Personal Data Processing Policy2019-10-20T21:05:13+00:00

Personal Data Processing Policy


1. General Provisions:

The current personal data processing policy constructed in accordance with the requirements of the Federal law from 27.07.2006. №152-F3 «On personal data» and defines the order of the processing of personal data and the measures for ensuring the security of personal data of LLC “Spa Development” (further – Operator).

1. Operator sets as their most important goal and the condition for carrying out their activities the compliance with the rights and freedoms of man and citizen during the processing of his personal data, including the protection of privacy rights, personal and family secrets.

2. The current policy of the Operator in regards to the processing of personal data (further – Policy) applies to all information, which the Operator can obtain about the visitors of the website .

2. Definitions, used in the Policy

1. Automated processing of personal data – processing of personal data using computer technology;

2. Blocking of personal data – temporary cessation of the processing of personal data (with the exception of cases, where the processing is required for the clarification of personal details);

3. Website – an aggregation of graphic and informational material, as well as programmes for computers and databases, providing their accessibility to the internet through the web address ;

4. Informational system of personal data – an aggregation being stored in databases of personal data, and providing the processing of their informational technologies and technical means;

5. Anonymising of personal data – actions, as a result of which it is impossible without the utilisation of additional information to discover the belonging of personal data to a certain User or subject of personal data;

6. Processing of personal data – any action (operation) or aggregation of actions (operations), done with the usage of means of automation or without the use of such means with personal data, including the collection, recording, systematisation, accumulation, storage, clarification (updating, changing), extraction, usage, transfer (distribution, provision, access), anonymisation, blocking, deletion, destruction of personal data;

7. Operator – governmental body, municipal body, legal or physical entity, independently or collectively with other entities organising and (or) carrying out the processing of personal data, composition of personal data to be processed, actions (operations) performed with personal data;

8. Personal Data – any information, attributable directly or indirectly to a certain or determinable User of the website ;

9. User – any visitor of the website ;

10. Provision of personal data – actions, directed towards the revealing of personal data to a certain entity or a certain circle of entities;

11. Distribution of personal data – any actions, directed towards the revealing of personal data to an unspecified circle of entities (transfer of personal data) or the familiarisation with personal data of an unlimited circle of entities, including the disclosure of personal data in mass media, deployment in networks of information and telecommunications or granting access to the personal data with any other methods;

12. Cross-Border transfer of personal data – transfer of personal data to the territory of a foreign government, to a foreign authority, foreign physical or foreign legal entity;

13. Destruction of personal data – any actions, as a result of which the personal data is irreversibly destroyed with impossibility of further recovery of the contents of the personal data in the informational system of personal data and (or) resulting in the destruction of the physical carriers of personal data.

3. Operator may process the following personal data of the User

1. Surname, given name, patronomics;

2. Email address;

3. Telephone numbers;

4. In addition on the website the collection and processing of anonymised data about the visitors (including «cookie» files) is taking place with the help of internet-statistic services (Yandex Metrics and Google Analytics and others).

5. Aforementioned data further following the text of the Policy are merged with the shared term Personal data.

4. The goals of processing personal data

1. The goal of processing the personal data of the User – the formation, execution and termination of civil law contracts. 2. In addition the Operator reserves the right to notify the User about new products and services, special offers and various events. The user is always able to refuse the receiving of any informational messages, having sent a letter to the Operator to the email address with the subject line «Refusal of receiving notifications of new products and services and special offers». 3. Anonymised data of the Users, collected with the help of internet-statistics services, serves for the collection of information regarding the actions of the User on the website, improvements of the quality of the website and its content.

5. Legal grounds for processing personal data

1. The Operator processes the personal data of the User only if they fill it in and/or them sending the data independently through special forms, located on the website . Filling in the corresponding forms and/or sending their personal data to the Operator, the User expresses their agreement with the current Policy.

2. The Operator processes anonymised data about the User in the case, if it is permitted in the settings of the browser of the User (including the saving of the «cookie» files and the usage of the JavaScript technology).

6. Order of the collection, storage, transfer and other forms of processing of personal data

The security of personal data, which is processed by the Operator, is ensured through the means of realising legal, organisational and technical means necessary for the fulfillment in full accordance with the requirements of the current legislation in the area of the protection of personal data.

1. Operator provides the safekeeping of personal data and takes all possible measures, forbidding the access to personal data by unauthorised entities.

2. Personal data of the User will never, under any circumstances will be transferred to third parties, with the exception in cases, related to compliance with the current legislation.

3. In the case of detection of inaccuracies in the personal data, the User may actualise them independently, by sending the Operator a notice to the email address of the Operator with the subject line «Actualisation of personal data». 4. The period of the processing of personal data remains unlimited. The User may at any moment retract their consent to the processing of their personal data by sending the Operator a notice to the email address of the Operator with the subject line «Retraction of consent to the processing of personal data».

7. Cross-Border transfer of personal data

1. The Operator before realising the Cross-Border transfer of personal data must ensure, that foreign governments, on the territory of which the transfer of personal data is proposed, provides adequate and secure protections of the rights of the subjects of the personal data.

2. Cross-Border transfer of personal data on the territory of foreign governments, not subject to the aforementioned requirements, may only take place in the case of consent in written form to the Cross-Border transfer from the subject of the personal data regarding the transfer of their personal data and/or the execution of the contract, whose side is the subject of personal data.

8. Final provisions:

1. The User may receive any clarification regarding any questions of interest, concerning the processing of their personal data, by addressing the operator using the email address .

2. Any changes made to the personal data processing policy of the Operator will be reflected in the following document. The Policy is in effect indefinitely until its replacement by a new version.

3. The actual version of the Policy is freely available on the Internet at the address