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Privacy Policy

Privacy Policy (Personal Data Processing Policy)

1. General provisions

This Privacy Policy (the “Policy”) is prepared in accordance with Federal Law No. 152-FZ of 27 July 2006 “On Personal Data” (the “Law”) and defines how personal data is processed and the measures taken to ensure its security by Individual Entrepreneur Anastasia Radikovna Semenova (the “Operator”).

Address: 30–94 Oktyabrskaya St., Magnitogorsk, 455023, Russia;
TIN (INN) 745500522760;
OGRNIP 317745600046193;
E-mail: info@smorodinacosmetic.com.

Person responsible for organizing personal data processing:
Anastasia Radikovna Semenova, e-mail: info@smorodinacosmetic.com.

1.1. The Operator regards respect for the rights and freedoms of individuals, including the right to privacy and to personal and family confidentiality, as a fundamental condition of its activity.

1.2. This Policy applies to all information the Operator may obtain about visitors of the website smorodinacosmetic.com.

2. Key terms

The terms used in this Policy have the meanings defined by the Law, including: processing of personal data, automated processing, blocking, anonymization, destruction, disclosure, provision and cross-border transfer of personal data.

2.1. Personal data means any information relating directly or indirectly to an identified or identifiable user of the website smorodinacosmetic.com.

2.2. User means any visitor of the website.

3. Rights and obligations of the Operator and data subjects

3.1. The Operator is entitled to receive accurate data from the data subject, to determine the set of protective measures, and, in cases provided by the Law, to continue processing after withdrawal of consent where lawful grounds exist.

3.2. The Operator undertakes to process personal data in the manner established by the legislation of the Russian Federation; to provide the data subject with information about the processing of their data; to respond to requests; to take measures to protect the data; to cease processing and destroy the data in the cases provided by the Law; and to ensure open access to this Policy.

3.3. The data subject has the right to obtain information about the processing of their data, to demand its clarification, blocking or destruction, to withdraw consent, and to appeal the Operator’s actions to Roskomnadzor or in court.

4. Principles of processing

Processing is carried out on a lawful and fair basis and is limited to the achievement of specific, predefined and lawful purposes. Only personal data consistent with the purposes of processing is processed; its content and volume correspond to the stated purposes, and excessiveness is not permitted (data minimization). Data is stored no longer than the purposes of processing require.

5. Purposes of processing, data categories, retention periods and destruction

5.1. Access to website services, registration and account management

Data subjects: website visitors and registered users.
Personal data: full name; e-mail address; phone number; password (account login data); device and browser data (IP address, device type, operating system, browser).
Legal basis: consent of the data subject.
Retention period: until the account is deleted or consent is withdrawn.
Destruction: upon achievement of the purpose, withdrawal of consent or account deletion, the data is destroyed or anonymized within no more than 30 days.

5.2. Conclusion and performance of the sale contract, order fulfilment and delivery

Data subjects: customers.
Personal data: full name; e-mail address; phone number; delivery address.
Legal basis: processing necessary for the performance of a contract to which the data subject is a party (para. “b”, part 1, art. 6 of the Law).
Retention period: for the term of the contract and the subsequent document-retention period required by accounting legislation (at least 5 years).
Destruction: after the retention period expires, the data is destroyed or anonymized within no more than 30 days.

5.3. Information about news, promotions and special offers (marketing communications)

Data subjects: users who subscribed or consented to marketing communications.
Personal data: first and last name; e-mail address; phone number; date of birth (if provided, for greetings and personalized offers).
Legal basis: consent to receive advertising and information communications.
Retention period: until consent is withdrawn.
Destruction: within no more than 30 days after withdrawal of consent.

5.4. Website operation, security and improvement (web analytics)

Data subjects: website visitors.
Personal data: cookies, IP address, device data, information about actions on the website (in anonymized / aggregated form).
Legal basis: consent expressed through the cookie banner.
Retention period: no more than one year from obtaining consent or until it is withdrawn.
Destruction: automatic deletion upon expiry of the retention period or withdrawal of consent.

6. Transfer of personal data to third parties

To achieve the purposes above, the Operator engages the following parties and transfers personal data to them only to the extent necessary for them to perform their functions:

Yandex LLC (Yandex.Metrica service) — web analytics; data is processed on servers located in the Russian Federation;
RetailCRM service — order processing and customer communication;
Unisender service — sending of service and (subject to consent) marketing messages;
Delivery and logistics companies — delivery of ordered goods.

Personal data is not transferred to other third parties without the data subject’s consent, except in cases provided by the legislation of the Russian Federation.

7. Storage location and data security

Personal data is processed and stored on servers located in the Russian Federation. The Operator takes legal, organizational and technical measures to protect personal data against unauthorized access, destruction, alteration, blocking, copying, provision or dissemination.

8. Cross-border data transfer

The Operator does not carry out cross-border transfer of personal data. Should such a need arise, the Operator will notify the authorized data-protection authority prior to any transfer, as required by art. 12 of the Law.

9. Withdrawal of consent and requests

The data subject may update their data or withdraw consent at any time by sending a notice to info@smorodinacosmetic.com. After consent is withdrawn, the Operator ceases processing and destroys the personal data within no more than 30 days, unless processing may lawfully continue on other grounds.

10. Final provisions

This Policy is effective indefinitely until replaced by a new version. The current version is available at smorodinacosmetic.com/terms_en/.

Note: In case of any discrepancy, the Russian-language version of this Policy prevails.

Last updated: 10 July 2026