PERSONAL DATA PROCESSING POLICY

1. General Provisions
This Personal Data Processing Policy is drawn up in accordance with the requirements of Federal Law No. 152-FZ dated 07.27.2006 "On Personal Data" (hereinafter "Personal Data Law") and defines the procedure for processing personal data and measures to ensure the security of personal data taken by TRENDTONIK, LLC (hereinafter "Operator").
1.1. The Operator sets as their most important goal and condition within the scope of activity implementation the observance of human and civil rights and freedoms in processing their personal data, including protecting the privacy rights and personal and family secrets.
1.2. The Operator's policy regarding personal data processing (hereinafter "Policy") applies to all information the Operator can obtain about visitors to the following website: https://trendtonik.ru/eng.
2. Key Terms Used in the Policy
2.1. Automated personal data processing: Personal data processing using computer technology.
2.2. Personal data blocking: Temporary termination of personal data processing (except for cases where processing is required to clarify personal data).
2.3. Website: A collection of graphic and informational materials, computer programs, and databases that ensure their availability on the Internet at the following address: https://trendtonik.ru/eng.
2.4. Personal data information system: A set of personal data contained in databases, information technologies, and technical means that ensure their processing.
2.5. Personal data depersonalization: Actions resulting in the impossibility of determining personal data's identity 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/without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
2.7. Operator: A state body, municipal body, legal entity, or individual who independently or jointly with other persons organizes and/or processes personal data, as well as determines the processing personal data purposes, the composition of personal data to be processed, and actions (operations) performed with personal data.
2.8. Personal data: Any information related directly or indirectly to a specific/identifiable User of the website: https://trendtonik.ru/eng.
2.9. Personal data authorized by the personal data subject for distribution: Personal data, access to which is provided to an unlimited number of persons by the personal data subject by giving consent to the processing of personal data authorized by the personal data subject for distribution in accordance with the procedure under the Personal Data Low (hereinafter "personal data authorized for distribution").
2.10. User: Any visitor to the https://trendtonik.ru/eng.
2.11. Personal data provision: Actions aimed at disclosing personal data to a specific person/group of persons.
2.12. Personal data distribution: Any actions aimed at personal data disclosure to a certain group of persons (personal data transfer) or familiarization with the personal data of an unlimited number of persons, including the publication of personal data in the media, posting in information and telecommunications networks, or providing access to personal data in any other way.
2.13. Cross-border transfer of personal data: Personal data transfer to the territory of a foreign state to a foreign state authority, a foreign individual, or a foreign legal entity.
2.14. Personal data destruction: Any actions resulting from which personal data is permanently destroyed with the inability to further restore the personal data content in the personal data information system and/or the personal data material carriers are destroyed.
3. Basic Rights and Obligations of the Operator
3.1. The Operator has the right to:
– Receive reliable information and/or documents containing personal data from the personal data subject;
– In case the subject of personal data withdraws consent to the personal data processing, continue processing personal data without the consent of the personal data subject if there are grounds specified in the Personal Data Law;
– Independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations provided by the Personal Data Law and regulatory legal acts adopted by it, unless otherwise provided by the Personal Data Law or other federal laws.
3.2. The Operator is obliged to:
– Provide the personal data subject (at their request) with information concerning their personal data processing;
– Organize the personal data processing according to the procedure established by the current legislation of the Russian Federation;
– Respond to requests from personal data subjects and their legal representatives according to the Personal Data Law requirements;
– Inform the authorized body for protecting the rights of personal data subjects (at the request of this body) about the necessary information within 10 days from the date of receipt of such a request;
– Publish or otherwise provide unrestricted access to the Policy regarding personal data processing;
– Take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access to them, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other illegal actions in relation to personal data;
– Stop transferring (distributing, providing, accessing), processing, and destroying personal data in the cases provided by the Personal Data Law;
– Perform other duties provided 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 regarding processing their personal data, except in cases provided by federal laws. The information is provided to the personal data subject by the Operator in an accessible form, and it should not contain personal data related to other personal data subjects, except in cases where legitimate grounds for disclosure of such personal data exist. The list of information and the procedure for obtaining it are established by the Personal Data Law;
– Demand from the Operator clarification of their personal data, their blocking, or destruction if the personal data is incomplete, outdated, inaccurate, illegally obtained, or is not necessary for the stated purpose of processing, as well as to take measures prescribed by the law to protect their rights;
– Set a precondition of preliminary consent when processing personal data to promote goods, works, or services on the market;
– Withdraw consent for the processing of personal data, as well as submit a request to cease the processing of personal data;
– Challenge in the authorized body for the protection of the rights of personal data subjects or in court the illegal actions or inaction of the Operator in the processing of their personal data;
– Exercise other rights provided by the legislation of the Russian Federation.
4.2. Personal data subjects are obliged to:
– Provide the Operator with accurate information about themselves;
– Inform the Operator about the clarification (update, change) of their personal data.
4.3. Individuals who provide the Operator with false information about themselves or information about another personal data subject without the latter's consent bear responsibility in accordance with the legislation of the Russian Federation.
5. Principles of Personal Data Processing
5.1. Personal data processing is carried out on a legal and fair basis.
5.2. Personal data processing is limited to the achievement of specific, predetermined, and legitimate purposes. Personal data processing incompatible with the purposes of personal data collection is not allowed.
5.3. Combining databases containing personal data processed for incompatible purposes is not allowed.
5.4. Only personal data that corresponds to 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 their processing. Redundancy of processed personal data in relation to the stated purposes of their processing is not allowed.
5.6. During the processing of personal data, accuracy, sufficiency, and (if necessary) relevance of the personal data to the processing purposes are ensured. The Operator takes necessary measures and/or ensures their adoption to delete or clarify incomplete or inaccurate data.
5.7. Personal data is stored in a form that allows the identification of the personal data subject no longer than the purposes of personal data processing require unless the period of personal data storage is established by federal law, an agreement to which the subject of personal data is a party, beneficiary, or guarantor. Processed personal data is destroyed or depersonalized upon reaching the processing purposes or in case of no longer needing to achieve these purposes unless otherwise provided by federal law.
6. Purposes of Personal Data Processing
Processing Purpose
Providing User access to services, information, and/or materials contained on the website
Personal Data

• Last name, first name, patronymic
• Email address
• Phone numbers
• Year, month, date, and place of birth

Legal Grounds

• Contracts concluded between the Operator and the Personal Data Subject

Types of Personal Data Processing

• Sending informational emails to the email address

7. Conditions of Personal Data Processing
7.1. Personal data processing is carried out with the consent of the personal data subject to process their personal data.
7.2. Personal data processing is necessary to achieve the purposes stipulated by an international treaty of the Russian Federation or by law, to fulfill functions, powers, and duties imposed on the Operator by the legislation of the Russian Federation.
7.3. Personal data processing is necessary for the administration of justice, the execution of a judicial act, an act of another authority, or an official subject to enforcement according to the legislation of the Russian Federation on enforcement proceedings.
7.4. Personal data processing is necessary for the performance of a contract, where the personal data subject is a party, a beneficiary, or a guarantor of the contract, as well as for the contract conclusion at the initiative of the personal data subject or a contract under which the personal data subject will be a beneficiary or a 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 objectives, provided that the rights and freedoms of the personal data subject are not violated.
7.6. Personal data processing is carried out for personal data that are publicly available, with unrestricted access granted by the personal data subject at their request (hereinafter "publicly available personal data").
7.7. Personal data processing is carried out for personal data subject to publication or mandatory disclosure in accordance with federal law.
8. Procedure for Collection, Storage, Transfer, and Other Types of Personal Data Processing
The 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 requirements of the current legislation in the field of personal data protection.
8.1. The Operator ensures the safety 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 the execution of applicable laws or if the personal data subject has given consent to the Operator for the data transfer to a third party to fulfill obligations under a civil contract.
8.3. In case inaccuracies in personal data are identified, the User can update them independently by sending a notification to the Operator at the email address info@trendtonik.ru with the note "Personal Data Update."
8.4. The processing period of personal data is determined by the achievement of the purposes for which personal data was collected unless the contract or the current legislation specifies a different period.
The User can revoke their consent for personal data processing at any time by sending a notification to the Operator via email to the Operator's email address info@trendtonik.ru with the note "Withdrawal of Consent for Personal Data Processing."
8.5. All information collected by third-party services, including payment systems, communication means, and other service providers, is stored and processed by these parties (Operators) according to their User Agreement and Privacy Policy. The personal data subject agrees to them. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this section.
8.6. Restrictions imposed by the personal data subject on transfer (except for providing access) and processing or conditions for processing (except for gaining access) of personal data allowed for distribution are not applicable in cases of personal data processing in the public, social, and other public interests as defined by the legislation of the Russian Federation.
8.7. The Operator ensures the confidentiality of personal data during its processing.
8.8. The Operator stores personal data in a form allowing identification of the personal data subject for no longer than necessary for personal data processing unless the storage period is established by federal law, a contract, a party to which, a beneficiary, or a guarantor of which is the personal data subject.
8.9. The termination of personal data processing can be triggered by the achievement of the purposes of personal data processing, 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 the identification of unlawful personal data processing.
9. List of Actions Performed by the Operator with Obtained Personal Data
9.1. The Operator performs collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
9.2. The Operator conducts automated processing of personal data, obtaining and/or transferring the received information via information and telecommunication networks or without them.
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 the protection of the rights of personal data subjects about their intention to carry out cross-border transfer of personal data (such notification is sent separately from the notification of intention to process personal data).
10.2. Before submitting the notification above, the Operator must obtain relevant information from the authorities of a foreign state, foreign individuals, or foreign legal entities to whom the cross-border transfer of personal data is planned.
11. Confidentiality of Personal Data
The Operator and other persons with access to personal data are obliged not to disclose such data to third parties and not to distribute personal data without the personal data subject's consent unless otherwise provided by federal law.
12. Final Provisions
12.1. The User can obtain any clarifications on matters related to processing their personal data by contacting the Operator via email at info@trendtonik.ru.
12.2. Any changes to the policy of personal data processing by the Operator will be reflected in this document. The policy is valid indefinitely until replaced by a new version.
12.3. The current version of the Policy is publicly available on the Internet at https://trendtonik.ru/eng.