Personal Data Processing Policy

General Provisions

This Personal Data Processing Policy has been prepared in accordance with the requirements of Clause 2, Part 1, Article 18.1 and Article 3 of Federal Law No. 152-FZ “On Personal Data” dated July 27, 2006 (hereinafter referred to as the Personal Data Law) and defines the procedure for processing personal data and the measures taken by ARMO LLC (hereinafter referred to as the Operator) to ensure the security of personal data.

1.1.

The Operator sets as its purpose and condition for carrying out its activities the observance of human and civil rights and freedoms when processing personal data, including the protection of the rights to privacy, personal and family secrets.

1.2.

This Policy of the Operator regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator may receive about visitors of the website https://armo-wear.ru.

1.3. Main rights and obligations of the Operator

1.3.1. The Operator has the right to:

— receive reliable information and/or documents containing personal data from the personal data subject;

— in the event that the personal data subject withdraws consent to the processing of personal data, continue processing personal data without the subject’s consent if there are grounds specified in the Personal Data Law;

— independently determine the composition and list of measures necessary and sufficient to ensure compliance with the obligations provided for by the Personal Data Law and the regulatory legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.

1.3.2. The Operator is obliged to:

— provide the personal data subject, upon request, with information concerning the processing of their personal data;

— organize the processing of personal data in accordance with the procedure established by the current 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 body for the protection of the rights of personal data subjects, upon its request, with the necessary information within 30 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, organizational and technical measures to protect personal data from unlawful or accidental access, destruction, alteration, blocking, copying, provision, distribution of personal data, as well as from other unlawful actions in relation to personal data;

— cease the transfer, distribution, provision of access, processing and destroy personal data in the procedure and cases provided for by the Personal Data Law;

— perform other duties provided for by the Personal Data Law.

1.4. Main rights and obligations of personal data subjects

1.4.1. Personal data subjects have the right to:

— receive information concerning the processing of their personal data, except in cases provided for by federal laws. Such information shall be provided by the Operator in an accessible form and shall not contain personal data relating to other personal data subjects, except in cases where there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;

— require the Operator to clarify their personal data, block or destroy it if the personal data is incomplete, outdated, inaccurate, unlawfully obtained or not necessary for the stated purpose of processing, as well as take measures provided by law to protect their rights;

— impose a condition of prior consent when processing personal data for the purpose of promoting goods, works and services on the market;

— withdraw consent to the processing of personal data;

— appeal to the authorized body for the protection of the rights of personal data subjects or to a court against unlawful actions or inaction of the Operator when processing personal data;

— exercise other rights provided for by the legislation of the Russian Federation.

1.4.2. Personal data subjects are obliged to:

— provide the Operator with reliable data about themselves;

— notify the Operator of any clarification, update or change of their personal data.

1.4.3.

Persons who have provided the Operator with false information about themselves or information about another personal data subject without the consent of the latter shall be liable in accordance with the legislation of the Russian Federation.

2. Purposes of Personal Data Collection

2.1. The purposes of processing the User’s personal data are:

— informing the User by sending emails;

— conclusion, execution and termination of civil-law contracts;

— providing the User with access to services, information and/or materials contained on the website https://armo-wear.ru.

2.2.

The Operator also has the right to send the User notifications about new products and services, special offers and various events. The User may at any time refuse to receive informational messages by sending an email to the Operator at armo-wear@inbox.ru with the subject line: “Refusal of notifications about new products, services and special offers”.

2.3.

Anonymized User data collected through internet statistics services is used to collect information about Users’ actions on the website, improve the quality of the website and its content.

3. Legal Grounds for Personal Data Processing

3.1. The legal grounds for the Operator’s processing of personal data are:

— the Constitution of the Russian Federation;

— the Civil Code of the Russian Federation;

— Federal Law No. 149-FZ “On Information, Information Technologies and Information Protection” dated July 27, 2006;

— federal laws and other regulatory legal acts in the field of personal data protection;

— the Operator’s charter documents;

— contracts concluded between the Operator and the personal data subject;

— Users’ consent to the processing of their personal data, including consent to the processing of personal data permitted for distribution.

3.2.

The Operator processes the User’s personal data only if it is filled in and/or sent by the User independently through special forms located on the website https://armo-wear.ru or sent to the Operator by email. By filling in the relevant forms and/or sending personal data to the Operator, the User expresses consent to this Policy.

3.3.

The Operator processes anonymized data about the User if this is permitted in the User’s browser settings.

3.4.

The personal data subject independently decides whether to provide their personal data and gives consent freely, of their own will and in their own interest.

4. Scope and Categories of Processed Data, Categories of Personal Data Subjects

4.1. The Operator may process the personal data of the following subjects:

— clients and counterparties of the Operator who are individuals;

— representatives/employees of the Operator’s clients and counterparties who are legal entities;

— visitors of the Operator’s website or websites.

4.2. The Operator may process the following personal data of the User:

— surname, first name, patronymic;

— email addresses;

— phone numbers;

— postal addresses.

4.3.

The website also collects and processes anonymized data about visitors, including cookie files, using internet statistics services such as Yandex Metrica and others.

4.4.

The above-mentioned data are hereinafter collectively referred to as Personal Data.

4.5.

The Operator does not process special categories of personal data relating to race, nationality, political opinions, religious or philosophical beliefs, or intimate life.

4.6.

Processing of personal data permitted for distribution from among the special categories of personal data specified in Part 1 of Article 10 of the Personal Data Law is allowed if the prohibitions and conditions provided for by Article 10.1 of the Personal Data Law are observed.

4.7.

The User’s consent to the processing of personal data permitted for distribution is executed separately from other consents to the processing of personal data. At the same time, the conditions provided for, in particular, by Article 10.1 of the Personal Data Law are observed. The requirements for the content of such consent are established by the authorized body for the protection of the rights of personal data subjects.

4.7.1.

The User provides consent to the processing of personal data permitted for distribution directly to the Operator.

4.7.2.

The Operator is obliged, no later than three business days from the receipt of the User’s consent, to publish information about the processing conditions, as well as the existence of prohibitions and conditions for the processing by an unlimited number of persons of personal data permitted for distribution.

4.7.3.

The transfer, distribution, provision or access to personal data permitted by the personal data subject for distribution must be terminated at any time at the request of the personal data subject.

Such request must include the surname, first name, patronymic, if any, contact information, including phone number, email address or postal address of the personal data subject, as well as a list of personal data whose processing must be terminated. The personal data specified in such request may be processed only by the Operator to whom the request is addressed.

4.7.4.

Consent to the processing of personal data permitted for distribution ceases to be effective from the moment the Operator receives the request specified in Clause 4.7.3 of this Personal Data Processing Policy.

5. Principles of Personal Data Processing

5.1.Personal data processing is carried out on a lawful and fair basis.

5.2.

Personal data processing is limited to achieving specific, predetermined and lawful purposes. Processing of personal data incompatible with the purposes of personal data collection is not allowed.

5.3.

Combining databases containing personal data processed for purposes incompatible with each other is not allowed.

5.4.

Only personal data that meets the purposes of its processing shall be processed.

5.5.

The content and scope of processed personal data correspond to the stated purposes of processing. Excessive processing of personal data in relation to the stated purposes of processing is not allowed.

5.6.

When processing personal data, the accuracy of personal data, its sufficiency and, where necessary, relevance in relation to the purposes of personal data processing are ensured. The Operator takes necessary measures and/or ensures that measures are taken to delete or clarify incomplete or inaccurate data.

5.7.

Personal data shall be stored in a form that allows the personal data subject to be identified for no longer than required by the purposes of personal data processing, unless the storage period is established by federal law or by a contract to which the personal data subject is a party, beneficiary or guarantor. Processed personal data shall be destroyed or anonymized upon achievement of the processing purposes or in the event that the need to achieve these purposes is lost, unless otherwise provided by federal law.

6. Conditions for Personal Data Processing

6.1.

Personal data processing is carried out with the consent of the personal data subject to the processing of their personal data.

6.2.

Personal data processing is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, and to exercise the functions, powers and duties imposed on the Operator by the legislation of the Russian Federation.

6.3.

Personal data processing is necessary for the administration of justice, execution of a judicial act, act of another authority or official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.

6.4.

Personal data processing 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.

6.5.

Personal data processing is necessary for the exercise of the rights and legitimate interests of the Operator or third parties, or for the achievement of socially significant purposes, provided that this does not violate the rights and freedoms of the personal data subject.

6.6.

Personal data is processed where access to it by an unlimited number of persons has been provided by the personal data subject or at their request, hereinafter referred to as publicly available personal data.

6.7.

Personal data subject to publication or mandatory disclosure in accordance with federal law is processed.

7. 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 current legislation in the field of personal data protection.

7.1.

The Operator ensures the safety of personal data and takes all possible measures to exclude access to personal data by unauthorized persons.

7.2.

The User’s personal data will never, under any circumstances, be transferred to third parties, except in cases related to the implementation of current legislation or where the personal data subject has given consent to the Operator to transfer data to a third party for the performance of obligations under a civil-law contract.

7.3.

If inaccuracies in personal data are identified, the User may update them independently by sending a notification to the Operator’s email address armo-wear@inbox.ru with the subject line: “Personal Data Update”.

7.4.

The period of personal data processing is determined by the achievement of the purposes for which the personal data was collected, unless another period is provided for by a contract or current legislation.

The User may withdraw consent to the processing of personal data at any time by sending a notification to the Operator by email at armo-wear@inbox.ru with the subject line: “Withdrawal of Consent to Personal Data Processing”.

7.5.

All information collected by third-party services, including payment systems, communication tools and other service providers, is stored and processed by such parties, or operators, in accordance with their User Agreement and Privacy Policy. The personal data subject and/or User must independently and timely review such documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.

7.6.

Restrictions established by the personal data subject on transfer, except for provision of access, as well as on processing or processing conditions, except for obtaining access, of personal data permitted for distribution, shall not apply in cases where personal data is processed in state, public or other public interests as defined by the legislation of the Russian Federation.

7.7.

When processing personal data, the Operator ensures the confidentiality of personal data.

7.8.

The Operator stores personal data in a form that allows the personal data subject to be identified for no longer than required by the purposes of personal data processing, unless the storage period is established by federal law or by a contract to which the personal data subject is a party, beneficiary or guarantor.

7.9.

The condition for termination of personal data processing may be 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, as well as detection of unlawful processing of personal data.

8. List of Actions Performed by the Operator with Received Personal Data

8.1.

The Operator performs collection, recording, systematization, accumulation, storage, clarification, update, modification, extraction, use, transfer, distribution, provision, access, anonymization, blocking, deletion and destruction of personal data.

8.2.

The Operator performs automated processing of personal data with or without receiving and/or transferring the received information via information and telecommunication networks.

9. Cross-Border Transfer

The Operator may carry out cross-border transfer of Personal Data in cases provided for by this Policy, only with the User’s consent, for the following purposes:

— identification of a party within communication using WhatsApp messenger, a product of Meta Platforms Inc., and Telegram messenger, a product of Telegram Messenger Inc.;

— consulting and sending information related to the services/goods provided, including but not limited to clarification of order details, booking confirmation, and technical support.

When carrying out cross-border transfer, the Operator undertakes to ensure the security of such transfer.

10. Final Provisions

10.1.

The User may obtain any clarifications on matters of interest concerning the processing of their personal data by contacting the Operator via email at armo-wear@inbox.ru.

10.2.

Any changes to the Operator’s Personal Data Processing Policy will be reflected in this document. The Policy is valid indefinitely until replaced by a new version.

10.3.

The current version of the Policy is freely available on the Internet at:

https://armo-wear.ru/support/#docs.