Privacy Policy
Personal Data Processing Policy
1. General Provisions
This Personal Data Processing Policy is prepared in accordance with the requirements of Federal Law No. 152-FZ dated 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 personal data security taken by https://lapticafe.ru/ (hereinafter referred to as the Operator).
1.1. The Operator considers the observance of human and civil rights and freedoms when processing their personal data, including the protection of privacy, personal and family secrets, as its most important goal and condition for conducting its activities.
1.2. This Operator’s policy regarding personal data processing (hereinafter referred to as the Policy) applies to all information that the Operator may obtain about visitors to the website https://lapticafe.ru/.
2. Key Definitions Used in the Policy
2.1. Automated personal data processing – processing of personal data using computer technology.
2.2. Blocking of personal data – temporary cessation of personal data processing (except when processing is necessary to clarify personal data).
2.3. Website – a set of graphical and informational materials, as well as computer programs and databases ensuring their availability on the internet at the network address https://lapticafe.ru/.
2.4. Personal data information system – a set of personal data contained in databases and ensuring their processing through information technologies and technical means.
2.5. Depersonalization of personal data – actions making it impossible to determine the belonging of personal data to a specific User or other personal data subject without using additional information.
2.6. Personal data processing – any action (operation) or set of actions (operations) performed with or without automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
2.7. Operator – a state body, municipal body, legal entity or individual independently or jointly with others organizing and/or performing personal data processing, as well as determining the purposes of personal data processing, 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://lapticafe.ru/.
2.9. Personal data permitted by the personal data subject for dissemination – personal data to which access has been provided by the personal data subject by giving consent to the processing of personal data permitted for dissemination in accordance with the Personal Data Law (hereinafter referred to as personal data permitted for dissemination).
2.10. User – any visitor to the website https://lapticafe.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. Dissemination of personal data – any actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or making personal data available to an unlimited group of persons, including publication of personal data in mass media, placement 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, foreign individual, or foreign legal entity.
2.14. Destruction of personal data – any actions resulting in the irreversible destruction of personal data with the impossibility of further restoring the content of personal data in the personal data information system and/or destruction of physical media containing personal data.
3. Operator’s Key Rights and Obligations
3.1. The Operator has the right to:
— receive from the personal data subject reliable information and/or documents containing personal data;
— in case the personal data subject withdraws consent to personal data processing, as well as submits a request to cease personal data processing, the Operator may continue processing personal data without the 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 obligations stipulated by the Personal Data Law and relevant regulatory legal acts, 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 regarding the processing of their personal data;
— organize personal data processing in accordance with current Russian legislation;
— respond to inquiries and requests from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
— provide the authorized body for protection of personal data subjects’ rights with necessary information within 10 days from the date of receiving such request;
— publish or otherwise provide unrestricted access to this Policy regarding personal data processing;
— take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, alteration, blocking, copying, provision, dissemination, as well as from other unlawful actions regarding personal data;
— cease transfer (distribution, provision, access) of personal data, cease processing, and destroy personal data in cases and manner provided by the Personal Data Law;
— perform other duties stipulated by the Personal Data Law.
4. Personal Data Subjects’ Key Rights and Obligations
4.1. Personal data subjects have the right to:
— receive information regarding the processing of their personal data, except in cases stipulated by federal laws. The information is provided to the personal data subject by the Operator in an accessible form and must not contain personal data relating to other personal data subjects, except when 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, block, or destroy their personal data if the data is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated processing purpose, as well as take legal measures to protect their rights;
— set a condition of prior consent when processing personal data for marketing purposes;
— withdraw consent to personal data processing, as well as submit a request to cease personal data processing;
— appeal to the authorized body for protection of personal data subjects’ rights or in court against unlawful actions or inaction of the Operator when processing their personal data;
— exercise other rights provided by Russian legislation.
4.2. Personal data subjects are obliged to:
— provide the Operator with accurate information about themselves;
— inform the Operator about updates (changes, corrections) to their personal data.
4.3. Persons who provided the Operator with false information about themselves or information about another personal data subject without the latter’s consent are liable in accordance with Russian legislation.
5. Principles of Personal Data Processing
5.1. Personal data processing is carried out on a lawful and fair basis.
5.2. Personal data processing is limited to achieving specific, predetermined, and lawful purposes. Processing of personal data incompatible with the purposes of personal data collection is not permitted.
5.3. Merging of databases containing personal data processed for incompatible purposes is not permitted.
5.4. Only personal data that meets the processing purposes may be processed.
5.5. The content and volume of processed personal data correspond to the stated processing purposes. Excessive processing of personal data in relation to the stated processing purposes is not permitted.
5.6. When processing personal data, the accuracy of personal data, their sufficiency, and, where necessary, relevance to the purposes of personal data processing are ensured. The Operator takes necessary measures and/or ensures their implementation to delete or clarify incomplete or inaccurate data.
5.7. Personal data is stored in a form that allows identification of the personal data subject for no longer than required by the purposes of personal data processing, unless the storage period is established by federal law, an agreement, or if the personal data subject is a party, beneficiary, or guarantor under such agreement. Processed personal data is destroyed or depersonalized upon achieving the processing purposes or when the necessity to achieve these purposes is lost, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing
| Processing Purpose | Notifying the User via email or phone |
|---|---|
| Personal Data |
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| Legal Basis |
|
| Types of Personal Data Processing |
|
7. Conditions for Personal Data Processing
7.1. Personal data processing is carried out with the consent of the personal data subject to the processing of their personal data.
7.2. Personal data processing is necessary to achieve purposes stipulated by an international treaty of the Russian Federation or law, for performing functions, powers, and duties imposed on the operator by Russian legislation.
7.3. Personal data processing is necessary for administering justice, executing a judicial act, an act of another authority or official subject to execution in accordance with Russian legislation on enforcement proceedings.
7.4. Personal data processing is necessary for executing an agreement where the personal data subject is a party, beneficiary, or guarantor, as well as for concluding an agreement initiated by the personal data subject or an agreement where the personal data subject will be a beneficiary or guarantor.
7.5. Personal data processing is necessary to exercise 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. Processing of personal data is carried out where access to such data is provided by the personal data subject or at their request (hereinafter referred to as publicly available personal data).
7.7. Processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.
8. 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 current legislation on personal data protection.
8.1. The Operator ensures the security of personal data and takes all possible measures to prevent unauthorized access to personal data.
8.2. The User’s personal data will never, under any circumstances, be transferred to third parties, except in cases related to compliance with applicable laws or when the personal data subject has consented to the Operator transferring data to a third party to fulfill obligations under a civil contract.
8.3. If inaccuracies in personal data are identified, the User may update them independently by sending a notification to the Operator’s email address info@lapticafe.ru with the subject “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 another period is stipulated by the contract or applicable law.
The User may at any time withdraw their consent to personal data processing by sending a notification to the Operator via email to info@lapticafe.ru with the subject “Withdrawal of Consent to Personal Data Processing”.
The User may at any time withdraw their consent to personal data processing by sending a notification to the Operator via email to info@lapticafe.ru with the subject “Withdrawal of Consent to Personal Data Processing”.
8.5. All information collected by third-party services, including payment systems, communication tools, 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 is obliged to familiarize themselves with these documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.
8.6. Prohibitions established by the personal data subject on the transfer (except for granting access), as well as on processing or conditions of processing (except for obtaining access) of personal data permitted for dissemination, do not apply in cases of personal data processing in state, public, and other public interests defined by Russian legislation.
8.7. The Operator ensures the confidentiality of personal data when processing personal data.
8.8. The Operator stores personal data in a form that allows identification of the personal data subject for no longer than required by the purposes of personal data processing, unless the storage period is established by federal law, an agreement where the personal data subject is a party, beneficiary, or guarantor.
8.9. The termination of personal data processing may be conditioned by the achievement of personal data processing purposes, expiration of the personal data subject’s consent, withdrawal of consent by the personal data subject, or a request to cease personal data processing, as well as identification of unlawful personal data processing.
9. List of Actions Performed by the Operator with Received Personal Data
9.1. The Operator performs collection, recording, systematization, accumulation, storage, clarification (updating, changing), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
9.2. The Operator performs automated processing of personal data with receipt and/or transmission of the obtained information via information and telecommunication networks or without such transmission.
10. Cross-Border Transfer of Personal Data
10.1. Before commencing activities related to cross-border transfer of personal data, the Operator must notify the authorized body for protection of personal data subjects’ rights of its intention to perform cross-border transfer of personal data (such notification is sent separately from the notification of intention to perform personal data processing).
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 the cross-border transfer of personal data is planned.
11. 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 by federal law.
12. Final Provisions
12.1. The User may obtain any clarifications on questions regarding the processing of their personal data by contacting the Operator via email at info@lapticafe.ru.
12.2. 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.
12.3. The current version of the Policy is freely available on the Internet at https://lapticafe.ru/privacy-policy/.