PERSONAL DATA PROCESSING POLICY

This Personal Data Processing Policy (hereinafter referred to as the "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 measures taken by COSMIRA LLC (hereinafter referred to as the "Operator") to ensure the security of personal data.

1.1. The Operator regards the observance of human and civil rights and freedoms in the processing of personal data as one of its most important goals and essential conditions for conducting its activities, including the protection of the right to privacy, personal and family confidentiality.

1.2. This Policy of the Operator regarding the processing of personal data applies to all information that the Operator may obtain about visitors to the website https://cosmira.ru.

2.1. Automated processing of personal data — processing of personal data using computer technology.

2.2. Blocking of personal data — temporary suspension of the processing of personal data (except when processing is necessary to clarify personal data).

2.3. Website — a set of graphic and informational materials, as well as computer programs and databases ensuring their accessibility on the Internet at the network address https://cosmira.ru.

2.4. Personal data information system — a set of personal data contained in databases and the information technologies and technical means that ensure their processing.

2.5. Depersonalization of personal data — actions resulting in the impossibility to determine, without the use of additional information, whether personal data belong to a specific User or another personal data subject.

2.6. Processing of personal data — any action (operation) or a set of actions (operations) performed with or 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 or municipal authority, legal entity, or individual that, independently or jointly with others, organizes and/or carries out the processing of personal data, determines the purposes of personal data processing, the composition of personal data to be processed, and the actions (operations) performed with personal data.

2.8. Personal data — any information relating directly or indirectly to a specific or identifiable User of the website https://cosmira.ru.

2.9. Personal data permitted by the personal data subject for dissemination — personal data to which access by an unlimited number of persons has been granted by the personal data subject through consent to the processing of such data in accordance with the procedure established by the Personal Data Law.

2.10. User — any visitor of the website https://cosmira.ru.

2.11. Provision of personal data — actions aimed at disclosing personal data to a certain person or a certain circle of persons.

2.12. Dissemination of personal data — any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or making personal data available to an indefinite number of persons, including publication in mass media, posting on information and telecommunication networks, or providing access to personal data in any other way.

2.13. Cross-border transfer of personal data — the transfer of personal data to the territory of a foreign state, to a foreign state authority, foreign individual, or foreign legal entity.

2.14. Destruction of personal data — any actions resulting in the irreversible destruction of personal data, making it impossible to restore the content of personal data in the personal data information system and/or resulting in the destruction of tangible media containing personal data.

3.1. The Operator has the right to:

• receive from the personal data subject reliable information and/or documents containing personal data;
• continue processing personal data without the consent of the personal data subject in cases provided for by the Personal Data Law, including when consent has been withdrawn or a request for termination of processing has been submitted;
• independently determine the composition and list of measures necessary and sufficient to ensure compliance with the obligations provided by the Personal Data Law and other regulatory acts, unless otherwise stipulated by the Personal Data Law or other federal laws.

3.2. The Operator shall:

• provide the personal data subject, upon request, with information regarding the processing of their personal data;
• organize the processing of personal data in accordance with the legislation of the Russian Federation;
• respond to requests and inquiries from personal data subjects and their legal representatives as required by the Personal Data Law;
• provide the authorized body for the protection of the rights of personal data subjects, upon request, with necessary information within ten (10) days from the date of receipt of such a request;
• publish or otherwise ensure unrestricted access to this Policy on the processing of personal data;
• take legal, organizational, and technical measures to protect personal data against unlawful or accidental access, destruction, modification, blocking, copying, provision, dissemination, and other unauthorized actions;
• cease the transfer (distribution, provision, access) and processing of personal data and destroy personal data in accordance with the procedure and in cases provided by the Personal Data Law;
• fulfill other obligations established by the Personal Data Law.

4.1. Personal data subjects have the right to:

• receive information regarding the processing of their personal data, except in cases provided by federal laws. Such information shall be provided by the Operator in an accessible form and shall not include personal data relating to other subjects unless there are legal grounds for such disclosure. The list of information and the procedure for its provision are established by the Personal Data Law;
• request the Operator to clarify, block, or destroy their personal data if such data are incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, and take legal measures to protect their rights;
• require prior consent for the processing of personal data for the purpose of promoting goods, works, and services on the market;
• withdraw consent to the processing of personal data and submit a request to terminate the processing of personal data;
• appeal unlawful actions or inaction of the Operator in the processing of personal data to the authorized body for the protection of the rights of personal data subjects or in court;
• exercise other rights provided by the legislation of the Russian Federation.

4.2. Personal data subjects shall:

• provide the Operator with reliable information about themselves;
• notify the Operator about the clarification (updating, modification) of their personal data.

4.3. Persons who have provided the Operator with inaccurate information about themselves or information about another personal data subject without that person’s consent shall be liable in accordance with the legislation of the Russian Federation.

5.1. The processing of personal data shall be carried out on a lawful and fair basis.

5.2. The processing of personal data shall be limited to the achievement of specific, predetermined, and lawful purposes. The processing of personal data incompatible with the purposes of collecting personal data shall not be allowed.

5.3. It shall not be permitted to combine databases containing personal data that are processed for purposes that are incompatible with each other.

5.4. Only personal data that meet the purposes of their processing shall be subject to processing.

5.5. The content and scope of processed personal data shall correspond to the declared purposes of processing. The processing of excessive personal data in relation to the declared purposes shall not be permitted.

5.6. During the processing of personal data, accuracy, sufficiency, and, where necessary, relevance of personal data in relation to the purposes of processing shall be ensured. The Operator shall take necessary measures and/or ensure that such measures are taken to delete or clarify incomplete or inaccurate data.

5.7. Personal data shall be stored in a form that allows the identification of the personal data subject for no longer than is required by the purposes of personal data processing, unless a longer storage period is established by federal law, an agreement to which the personal data subject is a party, beneficiary, or guarantor. Processed personal data shall be destroyed or depersonalized upon the achievement of processing purposes or when the need to achieve such purposes is lost, unless otherwise provided by federal law.

Purpose of processing:
Informing the User by sending electronic messages.

Personal data processed:

• Surname, first name, patronymic;
• Email address;
• Phone numbers;
• Date, month, year, 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 User’s email address.

7.1. Personal data shall be processed with the consent of the personal data subject to the processing of their personal data.

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

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

7.4. The processing of personal data 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 initiated by the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor.

7.5. The processing of personal data is necessary to exercise the rights and legitimate interests of the Operator or third parties, or to achieve socially significant purposes, provided that the rights and freedoms of the personal data subject are not thereby violated.

7.6. The processing of personal data made publicly available by the personal data subject or at their request shall be carried out (hereinafter referred to as “publicly available personal data”).

7.7. The processing of personal data subject to publication or mandatory disclosure in accordance with federal law shall be carried out.

The security of personal data processed by the Operator shall be 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 shall ensure the confidentiality and security of personal data and take all possible measures to prevent unauthorized access by third parties.

8.2. The User’s personal data shall never, under any circumstances, be transferred to third parties except in cases related to the fulfillment of applicable legal obligations or when the personal data subject has granted the Operator consent for such transfer to a third party in order to perform obligations under a civil law contract.

8.3. If inaccuracies in personal data are identified, the User may independently update such data by sending a notification to the Operator’s email address i. andreeva@cosmira.ru with the note "Personal Data Update."

8.4. The period of personal data processing shall be determined by the achievement of the purposes for which personal data were collected, unless otherwise provided by contract or applicable legislation.
The User may at any time withdraw their consent to the processing of personal data by sending an email to the Operator at i. andreeva@cosmira.ru with the note "Withdrawal of Consent for Personal Data Processing."

8.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by such entities (Operators) in accordance with their User Agreements and Privacy Policies. The personal data subject is obliged to review these documents independently. The Operator is not responsible for the actions of third parties, including service providers mentioned in this paragraph.

8.6. Restrictions established by the personal data subject on the transfer (other than access provision), as well as on the processing or conditions of processing (other than access) of personal data permitted for dissemination, shall not apply in cases where personal data are processed in state, public, or other public interests defined by the legislation of the Russian Federation.

8.7. When processing personal data, the Operator shall ensure their confidentiality.

8.8. The Operator shall store personal data in a form allowing identification of the personal data subject for no longer than is required by the purposes of processing, unless a longer period is established by federal law or by a contract to which the personal data subject is a party, beneficiary, or guarantor.

8.9. The processing of personal data shall be terminated upon achievement of processing purposes, expiration of the consent period, withdrawal of consent by the personal data subject, submission of a request for termination of processing, or detection of unlawful processing of personal data.

9.1. The Operator performs the 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 performs automated processing of personal data, including obtaining and/or transmitting such information via information and telecommunication networks or without them.

10.1. Prior to the commencement of cross-border transfer of personal data, the Operator shall notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out such transfer (this notification shall be submitted separately from the notification of intent to process personal data).

10.2. Before submitting the above-mentioned notification, the Operator shall obtain relevant information from the authorities of the foreign state, foreign individuals, or foreign legal entities to which cross-border transfer of personal data is intended.

The Operator and other persons who have gained access to personal data shall not disclose or distribute such data to third parties without the consent of the personal data subject, unless otherwise provided by federal law.

12.1. The User may obtain any clarifications regarding matters relating to the processing of their personal data by contacting the Operator via email at i. andreeva@cosmira.ru.

12.2. Any amendments to the Operator’s Personal Data Processing Policy shall be reflected in this document. The Policy shall remain in effect indefinitely until replaced by a new version.

12.3. The current version of the Policy is freely available on the Internet at https://cosmira.ru/privacy.