Personal Data Processing Policy

1. General Provisions
This personal data processing policy is prepared in accordance with the requirements of Federal Law No. 152-FZ dated July 27, 2006 "On Personal Data" (hereinafter referred to as the Personal Data Law) and defines the procedure for processing personal data and measures to ensure the security of personal data taken by [Full Name] (hereinafter referred to as the Operator).
1.1. The Operator considers the observance of human and civil rights and freedoms in the processing of personal data, including the protection of the right to privacy, personal and family secrets, to be one of its most important goals and conditions for carrying out its activities.
1.2. This Policy of the Operator regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator may receive about visitors to the website babushka.ae.
2. Key Terms Used in the Policy
2.1. Automated processing of personal data — processing of personal data using computer technology.
2.2. Blocking of personal data — temporary suspension of the processing of personal data (except in cases where processing is necessary to clarify personal data).
2.3. Website — a collection of graphic and informational materials, as well as software and databases, which make them available on the Internet at https://babushka.ae.
2.4. Personal data information system — a set of personal data contained in databases and the information technologies and technical means that ensure their processing.
2.5. Depersonalization of personal data — actions that make it impossible to determine, without using additional information, whether personal data belong to a specific User or another data subject.
2.6. Processing of personal data — any action (operation) or a set of actions (operations) performed with or without the use of automation tools involving personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
2.7. Operator — a state body, municipal body, legal or natural person who, independently or jointly with others, organizes and/or carries out the processing of personal data, and determines the purposes of processing personal data, the scope of personal data to be processed, and the actions (operations) performed with the personal data.
2.8. Personal data — any information relating directly or indirectly to an identified or identifiable User of the website https://babushka.ae.
2.9. Personal data made publicly available by the data subject — personal data to which the data subject has granted access to an unlimited number of people by consenting to the processing of personal data for distribution, in accordance with the Personal Data Law (hereinafter referred to as publicly available personal data).
2.10. User — any visitor of the website https://babushka.ae.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Dissemination of personal data — any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or at making personal data available to an unlimited number of persons, including publication in mass media, placement in information and telecommunication networks, or otherwise providing access to personal data.
2.13. Cross-border transfer of personal data — the transfer of personal data to the territory of a foreign state, to a foreign governmental authority, a foreign individual, or a foreign legal entity.
2.14. Destruction of personal data — any actions that result in the irreversible destruction of personal data, making it impossible to restore the contents of personal data in the personal data information system and/or resulting in the destruction of physical carriers of personal data.
3. Main Rights and Obligations of the Operator
3.1. The Operator has the right to:

receive from the personal data subject accurate information and/or documents containing personal data;
continue processing personal data without the consent of the data subject in the event that the data subject withdraws their consent to the processing of personal data or submits a request to stop processing, provided there are grounds as specified in the Personal Data Law;
independently determine the composition and list of measures necessary and sufficient to ensure fulfillment of the obligations provided by the Personal Data Law and other applicable regulatory legal acts, unless otherwise stipulated by the Personal Data Law or other federal laws.

3.2. The Operator is obliged to:

provide the personal data subject, upon request, with information regarding the processing of their personal data;
organize the processing of personal data in accordance with the procedures established by current legislation of the Russian Federation;
respond to inquiries and requests from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
provide the authorized body for the protection of the rights of personal data subjects, upon request, with the required information within 10 days from the date of receipt of such request;
publish or otherwise ensure unrestricted access to this Personal Data Processing Policy;
take 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;
cease the transfer (dissemination, provision, access) of personal data, stop processing, and destroy personal data in the manner and in the cases stipulated by the Personal Data Law;
fulfill other obligations as required by the Personal Data Law.

4. Main Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects have the right to:

receive information regarding the processing of their personal data, except in cases provided for by federal laws. The information shall be provided by the Operator in an accessible form and must not contain personal data relating to other personal data subjects, unless there are lawful grounds for disclosing such data. The list of such information and the procedure for its provision are established by the Personal Data Law;
demand that the Operator clarify, block, or delete their personal data if the data is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, as well as to take other actions provided by law to protect their rights;
impose a condition of prior consent for the processing of their personal data for the purposes of promoting goods, works, and services in the market;
withdraw their consent to the processing of personal data and request the termination of personal data processing;
appeal to the authorized body for the protection of the rights of personal data subjects or to a court if the Operator performs unlawful actions or omissions in relation to the processing of their personal data;
exercise other rights provided by the legislation of the Russian Federation.

4.2. Personal data subjects are obliged to:

provide the Operator with accurate information about themselves;
inform the Operator of any clarification (update, change) of their personal data.

**4.3. Persons who provide the Operator with inaccurate information about themselves or with information about another personal data subject without that subject’s consent are liable in accordance with the legislation of the Russian Federation.
5. Principles of Personal Data Processing
5.1. The processing of personal data is carried out on a lawful and fair basis.
5.2. The processing of personal data is limited to achieving specific, predetermined, and lawful purposes. Processing of personal data that is incompatible with the purposes of data collection is not allowed.
5.3. The merging of databases containing personal data, the processing of which is carried out for purposes that are incompatible with each other, is not permitted.
5.4. Only personal data that corresponds to the purposes of its processing shall be subject to processing.
5.5. The content and scope of the processed personal data must correspond to the stated purposes of processing. The processing of excessive personal data in relation to the stated purposes is not permitted.
5.6. Accuracy, sufficiency, and, where necessary, relevance of personal data with respect to the purposes of processing shall be ensured. The Operator shall take the necessary measures and/or ensure their implementation to delete or clarify incomplete or inaccurate data.
5.7. Personal data shall be stored in a form that allows identification of the data subject for no longer than required by the purposes of the processing, unless a longer storage period is established by federal law or an agreement to which the data subject is a party, beneficiary, or guarantor. Processed personal data shall be destroyed or anonymized upon achievement of the processing purposes or when the need to achieve these purposes no longer exists, unless otherwise provided by federal law.
6. Purpose of Personal Data Processing
Purpose of processing: informing the User via phone calls.
Personal data involved: Name, Phone number.
Legal basis: Federal Law "On Information, Information Technologies and Information Protection" dated July 27, 2006, No. 149-FZ.
Types of personal data processing: Transfer of personal data.
7. Conditions for Personal Data Processing
7.1. Personal data is processed with the consent of the personal data subject to the processing of their personal data.
7.2. The processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, or to fulfill the functions, powers, and duties imposed on the Operator by the legislation of the Russian Federation.
7.3. The processing of personal data is necessary for the administration of justice, enforcement of a judicial act, or an act of another authority or official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. The processing of personal data is necessary for the performance of a contract to which the personal data subject is a party, beneficiary, or guarantor, as well as for the conclusion of a contract at the initiative of the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor.
7.5. The processing of personal data is necessary to exercise the rights and legitimate interests of the Operator or third parties or to achieve socially significant goals, provided that the rights and freedoms of the personal data subject are not thereby violated.
7.6. Processing is carried out for personal data to which the subject has granted access to an unlimited number of persons or upon their request (hereinafter — publicly available personal data).
7.7. Processing is carried out for personal data that is subject to publication or mandatory disclosure under federal law.
8. Procedure for Collection, Storage, Transfer, and Other Forms of Personal Data Processing
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 legislation in the field of personal data protection.
8.1. The Operator ensures the security of personal data and takes all possible measures to prevent unauthorized access to personal data.
8.2. The User’s personal data shall never, under any circumstances, be transferred to third parties, except in cases related to compliance with applicable legislation or when the personal data subject has given the Operator consent to transfer data to a third party for the performance of obligations under a civil law contract.
8.3. If inaccuracies are found in personal data, the User may update the data independently by sending a notification to the Operator at the email address: hr@babushka.ae with the subject line "Update of Personal Data."
8.4. The period of personal data processing is determined by the achievement of the purposes for which the personal data was collected, unless a different period is established by contract or applicable law.
The User may withdraw their consent to personal data processing at any time by sending a notification to the Operator via email to hr@babushka.ae with the subject line "Withdrawal of Consent to Personal Data Processing."
8.5. All information collected by third-party services, including payment systems, communication providers, and other service providers, is stored and processed by those entities (Operators) in accordance with their User Agreements and Privacy Policies. The personal data subject is responsible for familiarizing themselves with such documents. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this clause.
8.6. Any restrictions set by the personal data subject on the transfer (except granting access), as well as on the processing or conditions of processing (except access) of personal data permitted for dissemination, do not apply when the personal data is processed in the interests of the state, society, or other public interests as defined by Russian law.
8.7. When processing personal data, the Operator ensures the confidentiality of the data.
8.8. The Operator stores personal data in a format that allows identification of the personal data subject for no longer than is necessary to achieve the purposes of personal data processing, unless a longer storage period is required by federal law, a contract, or where the personal data subject is a party, beneficiary, or guarantor.
8.9. The processing of personal data may be terminated upon the achievement of the purpose of processing, the expiration of the subject’s consent, withdrawal of consent by the subject, a request to cease processing, or upon identification of unlawful processing of personal data.
9. List of Actions Performed by the Operator with Collected Personal Data
9.1. The Operator carries out the collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
9.2. The Operator performs automated processing of personal data with or without the transmission and/or receipt of the obtained information through information and telecommunication networks.
10. Cross-Border Transfer of Personal Data
10.1. Before beginning any cross-border transfer of personal data, the Operator is required to notify the authorized body for the protection of personal data subjects' rights of its intention to perform such transfers (this notification is submitted separately from the general notification of intent to process personal data).
10.2. Prior to submitting the above-mentioned notification, the Operator must obtain relevant information from the foreign government authorities, foreign individuals, or foreign legal entities to whom the personal data will be transferred.
11. Confidentiality of Personal Data
The Operator and other individuals who have access to personal data are obligated not to disclose such data to third parties or distribute it without the consent of the personal data subject, unless otherwise stipulated by federal law.
12. Final Provisions
12.1. The User may contact the Operator for any clarification regarding the processing of their personal data via email at: hr@babushka.ae.
12.2. Any changes to the Operator’s personal data processing policy will be reflected in this document. The Policy remains in effect indefinitely until replaced by a new version.
12.3. The current version of the Policy is publicly available online at: https://babushka.ae/privacy/