This personal data processing policy is drawn up in accordance with Federal Law No. 152-FZ of 27.07.2006 "On Personal Data" (the "Personal Data Law") and defines the procedure for processing personal data and the measures taken to ensure its security by [operator's legal name and details] (the "Operator").
1.1. The Operator's most important goal and condition for carrying out its activities is observing the rights and freedoms of individuals when processing their personal data, including protecting the right to privacy, personal and family secrets.
1.2. This policy on the processing of personal data (the "Policy") applies to all information the Operator may obtain about visitors of the website sublima.ru.
3.1. The Operator has the right to:
3.2. The Operator is obliged to:
4.1. Subjects of personal data have the right to:
4.2. Subjects of personal data are obliged to:
4.3. Persons who have provided the Operator with false information about themselves, or information about another subject of personal data without the latter's consent, bear liability in accordance with Russian law.
5.1. Last name and first name.
5.2. Phone number.
5.3. Email address.
5.4. Delivery address (city, street, house, apartment) — when arranging delivery.
5.5. Comments and wishes regarding the order, if specified by the User.
5.6. The website also collects and processes de-personalized visitor data (including "cookie" files) using web analytics services (Yandex.Metrica, Google Analytics and others).
5.7. Payment details (card details, etc.) are not transferred to or stored by the Operator — they are processed directly by the partner payment system in accordance with its own privacy policy.
5.8. The data listed above are jointly referred to in this Policy as Personal Data.
5.9. The Operator does not process special categories of personal data relating to race, ethnicity, political views, religious or philosophical beliefs, or private life.
5.10. Processing of personal data permitted for distribution, among the special categories referred to in Part 1, Art. 10 of the Personal Data Law, is allowed provided the prohibitions and conditions set out in Art. 10.1 of the Personal Data Law are observed.
5.11. The User's consent to the processing of personal data permitted for distribution is issued separately from other consents to the processing of their personal data.
5.11.1. Consent to the processing of personal data permitted for distribution is provided by the User to the Operator directly.
5.11.2. The Operator is obliged, within no more than three business days from receiving such consent, to publish information on the terms of processing and on any prohibitions and conditions applicable to processing by an unlimited group of persons of personal data permitted for distribution.
5.11.3. The transfer (distribution, provision, access) of personal data permitted by the subject for distribution must be stopped at any time at the subject's request.
5.11.4. Consent to the processing of personal data permitted for distribution ceases to be effective from the moment the Operator receives the request referred to in clause 5.11.3 of this Policy.
6.1. Personal data is processed on a lawful and fair basis.
6.2. Personal data processing is limited to achieving specific, predetermined and legitimate purposes. Processing incompatible with the purposes of data collection is not permitted.
6.3. Combining databases containing personal data processed for incompatible purposes is not permitted.
6.4. Only personal data that meets the purposes of its processing is subject to processing.
6.5. The content and scope of the personal data processed correspond to the stated purposes of processing. Excessive processing of personal data is not permitted.
6.6. When processing personal data, its accuracy and sufficiency are ensured, and where necessary its relevance to the purposes of processing.
6.7. Personal data is stored in a form that allows the subject of personal data to be identified for no longer than required by the purposes of processing. Processed personal data is destroyed or de-personalized once the purposes of processing have been achieved.
7.1. The purpose of processing the User's personal data:
7.2. The Operator also has the right to send the User notifications about new products and services, special offers and various events. The User may always opt out of receiving such messages by sending the Operator an email to [Sublima contact email] marked "Unsubscribe from notifications".
7.3. De-personalized User data collected through web analytics services serves to gather information about User actions on the website and to improve the quality of the website and its content.
8.1. The legal grounds for the Operator's processing of personal data are:
8.2. The Operator processes the User's personal data only when it has been entered and/or submitted by the User themselves through special forms on the website, or sent to the Operator by email.
8.3. The Operator processes de-personalized data about the User where this is permitted by the User's browser settings (storage of "cookie" files and the use of JavaScript technology are enabled).
8.4. The subject of personal data independently decides whether to provide their personal data and gives consent freely, of their own will and in their own interest.
9.1. Personal data is processed with the consent of the subject of personal data to the processing of their personal data.
9.2. Personal data processing is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law.
9.3. Personal data processing is necessary for the administration of justice, the execution of a judicial act, or an act of another body or official.
9.4. Personal data processing is necessary for the performance of a contract to which the subject of personal data is a party, beneficiary, or guarantor.
9.5. Personal data processing is necessary to exercise the rights and legitimate interests of the operator or third parties, or to achieve socially significant purposes, provided the rights and freedoms of the subject of personal data are not violated.
9.6. Processing is carried out on personal data to which an unlimited group of persons has been granted access by the subject of personal data or at their request (publicly available personal data).
9.7. Processing is carried out on personal data subject to publication or mandatory disclosure in accordance with federal law.
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 applicable law in the field of personal data protection.
10.1. The Operator ensures the safety of personal data and takes all possible measures to prevent access to it by unauthorized persons.
10.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to compliance with applicable law, or where the subject of personal data has given the Operator consent to transfer data to a third party for the performance of obligations under a civil-law contract (including a delivery service — to hand over the order to the User).
10.3. If inaccuracies are found in personal data, the User may update it themselves by sending the Operator a notice at [Sublima contact email] marked "Personal data update".
10.4. The period of personal data processing is determined by achievement of the purposes for which the personal data was collected. The User may withdraw their consent to processing at any time by sending the Operator a notice by email at [Sublima contact email] marked "Withdrawal of consent to personal data processing".
10.5. All information collected by third-party services, including payment systems, communication tools and other service providers, is stored and processed by those parties (Operators) in accordance with their own User Agreement and Privacy Policy.
10.6. Prohibitions established by the subject of personal data on the transfer of personal data permitted for distribution do not apply where personal data is processed for state, public or other public interests.
10.7. The Operator ensures the confidentiality of personal data when processing it.
10.8. The Operator stores personal data in a form that allows the subject to be identified for no longer than required by the purposes of processing.
10.9. Processing of personal data may be terminated upon achievement of the purposes of processing, expiry of the subject's consent, withdrawal of consent by the subject, or the discovery of unlawful processing.
11.1. The Operator carries out collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), de-personalization, blocking, deletion and destruction of personal data.
11.2. The Operator carries out automated processing of personal data, with or without receiving and/or transmitting the information obtained via information and telecommunication networks.
12.1. Before commencing a cross-border transfer of personal data, the Operator must ensure that the foreign state to which the personal data is intended to be transferred provides reliable protection of the rights of personal data subjects.
12.2. Cross-border transfer of personal data to the territories of foreign states that do not meet the above requirements may only be carried out with the written consent of the subject of personal data to the cross-border transfer of their personal data, and/or for the performance of a contract to which the subject of personal data is a party.
The Operator and other persons who have gained access to personal data are obliged not to disclose it to third parties and not to distribute it without the consent of the subject of personal data, unless otherwise provided by federal law.
14.1. The User may obtain any clarification on questions concerning the processing of their personal data by contacting the Operator at [Sublima contact email].
14.2. 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.
14.3. The current version of the Policy is freely available on the internet at sublima.ru/politika-konfidentsialnosti.