PERSONAL DATA PROCESSING POLICY

TERMS

Personal data – any information relating to a directly or indirectly identified or identifiable natural person (personal data subject).

Processing of personal data – any action (operation) or set of actions (operations) performed with or without the use of automation tools on personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (dissemination, provision, access), depersonalization, blocking, deletion, and destruction of personal data.

User data – data automatically collected or generated through the use of the Website, including the duration of page visits, actions, clicks, and other behavioral information.

Cookies are small pieces of data stored on the user’s device.

Data controller — the party that determines the purposes and means of processing personal data. For the purposes of this Policy, the Controller is ООО «ВАЙСИЗОН».

Data processor — any party (other than an employee of the controller) that processes data on behalf of the controller.

Data subject — the natural person whose personal data is processed.

User — a person who uses the Website, including for placing an order. The User is a personal data subject.

INTRODUCTION

1.1. This document defines the policy of ООО «ВАЙСИЗОН» regarding the processing of personal data and applies to all information that the Store may obtain during the User’s use of the Website and the placement and fulfillment of an order.

Placing an order constitutes the User’s full and unconditional consent to the User Agreement, as well as to this Policy and the conditions for processing personal information specified herein. In case of disagreement with the conditions, the User is obliged to discontinue use of the Website.

This Policy applies to all personal data processing operations, including collection, recording, systematization, accumulation, storage, clarification, extraction, use, transfer, depersonalization, blocking, deletion, and destruction.

1.2. This Policy has been developed in accordance with the requirements of Federal Law of the Russian Federation №152-ФЗ "On Personal Data" and also takes into account the provisions of GDPR with respect to international standards for the protection of personal data.

PERSONAL DATA OF USERS

2.1. Personal data of Users means any information and data relating to a directly or indirectly identified or identifiable natural person that the Seller obtains in the course of using the Website, placing and fulfilling Orders, as well as through any other interaction of the User with ООО «ВАЙСИЗОН».

2.1.1. Data, including personal data, that the User provides about themselves voluntarily when placing an Order, registering on the Website, filling out feedback forms, subscribing to newsletters, participating in promotions, as well as during the fulfillment of an Order or any other interaction with the Website.

2.1.2. Data automatically transmitted to the Seller when using the Website, including but not limited to:

• IP address
• cookie data
• information about the User’s browser or other software used to access the Website
• technical characteristics of the User’s hardware and software
• device model and type
• operating system
• date and time of access to the Website
• addresses of requested pages
• referral sources
• information about the User’s actions on the Website
• session duration and other similar data

2.1.3. Other information about the User, the processing of which is provided for by the terms of the services rendered by the Seller and is necessary to achieve the purposes defined by this Policy.

2.1.4. The User’s personal data may include, among other things but not limited to:

• Last name, First name, Patronymic
• Contact phone number
• Email address
• Order delivery address
• History of orders and inquiries
• Cookies and user data
• Other information provided by the User voluntarily

2.2. The Seller proceeds on the assumption that the User provides accurate, up-to-date, and sufficient personal data and updates such information in a timely manner in the event of any changes.

2.3. ООО «ВАЙСИЗОН» has the right to make changes to this Policy unilaterally. The new revision of the Policy comes into force from the moment it is posted on the Website.

The current revision of the Policy is permanently available for review at: https://viceseason.com

The User is advised to review the contents of this Policy regularly in order to stay informed of any possible changes to the conditions for processing personal data.

2.4. USE OF COOKIES

The Seller uses cookies and similar technologies to track User activity on the Website.

Cookies are sent to the User’s device from the web server and stored in the browser in order to:

• ensure the correct operation of the Website’s functionality
• save user settings
• analyze traffic
• improve the quality of service
• conduct marketing and analytical research

Auxiliary tracking technologies are also used, including beacons, tags, and scripts, which allow the collection and analysis of information about User actions.

The User has the right to change their browser settings to refuse the use of cookies or to receive notifications about their transmission. However, disabling cookies may lead to the incorrect operation of certain functions of the Website.

2.5.1. Session cookies used for the correct functioning of the Website and to enable navigation.

2.5.2. Personal cookies used to remember settings, preferences, and user parameters.

2.5.3. Security cookies intended to protect data and prevent unauthorized access.

PURPOSES OF PERSONAL DATA PROCESSING

3.1. The Seller processes and stores only those personal data that are necessary to provide services to the User, to place and fulfill orders, to perform obligations under contracts, and to ensure the full functioning of the VICESEASON online store in accordance with the terms of the Public Offer posted on the Internet at: https://viceseason.com.

3.2. The list of actions with personal data to which the User consents includes, but is not limited to:

• receiving, collecting, and storing the User’s personal data in electronic form and (where necessary) on paper media
• systematization, accumulation, clarification (updating, modification) of personal data
• use of personal data to conclude and perform sale and purchase agreements and service contracts
• transfer of the User’s personal data to third parties in the manner established by the legislation of the Russian Federation, solely for the purposes of fulfilling orders and contractual obligations
• use of personal data to inform the User about the status of orders, changes in conditions, news, promotions, and offers of the Seller
• sending advertising, informational, and marketing communications, whereby the User has the right to opt out of receiving such communications at any time
• communication with the User, including the handling of inquiries, requests, complaints, and notifications
• conducting statistical, analytical, and marketing research based on depersonalized data
• improving the quality of service, the user experience, and the functionality of the Website

PRINCIPLES OF PERSONAL DATA PROCESSING

4.1. The processing of personal data is carried out by ООО «ВАЙСИЗОН» based on the following principles:

4.1.1. Personal data is processed on a lawful, fair, and transparent basis, in compliance with the rights and legitimate interests of personal data subjects.

4.1.2. The processing of personal data is limited to the achievement of specific, predetermined, and lawful purposes. The processing of personal data that is incompatible with the purposes of its collection is not permitted.

4.1.3. The merging of databases containing personal data processed for mutually incompatible purposes is not permitted.

4.1.4. Only those personal data that correspond to the stated purposes of their processing and are necessary to achieve such purposes are subject to processing.

4.1.5. The content and volume of the personal data processed must correspond to the stated purposes of processing. The processing of excessive data is not permitted.

4.1.6. When processing personal data, its accuracy, relevance, sufficiency, and, where necessary, timely updating are ensured.

4.1.7. Personal data is stored in a form that allows the personal data subject to be identified for no longer than required by the purposes of processing, unless otherwise provided by the legislation of the Russian Federation.

CONDITIONS FOR PERSONAL DATA PROCESSING

5.1. The processing of personal data is carried out by the Seller in accordance with the requirements of Federal Law of the Russian Federation №152-ФЗ "On Personal Data" and is permitted if at least one of the following conditions is met:

• the personal data subject has consented to the processing of their data
• the processing of personal data is necessary for the performance of a contract to which the personal data subject is a party
• the processing is necessary to fulfill the obligations of the operator provided for by law
• the processing is necessary to protect the life, health, or other vital interests of the personal data subject
• the processing is carried out for statistical and research purposes, provided that the data is mandatorily depersonalized
• the processing of data to which access by an unlimited number of persons has been granted by the personal data subject
• other grounds provided for by the current legislation of the Russian Federation

5.2. Biometric personal data is not processed by ООО «ВАЙСИЗОН».

5.3. Decisions producing legal consequences for the personal data subject are not made on the basis of solely automated processing of personal data.

5.4. The fact that the User voluntarily provides their personal data is recognized by this Policy as an expression of consent to the processing of such data.

5.5. The Seller has the right to entrust the processing of personal data to third parties on the basis of a concluded contract. Such parties undertake to maintain confidentiality and ensure the security of personal data.

In the event that the processing of personal data is entrusted to third parties, ООО «ВАЙСИЗОН» bears responsibility to the personal data subject for the actions of such parties.

OBLIGATIONS OF THE PARTIES

6.1. The User is obliged to provide accurate and up-to-date information about their personal data necessary to fulfill an order, perform contractual obligations, and properly render services by the Seller.

In the event of changes to previously provided personal data, the User undertakes to promptly update or supplement such information by making the changes independently or by notifying the Seller in any available manner.

6.2. In accordance with the requirements of Federal Law №152-ФЗ "On Personal Data", ООО «ВАЙСИЗОН» undertakes to:

• provide the personal data subject, upon their written or electronic request, with information concerning the processing of their personal data, or, on lawful grounds, provide a reasoned refusal
• at the request of the personal data subject, clarify, block, or destroy the personal data being processed if such data is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing
• • notify the personal data subject of the processing of their personal data if such data was not obtained directly from the personal data subject, except in the following cases:
  • the personal data subject has already been notified of the processing of their personal data by the relevant operator
  • the personal data was obtained by the operator on the basis of a federal law or in connection with the performance of a contract to which the personal data subject is a party
  • the personal data was made publicly available by the personal data subject or obtained from publicly available sources
  • the Seller processes personal data for statistical, research, or other scientific purposes, provided that such data is mandatorily depersonalized
  • providing the personal data subject with information about the processing violates the rights and legitimate interests of third parties

6.3. In the event that the personal data subject withdraws consent to the processing of their personal data, the Seller undertakes to cease processing such data and to destroy it within a period not exceeding thirty calendar days from the date of receipt of the corresponding written notification, unless otherwise provided by an agreement between the Seller and the personal data subject or by the requirements of the legislation of the Russian Federation.

The Seller notifies the personal data subject of the destruction of personal data in the established manner.

6.4. The User agrees that the Seller has the right to transfer personal data to third parties solely for the purposes of fulfilling orders, rendering services, performing contractual obligations, and in cases provided for by the current legislation of the Russian Federation.

MEASURES TO ENSURE THE SECURITY OF PERSONAL DATA DURING ITS PROCESSING

7.1. When processing personal data, ООО «ВАЙСИЗОН» takes the necessary legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision, dissemination, as well as from other unlawful actions with respect to personal data.

7.2. The security of personal data is ensured, in particular, through:

• identifying current threats to the security of personal data during its processing in personal data information systems
• applying a set of organizational and technical measures to ensure the security of personal data during its processing, necessary to meet the requirements for personal data protection, the fulfillment of which ensures the levels of protection established by the Government of the Russian Federation
• using certified information protection tools in cases provided for by law
• assessing the effectiveness of the measures taken to ensure the security of personal data before information systems are put into operation
• detecting instances of unauthorized access to personal data and taking timely measures to prevent and eliminate the consequences of such incidents
• preserving the evidentiary base and event logs in the event of attempts of unauthorized access
• restoring personal data modified or destroyed as a result of unauthorized access
• ongoing monitoring of compliance with legal requirements and internal regulations in the field of personal data security

DATA PROCESSORS AND OTHER WEBSITES

8.1. The Seller has the right to use third-party services, software solutions, and individual persons (hereinafter – Service Providers) to support the operation of the Website, provide related services, analyze user behavior, and optimize business processes.

Such parties are granted access to personal data solely to the extent necessary to perform the tasks entrusted to them on behalf of ООО «ВАЙСИЗОН», and undertake not to disclose or use the data for any other purposes.

8.2. The Seller may use remarketing and behavioral advertising technologies on third-party websites. As part of this, cookies may be used to create advertising offers based on the User’s previous visits to the Website.

8.3. The Seller may use the services of third-party payment operators (including the payment services of Альфа-Банка) to process payments. The Seller does not store or collect the full details of the User’s payment cards. Such information is transmitted directly to the payment provider, and data processing is governed by the privacy policy of the relevant provider.

8.4. The Seller has the right to use email newsletter services and CRM systems (including RetailCRM) to notify users, process orders, and communicate.

8.5. The Website may contain links to third-party websites and resources not operated by ООО «ВАЙСИЗОН». By following such links, the User agrees that the Seller bears no responsibility for the data processing policies and actions of such websites.

8.6. The Seller recommends that the User independently review the privacy policy of each third-party resource that they visit.

8.7. ООО «ВАЙСИЗОН» does not control and bears no responsibility for the content, terms of use, and actions of third-party websites and services.

SELLER CONTACTS

ООО «ВАЙСИЗОН»

ИНН: 6700016470

ОГРН: 1246700005837

Legal address: Смоленская область, г. Смоленск, ул. Николаева, д. 51, офис P2

Email: viceseason@inbox.ru

Phone: +7 920 308-70-30

Website: https://viceseason.com