Privacy Policy for the Processing of Personal Data

1. General Provisions

This Personal Data Processing Policy has been prepared in accordance with the requirements of Federal Law No. 152-FZ of 27 July 2006 "On Personal Data" (the Personal Data Law) and defines the procedure for processing personal data and the measures taken by Region Vkusa LLC (the Operator) to ensure the security of personal data.

1.1. The Operator considers respect for the rights and freedoms of individuals and citizens in the processing of their personal data, including the protection of privacy and personal and family secrets, to be the most important purpose and condition of its activities.

1.2. This Operator's Personal Data Processing Policy (the Policy) applies to all information that the Operator may obtain about visitors to https://chopbbq.ru.

2. Key Terms Used in the Policy

2.1. Automated processing of personal data means the processing of personal data using computer equipment.

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 the collection of graphic and informational materials, computer programs and databases that make them available on the internet at https://chopbbq.ru.

2.4. Personal data information system means the totality of personal data contained in databases and the information technologies and technical means that enable their processing.

2.5. Depersonalization of personal data means actions that make it 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, including collection, recording, systematization, accumulation, storage, clarification (updating or modification), retrieval, use, transfer (dissemination, provision or access), depersonalization, blocking, deletion and destruction.

2.7. Operator means a state authority, municipal authority, legal entity or individual that, independently or jointly with others, organizes and/or carries out personal data processing and determines the purposes of processing, the composition 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 https://chopbbq.ru.

2.9. Personal data authorized by the personal data subject for dissemination means personal data to which an unlimited number of persons has been granted access by the personal data subject through consent to the processing of personal data authorized for dissemination in accordance with the Personal Data Law.

2.10. User means any visitor to https://chopbbq.ru.

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. Dissemination 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 provision of access 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 state authority, foreign individual or foreign legal entity.

2.14. Destruction of personal data means any actions that result in the irreversible destruction of personal data with no possibility of restoring its content in a 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 is entitled to:

— obtain reliable information and/or documents containing personal data from the personal data subject;

— continue processing personal data without the consent of the personal data subject if the subject withdraws consent or requests the termination of processing, where the grounds specified in the Personal Data Law exist;

— independently determine the composition and list of measures necessary and sufficient to fulfil the obligations established by the Personal Data Law and related regulations, 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 legislation of the Russian Federation;

— respond to requests from personal data subjects and their legal representatives in accordance with the Personal Data Law;

— provide the authorized body for the protection of personal data subjects' rights, upon its request, with the necessary information within 10 days of receiving the 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, dissemination and other unlawful actions;

— terminate the transfer, provision and access to personal data, terminate processing and destroy personal data in the procedure and cases provided for by the Personal Data Law;

— fulfil other obligations established by the Personal Data Law.

4. Main Rights and Obligations of Personal Data Subjects

4.1. Personal data subjects are entitled to:

— receive information concerning the processing of their personal data, except in cases provided for by federal laws. The information is provided by the Operator in an accessible form and must not contain personal data relating to other personal data subjects unless there are legal grounds for disclosure. 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 unnecessary 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 promotion of goods, works and services on the market;

— withdraw consent to personal data processing and request the termination of personal data processing;

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

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

4.2. Personal data subjects are obliged to:

— provide the Operator with reliable information about themselves;

— notify the Operator of clarification, updating or modification of their personal data.

4.3. Persons who provide the Operator with inaccurate information about themselves, or information about another personal data subject without that person'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 lawfully and fairly.

5.2. Personal data processing is limited to the achievement of specific, predetermined and lawful purposes. Processing incompatible with the purposes for which personal data was collected is not permitted.

5.3. Combining databases containing personal data processed for incompatible purposes is not permitted.

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

5.5. The content and scope of processed personal data correspond to the declared purposes of processing. Processed personal data must not be excessive in relation to those purposes.

5.6. Personal data processing ensures the accuracy, sufficiency and, where necessary, relevance of personal data in relation to the purposes of processing. The Operator takes the necessary measures and/or ensures their adoption to delete or clarify incomplete or inaccurate data.

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

6. Purposes of Personal Data Processing

Purpose of processing: informing the User by sending emails.

Personal data: surname, first name, patronymic; email address; telephone numbers.

Legal grounds: the Operator's charter and incorporation documents.

Types of personal data processing: sending informational emails to an email address.

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, or to exercise functions, powers and obligations imposed on the Operator by Russian legislation.

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

7.4. Personal data processing is necessary for the performance of a contract to which the personal data subject is a party, beneficiary or guarantor, or for entering into 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. Personal data processing is necessary for the exercise of the rights and legitimate interests of the Operator or third parties, or to achieve 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 as publicly available personal data.

7.7. Personal data subject to publication or mandatory disclosure under federal law is processed.

8. Procedure for Collection, Storage, Transfer and Other Processing of Personal Data

The security of personal data processed by the Operator is ensured through legal, organizational and technical measures necessary to fully comply with current legislation in the field of personal data protection.

8.1. The Operator ensures the safety of personal data and takes all possible measures to prevent access to personal data by unauthorized persons.

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

8.3. If inaccuracies in personal data are identified, the User may update the data independently by sending a notice to the Operator at chop_bbq@mail.ru marked "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 a different period is provided by a contract or applicable law.

The User may withdraw consent to personal data processing at any time by sending a notice to chop_bbq@mail.ru marked "Withdrawal of Consent to Personal Data Processing".

8.5. All information collected by third-party services, including payment systems, communications services and other service providers, is stored and processed by those persons in accordance with their user agreements and privacy policies. 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. Restrictions established by the personal data subject on the transfer (except for the provision of access), processing or conditions of processing (except for obtaining access) of personal data authorized for dissemination do not apply in cases of processing in state, public and other public interests defined by Russian legislation.

8.7. The Operator ensures the confidentiality of personal data when processing it.

8.8. The Operator stores personal data in a form that permits identification of the personal data subject for no longer than required by the purposes of processing, unless the storage period is established by federal law or a contract to which the personal data subject is a party, beneficiary or guarantor.

8.9. Conditions for terminating personal data processing may include achievement of the processing purposes, expiry of the personal data subject's consent, withdrawal of consent, a request to terminate processing, or identification of unlawful 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 (disseminates, provides or grants access to), depersonalizes, blocks, deletes and destroys personal data.

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

10. Cross-Border Transfer of Personal Data

10.1. Before commencing 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 notification is submitted separately from the notification of intent to process personal data.

10.2. Before submitting the above notification, the Operator must obtain relevant information from foreign state authorities, foreign individuals and foreign legal entities to whom 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 or disseminate personal data to third parties 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 regarding the processing of their personal data by contacting the Operator at chop_bbq@mail.ru.

12.2. This document will reflect any changes to the Operator's Personal Data Processing Policy. The Policy is effective indefinitely until replaced by a new version.

12.3. The current version of the Policy is publicly available on the internet at https://chopbbq.ru.