Privacy Policy 1. General ProvisionsThis Privacy Policy has been prepared 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 the measures taken to ensure the security of personal data by Oleg Leonidovich Perfilov (hereinafter referred to as the Operator).1.1. The Operator considers the observance of the rights and freedoms of individuals and citizens in the processing of their personal data, including the protection of the right to privacy, personal and family confidentiality, to be its highest priority and an essential condition for carrying out its activities.1.2. This Privacy Policy of the Operator (hereinafter referred to as the Policy) applies to all information that the Operator may obtain about visitors to the website https://en.bergamot.rest/. 2. DefinitionsFor the purposes of this Policy, the following terms shall have the meanings set forth below:2.1. Automated Processing of Personal Data means the processing of personal data using computer technology.2.2. Blocking of Personal Data means the temporary suspension of the processing of personal data, except where processing is necessary for the clarification or updating of personal data.2.3. Website means a collection of graphic and informational materials, as well as software and databases, ensuring their availability on the Internet at https://en.bergamot.rest/.2.4. Personal Data Information System means a combination of personal data contained in databases and the information technologies and technical means used for processing such data.2.5. Depersonalization (Anonymization) of Personal Data means actions resulting in the impossibility of determining, without additional information, whether personal data belongs to a specific User or another personal data subject.2.6. Processing of Personal Data means any operation or set of operations performed on personal data, with or without the use of automation tools, including collection, recording, systematization, accumulation, storage, updating, modification, retrieval, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.2.7. Operator means a state authority, municipal authority, legal entity, or individual that independently or jointly with others organizes and/or carries out the processing of personal data and determines the purposes of processing, the scope of personal data to be processed, and the operations performed on personal data.2.8. Personal Data means any information relating directly or indirectly to an identified or identifiable User of the website https://en.bergamot.rest/.2.9. Personal Data Permitted for Dissemination means personal data to which the data subject has granted public access by giving consent for processing in accordance with the Personal Data Law.2.10. User means any visitor to the website https://en.bergamot.rest/.2.11. Provision of Personal Data means actions aimed at disclosing personal data to a specific person or a specific group of persons.2.12. Dissemination of Personal Data means any actions aimed at disclosing personal data to an indefinite number of persons, including publication in the media, posting on information and telecommunication networks, or otherwise making such data publicly available.2.13. Cross-Border Transfer of Personal Data means the transfer of personal data to the territory of a foreign state, to a foreign government authority, foreign individual, or foreign legal entity.2.14. Destruction of Personal Data means any actions resulting in the irreversible destruction of personal data without the possibility of restoring its contents in the personal data information system and/or the destruction of physical media containing personal data. 3. 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 the consent of the data subject after such consent has been withdrawn, provided there are legal grounds established by the Personal Data Law;independently determine the composition and scope of measures necessary and sufficient to ensure compliance with the Personal Data Law and other applicable legal acts, unless otherwise provided by law.3.2. The Operator is obliged to:provide the data subject, upon request, with information regarding the processing of their personal data;organize the processing of personal data in accordance with the applicable legislation of the Russian Federation;respond to requests and inquiries from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;provide the authorized supervisory authority with the necessary information within thirty (30) days from receipt of its request;publish or otherwise ensure unrestricted access to this Privacy Policy;implement legal, organizational, and technical measures necessary to protect personal data against unauthorized or accidental access, destruction, modification, blocking, copying, disclosure, distribution, and other unlawful actions;terminate the dissemination, provision, or processing of personal data and destroy personal data in cases provided for by law;fulfill other obligations established by the legislation of the Russian Federation.4. Rights and Obligations of Personal Data Subjects 4.1. Personal data subjects have the right to:obtain information regarding the processing of their personal data, except where otherwise provided by federal law. Such information shall be provided by the Operator in an accessible form and must not contain personal data relating to other data subjects unless there are legal grounds for disclosing such 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 such data are incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the stated purpose of processing, as well as to take legal measures to protect their rights;require prior consent for the processing of personal data for the purpose of marketing goods, works, or services;withdraw consent to the processing of personal data;appeal unlawful actions or omissions of the Operator related to the processing of personal data to the authorized supervisory authority or in court;exercise other rights provided by the legislation of the Russian Federation.4.2. Personal data subjects are obliged to:provide the Operator with accurate personal data;notify the Operator of any updates or changes to their personal data.4.3.Persons who provide the Operator with inaccurate information about themselves or about another personal data subject without that person's consent shall be liable in accordance with the legislation of the Russian Federation. 5. Categories of Personal Data ProcessedThe Operator may process the following personal data of the User:5.1. Full name.5.2. Telephone numbers.5.3. The Website also collects and processes anonymized visitor data (including cookies) using web analytics services (such as Yandex Metrica, Google Analytics, and other similar services).5.4. Throughout this Policy, all of the above information is collectively referred to as Personal Data.5.5. The Operator does not process special categories of personal data relating to racial or ethnic origin, political opinions, religious or philosophical beliefs, or intimate life.5.6. Processing of special categories of personal data permitted for dissemination under Article 10.1 of the Personal Data Law is carried out only if the prohibitions and conditions established by law are observed.5.7. Consent to the processing of personal data permitted for dissemination shall be obtained separately from other consents to the processing of personal data, in accordance with Article 10.1 of the Personal Data Law.5.7.1. The User provides such consent directly to the Operator.5.7.2. Within three (3) business days after receiving such consent, the Operator shall publish information regarding the conditions of processing and any restrictions applicable to personal data permitted for dissemination.5.7.3. The dissemination of personal data permitted for public distribution shall be terminated at any time upon the request of the personal data subject. Such request must include the subject's full name (where applicable), contact details (telephone number, email address, or postal address), and the list of personal data whose dissemination is to be terminated.5.7.4. Consent to the processing of personal data permitted for dissemination shall terminate upon receipt by the Operator of the request specified in Clause 5.7.3 of this Policy. 6. Principles of Personal Data Processing6.1. Personal data shall be processed lawfully and fairly.6.2. Processing shall be limited to achieving specific, predetermined, and lawful purposes. Personal data shall not be processed in a manner incompatible with those purposes.6.3. Databases containing personal data processed for incompatible purposes shall not be combined.6.4. Only personal data relevant to the stated purposes of processing shall be processed.6.5. The content and scope of processed personal data shall correspond to the stated purposes. Excessive personal data shall not be processed.6.6. The Operator shall ensure that personal data are accurate, sufficient, and, where necessary, kept up to date. The Operator shall take all necessary measures to delete or correct incomplete or inaccurate data.6.7. Personal data shall be stored in a form that permits identification of the data subject for no longer than necessary to achieve the purposes of processing, unless a longer retention period is required by federal law or by a contract to which the data subject is a party or beneficiary. Upon achievement of the processing purposes or when such purposes are no longer necessary, personal data shall be destroyed or anonymized unless otherwise required by law. 7. Purposes of Personal Data Processing 7.1.The Operator processes the User's personal data for the purpose of providing access to the services, information, and materials available on the Website https://en.bergamot.rest/.7.2.The Operator may also send the User notifications regarding new products and services, special offers, and various events. The User may opt out of receiving such communications at any time by sending an email to pr@bergamot.rest with the subject line:"Opt-out of notifications regarding new products, services, and special offers."7.3.Anonymized data collected through web analytics services are used to gather information about Users' interactions with the Website and to improve the quality and content of the Website.8. Legal Grounds for the Processing of Personal Data8.1. The legal grounds for the processing of personal data by the Operator include:- legislative and other regulatory legal acts governing the Operator's activities (for example, where applicable, Federal Law No. 149-FZ of July 27, 2006 "On Information, Information Technologies and Information Protection");
- the Operator's constitutional and corporate documents;
- agreements concluded between the Operator and the personal data subject;
- federal laws and other regulatory legal acts governing the protection of personal data;
- consents provided by Users for the processing of their personal data, including consent to the processing of personal data permitted for dissemination.
8.2. The Operator processes the User's personal data only if such data are voluntarily provided by the User through forms available on the Website https://en.bergamot.rest/ or submitted to the Operator by email. By completing the relevant forms or otherwise providing personal data, the User agrees to this Privacy Policy.8.3. The Operator processes anonymized User data if such processing is permitted by the User's browser settings (including the use of cookies and JavaScript technology).8.4. The personal data subject independently decides whether to provide their personal data and gives consent freely, voluntarily, and in their own interests. 9. Conditions for the Processing of Personal Data9.1. Personal data shall be processed only with the consent of the personal data subject, unless otherwise provided by applicable law.9.2. Personal data may be processed where necessary to fulfill obligations established by international treaties of the Russian Federation or by law, as well as to perform functions, powers, and duties imposed on the Operator by the legislation of the Russian Federation.9.3. Personal data may be processed where necessary for the administration of justice or the enforcement of judicial acts or acts of other competent authorities.9.4. Personal data may be processed where necessary for the performance of a contract to which the personal data subject is a party, beneficiary, or guarantor, or for entering into such a contract at the initiative of the personal data subject.9.5. Personal data may be processed where necessary for the legitimate interests of the Operator or third parties, or for the achievement of socially significant objectives, provided that the rights and freedoms of the personal data subject are not violated.9.6. Publicly available personal data may be processed if access to such data has been granted by the personal data subject or at their request.9.7. Personal data subject to mandatory publication or disclosure in accordance with federal law may also be processed. 10. Procedure for the Collection, Storage, Transfer, and Other Processing of Personal DataThe security of personal data processed by the Operator is ensured through the implementation of legal, organizational, and technical measures necessary to fully comply with the applicable legislation on personal data protection.10.1. The Operator shall ensure the confidentiality and security of personal data and take all reasonable measures to prevent unauthorized access.10.2. The User's personal data shall never be transferred to third parties except where required by applicable law or where the personal data subject has expressly consented to such transfer for the performance of contractual obligations.10.3. If inaccuracies are identified in personal data, the User may update such data by sending a notification to pr@bergamot.rest with the subject line:"Personal Data Update."10.4. Personal data shall be processed for as long as necessary to achieve the purposes for which they were collected, unless a different retention period is required by law or contract.The User may withdraw consent to the processing of personal data at any time by sending an email to pr@bergamot.rest with the subject line:"Withdrawal of Consent to the Processing of Personal Data."10.5. Any information collected by third-party service providers, including payment systems, communication providers, or other service providers, shall be stored and processed by such providers in accordance with their own Terms of Service and Privacy Policies. Users are responsible for reviewing those documents. The Operator shall not be liable for the actions of such third parties.10.6. Restrictions imposed by the personal data subject on the transfer or processing of personal data permitted for dissemination shall not apply where processing is carried out in the public interest as provided by the legislation of the Russian Federation.10.7. The Operator shall maintain the confidentiality of personal data throughout the processing period.10.8. Personal data shall be stored in a form allowing identification of the personal data subject only for as long as necessary to achieve the purposes of processing, unless otherwise required by federal law or contract.10.9. Processing of personal data shall cease upon achievement of the processing purposes, expiration of the consent period, withdrawal of consent by the personal data subject, or detection of unlawful processing. 11. Operations Performed on Personal Data11.1. The Operator performs the following operations in relation to personal data:- collection;
- recording;
- systematization;
- accumulation;
- storage;
- updating (modification);
- retrieval;
- use;
- transfer (distribution, provision, access);
- anonymization;
- blocking;
- deletion;
- destruction.
11.2. The Operator carries out automated processing of personal data with or without the transfer of information via information and telecommunication networks.12. Cross-Border Transfer of Personal Data12.1. Before initiating any cross-border transfer of personal data, the Operator shall ensure that the foreign state to whose territory the transfer is planned provides an adequate level of protection for the rights of personal data subjects.12.2. Cross-border transfer of personal data to foreign states that do not provide an adequate level of protection may only be carried out in the following cases:- where the personal data subject has provided written consent to such cross-border transfer; or
- where the transfer is necessary for the performance of a contract to which the personal data subject is a party.
13. Confidentiality of Personal DataThe Operator and any other persons who have obtained access to personal data shall be obliged not to disclose or distribute such personal data to third parties without the consent of the personal data subject, unless otherwise required by applicable law. 14. Final Provisions14.1. Users may obtain clarification regarding any questions related to the processing of their personal data by contacting the Operator via email at pr@bergamot.rest.14.2. Any amendments to this Privacy Policy shall be reflected in this document. The Policy shall remain effective indefinitely until it is replaced by a new version.14.3. The current version of this Privacy Policy is publicly available at:https://en.bergamot.rest/ 