Personal Data Processing Policy

This personal data processing policy is drafted in accordance with the requirements of Federal Law No. 152-FZ “On Personal Data” dated 27.07.2006 (hereinafter – the “Personal Data Law”) and defines the procedure for processing personal data and the measures to ensure the security of personal data taken by Golubeva Kristina Igorevna (hereinafter – the “Operator”).
The Operator considers compliance with human and civil rights and freedoms in processing personal data, including the protection of privacy, personal and family secrets, as a primary goal and condition of its activities. This Policy applies to all information the Operator may obtain about visitors to the imm-thai.com website.

Key Concepts
Automated processing of personal data – processing personal data using computing equipment.
Blocking of personal data – temporary suspension of personal data processing (except when processing is necessary to clarify personal data).
Website – a set of graphical and informational materials, software, and databases making them available on the Internet at imm-thai.com.
Personal data information system – a set of personal data contained in databases and the information technologies and technical means ensuring their processing.
Anonymization of personal data – actions making it impossible to determine the owner of personal data without additional information.
Processing of personal data – any action or set of actions with personal data, including collection, recording, systematization, accumulation, storage, updating, retrieval, use, transfer, anonymization, blocking, deletion, destruction.
Operator – a state body, municipal body, legal or physical person organizing and/or performing personal data processing and determining the purpose, composition, and operations with personal data.
Personal data – any information directly or indirectly relating to a specific or identifiable visitor of imm-thai.com.
Personal data permitted for dissemination – personal data whose access is allowed to an unlimited circle of persons with the subject’s consent.
User – any visitor to imm-thai.com.
Provision of personal data – actions aimed at disclosing personal data to a specific person or group.
Dissemination of personal data – actions aimed at disclosing personal data to an unspecified circle of persons or making it publicly accessible.
Cross-border transfer of personal data – transfer of personal data to a foreign country’s authority, individual, or legal entity.
Destruction of personal data – actions resulting in irreversible deletion of personal data with no possibility of recovery.

Rights and Obligations of the Operator
The Operator has the right to obtain accurate information from data subjects, continue processing personal data in certain cases even if consent is withdrawn, and independently determine necessary measures to ensure compliance with the Personal Data Law.
The Operator must provide information about personal data processing, organize processing according to Russian law, respond to inquiries, ensure access to this Policy, take legal, organizational, and technical measures to protect personal data, and stop processing or destroy personal data as required by law.

Rights and Obligations of Personal Data Subjects
Data subjects have the right to access information about their data, request clarification, blocking, or destruction of data, set conditions for processing for marketing purposes, withdraw consent, and appeal unlawful actions.
Data subjects must provide accurate information and notify the Operator of updates. Providing false data or data of another person without consent carries liability under Russian law.

Principles of Personal Data Processing
Processing must be lawful and fair, limited to specific, predetermined, and legal purposes. Data should not be combined or processed beyond the stated purposes. Data accuracy and relevance must be ensured. Storage should not exceed the period necessary for achieving processing purposes unless otherwise specified by law.

Purpose and Legal Basis for Processing
Purpose: Clarifying order details and providing consultation
Data: Name, phone number, email
Legal basis: Federal Law No. 149-FZ “On Information, Information Technologies, and Protection of Information”
Processing types: Collection, recording, systematization, accumulation, storage, destruction, and anonymization of personal data

Conditions for Processing
Processing is carried out with the subject’s consent, for legal purposes under Russian law, for execution of contracts, protection of rights, or public interest. Publicly available data or data required to be published by law may also be processed.

Collection, Storage, Transfer, and Other Processing
Data security is ensured through legal, organizational, and technical measures. Personal data is protected from unauthorized access and is not transferred to third parties except by law or with consent. Users may update their data by contacting the Operator via email at jack.fruit.imm.thai@gmail.com. Processing duration is determined by the purpose unless otherwise stipulated. Users may withdraw consent at any time. Third-party services may collect and process data according to their own policies. Restrictions on data transfer do not apply for public or legally mandated processing.

Actions Performed by the Operator
The Operator collects, records, systematizes, accumulates, stores, updates, retrieves, uses, transfers, anonymizes, blocks, deletes, and destroys personal data. Automated processing may include data transmission via telecommunications networks.

Cross-Border Transfer
Before transferring data abroad, the Operator must notify Russian authorities and obtain relevant information from foreign recipients.

Confidentiality
The Operator and other persons with access must not disclose personal data without consent, unless required by law.

Final Provisions
Users can request clarifications via email at jack.fruit.imm.thai@gmail.com. This document will reflect any changes in the Operator’s data processing policy. The Policy is valid indefinitely until replaced by a new version. The current version is available online at https://imm-thai.com/politika/en.