POLICY ON THE PROCESSING OF PERSONAL DATA

1. General Provisions
This Policy on the Processing of Personal Data is prepared in accordance with the requirements of Federal Law No. 152-FZ dated 27.07.2006, "On Personal Data" (hereinafter, the Personal Data Law). It defines the procedure for processing personal data and measures to ensure the security of personal data undertaken by Anastasia Evgenievna Saakyan (hereinafter, the Operator).
1.1. The Operator sets as its most important goal and condition for implementing its activities the observance of the rights and freedoms of a person and citizen in the processing of his personal data, including the protection of the rights to inviolability of private life and personal and family privacy.
1.2. This Operator's Policy regarding processing personal data (from now on - the Policy) applies to all information that the Operator may obtain about visitors to the website https://kodidesign.com.

2. Basic Concepts Used in the Policy
2.1. Automated processing of personal data - processing of personal data using computer technology.
2.2. Blocking personal data - temporary suspension of processing of personal data (except for cases where processing is necessary to clarify personal data).
2.3. Website - a set of graphic and informational materials, computer programs, and databases that ensure their availability on the Internet at the network address https://kodidesign.com.
2.4. An information system of personal data is a set of personal data contained in databases and information technologies and technical means that ensure their processing.
2.5. Anonymization of personal data—actions that make it impossible to determine, without using additional information, the ownership of personal data to a specific User or another subject of personal data.
2.6. Processing of personal data—any action (operation) or a set of actions (operations) performed with the use of automation tools or without the use of such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking deletion, or destruction of personal data.
2.7. Operator - a state body, municipal body, legal entity, or individual, independently or jointly with other persons organizing and (or) carrying out the processing of personal data, as well as determining the purposes of processing personal data, the composition of personal data to be processed, 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://kodidesign.com.
2.9. Personal data permitted by the subject of personal data for distribution - personal data, access of an unlimited number of persons to which is provided by the subject of personal data by giving Consent to the processing of personal data permitted by the subject of personal data for distribution in the manner prescribed by the Personal Data Law (from now on - personal data permitted for distribution).
2.10. User - any visitor to the website https://kodidesign.com.
2.11. Provision of personal data - actions aimed at disclosing personal data to a specific person or a certain circle of persons.
2.12. Distribution of personal data - any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or at familiarizing an unlimited number of persons with personal data, including disclosure of personal data in the media, placement in information and telecommunications 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 the authority of a foreign state, a foreign individual, or a foreign legal entity.
2.14. Destruction of personal data - any actions resulting from which personal data are destroyed irretrievably with the impossibility of further restoring the content of personal data in the personal data information system and (or) destroyed material carriers of personal data.

3. Basic Rights and Obligations of the Operator
3.1. The Operator has the right:
- to receive from the subject of personal data reliable information and/or documents containing personal data;
- to continue processing personal data without the Consent of the subject of personal data 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 provided for by the Personal Data Law and adopted by its normative legal acts, unless otherwise provided by the Personal Data Law or other federal laws.
3.2. The Operator is obliged:
- to provide the subject of personal data, upon his request, with information concerning the processing of his data;
- to organize the processing of personal data by the procedure established by the current legislation of the Russian Federation;
- to respond to requests and inquiries of subjects of personal data and their legal representatives by the requirements of the Personal Data Law;
- to inform the authorized body for the protection of the rights of subjects of personal data, upon request of this body, the necessary information within 30 days from the date of receipt of such a request;
- to publish or otherwise provide unrestricted access to this Policy regarding the processing of personal data;
- to take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access to them, destruction, modification, blocking, copying, provision, dissemination of personal data, as well as from other illegal actions about personal data;
- to terminate the transfer (distribution, provision, access) of personal data, to terminate the processing and to destroy personal data in the order and cases provided for by the Personal Data Law;
- to fulfill other obligations provided for by the Personal Data Law.

4. Basic Rights and Obligations of Subjects of Personal Data
4.1. Subjects of personal data have the right:
- to receive information concerning processing his personal data, except for cases provided for by federal laws. The Operator offers the information to the subject of personal data in an accessible form, and it should not contain personal data related to other subjects of personal data unless there are legal grounds for disclosing such personal data. The Personal Data Law establishes the list of information and the procedure for obtaining it;
- to require the Operator to clarify his data, their blocking or destruction if the personal data are incomplete, outdated, inaccurate, illegally obtained, or not necessary for the stated purpose of processing, as well as to take legally prescribed measures to protect his rights;
- to put forward the condition of prior Consent when processing personal data to promote goods, works, and services on the market;
- to withdraw Consent to the processing of personal data;
- to appeal to the authorized body for the protection of the rights of subjects of personal data or, in a judicial procedure, the illegal actions or inaction of the Operator in the processing of his data;
- to exercise other rights provided by the legislation of the Russian Federation.
4.2. Subjects of personal data are obliged:
- to provide the Operator with reliable data about themselves;
- to inform the Operator about clarifying (updating, changing) their personal data.
4.3. Persons who have transferred to the Operator unreliable information about themselves or information about another subject of personal data without the latter's Consent shall bear responsibility by the legislation of Georgia.

5. The Operator may process the following personal data of the User
5.1. Last name, first name, patronymic.
5.2. Phone numbers.
5.3. The website also collects and processes anonymized data about visitors (including cookies) using internet statistics services (Yandex Metrica, Google Analytics, and others).
5.4. The above data, which are incorporated hereinafter into the Policy, are united by the general concept of Personal data.
5.5. The Operator does not process special categories of personal data concerning racial, national origin, political views, religious or philosophical beliefs, and private life.
5.6. The processing of personal data permitted for distribution among special categories of personal data specified in Part 1 of Article 10 of the Personal Data Law is allowed if the prohibitions and conditions stipulated by Article 10.1 of the Personal Data Law are observed.
5.7. The User's Consent to the processing of personal data permitted for distribution is drawn up separately from other consents for processing his personal data. The conditions for compliance are, in particular, Article 10.1 of the Personal Data Law. The requirements for the content of such Consent are established by the authorized body for the protection of the rights of personal data subjects.
5.7.1 Consent to processing personal data permitted for distribution, the User provides directly to the Operator.
5.7.2 The Operator is obliged, no later than three working days from the date of receipt of the User's Consent specified, to publish information about the conditions of processing, about the presence of prohibitions and conditions for the processing of an unlimited number of persons personal data permitted for distribution.
5.7.3 The transfer (distribution, provision, access) of personal data permitted by the subject of personal data for distribution must be terminated at any time at the request of the subject of personal data. This requirement must include the last name, first name, patronymic (if any), contact information (phone number, email address, or postal address) of the subject of personal data, as well as a list of personal data, the processing of which must be terminated. The personal data specified in this requirement may be processed only by the Operator to whom it is directed.
5.7.4 The Consent to the processing of personal data permitted for distribution ceases to have effect from the moment the Operator receives the request specified in paragraph 5.7.3 of this Policy regarding the processing of personal data.

6. Principles of Personal Data Processing
6.1. The processing of personal data is carried out on a lawful and fair basis.
6.2. The processing of personal data is limited to achieving specific, predetermined, and lawful purposes. It is not permitted to process personal data incompatible with the collection of individual data.
6.3. The merging of databases containing personal data, the processing of which is carried out for incompatible purposes, is not permitted.
6.4. Only personal data that meet the purposes of their processing are subject to processing.
6.5. The content and volume of processed personal data correspond to the stated purposes of processing. The processing of personal data over the stated purposes of their processing is not permitted.
6.6. When processing personal data, the Operator ensures their accuracy, sufficiency, and, where necessary, relevance to the purposes of processing personal data. The Operator takes necessary measures and/or ensures their adoption to delete or clarify incomplete or inaccurate data.
6.7. The storage of personal data is carried out in a form that allows determining the subject of personal data, no longer than required by the purposes of processing personal data if the storage period for personal data is not established by federal law, contract, the party to which, the beneficiary or guarantor of which is the subject of personal data. The processed personal data are destroyed or anonymized upon achievement of the processing purposes or in case of loss or the need to achieve these purposes unless otherwise provided by federal law.

7. Purposes of Personal Data Processing
7.1. The purpose of processing the User's data:
- clarification of order details.
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 can always refuse to receive informational messages by sending a letter to the Operator's email address info@kodidesign.ru with the note "Refusal to receive notifications about new products and services and special offers".
7.3. Anonymized User data collected using internet statistics services is used to collect information about User's actions on the website and improve the quality of the website and its content.

8. Legal Basis for Personal Data Processing
8.1. The legal basis for the processing of personal data by the Operator is:
- Federal Law "On Information, Information Technologies, and Protection of Information" dated 27.06.2006 N 149-FZ;
- federal laws and other normative legal acts in the field of personal data protection;
- consents of Users to the processing of their data, to the processing of personal data permitted for distribution.
8.2. The Operator processes the User's data only if they are filled in and/or sent by the User independently through particular forms located on the website https://kodidesign.com or sent to the Operator via email. Filling in the relevant forms and/or sending your personal data to the Operator, the User expresses his Consent to this Policy.
8.3. The Operator processes anonymized data about the User if it is allowed in the settings of the User's browser (e.g., enabling the saving of "cookies" and the use of JavaScript technology).
8.4. The subject of personal data independently decides on providing his personal data and gives Consent freely, in his interest, and voluntarily.

9. Conditions for Personal Data Processing
9.1. Personal data processing is carried out with Consent from the subject of personal data to process his personal data.
9.2. Personal data processing is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or the law to fulfill the functions, powers, and duties assigned by the legislation of the Russian Federation to the Operator.
9.3. Personal data processing is necessary to carry out justice, to execute a court decision, or to execute another body's or official's act, subject to execution in accordance with Georgia legislation on enforcement proceedings.
9.4. Personal data processing is necessary to fulfill the contract, the party to which, the beneficiary or guarantor of which is the subject of personal data, as well as to conclude an agreement on the initiative of the subject of personal data or a contract under which the subject of personal data will be the 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 that the rights and freedoms of the subject of personal data are not violated.
9.6. Personal data is processed, and access to an unlimited number of persons is provided by the subject of personal data or at his request (hereinafter—publicly available personal data).
9.7. Personal data processing is carried out subject to publication or mandatory disclosure by national law.

10. Order of Collection, Storage, Transfer, and Other Types of Personal Data Processing Security of personal data processed by the Operator is ensured by implementing legal, organizational, and technical measures necessary to fully comply 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 prevent unauthorized access to personal data.
10.2. The User's data will never, under any 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 the Operator consent to transfer data to a third party to fulfill obligations under a civil law contract.
10.3. If personal data inaccuracies are identified, the User can update them independently by sending a notification to the Operator's email address info@kodidesign.ru with the note "Update of personal data."
10.4. The processing period of personal data is determined by achieving the purposes for which personal data were collected, unless the contract or the current legislation provides another period.
The User can withdraw his Consent to the processing of personal data at any time by emailing the Operator at info@kodidesign.ru with the note "Withdrawal of consent to the processing of personal data."
10.5. All information collected by third-party services, including payment systems, communication means, and other service providers, is stored and processed by these persons (Operators) by their User Agreement and Privacy Policy. The subject of personal data and/or the User must independently and timely familiarize themselves with these documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this paragraph.
10.6. The established subject of personal data prohibitions on transfer (except for providing access), as well as on processing or conditions for processing (except for obtaining access) personal data permitted for distribution, do not apply in cases of processing personal data in state, public, and other public interests defined by the legislation of the Russian Federation.
10.7. The Operator ensures the confidentiality of personal data during their processing.
10.8. The Operator stores personal data in a form that allows determining the subject of personal data no longer than required by the purposes of processing personal data, unless the storage period for personal data is established by federal law or contract, the party to which, the beneficiary or guarantor of which is the subject of personal data.
10.9. The condition for the termination of personal data processing may be the achievement of the purposes of personal data processing, the expiration of the consent term of the subject of personal data, or the withdrawal of Consent by the subject of personal data, as well as the detection of illegal processing of personal data.

11. List of Actions Performed by the Operator with the Received Personal Data
11.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), extracts, uses, transfers (distribution, provision, access), anonymizes, blocks, deletes, and destroys personal data.
11.2. The Operator carries out automated processing of personal data with the receipt and/or transmission of the received information through information and telecommunications networks or without such.

12. Cross-Border Transfer of Personal Data
12.1. The Operator must ensure that the foreign state, to the territory of which it is intended to transfer personal data, provides reliable protection of the rights of subjects of personal data before the start of such transfer.
12.2. Cross-border transfer of personal data on the territory of foreign states that do not meet the above requirements may be carried out only if there is a written consent of the subject of personal data to the cross-border transfer of his personal data and/or execution of the contract, the party to which is the subject of personal data.

13. Confidentiality of Personal Data
The Operator and other persons who have gained access to personal data are obliged not to disclose to third parties or distribute personal data without the Consent of personal data subject, unless otherwise provided by federal law.

14. Final Provisions
14.1. The User can obtain any clarifications on issues of interest regarding the processing of his personal data by contacting the Operator via email info@k