notification to the Operator at the Operator’s email address sale.secretstation@mail.ru, marked ‘Update of personal data’.

6.4. The period for the processing of personal data is unlimited. The User may withdraw their consent to the processing of personal data at any time by sending a notification to the Operator via email to the Operator’s email address sale.secretstation@mail.ru, marked ‘Withdrawal of consent to the processing of personal data’.



7. Cross-border transfer of personal data


7.1. Prior to carrying out a cross-border transfer of personal data, the controller must ensure that the foreign state to which the personal data is to be transferred provides adequate protection of the rights of data subjects.

7.2. Cross-border transfer of personal data to foreign countries that do not meet the above requirements may only take place if the data subject has given their written consent to the cross-border transfer of their personal data and/or for the performance of a contract to which the data subject is a party.



8. Final provisions


8.1. The User may obtain any clarification on matters of interest concerning the processing of their personal data by contacting the Controller via email at sale.secretstation@mail.ru.

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

8.3. The current version of the Policy is freely available on the internet at https://alexandersecret.shop/policy.

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 July 2006 No. 152-FZ ‘On Personal Data’ and sets out the procedure for processing personal data and the measures taken to ensure the security of personal data by Alexander Sergeyevich Larin, TIN 623201055974 (hereinafter – the Controller).

1.1. The Operator considers the observance of human and civil rights and freedoms when processing personal data, including the protection of the rights to privacy and personal and family confidentiality, to be its primary objective and a prerequisite for carrying out its activities.

1.2. This Policy of the Operator regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator may obtain about visitors to the website https://alexandersecret.shop/.


2. Key terms used in the Policy


2.1. Automated processing of personal data – the processing of personal data using computer technology;

2.2. Blocking of personal data – the temporary suspension of the processing of personal data (except where processing is necessary to verify the accuracy of the personal data);

2.3. Website – a collection of graphic and informational materials, as well as computer programs and databases, ensuring their availability on the internet at the web address https://alexandersecret.shop/;

2.4. Personal data information system – a collection of personal data contained in databases, together with the information technology and technical means ensuring their processing;

2.5. Anonymisation of personal data – actions resulting in the impossibility of determining, without the use of additional information, the attribution of personal data to a specific User or other data subject;

2.6. Processing of personal data — any action (operation) or set of actions (operations) performed with or without the use of automated means on personal data, including the collection, recording, systematisation, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), anonymisation, blocking, deletion, and destruction of personal data;

2.7. Controller – a state body, municipal body, legal entity or natural person who, independently or jointly with other persons, organises and/or carries out the processing of personal data, as well as determines the purposes of the processing of personal data, the scope of personal data to be processed, and the actions (operations) performed on personal data;

2.8. Personal data – any information relating directly or indirectly to an identified or identifiable User of the website https://alexandersecret.shop/;

2.9. User – any visitor to the website https://alexandersecret.shop/;


2.10. Disclosure of personal data – actions aimed at disclosing personal data to a specific person or a specific group of persons;

2.11. Dissemination of personal data – any actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or to enable an unlimited group of persons to access personal data, including the publication of personal data in the media, posting on information and telecommunications networks, or providing access to personal data by any other means;

2.12. Cross-border transfer of personal data – the transfer of personal data to the territory of a foreign state to a public authority of a foreign state, a foreign natural person or a foreign legal entity;

2.13. Destruction of personal data – any actions resulting in the irreversible destruction of personal data, rendering it impossible to subsequently restore the content of the personal data within the personal data information system and/or the destruction of physical media containing personal data.



3. The Controller may process the following personal data of the User


3.1. Surname, first name, patronymic;

3.2. Email address;

3.3. Telephone numbers;

3.4. Address of actual place of residence or place of stay;

3.5. The website also collects and processes anonymised data about visitors (including ‘cookies’) using web analytics services (Yandex Metrica, Google Analytics and others).

3.6. The data listed above is hereinafter referred to collectively as ‘Personal Data’ in this Policy.



4. Purposes of processing personal data


4.1. The purpose of processing the User’s personal data is to inform the User by sending emails; and to dispatch orders to the User at their place of residence or place of stay.

4.2. The Operator also has the right to send the User notifications about new products and services, special offers and various events. The User may at any time opt out of receiving such communications by sending an email to the Operator at sale.secretstation@mail.ru with the subject line ‘Opt-out of notifications about new products and services and special offers’.

4.3. De-identified User data collected via web analytics services is used to gather information about Users’ activities on the website and to improve the quality of the website and its content.



5. Legal basis for the processing of personal data


5.1. The Operator processes the User’s personal data only if the User fills in and/or submits it themselves via special forms located on the website https://alexandersecret.shop/. By filling in the relevant forms and/or submitting their personal data to the Operator, the User expresses their consent to this Policy.



6. Procedures for the collection, storage, transfer and other forms of processing of personal data


The security of personal data processed by the Operator is ensured through the implementation of legal, organisational and technical measures necessary to fully comply with the requirements of current legislation on the protection of personal data.


6.1. The Operator ensures the security of personal data and takes all possible measures to prevent unauthorised persons from accessing personal data.

6.2. The User’s personal data will never, under any circumstances, be transferred to third parties, except in cases related to compliance with applicable legislation.

6.3. Should any inaccuracies be identified in the personal data, the User may update them independently by sending a notification to the Operator at the Operator’s email address sale.secretstation@mail.ru, marked ‘Update of personal data’.

6.4. The period for the processing of personal data is unlimited. The User may withdraw their consent to the processing of personal data at any time by sending a notification to the Operator via email to the Operator’s email address sale.secretstation@mail.ru, marked ‘Withdrawal of consent to the processing of personal data’.




7. Cross-border transfer of personal data


7.1. Prior to carrying out a cross-border transfer of personal data, the controller must ensure that the foreign state to which the personal data is to be transferred provides adequate protection of the rights of data subjects.

7.2. Cross-border transfer of personal data to foreign countries that do not meet the above requirements may only take place if the data subject has given their written consent to the cross-border transfer of their personal data and/or for the performance of a contract to which the data subject is a party.



8. Final provisions


8.1. The user may obtain any clarifications on matters of interest concerning the processing of their personal data by contacting the Controller via email at sale.secretstation@mail.ru

8.2. This document will reflect any changes to the Controller’s personal data processing policy. This Policy remains in force indefinitely until replaced by a new version.

8.3. The current version of the Policy is freely available on the internet at https://alexandersecret.shop/policy.


8.4. By using the website, you also agree that https://alexandersecret.shop has the right to transfer to Limited Liability Company “T-Pogotki” (OGRN 1237700231449, INN 7743414212, Address: 125212, Moscow, Golovinskoe Shosse, 5, building 1, flat 193) all my personal data held by or accessible to https://alexandersecret.shop.