Personal Data Processing and Cookie Policy
Publication date: 10.01.2022
1. General provisions
This Personal Data Processing Policy is drafted in accordance with Federal Law No. 152-FZ of 27.07.2006 “On Personal Data” (hereinafter – the Personal Data Law) and defines the procedure for processing personal data and measures to ensure the security of personal data implemented by Feerichno LLC (Taxpayer Identification Number (INN): 7719667847, Primary State Registration Number (OGRN): 1087746148643) (hereinafter – the Operator).
1.1. The Operator considers the observance of human and civil rights and freedoms in the processing of personal data, including the protection of the rights to privacy, personal and family secrets, as one of its most important goals and conditions for carrying out its activities.
1.2. This Personal Data Processing Policy of the Operator (hereinafter – the Policy) applies to all information that the Operator may receive about visitors to the website https://www.enchantingexpo.com.
2. Basic terms used in the Policy
2.1. Automated processing of personal data – processing of personal data by means of computer technology.
2.2. Blocking of personal data – temporary suspension of the processing of personal data (except where processing is required to clarify personal data).
2.3. Website – a set of graphic and information materials, as well as computer programs and databases that ensure their availability on the Internet at the network address https://www.enchantingexpo.com.
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. Depersonalisation of personal data – actions that result in it being impossible, without the use of additional information, to determine whether personal data belongs to a specific User or another personal data subject.
2.6. Processing of personal data – any action (operation) or set of actions (operations) performed using automation tools or without such tools with personal data, including collection, recording, systematisation, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalisation, blocking, deletion and destruction of personal data.
2.7. Operator – a state body, municipal body, legal entity or individual which, independently or jointly with other persons, organises and/or carries out the processing of personal data, as well as determines the purposes of personal data processing, the composition of personal data to be processed and 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://www.enchantingexpo.com.
2.9. Personal data permitted for dissemination by the personal data subject – personal data to which access to an unlimited number of persons is provided by the personal data subject by giving consent to the processing of personal data permitted by the personal data subject for dissemination in the manner provided for by the Personal Data Law (hereinafter – personal data permitted for dissemination).
2.10. User – any visitor to the website https://www.enchantingexpo.com.
2.11. Provision of personal data – actions aimed at disclosing personal data to a specific person or a specific circle of persons.
2.12. Dissemination of personal data – any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or at making personal data available to an indefinite circle of persons, including the publication of personal data in mass media, placement in information and telecommunication networks or provision of 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 an authority of a foreign state, a foreign individual or a foreign legal entity.
2.14. Destruction of personal data – any actions as a result of which personal data are irretrievably destroyed with no possibility of further restoration of the content of personal data in the personal data information system and/or material carriers of personal data are destroyed.
2.15. Cookies – small text files that are stored on the user’s device (computer, mobile phone, tablet) when visiting websites and may contain an identifier, settings and information about the user’s interaction with the website.
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;
— in the event of withdrawal by the personal data subject of consent to the processing of personal data and/or submission of a request to cease processing of personal data, continue processing of personal data without the consent of the personal data subject where there are grounds specified in the Personal Data Law;
— independently determine the composition and list of measures necessary and sufficient to ensure fulfilment of the obligations provided for by the Personal Data Law and regulatory legal acts adopted in accordance with it, unless otherwise provided for by the Personal Data Law or other federal laws.
3.2. The Operator shall:
— provide the personal data subject, upon his/her request, with information concerning the processing of his/her personal data;
— organise the processing of personal data in accordance with the applicable legislation of the Russian Federation;
— respond to requests and applications from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
— notify the authorised body for the protection of the rights of personal data subjects, upon its request, of the required information within 10 days from the date of receipt of such request;
— publish or otherwise ensure unrestricted access to this Policy regarding the processing of personal data;
— take legal, organisational and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision, dissemination, as well as from other unlawful actions in relation to personal data;
— cease transfer (dissemination, provision, access) of personal data, cease processing and destroy personal data in the manner and in cases provided for by the Personal Data Law;
— fulfil 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 concerning the processing of their personal data, except in cases provided for by federal laws. 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 where there are lawful grounds for disclosure of such personal data. The list of information and the procedure for its receipt are established by the Personal Data Law;
— require the Operator to clarify their personal data, block or destroy them if the personal data are incomplete, outdated, inaccurate, unlawfully obtained or are not necessary for the stated purpose of processing, as well as take measures provided by law to protect their rights;
— stipulate a requirement for prior consent in processing personal data for the purpose of promoting goods, works and services on the market;
— withdraw consent to the processing of personal data and submit a request to cease processing of personal data;
— appeal to the authorised body for the protection of the rights of personal data subjects or in court against unlawful actions or omissions of the Operator in processing their personal data;
— exercise other rights provided for by the legislation of the Russian Federation.
4.2. Personal data subjects shall:
— provide the Operator with accurate information about themselves;
— notify the Operator of the clarification (updating, modification) of their personal data.
4.3. Persons who have provided the Operator with inaccurate information about themselves or information about another personal data subject without the consent of such subject shall be liable in accordance with the legislation of the Russian Federation.
5. Principles of personal data processing
5.1. Processing of personal data is carried out on a lawful and fair basis.
5.2. Processing of personal data is limited to achieving specific, predetermined and lawful purposes. Processing of personal data incompatible with the purposes of collecting personal data is not permitted.
5.3. It is not permitted to combine databases containing personal data that are processed for purposes incompatible with each other.
5.4. Only personal data that meet the purposes of their processing are subject to processing.
5.5. The content and volume of processed personal data correspond to the stated purposes of processing. Excessive processing of personal data in relation to the stated purposes of their processing is not permitted.
5.6. When processing personal data, accuracy, sufficiency and, where necessary, relevance of personal data to the purposes of their processing are ensured. The Operator shall take necessary measures and/or ensure their adoption to delete or clarify incomplete or inaccurate data.
5.7. Personal data are 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 a period for storage of personal data is established by federal law, a contract to which the personal data subject is a party, beneficiary or guarantor. Processed personal data are destroyed or depersonalised upon achievement of the purposes of processing or if the need to achieve these purposes is lost, unless otherwise provided for by federal law.
6. Purposes of personal data processing, categories and list of processed personal data, legal grounds and methods of processing
| Purpose of processing | Personal data | Legal grounds (152-FZ) | Types of personal data processing |
|---|---|---|---|
| Ensuring the functioning and security of the website | Automatically collected technical data: - IP address - Cookie data (technically necessary) - Browser type and version - Operating system type and version - Screen resolution - Source of transition to the site - Date and time of visit - Visited pages |
para. 7 Part 1 Article 6 (Legitimate interests of the Operator to ensure the functioning and security of the website) |
Collection (automatic), recording, systematisation, accumulation, storage, use, depersonalisation, blocking, deletion. Automated processing. |
| Processing User requests and enquiries (via contact forms, email, phone) | - Surname, first name, patronymic (if provided) - Email address - Phone number - Content of the request/message - Other data voluntarily provided by the User |
para. 1 Part 1 Article 6 (Consent of the personal data subject) and/or para. 5 Part 1 Article 6 (Actions to conclude/perform a contract at the initiative of the subject, if applicable to the request) |
Collection, recording, systematisation, accumulation, storage, clarification (updating, modification), extraction, use (for response and contact), deletion. Automated and non-automated processing. |
| Information and marketing mailings (news, promotions, special offers) | - Email address - Name (if provided for personalisation) |
para. 1 Part 1 Article 6 (Consent of the personal data subject) obtained separately for marketing purposes. | Collection, recording, systematisation, accumulation, storage, use (for sending mailings), blocking (upon unsubscribe), deletion. Automated processing. Providing the option to unsubscribe. |
| Analysis of website usage and improvement of its performance (web analytics) | Cookie data (analytical): - Pseudonymised IP address - Cookie identifiers - Data on interaction with the site (page views, session time, clicks, source) - General geolocation data (city/country) - Technical characteristics of the device and software. * Data are processed mainly in aggregated/pseudonymised form. |
para. 1 Part 1 Article 6 (Consent of the personal data subject) for the use of non-essential (analytical) cookies. | Collection (automatic), recording, systematisation, accumulation, storage, use (for analysis), depersonalisation, aggregation, transfer (of depersonalised/pseudonymised data to analytics services), deletion. Automated processing. |
| Conclusion and execution of contracts with Users/Clients | - Surname, first name, patronymic - Contact details (email, phone) - Address (if required for performance) - Payment details (processed securely, often via third parties) - Company details (for legal entities/individual entrepreneurs) - Other data necessary for the contract |
para. 5 Part 1 Article 6 (Processing is necessary for the performance of a contract to which the personal data subject is a party, beneficiary or guarantor, or to conclude a contract at the initiative of the subject) |
Collection, recording, systematisation, accumulation, storage, clarification, extraction, use (for contract performance, communication, invoicing), transfer (where necessary for performance), blocking, deletion (upon expiry of retention periods). Automated and non-automated processing. |
Note: The specific list of processed personal data may vary. The Operator processes only those data that are necessary to achieve the stated purposes. Detailed information on the use of cookies is provided in the relevant section of this Policy or in the notice on the website.
7. Conditions for personal data processing
7.1. Processing of personal data is carried out with the consent of the personal data subject to the processing of his/her personal data.
7.2. Processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, to exercise the functions, powers and duties imposed on the Operator by the legislation of the Russian Federation.
7.3. Processing of personal data is necessary for the administration of justice, enforcement of a court judgment or another act of a body or official subject to enforcement in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. 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 the conclusion of 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. Processing of personal data is necessary for the exercise of the rights and legitimate interests of the Operator or third parties or for the achievement of socially important goals, provided that the rights and freedoms of the personal data subject are not thereby infringed.
7.6. Processing of personal data to which access is provided by the personal data subject to an unlimited number of persons or at his/her request (hereinafter – publicly available personal data) is carried out.
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, organisational and technical measures necessary to fully comply with the requirements of applicable legislation in the field of personal data protection.
8.1. The Operator ensures the safety of personal data and takes all possible measures to exclude unauthorised access to personal data.
8.2. Personal data of the User may be transferred to authorised state bodies of the Russian Federation only on the grounds and in accordance with the procedure established by the legislation of the Russian Federation.
8.3. If inaccuracies in personal data are identified, the User may update them independently by sending a notification to the Operator via email at info@enchantingexpo.com with the subject line “Update of personal data”.
8.4. The period of personal data processing is determined by achieving the purposes for which personal data were collected, unless another period is provided for by a contract or applicable law. The User may withdraw his/her consent to the processing of personal data at any time by sending a notification to the Operator via email at info@enchantingexpo.com with the subject line “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 such persons (Operators) in accordance with their User Agreements and Privacy Policies. The personal data subject shall independently familiarise himself/herself in good time with such documents. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this paragraph.
8.6. Restrictions established by the personal data subject on transfer (other than provision of access), as well as on processing or conditions for processing (other than access) of personal data permitted for dissemination do not apply in cases of processing of personal data in state, public or other public interests defined by the legislation of the Russian Federation.
8.7. The Operator ensures the confidentiality of personal data in the course of processing.
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 processing personal data, unless a longer period for personal data storage is established by federal law, a contract to which the personal data subject is a party, beneficiary or guarantor.
8.9. Grounds for terminating the processing of personal data may include achievement of the purposes of personal data processing, expiry of the period of validity of the personal data subject’s consent, withdrawal of consent by the personal data subject or a request to cease processing of personal data, as well as detection of unlawful processing of personal data.
9. List of actions performed by the Operator with received personal data
9.1. The Operator carries out collection, recording, systematisation, accumulation, storage, clarification (updating, modification), extraction, use, transfer (dissemination, provision, access), depersonalisation, blocking, deletion and destruction of personal data.
9.2. The Operator performs automated processing of personal data with receipt and/or transmission of the received information via information and telecommunication networks or without such transmission.
10. Cross-border transfer of personal data
10.1. Before starting cross-border transfer of personal data, the Operator shall notify the authorised body for the protection of the rights of personal data subjects of its intention to carry out cross-border transfer of personal data (such notification is sent separately from the notification of the intention to process personal data).
10.2. Before submitting the above notification, the Operator shall obtain from the authorities of a foreign state, foreign individuals and foreign legal entities to whom cross-border transfer of personal data is planned the relevant information.
11. Cookies and analysis of visits to our website
We want you to be able to use our website as we intended. Therefore, for its correct operation we use cookies that are collected in relation to Users. By continuing to use our website, you agree to the use of cookies in accordance with this Policy.
11.1. What are cookies?
Cookies are small text files, usually consisting of letters and numbers, that are stored on your device (computer, smartphone or tablet) when you visit websites. Cookies allow a website to recognise your device and display our site in accordance with your preferences.
11.2. Types of cookies we use
We use the following types of cookies on our website:
1. Technical (necessary) cookies – ensure the operation of the basic functions of the site; without them the site cannot function properly.
2. Analytical cookies – help us analyse the use of the site and improve its operation.
3. Functional cookies – allow us to remember your settings and preferences.
4. Marketing cookies – used to personalise advertising and track the effectiveness of advertising campaigns.
11.3. Specific cookies we use
| Name | Provider | Type | Retention period | Description |
|---|---|---|---|---|
| _ym_d | .www.enchantingexpo.com | Analytical | 1 year | Stores the date of the first visit to the site |
| _ym_isad | www.enchantingexpo.com | Analytical | 1 day | Determines whether ad blocking is enabled in your browser |
| _ym_uid | www.enchantingexpo.com | Analytical | Unlimited | Collects anonymised information about visitor behaviour and anonymised visitor statistics |
| _ym_visorc | www.enchantingexpo.com | Analytical | 1 day | Used to ensure correct operation of WebVisor |
| _ga | .www.enchantingexpo.com | Analytical | 2 years | Used to distinguish users |
| _gid | .www.enchantingexpo.com | Analytical | 24 hours | Used to distinguish users |
| _gat | .www.enchantingexpo.com | Analytical | 1 minute | Used to throttle request rate |
| BITRIX_SM_* | www.enchantingexpo.com | Functional | Up to 1 year | Cookies required for the operation of Bitrix24 functions |
Data collected using cookies do not constitute special categories of personal data or biometric personal data within the meaning of Articles 10–11 of Federal Law No. 152-FZ and are processed by automated means.
The legal basis for processing your data in this case is your consent to personal data processing, provided by the User of the site through conclusive actions – continued use of the site.
Upon expiry of the specified processing periods, personal data are destroyed by deleting them from information systems using built-in tools of the information system.
11.4. Managing cookies
You can disable or limit the sending of cookies at any time via your browser settings:
- Google Chrome: Menu → Settings → Show advanced settings → Privacy → Content settings
- Mozilla Firefox: Menu → Settings → Privacy & Security → Cookies and Site Data
- Safari: Settings → Safari → Privacy & Security
- Microsoft Edge: Menu → Settings → Cookies and site permissions
Please note that disabling certain cookies may affect the functionality of the website.
12. Transfer of data to third parties
To provide services and improve their quality, we transfer information about you to the following third parties:
| Purpose of processing | Third parties, their location and link to privacy policy / website | Purpose of transfer | Address of the third party |
|---|---|---|---|
| Web analytics | LLC «Yandex» (Russia) (Privacy Policy) | Provider of web analytics services (Yandex Metrica) | 119021, Moscow, Leo Tolstoy St., 16 |
| Web analytics | Google Inc. (USA) (Privacy Policy) | Provider of web analytics services (Google Analytics) | 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA |
| Customer relationship management | LLC «1С-Bitrix» (Russia) (Privacy Policy) | CRM system | 109544, Moscow, Entuziastov Blvd., 2, floor 13, room 8–19 |
| Sending SMS notifications | LLC «SMS.RU» (Russia) (Privacy Policy) | Service for sending SMS messages | 141014, Mytishchi, Vera Voloshina St., 14, office 409 |