Policy on personal data processing

1. General provisions

This policy of personal data processing is drawn up in accordance with the requirements of the Federal Law dated 27.07.2006. No. 152-FZ "On Personal Data" (hereinafter - the Law on Personal Data) and determines the order of personal data processing and measures to ensure the security of personal data undertaken by LLC "Concept of Recreation DME" (hereinafter - the Operator).
1.1. The Operator sets as its most important goal and condition of its activity the observance of human and citizen's rights and freedoms during the processing of personal data, including the protection of the rights to privacy, personal and family secrecy.
1.2. This Operator's policy on personal data processing (hereinafter referred to as the Policy) applies to all information that the Operator may obtain about the visitors of the website https://gettsleep.com.

2. Basic concepts used in the Policy

2.1 Automated processing of personal data - processing of personal data by means of computer equipment.
2.2. Blocking of personal data - temporary cessation of personal data processing (except for cases when processing is necessary for clarification of personal data).
2.3. Website - a set of graphic and informational materials, as well as computer programs and databases, ensuring their availability on the Internet at the network address https://gettsleep.com.
2.4. Personal data information system - a set of personal data contained in databases and information technologies and technical means ensuring their processing.
2.5. Personal data depersonalization - actions as a result of which it is impossible to determine, without using additional information, whether personal data belong to a particular User or other subject of personal data.
2.6 Processing of personal data - any action (operation) or set of actions (operations) performed with the use of automation means or without the use of such means with personal data, including collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
2.7. Operator - a state authority, municipal authority, legal entity or individual, independently or jointly with other persons organizing and (or) carrying out processing of personal data, as well as determining the purposes of personal data processing, composition of personal data subject to processing, actions (operations) performed with personal data.
2.8. Personal data - any information relating directly or indirectly to a certain or defined User of the website https://gettsleep.com.
2.9. Personal data authorized by the subject of personal data for dissemination - personal data to which access to an unlimited number of persons is granted by the subject of personal data by giving consent to the processing of personal data authorized by the subject of personal data for dissemination in the manner prescribed by the Personal Data Law (hereinafter - personal data authorized for dissemination).
2.10. User - any visitor of the website https://gettsleep.com.
2.11. Provision of personal data - actions aimed at disclosure of personal data to a certain person or a certain circle of persons.
2.12. Dissemination of personal data - any actions aimed at disclosure of personal data to an indefinite number of persons (transfer of personal data) or at familiarization with personal data of an unlimited number of persons, including disclosure of personal data in mass media, placement in information and telecommunication networks or providing access to personal data in any other way.
2.13. Cross-border transfer of personal data - transfer of personal data to the territory of a foreign country to a foreign government authority, a foreign individual or a foreign legal entity.
2.14. Destruction of personal data - any actions, as a result of which personal data are irretrievably destroyed with the impossibility of further recovery of the content of personal data in the information system of personal data and (or) material carriers of personal data are destroyed.

3. Basic rights and obligations of the Operator

3.1 The Operator has the right to: - to receive from the personal data subject reliable information and/or documents containing personal data;
- in case the personal data subject revokes his/her consent to the processing of personal data, the Operator has the right to continue the processing of personal data without the consent of the personal data subject if there are grounds specified in the Personal Data Law;
- to independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations stipulated by the Personal Data Law and those adopted in the
3.2. The Operator is obliged to: - provide the personal data subject at his/her request with information regarding the processing of his/her personal data;
- organize the processing of personal data in accordance with the procedure established by the current legislation of the Russian Federation;
- respond to appeals and requests of personal data subjects and their legal representatives in accordance with the requirements of the Law on Personal Data;
- report to the authorized body for the protection of the rights of personal data subjects at the request of this body the necessary information within 30 days from the date of receipt of such a request

4. Basic rights and obligations of personal data subjects

4.1 Personal data subjects have the right to: - to receive information regarding the processing of his/her personal data, except in cases provided for by federal laws. Information shall be provided to the subject of personal data by the Operator in an accessible form and shall not contain personal data relating to other subjects of personal data, except in cases where there are legal grounds for disclosure of such personal data. The list of information and the procedure for obtaining it is established by the Law on Personal Data;
- to demand from the Operator to clarify his personal data, block or destroy them in case the personal data are incomplete, outdated, inaccurate, illegally obtained or are not necessary for the stated purpose of processing, as well as to take measures provided by law to protect his rights; - to impose a condition of prior consent when processing personal data for the purpose of promotion of goods, works and services on the market ;
- to withdraw the personal data from the Operator ;
- to withdraw the personal data from the market;
- to request the Operator's consent to the processing of personal data for the purpose of promotion of goods, works and services.
4.2. Personal data subjects are obliged to: - to provide the Operator with reliable data about themselves; - to inform the Operator about the clarification (update, change) of their personal data.
4.3. Persons who have provided the Operator with false information about themselves, or information about another subject of personal data without the consent of the latter, shall be liable in accordance with the legislation of the Russian Federation.

5. The Operator may process the following personal data of the User

5.1 Surname, first name, patronymic.
5.2. E-mail address.
5.3. Telephone numbers.
5.4. Year, month, date and place of birth.
5.5. Details of the identity document.
5.6. The site also collects and processes anonymized data about visitors (including cookies) using Internet statistics services (Yandex Metrica and Google Analytics and others).
5.7. The aforementioned data are hereinafter referred to in the text of the Policy as Personal Data.
5.8. The Operator does not process special categories of personal data concerning race, nationality, political views, religious or philosophical beliefs, intimate life.
5.9. Processing of personal data, authorized for dissemination, from among the special categories of personal data specified in Article 10.1 of the Personal Data Law, is allowed if the prohibitions and conditions provided for in Article 10.1 of the Personal Data Law are observed.
5.10. The User's consent to the processing of personal data authorized for dissemination is executed separately from other consents to the processing of his/her personal data. In this case, the conditions stipulated, in particular, in Article 10.1 of the Law on Personal Data shall be observed. The requirements for the content of such consent shall be established by the authorized body for the protection of the rights of personal data subjects.
5.10.1 The User provides the Operator directly with the consent to the processing of personal data authorized for dissemination.
5.10.2 The Operator is obliged to publish information about the conditions of processing, prohibitions and conditions for processing of personal data authorized for dissemination by an unlimited number of persons within three working days from the moment of receiving the said consent of the User.
5.10.3 The transfer (dissemination, provision, access) of personal data authorized by the subject of personal data for dissemination shall be terminated at any time at the request of the subject of personal data. This request shall include the surname, first name, patronymic (if any), contact information (telephone number, e-mail address or postal address) of the personal data subject, as well as a list of personal data whose processing is subject to termination. The personal data specified in this request may be processed only by the Operator to whom it is sent.
5.10.4 Consent to the processing of personal data authorized for dissemination terminates upon receipt by the Operator of the request specified in clause 5.10.3 of this Policy on Personal Data Processing.

6. Principles of personal data processing

6.1 The processing of personal data shall be carried out on a lawful and fair basis.
6.2. Processing of personal data is limited to the achievement of specific, predetermined and legitimate purposes. Processing of personal data incompatible with the purposes of personal data collection is not allowed.
6.3. It is not allowed to merge databases containing personal data processed for incompatible purposes.
6.4. Only personal data that meet the purposes of their processing shall be processed.
6.5. The content and scope of processed personal data correspond to the stated purposes of processing. The redundancy of the processed personal data in relation to the stated purposes of their processing is not permitted.
6.6. When processing personal data, the accuracy of personal data, their sufficiency and, where necessary, relevance in relation to the purposes of personal data processing shall be ensured. The Operator shall take the necessary measures and/or ensure that they are taken to delete or clarify incomplete or inaccurate data.
6.7. Personal data shall be stored in a form that allows identification of the subject of personal data for no longer than required by the purposes of personal data processing, unless the period of personal data storage is established by federal law, a contract to which the subject of personal data is a party, beneficiary or guarantor. Processed personal data shall be destroyed or depersonalized upon achievement of the purposes of processing or in case of loss of necessity to achieve these purposes, unless otherwise provided for by federal law.

7. Purposes of personal data processing

7.1 The purpose of processing the User's personal data:
- informing the User by sending e-mails;
- providing the User with access to services, information and/or materials contained on the website https://gettsleep.com.
7.2. Also, the Operator has the right to send the User notifications about new products and services, special offers and various events. The User can always refuse to receive information messages by sending a letter to the Operator to the e-mail address privacy@gettsleep.com with the note "Refusal of notifications about new products and services and special offers".
7.3. The anonymized User data collected through Internet statistics services are used to collect information about User actions on the website, to improve the quality of the website and its content.

8. Legal basis for personal data processing

8.1 The legal grounds for personal data processing by the Operator are: - Operator's statutory (founding) documents;
- contracts concluded between the Operator and the subject of personal data;
- Federal Law No. 152-FZ "On Personal Data" dated 27.07.2006;
- federal laws, other legal acts in the field of personal data protection;
- Users' consent to the processing of their personal data, to the processing of personal data authorized for dissemination.
8.2. The Operator processes the User's personal data only if it is filled in and/or sent by the User through special forms located on https://gettsleep.com or sent to the Operator by e-mail. By filling in the relevant forms and/or sending his/her personal data to the Operator, the User expresses his/her consent to this Policy.
8.3. The Operator processes anonymized data about the User if it is allowed in the User's browser settings (cookies and JavaScript technology enabled).
8.4. The subject of personal data independently decides on the provision of his/her personal data and gives consent freely, of his/her own free will and in his/her own interest.

9. Conditions of personal data processing

9.1 Processing of personal data shall be carried out with the consent of the personal data subject to the processing of his/her personal data.
9.2. Processing of personal data is necessary to achieve the purposes stipulated by the international treaty of the Russian Federation or law, to fulfill the functions, powers and duties assigned to the operator by the legislation of the Russian Federation.
9.3. Processing of personal data is necessary for the administration of justice, execution of a judicial act, act of another body or official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
9.4. The processing of personal data is necessary for the execution of an agreement to which the personal data subject is a party or a beneficiary or guarantor, as well as for the conclusion of an agreement at the initiative of the personal data subject or an agreement under which the personal data subject will be a beneficiary or guarantor.
9.5. The processing of personal data is necessary for the exercise of the rights and legitimate interests of the operator or third parties or for the achievement of socially important purposes, provided that the rights and freedoms of the personal data subject are not violated.
9.6. Processing of personal data is carried out where access to which is granted to an unlimited number of persons by the subject of personal data or at his/her request (hereinafter - publicly available personal data).
9.7. Processing of personal data subject to publication or mandatory disclosure in accordance with federal law.

10. Procedure for collection, storage, transfer and other types of personal data processing

The security of personal data processed by the Operator is ensured by implementing legal, organizational and technical measures necessary for full compliance with the requirements of the current legislation in the field of personal data protection.
10.1 The Operator ensures the safety of personal data and takes all possible measures to exclude access to personal data by unauthorized persons.
10.2 The User's personal data will never, under no circumstances, be transferred to third parties, except in cases related to the execution of the current legislation or if the subject of personal data has given his/her consent to the Operator to transfer the data to a third party for the fulfillment of obligations under a civil law contract.
10.3 If any inaccuracies are detected in the personal data, the User may update them independently by sending a notice to the Operator to the Operator's e-mail address privacy@gettsleep.com with the remark "Personal Data Update".
10.4 The term of personal data processing is determined by the achievement of the purposes for which the personal data were collected, unless another term is stipulated by the contract or applicable law. The User may withdraw his/her consent to the processing of personal data at any time by sending a notice to the Operator by e-mail to the Operator's e-mail address privacy@gettsleep.com, marked "Withdrawal of consent to the processing of personal data".
10.5 All information that is collected by third-party services, including payment systems, means of communication and other service providers, is stored and processed by these persons (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data and/or User is obliged to familiarize himself/herself with the said documents in a timely manner. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.
10.6 The prohibitions established by the personal data subject on the transfer (except for granting access), as well as on the processing or conditions of processing (except for access) of personal data authorized for dissemination shall not apply in cases of processing personal data in the state, public and other public interests defined by the legislation of the Russian Federation.
10.7 The Operator shall ensure confidentiality of personal data when processing personal data.
10.8. The Operator shall store personal data in a form that allows to identify the subject of personal data for no longer than required for the purposes of personal data processing, unless the period of personal data storage is established by federal law, an agreement to which the subject of personal data is a party, beneficiary or guarantor.
10.9 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 or withdrawal of consent by the personal data subject, as well as detection of unlawful processing of personal data.

11. List of actions performed by the Operator with the received personal data

11.1 The Operator shall collect, record, systematize, accumulate, store, clarify (update, change), extract, use, transfer (disseminate, provide, access), depersonalize, block, delete and destroy personal data.
11.2 The Operator performs automated processing of personal data with or without receiving and/or transmitting the received information via information and telecommunication networks.

12. Cross-border transfer of personal data

12.1 Before commencing the trans-border transfer of personal data, the Operator is obliged to ensure that the foreign state, to the territory of which the transfer of personal data is supposed to be carried out, provides reliable protection of the rights of personal data subjects.
12.2 Trans-border transfer of personal data to the territory of foreign states, which do not meet the above requirements, may be carried out only in case of written consent of the personal data subject to the trans-border transfer of his/her personal data and/or fulfillment of the agreement to which the personal data subject is a party.

13. Confidentiality of personal data

The operator and other persons who have access to personal data are obliged not to disclose to third parties and not to disseminate personal data without the consent of the subject of personal data, unless otherwise provided for by federal law.

14. Final provisions

14.1. The User may obtain any clarifications on issues of interest regarding the processing of his/her personal data by contacting the Operator via e-mail at privacy@gettsleep.com.
14.2. This document will reflect any changes in the policy of personal data processing by the Operator. The Policy is valid indefinitely until it is replaced by a new version.
14.3. The current version of the Policy is freely available on the Internet at https://gettsleep.com/privacy.