Privacy Policy
Personal data processing policy
1. General Provisions
1.1. This Personal Data Processing Policy (hereinafter referred to as the Policy) is aimed at protecting the rights and freedoms of individuals whose personal data is processed by individual entrepreneur Pavel Anatolyevich Sokolov (hereinafter referred to as the Operator). This establishes the procedure for receiving, protecting, storing, processing and transferring personal data of Buyers, and applies to all information that the site administration may receive about users during their use of the site.
1.2. The Policy has been developed in accordance with the provisions of the Federal Law of 27.07.2006 No. 152-FZ "On Personal Data" (hereinafter referred to as the Federal Law "On Personal Data"), as well as the Federal Law of 27.07.2006 No. 149-FZ "On Information, Information Technologies and the Protection of Information", other regulatory and by-laws governing relations related to the processing of personal data.
1.3. The Policy is a publicly available document subject to publication and disclosure in accordance with the Federal Law “On Personal Data”.
1.4. The Policy regulates the processing of personal data of Buyers, which in the Policy are understood as legally capable subjects of personal data (individuals) who have provided their personal data to implement the possibility of using extended access to the website, its functionality, services and materials, as well as to conclude (form an offer to conclude) and (or) execute a purchase and sale agreement and (or) other related agreements in the online store, if the processing of such personal data is necessary for the execution of agreements.
1.5. Online store – an electronic service, through the functionality of which the Buyer has the opportunity to place an Order for the Goods in accordance with the terms of the Offer. The Buyer may access the Online store using the website in accordance with the Offer.
1.6. Offer – a public offer by the Seller to any Buyer to conclude a retail sale and purchase agreement for the Goods on its terms. The offer is public by virtue of paragraph 2 of Article 437 of the Civil Code of the Russian Federation. The offer is available to an unlimited number of persons by means of its placement by the Seller in the Online Store.
1.7. Internet site – a site located on the Internet at the address: https://jethome.ru , through which the Buyer has the opportunity to access the functionality of the Online Store.
1.8. Website Administration – the operator and employees authorized by the operator to manage the website, determining the composition of the personal data of Buyers, the purposes of collecting personal data, their processing and storage.
2. Information about the operator. Rights of the site administration.
2.1. The operator processing personal data is the individual entrepreneur Pavel Anatolyevich Sokolov (legal address 197227, St. Petersburg, Serebristy Boulevard 15-353, acting on the basis of registration certificate No. 310784734400477).
2.2. The Site Administration has the right to establish requirements for the composition of personal data of Buyers, which must be provided for the use of the Site;
2.3. The Site Administration does not verify the authenticity of the personal data provided by the Site Buyers, believing that they act in good faith and keep their personal data up to date.
2.4. The Site Administration is not responsible for the voluntary transfer by Buyers of their contact information, password or login to third parties.
2.5. The website administration has no right to receive and process personal data of Buyers about their political, religious and other beliefs and private life.
2.6. The Site Administration, at its own expense, ensures the protection of Buyers’ personal data from unauthorized use or loss in accordance with the procedure established by the legislation of the Russian Federation.
2.7. The Site Administration shall take measures necessary and sufficient to ensure the fulfillment of obligations stipulated by the Federal Law "On Personal Data" and the regulatory legal acts adopted in accordance with it. The Site Administration shall independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations stipulated by the Law on Personal Data and the regulatory legal acts adopted in accordance with it. Such measures shall include, in particular:
- appointment of a person responsible for organizing the processing of personal data;
- publication of documents defining the site's policy regarding the processing of personal datadata, local acts on the processing of personal data, defining for each purpose of processing personal data the categories and list of personal data to be processed, the categories of subjects whose personal data are processed, the methods, terms of their processing and storage, the procedure for the destruction of personal data upon achieving the purposes of their processing or upon the occurrence of other legal grounds, as well as local acts establishing procedures aimed at preventing and identifying violations of the legislation of the Russian Federation, eliminating the consequences of such violations. Such documents and local acts may not contain provisions limiting the rights of Buyers, or imposing on the site administration powers and obligations not provided for by the legislation of the Russian Federation;
- application of legal, organizational and technical measures to ensure the security of personal data;
- implementation of internal control and (or) audit of compliance of personal data processing with the Federal Law "On Personal Data" and regulatory legal acts adopted in accordance with it, requirements for the protection of personal data, the website policy regarding the processing of personal data, local acts of the website;
- assessment of the harm that may be caused to Buyers in the event of a violation of the Federal Law "On Personal Data", the ratio of the said harm and the measures taken by the site administration aimed at ensuring the fulfillment of the obligations stipulated by the Federal Law "On Personal Data";
- familiarization of the site employees directly involved in the processing of personal data with the provisions of the legislation of the Russian Federation on personal data, including requirements for the protection of personal data, documents defining the site's policy regarding the processing of personal data, local acts on issues of processing personal data, and (or) training of the said employees.
3. Personal data.
3.1. Personal data is any information relating to a directly or indirectly identified or identifiable natural person (subject of personal data).
3.2. The Operator processes the following personal data of Buyers and (or) Buyers:
3.2.1. Last name, first name and patronymic (if any);
3.2.2. Passport data and data of other identity documents;
3.2.3. Date of birth;
3.2.4. Gender;
3.2.5. Address of place of residence, registration and (or) stay;
3.2.6. Delivery address of goods;
3.2.7. Email address;
3.2.8. Telephone number;
3.2.9. information about the purchase history, including the names of the purchased goods/services and their cost, as well as information about interests based on data about the Buyer's behavior on the Internet, in the networks of telecommunications and Internet operators
3.2.9. Information specified in Section 4 of the Policy, which in certain cases may be qualified as personal data.
3.3. If the Operator processes only individual information specified in paragraph 3.2 of the Policy, taking into account their specificity, such information (their totality) may not be recognized as personal data in accordance with the Federal Law "On Personal Data". In this case, the processing of such information is carried out taking into account the provisions of the Policy, however, individual restrictions and requirements established in relation to personal data may not apply.
3.4. The volume of personal data of Buyers processed by the Operator may not exceed the volume of personal data specified in 3.2 of the Policy (taking into account Section 4 of the Policy).
3.5. Each Buyer independently determines the volume of their personal data, the consent for the processing of which they give to the Operator.
3.6. The Operator, without having an objective opportunity and legal grounds for doing so, does not verify the authenticity of the personal data provided by the Buyers. The Operator assumes that the Buyer provides up-to-date and accurate personal data.
3.7. The Website may contain links to websites of third parties. The Operator shall not be liable for the accuracy, completeness and reliability of information posted on websites of third parties, nor shall it be liable for the processing and confidentiality of personal data and other information transmitted by Buyers on websites of third parties.
4. Other confidential data when using the Internet site.
4.1. When using the Website, the Buyer may automatically transfer cookie files to the Operator.
4.2. Cookies are pieces of data stored in the browser of a computer, mobile phone or other smartphone, afterby means of which visiting websites on the Internet is carried out.
4.3. The following information from the Buyer may be transferred to the Operator via cookies: IP address, MAC address, external source of the transition to the Internet site (including backlinks), PHP session identifier, identification number of the invitation to the Internet site within the framework of referral programs, about the software and equipment used by the Buyer to work on the Internet, about communication channels, about information and materials transmitted and received using the Internet site, about the Buyer's behavior on the Internet site, as well as other information of a similar nature.
4.4. The Buyer has the ability to independently delete cookies and prohibit their transmission by using the functionality of the browser they use.
4.5. By using the Internet site, the Buyer expresses his consent to the transfer of cookies insofar as he has not implemented the option specified in paragraph 4.4 of the Policy in relation to the Internet site.
4.6. In order to improve the quality of service and ensure the possibility of legal protection, the site administration has the right to store log files on the actions performed by Buyers within the framework of using the site.
5. Information about the processing of personal data.
5.1. The Operator processes personal data on a lawful and fair basis to perform the functions, powers and duties imposed by law, to exercise the rights and legitimate interests of the Operator, Buyers and third parties.
5.2. The operator processes personal data both with and without the use of automation tools.
5.3. Actions related to the processing of personal data include collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (provision, access), depersonalization, blocking, deletion and destruction.
5.4. The Operator may analyze the Buyer’s preferences and monitor consumer behavior using third-party analytics services.
5.6. The Operator processes the personal data of Buyers no longer than required by the purposes of processing the personal data, unless otherwise provided by the requirements of the current legislation. The processing of the personal data of Buyers is terminated early in the event of withdrawal of consent to the processing of personal data.
5.7. After the termination of the processing of the Buyer’s personal data as provided for in paragraph 5.6 of the Policy, the personal data are subject to destruction in compliance with the requirements established by current legislation.
5.8. Personal data of Buyers are stored in electronic form in the personal data information system of the website, as well as in archived copies of the website’s databases.
5.9. When storing the personal data of Buyers, organizational and technical measures are observed to ensure their safety and prevent unauthorized access to them. Only employees of the website administration who are authorized to work with the personal data of Buyers and who have signed an agreement on non-disclosure of the personal data of Buyers may have access to the processing of the personal data of Buyers. The list of website employees who have access to the personal data of Buyers is approved by order.
5.10. The Site Administration may transfer personal data of Buyers to third parties only if this is necessary to prevent a threat to their life and health, as well as in cases established by law.
5.11. The Site Administration is obliged to provide personal data of Buyers only to authorized persons and only to the extent necessary for them to perform their job duties, in accordance with this privacy policy and the legislation of the Russian Federation.
5.12. When transferring personal data of Buyers, the site administration warns persons receiving this information that this data may only be used for the purposes for which it was communicated, and requires written confirmation from these persons of compliance with this condition.
6. Purposes of personal data processing.
6.1. The Operator processes the personal data of Buyers for the following purposes:
6.1.1. Compliance with legal requirements;
6.1.2. Compliance with the rights and legitimate interests of consumers;
6.1.3. Placing orders for goods by Buyers, if the processing of such personal data is necessary for placing orders for goods;
6.1.4. Conclusion and execution of the terms of civil law contracts, if the processing of such personal data is necessary for the conclusion and (or) execution of contracts;
6.1.5. Sale by Buyers is possiblethe possibility of using extended access to the Internet site, its functionality, services and materials;
6.1.6. Identification, authorization and registration of Buyers on the Internet site;
6.1.7. Information about goods, services, special promotions, including advertising, and offers of the Operator and third parties at the discretion of the Operator, including through advertising and (or) information mailings and notifications sent by e-mail, by telephone (including phone calls and sending text messages), as well as through the use of instant messengers (messaging programs via the Internet).
6.1.8. Providing Buyers with effective customer support;
6.1.9. Analysis of the quality of services provided and improvement of the quality of customer service, including through telephone and other surveys.
6.2. For the purposes specified in paragraph 6.1 of the Policy, the personal data specified in paragraph 3.2 of the Policy may be processed, with the exception of the personal data specified in subparagraphs 3.2.2 and 3.2.5 of the Policy, which may be processed only for the purposes specified in subparagraphs 6.1.1 – 6.1.4 of the Policy.
6.3. For the purposes of processing the personal data of Buyers specified in paragraph 6.2 of the Policy, the Operator, in accordance with the procedure established by the current legislation and on the basis of consent to the processing of personal data of Buyers received in accordance with the Policy, has the right to provide the personal data of Buyers to third parties. Such third parties have the right to process the personal data of Buyers in an amount no greater than that provided for by the Policy and subject to strict compliance with the requirements of the Federal Law "On Personal Data".
7. Consent to the processing of personal data.
7.1. The Operator processes personal data of Buyers with the consents provided by them.
7.2. The Operator ensures that Buyers provide explicit, specific, objective, informed, conscious, unambiguous and free consent to the processing of their personal data.
7.3. The Buyer’s consent to the processing of his personal data may be provided by the Buyer (received by the Operator) in the following ways:
7.3.1. Written consent of the Buyer, made in simple written form and (or) in the form of an electronic document signed with an electronic signature in accordance with Federal Law No. 63-FZ of 06.04.2011 “On Electronic Signature”;
7.3.2. Consent given at the time of clicking the “Register” button on the website, next to the statement “By clicking the “Register” button, I give my consent to the collection and processing of my personal data in accordance with the Policy on the processing of personal data.”
7.3.3. Consent given at the time of clicking the “Place an order” button on the website, next to the statement “By clicking the “Place an order” button, I give my consent to the collection and processing of my personal data in accordance with the Policy and accept the terms of the Offer.”
7.4. The processing of personal data permitted by the Buyer for distribution is carried out on the basis of a separate consent of the Buyer, executed in accordance with the requirements of the Federal Law "On Personal Data".
8. Rights of the personal data subject.
8.1. The subject of personal data has the following rights:
8.1.1. To receive personal data related to this subject and information regarding their processing. The Site Administration provides Buyers with free access to their personal data, including the right to receive copies of any record containing their personal data, except in cases stipulated by law;
8.1.2. To clarify, block or destroy his personal data if they are incomplete, outdated, inaccurate, illegally obtained or are not necessary for the stated purpose of processing;
8.1.3. To revoke the consent given by him to the processing of personal data;
8.1.4. To protect their rights and legitimate interests, including compensation for losses and moral damages in court;
8.1.5. To appeal the actions or inactions of the Operator to the authorized body for the protection of the rights of personal data subjects or in court.
8.2. In order to exercise their rights and legitimate interests, the personal data subject has the right to contact the Operator or send a request in person or through a representative to the address specified in paragraph 2.1 of the Policy, or by e-mail from the e-mail address, the details of which were previously provided to the Operator, to the following e-mail address of the Operator: sales@jethome.ru
ss="nl-align-center"> 9. Information on ensuring the security of personal data by the Operator.
9.1. The operator is responsible for organizing the processing of personal data to fulfill the obligations stipulated by the Federal Law “On Personal Data” and regulatory legal acts adopted in accordance with it.
9.2. The operator applies the following set of legal, organizational and technical measures to ensure the security of personal data to ensure the confidentiality of personal data and their protection from illegal actions:
9.2.1. Provides unlimited access to the Policy, a copy of which is posted at the address of the Operator; the Policy is also posted in electronic form on the Internet site;
9.2.2. In pursuance of the Policy, approves and puts into effect the document “Regulations on the processing of personal data” (hereinafter referred to as the Regulations) and other local acts;
9.2.3. Familiarizes employees with the provisions of the legislation on personal data, as well as with the Policy and Regulations;
9.2.4. Grants employees access to personal data processed in the Operator’s information system, as well as to their tangible media, only for the performance of their work duties;
9.2.5. Establishes the rules for access to personal data processed in the Operator’s information system, and also ensures the registration and accounting of all actions with them;
9.2.6. Assesses the harm that may be caused to personal data subjects in the event of a violation of the Federal Law “On Personal Data”;
9.2.7. Determines threats to the security of personal data when processing them in the Operator’s information system;
9.2.8. Apply organizational and technical measures and use information security tools necessary to achieve the established level of protection of personal data;
9.2.9. Detects instances of unauthorized access to personal data and takes measures to respond, including the restoration of personal data modified or destroyed as a result of unauthorized access to them;
9.2.10. Assesses the effectiveness of measures taken to ensure the security of personal data before putting the Operator’s information system into operation;
9.2.11. Carries out internal control of the compliance of personal data processing with the Federal Law "On Personal Data", regulatory legal acts adopted in accordance with it, requirements for the protection of personal data, the Policy, Regulation and other local acts, including control over the measures taken to ensure the security of personal data and their level of protection when processed in the Operator's information system.
9.3. Requirements for premises where personal data is processed:
9.3.1. The placement of equipment for personal data information systems, special equipment and the security of premises in which work is carried out with personal data, and the organization of the security regime in these premises must ensure the safety of personal data carriers and information protection means, and also exclude the possibility of uncontrolled entry or presence in these premises by unauthorized persons.
9.3.2. Premises in which technical means of personal data information systems are located or personal data carriers are stored must comply with fire safety requirements established by the current legislation of the Russian Federation.
9.3.3. In addition to the specified measures for special equipment and security of premises in which cryptographic means of information protection are installed or stored, additional requirements are implemented, determined by the methodological documents of the Federal Security Service of Russia.
9.4. Documents containing personal data of the Buyer and subject to destruction:
- on paper - destroyed by shredding;
- in electronic form - erased from information carriers or the carriers on which the information is stored are physically destroyed.
9.5. Persons guilty of violating the rules governing the receipt, processing and protection of personal data of Buyers are subject to disciplinary, material, civil, administrative and criminal liability in accordance with the procedure established by the current legislation of the Russian Federation.
9.6. Moral damage caused to the Buyer as a result of the violation of his rights, violation of the rules for processing personal data established by the Federal Law "On Personal Data", as well as the requirements for the protection of personal data established in accordance with the said Federal Law, is subject to compensation in accordance with the legislation.by the Russian Federation. Compensation for moral damage is carried out regardless of compensation for property damage and losses incurred by the Buyer.
10. Changes to Policy.
10.1. The Operator reserves the right to amend the Policy at any time. The Buyer's use of the Internet site after any changes have been made to the current Policy means acceptance of these changes.