Sole Proprietor Bobkov V.V.
2022–2026 • All rights reserved

Политика в отношении обработки данных

1. General Provisions

This personal data processing policy is drafted in accordance with the requirements of Federal Law No. 152-FZ of July 27, 2006 “On Personal Data” (hereinafter referred to as the “Personal Data Law”) and defines the procedure for processing personal data and measures to ensure the security of personal data undertaken by Sole Proprietor “Bobkov V.V.” OGRN 322695200019054 (hereinafter referred to as the “Operator”).

1.1. The Operator’s most important goal and condition for carrying out its activities is to respect the rights and freedoms of individuals when processing their personal data, including the protection of the right to privacy, personal, and family secrets.

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://creonano.ru.

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 of personal data (except when processing is necessary to clarify personal data).

2.3. Website – a set of graphic and informational materials, as well as computer software and databases, ensuring their availability on the internet at the network address https://creonano.ru.

2.4. Personal data information system – a set of personal data contained in databases and information technologies and technical means ensuring their processing.

2.5. Depersonalization of personal data – actions that make it impossible to determine, without additional information, the ownership of personal data to a specific User or other subject of personal data.

2.6. Processing of personal data – any action (operation) or set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, or destruction of personal data.

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

2.8. Personal data – any information relating directly or indirectly to a specific or identifiable User of the website https://creonano.ru.

2.9. Personal data permitted by the personal data subject for distribution – personal data to which an unlimited circle of persons has been granted access by the personal data subject by giving consent to the processing of personal data permitted by the personal data subject for distribution in the manner prescribed by the Personal Data Law (hereinafter referred to as “personal data permitted for distribution”).

2.10. User – any visitor to the website https://creonano.ru.

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

2.12. Distribution of personal data – any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or making personal data available to an unlimited circle of persons, including publishing personal data in the media, posting them in information and telecommunications 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 state authority, a foreign individual, or a foreign legal entity.

2.14. Destruction of personal data – any actions that result in the irrevocable destruction of personal data with the impossibility of further restoring the content of personal data in the personal data information system and/or the destruction of physical media containing personal data.

3. Basic Rights and Obligations of the Operator

3.1. The Operator has the right to:

– receive from the personal data subject reliable information and/or documents containing personal data;

– if the personal data subject withdraws consent to the processing of personal data, the Operator has the right to continue processing personal data without the consent of the personal data subject if there are grounds specified in the Personal Data Law;

– independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations provided for by the Personal Data Law and regulatory legal acts 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 their request, with information regarding the processing of their personal data;

– organize the processing of personal data in the manner established by the current legislation of the Russian Federation;

– respond to appeals and requests from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;

– notify the authorized body for the protection of the rights of personal data subjects, upon request from that body, of the necessary information within 30 days of receiving such a request;

– publish or otherwise provide unrestricted access to this Policy regarding the processing of personal data;

– take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, alteration, blocking, copying, provision, distribution of personal data, as well as from other unlawful actions regarding personal data;

– stop 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;

– fulfill other obligations provided for by the Personal Data Law.

4. Basic Rights and Obligations of Personal Data Subjects

4.1. Personal data subjects have the right to:

– receive information regarding the processing of their personal data, except in cases provided for by federal laws. Such information is provided to the personal data subject by the Operator in an accessible form and should not contain personal data relating to other personal data subjects, unless there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;

– require the Operator to clarify their personal data, block or destroy them if the personal data is incomplete, outdated, inaccurate, illegally obtained, or not necessary for the stated purpose of processing, as well as take measures provided by law to protect their rights;

– impose a condition of prior consent when processing personal data for the purpose of marketing goods, works, and services;

– withdraw consent to the processing of personal data;

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

– exercise other rights provided for by the legislation of the Russian Federation.

4.2. Personal data subjects are obliged to:

– provide the Operator with reliable data about themselves;

– inform the Operator about the clarification (updating, changing) of their personal data.

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

5. The Operator May Process the Following Personal Data of the User

5.1. Last name, first name, patronymic.

5.2. Email address.

5.3. Phone numbers.

5.4. Year, month, date, and place of birth.

5.5. Details of the identity document.

5.6. Taxpayer identification number, date of registration, details of the certificate of registration with the tax authority.

5.7. Place of residence.

5.8. The website also collects and processes anonymized data about visitors (including “cookie” files) using internet statistics services (Yandex Metrica, Google Analytics, and others).

5.9. The above data are hereinafter referred to collectively as Personal Data in the text of this Policy.

5.10. The Operator does not process special categories of personal data concerning race, nationality, political views, religious or philosophical beliefs, or intimate life.

5.11. Processing of personal data permitted for distribution from among the special categories of personal data specified in Part 1 of Article 10 of the Personal Data Law is permitted if the prohibitions and conditions provided for in Article 10.1 of the Personal Data Law are observed.

5.12. The User’s consent to the processing of personal data permitted for distribution is drawn up separately from other consents to the processing of their personal data. At the same time, the conditions provided for, in particular, in Article 10.1 of the Personal Data Law are observed. The requirements for the content of such consent are established by the authorized body for the protection of the rights of personal data subjects.

5.12.1. The User provides consent to the processing of personal data permitted for distribution to the Operator directly.

5.12.2. The Operator is obliged, no later than three business days from the date of receipt of the specified User consent, to publish information about the processing conditions, about the presence of prohibitions and conditions on the processing by an unlimited circle of persons of personal data permitted for distribution.

5.12.3. The transfer (distribution, provision, access) of personal data permitted by the personal data subject for distribution must be terminated at any time at the request of the personal data subject. This request must include the last name, first name, patronymic (if any), contact information (phone number, email address, or postal address) of the personal data subject, as well as a list of personal data whose processing is subject to termination. The personal data specified in this request may only be processed by the Operator to whom it is addressed.

5.12.4. Consent to the processing of personal data permitted for distribution terminates from the moment the Operator receives the request specified in clause 5.12.3 of this Policy regarding the processing of personal data.

6. Principles of Personal Data Processing

6.1. Processing of personal data is carried out on a lawful and fair basis.

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

6.3. Combining databases containing personal data processed for purposes that are incompatible with each other is not allowed.

6.4. Only personal data that meet the purposes of their processing are subject to processing.

6.5. The content and scope of the processed personal data correspond to the stated purposes of processing. Redundancy of the processed personal data in relation to the stated purposes of their processing is not allowed.

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

6.7. Personal data is stored in a form that allows identifying the personal data subject no longer than required by the purposes of processing personal data, unless the personal data retention 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 upon achieving the processing purposes or if the need to achieve these purposes is lost, unless otherwise provided for by federal law.

7. Purposes of Processing Personal Data

7.1. The purposes of processing User’s personal data are:

– informing the User by sending emails;

– concluding, executing, and terminating civil law contracts;

– providing the User with access to services, information, and/or materials contained on the website https://creonano.ru;

– clarifying order details, processing orders, and fulfilling orders.

7.2. The Operator also has the right to send the User notifications about new products and services, special offers, and various events. The User can always refuse to receive informational messages by sending an email to the Operator at supp@creonano.ru with the subject line “Refusal of notifications about new products and services and special offers”.

8. Legal Basis for Processing Personal Data

8.1. The legal basis for processing personal data by the Operator is:

– the Operator’s statutory (incorporation) documents;

– contracts concluded between the Operator and the personal data subject;

– Federal Law “On Information, Information Technologies and Information Protection” No. 149-FZ of July 27, 2006;

– federal laws, other regulatory legal acts in the field of personal data protection;

– User consents to the processing of their personal data, to the processing of personal data permitted for distribution.

8.2. The Operator processes the User’s personal data only if they are filled in and/or sent by the User independently through special forms located on the website https://creonano.ru or sent to the Operator by email. By filling out the relevant forms and/or sending their personal data to the Operator, the User expresses their concurrence with this Policy.

8.3. The Operator processes anonymized data about the User if this is allowed in the User’s browser settings (saving “cookie” files and using JavaScript technology are enabled).

8.4. The personal data subject independently decides to provide their personal data and gives consent freely, of their own will, and in their own interest.

9. Conditions for Processing Personal Data

9.1. Processing of personal data is carried out with the consent of the personal data subject to the processing of their personal data.

9.2. Processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or law, to carry out functions, powers, and duties assigned by the legislation of the Russian Federation to the operator.

9.3. Processing of personal data is necessary for the administration of justice, execution of a judicial act, an act of another body or official, subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.

9.4. Processing of personal data is necessary for the performance of a contract to which the personal data subject is a party, beneficiary, or guarantor, as well as for concluding a contract at the initiative of the personal data subject or a contract under which the personal data subject will be the beneficiary or guarantor.

9.5. Processing of personal data is necessary to exercise the rights and legitimate interests of the operator or third parties or to achieve socially significant goals, provided that this does not violate the rights and freedoms of the personal data subject.

9.6. Processing of personal data is carried out, access to which is provided by the personal data subject to an unlimited circle of persons or at their request (hereinafter referred to as “publicly available personal data”).

9.7. Processing of personal data is carried out, subject to publication or mandatory disclosure in accordance with federal law.

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

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

10.1. The Operator ensures the safety of personal data and takes all possible measures to prevent unauthorized persons from accessing personal data.

10.2. The User’s personal data will never, under any circumstances, be transferred to third parties, except in cases related to the execution of current legislation or if the personal data subject has given consent to the Operator to transfer data to a third party for the performance of obligations under a civil law contract.

10.3. If inaccuracies in personal data are identified, the User can update them independently by sending a notification to the Operator’s email address supp@creonano.ru with the subject line “Updating personal data”.

10.4. The period for processing personal data is determined by achieving the purposes for which the personal data was collected unless a different period is provided for by the contract or current legislation.

The User may at any time withdraw their consent to the processing of personal data by sending a notification to the Operator via email at supp@creonano.ru with the subject line “Withdrawal of consent to processing of personal data”.

10.5. All information collected by third-party services, including payment systems, communication means, and other service providers, is stored and processed by these persons (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject and/or the User is obliged to familiarize themselves with these documents in a timely manner on their own. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.

10.6. Prohibitions on transfer (except for providing access), as well as on processing or conditions for processing (except for obtaining access) of personal data permitted for distribution, established by the personal data subject, do not apply in cases of processing personal data in state, public, and other public interests determined by the legislation of the Russian Federation.

10.7. The Operator ensures the confidentiality of personal data when processing them.

10.8. The Operator stores personal data in a form that allows identifying the personal data subject no longer than required by the purposes of processing personal data, unless the personal data retention period is established by federal law or a contract to which the personal data subject is a party, beneficiary, or guarantor.

10.9. The condition for terminating the processing of personal data may be the achievement of the purposes of personal data processing, the expiration of the consent of the personal data subject, the withdrawal of consent by the personal data subject, as well as the detection of unlawful processing of personal data.

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

11.1. The Operator carries out collection, recording, systematization, accumulation, storage, clarification (updating, changing), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.

11.2. The Operator carries out automated processing of personal data with or without the receipt and/or transmission of the received information over information and telecommunication networks.

12. Cross-Border Transfer of Personal Data

12.1. Before starting the cross-border transfer of personal data, the Operator is obliged to ensure that the foreign state to whose territory the transfer of personal data is intended provides reliable protection of the rights of personal data subjects.

12.2. Cross-border transfer of personal data to the territory of foreign states that do not meet the above requirements may be carried out only if there is written consent from the personal data subject to the cross-border transfer of their personal data and/or the performance of a contract to which the personal data subject is a party.

13. Confidentiality of Personal Data

The Operator and other persons who have gained access to personal data are obliged not to disclose or distribute personal data to third parties without the consent of the personal data subject, unless otherwise provided for by federal law.

14. Final Provisions

14.1. The User may obtain any clarifications on issues regarding the processing of their personal data by contacting the Operator via email at supp@creonano.ru.

14.2. This document will reflect any changes to the Operator’s personal data processing policy. The Policy is valid indefinitely until replaced by a new version.

14.3. The current version of the Policy is freely available on the Internet at https://creonano.ru/en/privacy-policy.