Personal Data Processing Policy

This Personal Data Processing Policy has been prepared in accordance with Federal Law No. 152-FZ of 27 July 2006, “On Personal Data” (the Personal Data Law). It sets out the procedures for processing personal data and the measures taken by Lafeed LLC (the Operator) to protect personal data.
1.1. Respect for human and civil rights and freedoms when processing personal data, including the rights to privacy and personal and family confidentiality, is a primary objective and a condition of the Operator's activities.
1.2. This Policy applies to all information the Operator may obtain about visitors to https://lafeed.org.
1. General provisions
2. Definitions used in this Policy
2.1. Automated personal data processing means processing personal data using computer technology.
2.2. Blocking personal data means temporarily suspending processing, except where processing is necessary to clarify the data.
2.3. Website means the collection of graphical and informational materials, computer programs and databases that make those materials available online at https://lafeed.org.
2.4. Personal data information system means the personal data held in databases together with the information technologies and technical equipment used to process them.
2.5. Depersonalisation means actions that make it impossible to identify the User or other data subject to whom personal data relate without additional information.
2.6. Personal data processing means any action or set of actions performed on personal data, with or without automated means, including collection, recording, organisation, accumulation, storage, clarification (updating or amendment), retrieval, use, transfer (dissemination, provision or access), depersonalisation, blocking, deletion and destruction.
2.7. Operator means a state authority, municipal authority, legal entity or individual that independently or jointly organises and/or carries out personal data processing and determines its purposes, the data to be processed and the operations to be performed.
2.8. Personal data means any information relating directly or indirectly to an identified or identifiable User of https://lafeed.org.
2.9. Personal data authorised by the data subject for dissemination means personal data made available to an unrestricted group of persons through the data subject's consent in accordance with the Personal Data Law.
2.10. User means any visitor to https://lafeed.org.
2.11. Provision of personal data means actions intended to disclose personal data to a specified person or group of persons.
2.12. Dissemination of personal data means actions intended to disclose personal data to an unspecified group of persons or make them available to an unrestricted group, including publication in the media, placement on information and telecommunications networks, or provision of access by any other means.
2.13. Cross-border transfer means transferring personal data to the territory of a foreign state, to a foreign public authority, individual or legal entity.
2.14. Destruction of personal data means actions that irreversibly destroy personal data so that their content cannot subsequently be restored in the information system and/or that destroy physical media containing personal data.
3. Main rights and obligations of the Operator
3.1. The Operator has the right to:
— Obtain accurate information and/or documents containing personal data from the data subject;
— Continue processing personal data without consent after consent is withdrawn or a request to cease processing is received, where grounds provided by the Personal Data Law apply;
— Independently determine the measures necessary and sufficient to fulfil obligations under the Personal Data Law and regulations adopted pursuant to it, unless otherwise provided by that law or other federal laws.
3.2. The Operator must:
— Provide the data subject, upon request, with information about the processing of their personal data;
— Organise processing in accordance with applicable Russian Federation legislation;
— Respond to enquiries and requests from data subjects and their legal representatives in accordance with the Personal Data Law;
— Provide the authorised personal data protection authority with the requested information within 10 days of receiving its request;
— Publish or otherwise provide unrestricted access to this Policy;
— Take legal, organisational and technical measures to protect personal data against unlawful or accidental access, destruction, alteration, blocking, copying, provision, dissemination and other unlawful actions;
— Stop transferring or processing personal data and destroy them in the manner and circumstances provided by the Personal Data Law;
— Fulfil other obligations under the Personal Data Law.
4. Main rights and obligations of data subjects
4.1. Data subjects have the right to:
— Obtain information about the processing of their personal data, except in cases provided by federal law. The Operator must provide this information in an accessible form. It must not include personal data relating to other subjects unless there are lawful grounds for disclosure. The information to be provided and the procedure for obtaining it are established by the Personal Data Law;
— Require the Operator to clarify, block or destroy personal data that are incomplete, outdated, inaccurate, unlawfully obtained or unnecessary for the stated processing purpose, and take measures provided by law to protect their rights;
— Require prior consent for personal data processing for the purpose of promoting goods, works or services;
— Withdraw consent and request that personal data processing cease;
— Challenge unlawful actions or omissions by the Operator before the authorised personal data protection authority or in court;
— Exercise other rights under Russian Federation legislation.
4.2. Data subjects must:
— Provide the Operator with accurate information about themselves;
— Notify the Operator of clarifications, updates or changes to their personal data.
4.3. Persons who provide inaccurate information about themselves or information about another data subject without that person's consent are liable under Russian Federation legislation.
5. Principles of personal data processing
5.1. Personal data are processed lawfully and fairly.
5.2. Processing is limited to specific, predetermined and lawful purposes. Processing incompatible with the purposes for which personal data were collected is not permitted.
5.3. Databases containing personal data processed for incompatible purposes must not be combined.
5.4. Only personal data relevant to the processing purposes may be processed.
5.5. The content and volume of personal data must correspond to the stated purposes and must not be excessive.
5.6. The Operator ensures the accuracy and sufficiency of personal data and, where necessary, keeps them up to date for the processing purposes. The Operator takes or arranges the necessary measures to remove or clarify incomplete or inaccurate data.
5.7. Personal data are kept in an identifiable form no longer than necessary for the processing purposes, unless a retention period is established by federal law or by a contract to which the data subject is a party, beneficiary or guarantor. Data are destroyed or depersonalised when the purposes have been achieved or are no longer required, unless federal law provides otherwise.
5.8. Personal data are not transferred when a User obtains a promotional code, coupon or other promotion or discount on third-party resources.
6. Conditions for personal data processing
6.1. Personal data are processed with the data subject's consent.
6.2. Processing is necessary to achieve purposes provided by an international treaty of the Russian Federation or by law, or to perform functions, powers and obligations imposed on the Operator by Russian Federation legislation.
6.3. Processing is necessary for the administration of justice or execution of a judicial act or an act of another authority or official enforceable under Russian Federation enforcement legislation.
6.4. Processing is necessary to perform a contract to which the data subject is a party, beneficiary or guarantor, to conclude a contract at the data subject's initiative, or to conclude a contract under which the data subject will be a beneficiary or guarantor.
6.5. Processing is necessary to exercise the rights and legitimate interests of the Operator or third parties, or to achieve objectives of public importance, provided that the data subject's rights and freedoms are not infringed.
6.6. Processing concerns data made available to an unrestricted group of persons by the data subject or at their request (publicly available personal data).
6.7. Processing concerns data subject to publication or mandatory disclosure under federal law.
7. Collection, storage, transfer and other processing of personal data
The Operator protects personal data through legal, organisational and technical measures necessary to meet applicable personal data protection requirements in full.
7.1. The Operator safeguards personal data and takes all possible measures to prevent access by unauthorised persons.
7.2. The User's personal data will not be transferred to third parties except where required to comply with applicable law or where the data subject has consented to a transfer for the performance of obligations under a civil-law contract.
7.3. If the User identifies inaccuracies, they may update their data by emailing lafeed@mail.ru with the subject “Personal data update”.
7.4. Personal data are processed until the purposes for which they were collected are achieved, unless a different period is provided by contract or applicable law.
The User may withdraw consent at any time by emailing lafeed@mail.ru with the subject “Withdrawal of consent to personal data processing”.
7.5. Information collected by third-party services, including payment systems, communications services and other providers, is stored and processed by those parties under their own user agreements and privacy policies. The Operator is not responsible for the actions of third parties, including the providers referred to in this clause.
7.6. Restrictions imposed by the data subject on the transfer or processing of personal data authorised for dissemination, or conditions of such processing, do not apply where processing serves state, public or other public-interest purposes established by Russian Federation legislation. This provision concerns transfer other than the provision of access, and processing other than obtaining access.
7.7. The Operator maintains the confidentiality of personal data during processing.
7.8. When arranging delivery, the Operator may collect information about the delivery destination and recipient to calculate the route accurately. Goods are transported by freight companies and courier services. Charges follow the carrier's tariffs and depend on shipment volume, weight and distance from the point of dispatch.
7.9. The Operator keeps personal data in an identifiable form no longer than necessary for the processing purposes, unless a retention period is established by federal law or by a contract to which the data subject is a party, beneficiary or guarantor.
7.10. Processing may cease when its purposes have been achieved, consent expires or is withdrawn, a request to cease processing is received, or unlawful processing is identified.
8. Operations performed on personal data
8.1. The Operator collects, records, organises, accumulates, stores, clarifies (updates or amends), retrieves, uses, transfers (disseminates, provides or grants access to), depersonalises, blocks, deletes and destroys personal data.
8.2. The Operator carries out automated processing, with or without receiving and/or transmitting information through information and telecommunications networks.
9. Cross-border transfers of personal data
9.1. Before beginning cross-border transfers, the Operator must notify the authorised personal data protection authority of its intention to make such transfers. This notification is separate from the notification of an intention to process personal data.
9.2. Before submitting that notification, the Operator must obtain the relevant information from the foreign authorities, individuals or legal entities to which the data are to be transferred.
10. Confidentiality of personal data
The Operator and other persons with access to personal data must not disclose them to third parties or disseminate them without the data subject's consent, unless federal law provides otherwise.
11. Final provisions
11.1. The User may request clarification of any matter concerning the processing of their personal data by emailing lafeed@mail.ru.
11.2. Changes to the Operator's personal data processing policy will be reflected in this document. This Policy remains in effect until replaced by a new version.
11.3. The current Policy is publicly available online at https://lafeed.org.
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