1. General Provisions

This Personal Data Processing Policy is compiled in accordance with the requirements of Federal Law No. 152-FZ of 27.07.2006 "On Personal Data" (hereinafter referred to as the Personal Data Law) and determines the procedure for processing personal data and measures to ensure the security of personal data undertaken by LLC "APRIORIKA" (hereinafter referred to as the Operator).

1.1. The Operator's main goal and condition for carrying out its activities is the respect for human and civil rights and freedoms during the processing of personal data, including the protection of privacy, personal, and family secrets.

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 receive about visitors to the website https://apriorika.com.

2. Basic Concepts Used in the Policy

2.1. Automated Processing of Personal Data — processing of personal data using computer technology.

2.2. Blocking of Personal Data — temporary cessation of processing personal data (except when processing is necessary to clarify personal data).

2.3. Website — a collection of graphic and informational materials, as well as software and databases, providing their availability on the Internet at the network address https://apriorika.com.

2.4. Information System of Personal Data — a collection of personal data contained in databases and information technologies and technical means ensuring their processing.

2.5. Anonymization of Personal Data — actions that result in the impossibility of determining without additional information the affiliation of personal data 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 personal data using automation tools or without such tools, including collection, recording, systematization, accumulation, storage, clarification (update, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, destruction of personal data.

2.7. Operator — a state body, municipal body, legal entity or individual, independently or together with other persons organizing and/or performing the processing of personal data, as well as determining the purposes of processing personal data, the composition of personal data to be processed, actions (operations) performed with personal data.

2.8. Personal Data — any information related directly or indirectly to a specific or identifiable User of the website https://apriorika.com.

2.9. Personal Data Authorized by the Data Subject for Distribution — personal data, access to which is provided to an unlimited number of persons by the data subject by giving consent to the processing of personal data authorized for distribution by the data subject in accordance with the Personal Data Law (hereinafter — personal data authorized for distribution).

2.10. User — any visitor to the website https://apriorika.com.

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

2.12. Distribution of Personal Data — any actions aimed at disclosing personal data to an indefinite number of persons (transmission of personal data) or to making personal data available to an unlimited number of persons, including publishing personal data in the media, placing it in information and telecommunication networks, or providing access to personal data in any other way.

2.13. Cross-Border Transfer of Personal Data — transfer of personal data to the territory of a foreign state to a foreign authority, foreign individual, or foreign legal entity.

2.14. Destruction of Personal Data — any actions resulting in the irreversible destruction of personal data with no possibility of further recovery of the content of personal data in the information system of personal data and/or destruction of physical media containing personal data.

3. Basic 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 data subject;

— in case of withdrawal of consent to the processing of personal data by the data subject, as well as if a request is made to cease processing personal data, the Operator may continue processing personal data without the data subject's consent if there are grounds specified in the Personal Data Law;

— independently determine the composition and list of measures necessary and sufficient to ensure compliance with the obligations set out in the Personal Data Law and the 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 data subject, upon request, with information regarding the processing of their personal data;

— organize the processing of personal data in accordance with the applicable legislation of the Russian Federation;

— respond to requests and inquiries from 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 data subjects with necessary information within 10 days from the date of receipt of such a request;

— publish or otherwise ensure unrestricted access to this Policy regarding the processing of personal data;

— take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, alteration, blocking, copying, provision, distribution of personal data, as well as other illegal actions in relation to personal data;

— cease the transfer (distribution, provision, access) of personal data, stop processing and destroy personal data in the manner and cases provided for by the Personal Data Law;

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

4. Basic Rights and Duties of Data Subjects

4.1. Data subjects have the right to:

— receive information concerning the processing of their personal data, except in cases provided by federal laws. The information is provided by the Operator to the data subject in an accessible form and should not contain personal data related to other data subjects, except when there are legal grounds for disclosing such personal data. The list of information and the procedure for its receipt are established by the Personal Data Law;

— demand that the Operator clarify, block, or destroy their personal data if the personal data is incomplete, outdated, inaccurate, illegally obtained, or no longer necessary for the declared purpose of processing, as well as take measures provided by law to protect their rights;

— impose conditions for prior consent when processing personal data for the purpose of marketing goods, works, and services;

— withdraw consent to the processing of personal data, as well as make a request to cease processing personal data;

— appeal to the authorized body for the protection of the rights of data subjects or in court against unlawful actions or inactions of the Operator in the processing of their personal data;

— exercise other rights provided by the legislation of the Russian Federation.

4.2. Data subjects are obliged to:

— provide the Operator with accurate data about themselves;

— notify the Operator of any changes (updates, modifications) to their personal data.

4.3. Individuals who provide the Operator with false information about themselves or about another data subject without their consent are liable under the legislation

5. Principles and Conditions for Processing Personal Data

5.1. Processing of personal data is carried out on a legal and fair basis.

5.2. Processing of personal data is limited to achieving specific, predetermined, and legitimate goals. Processing of personal data that is incompatible with the purposes of collecting personal data is not allowed.

5.3. Only personal data that meets the purposes of its processing is subject to processing.

5.4. The content and scope of processed personal data correspond to the stated processing purposes. The processing of personal data is limited to achieving those purposes.

5.5. Personal data is stored in a form that allows the identification of data subjects no longer than required by the purposes of processing personal data, unless the period of personal data storage is established by federal law.

5.6. The operator takes necessary measures to protect personal data from unauthorized access, destruction, alteration, blocking, copying, provision, distribution, and other illegal actions.

6. Purposes of Processing Personal Data

6.1. The Operator processes personal data for the following purposes:

— providing access to the website https://apriorika.com;

— conducting marketing research and surveys;

— informing the Users of the website about new products and services;

— responding to inquiries and requests from Users;

— ensuring compliance with legal requirements and other regulations.

7. Legal Grounds for Processing Personal Data

7.1. The legal grounds for processing personal data are:

— the data subject's consent to the processing of their personal data;

— the necessity of processing personal data to perform a contract to which the data subject is a party or to perform pre-contractual obligations at the request of the data subject;

— the necessity of fulfilling the Operator's legal obligations;

— the necessity of protecting the vital interests of the data subject or another individual;

— processing personal data carried out in accordance with the Operator's statutory powers;

— other legal grounds established by the legislation of the Russian Federation.

8. Confidentiality of Personal Data

8.1. The Operator ensures the confidentiality of personal data during its processing and takes measures to prevent its unauthorized or accidental disclosure.

8.2. Confidentiality is not applied to personal data that is publicly available or disclosed by the data subject with their consent.

9. Measures to Ensure the Security of Personal Data

9.1. The Operator takes necessary and sufficient organizational and technical measures to protect personal data from unauthorized or accidental access, destruction, alteration, blocking, copying, provision, distribution, and other illegal actions in relation to personal data.

9.2. The Operator takes measures to ensure the security of personal data at all stages of its processing.

10. Cross-Border Transfer of Personal Data

10.1. The Operator ensures that the cross-border transfer of personal data to foreign countries is carried out in accordance with the requirements of the Personal Data Law.

10.2. The cross-border transfer of personal data is allowed only if the foreign country ensures adequate protection of the rights of data subjects.

11. Final Provisions

11.1. This Policy may be amended and/or supplemented by the Operator without any special notice to the data subjects. The new version of the Policy enters into force upon its publication on the website https://apriorika.com unless otherwise provided by the new version of the Policy.

11.2. The current version of the Policy is always available on the website https://apriorika.com.

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