Personal Data Processing Policy
1. General Provisions
This personal data processing policy has been prepared in accordance with the requirements of Federal Law No. 152-FZ dated 27.07.2006 “On Personal Data” (hereinafter referred to as the Personal Data Law) and determines the procedure for processing personal data and the measures taken to ensure the security of personal data by Pavel Vladimirovich Koreshkov (hereinafter referred to as the Operator).
1.1. The Operator considers the observance of human and civil rights and freedoms when processing personal data, including the protection of the rights to privacy, personal and family secrecy, to be its most important objective and condition for carrying out its activities.
1.2. This Operator’s policy 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 https://himalayangold.co/.
2. Key Terms Used in the Policy
2.1. Automated processing of personal data means the processing of personal data using computer technology.
2.2. Blocking of personal data means the temporary suspension of personal data processing, except in cases where processing is necessary to clarify personal data.
2.3. Website means 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://himalayangold.co/.
2.4. Personal data information system means 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 means actions as a result of which it becomes impossible, without using additional information, to determine whether personal data belongs to a specific User or another personal data subject.
2.6. Processing of personal data means any action (operation) or a set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
2.7. Operator means a state authority, municipal authority, legal entity, or individual that independently or jointly with other persons organizes and/or carries out the processing of personal data, and determines the purposes of personal data processing, the scope of personal data to be processed, and the actions (operations) performed with personal data.
2.8. Personal data means any information directly or indirectly related to an identified or identifiable User of the website https://himalayangold.co/.
2.9. Personal data permitted by the personal data subject for distribution means personal data to which access by an unlimited number of persons has been granted by the personal data subject by giving consent to the processing of personal data permitted by the personal data subject for distribution in the manner prescribed by the Personal Data Law (hereinafter referred to as personal data permitted for distribution).
2.10. User means any visitor to the website https://himalayangold.co/.
2.11. Provision of personal data means actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Distribution of personal data means any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or making personal data available to an unlimited number of persons, including the publication of personal data in the media, posting in information and telecommunications networks, or providing access to personal data in any other way.
2.13. Cross-border transfer of personal data means the transfer of personal data to the territory of a foreign state, to an authority of a foreign state, a foreign individual, or a foreign legal entity.
2.14. Destruction of personal data means any actions as a result of which personal data is irreversibly destroyed, making it impossible to further restore the content of personal data in a personal data information system, and/or as a result of which physical media containing personal data are destroyed.
3. Main Rights and Obligations of the Operator
3.1. The Operator has the right to:
— receive reliable information and/or documents containing personal data from the personal data subject;
— if the personal data subject withdraws consent to the processing of personal data, and also if the personal data subject submits a request to terminate the processing of personal data, the Operator has the right to continue processing personal data without the consent of the personal data subject if there are grounds specified in the Personal Data Law;
— 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 regulatory legal acts adopted in accordance with it, unless otherwise provided 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 concerning the processing of their personal data;
— organize the processing of personal data in the manner established by the current legislation of the Russian Federation;
— respond to requests and inquiries 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 of that body, with the necessary information within 10 days from the date of receipt of such request;
— publish or otherwise provide unrestricted access to this Policy regarding the processing of personal data;
— take legal, organizational, and technical measures to protect personal data against unlawful or accidental access, destruction, modification, blocking, copying, provision, distribution of personal data, as well as against other unlawful actions in relation to personal data;
— cease the transfer (distribution, provision, access) of personal data, cease processing, and destroy personal data in the manner and in the cases provided for by the Personal Data Law;
— fulfill other obligations provided for 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 concerning the processing of their personal data, except in cases provided for by federal laws. The information shall be provided to the personal data subject by the Operator in an accessible form and shall not contain personal data relating to other personal data subjects, except in cases where there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
— require the Operator to clarify their personal data, block it, or destroy it if the personal data is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, and to take measures provided by law to protect their rights;
— impose a condition of prior consent when personal data is processed for the purpose of promoting goods, works, and services on the market;
— withdraw consent to the processing of personal data, and also submit a request to terminate the processing of personal data;
— appeal to the authorized body for the protection of the rights of personal data subjects or in court against unlawful actions or omissions of the Operator when processing their personal data;
— exercise other rights provided for by the legislation of the Russian Federation.
4.2. Personal data subjects are obliged to:
— provide the Operator with reliable data about themselves;
— notify the Operator about the clarification (updating, modification) of their personal data.
4.3. Persons who have provided the Operator with unreliable information about themselves, or information about another personal data subject without the latter’s consent, shall be liable in accordance with the legislation of the Russian Federation.
5. Principles of Personal Data Processing
5.1. Personal data shall be processed on a lawful and fair basis.
5.2. Personal data processing shall be limited to the achievement of specific, predetermined, and lawful purposes. Processing of personal data that is incompatible with the purposes of personal data collection is not permitted.
5.3. It is not permitted to combine databases containing personal data where such data is processed for purposes incompatible with each other.
5.4. Only personal data that corresponds to the purposes of its processing shall be processed.
5.5. The content and scope of the processed personal data shall correspond to the stated purposes of processing. Excessive processing of personal data in relation to the stated purposes of its processing is not permitted.
5.6. When processing personal data, the accuracy of personal data, its sufficiency, and, where necessary, its relevance in relation to the purposes of personal data processing shall be ensured. The Operator shall take the necessary measures and/or ensure that such measures are taken to delete or clarify incomplete or inaccurate data.
5.7. Personal data shall be stored in a form that allows the personal data subject to be identified for no longer than required by the purposes of personal data processing, unless the storage period for personal data is established by federal law or by an agreement to which the personal data subject is a party, beneficiary, or guarantor. Processed personal data shall be destroyed or depersonalized upon achievement of the processing purposes or if the need to achieve these purposes is lost, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing
Purpose of processing informing the User by sending emails
Personal data
surname, name, patronymic
email address
phone numbers
Legal grounds
charter (constituent) documents of the Operator
Types of personal data processing
Collection, recording, systematization, accumulation, storage, destruction, and depersonalization 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. Personal data processing is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, and to exercise the functions, powers, and duties imposed on the Operator by the legislation of the Russian Federation.
7.3. Personal data processing is necessary for the administration of justice, execution of a judicial act, act of another body, or official that is subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. Personal data processing is necessary for the performance of an agreement to which the personal data subject is a party, beneficiary, or guarantor, as well as for concluding 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.
7.5. Personal data processing is necessary for the exercise of 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 personal data subject are not violated.
7.6. Personal data is processed where access by an unlimited number of persons has been granted by the personal data subject or at their request (hereinafter referred to as publicly available personal data).
7.7. Personal data subject to publication or mandatory disclosure in accordance with federal law is processed.
8. Procedure for Collection, Storage, Transfer, and Other Types 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 current legislation in the field of personal data protection.
8.1. The Operator ensures the safety of personal data and takes all possible measures to prevent unauthorized persons from accessing 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 current legislation or where 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 agreement.
8.3. If inaccuracies in personal data are identified, the User may update them independently by sending a notification to the Operator’s email address cco@himalayangold.co marked “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 another period is provided for by an agreement or current legislation.
The User may withdraw their consent to the processing of personal data at any time by sending the Operator a notification by email to the Operator’s email address cco@himalayangold.co marked “Withdrawal of consent to the processing of personal data”.
8.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by such persons (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject and/or with the specified documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.
8.6. Prohibitions established by the personal data subject on transfer (except for providing access), as well as on processing or the conditions of processing (except for obtaining access) of personal data permitted for distribution, do not apply in cases of personal data processing in state, public, and other public interests determined by the legislation of the Russian Federation.
8.7. When processing personal data, the Operator ensures the confidentiality of personal data.
8.8. The Operator stores personal data in a form that allows the personal data subject to be identified for no longer than required by the purposes of personal data processing, unless the storage period for personal data is established by federal law or by an agreement to which the personal data subject is a party, beneficiary, or guarantor.
8.9. The condition for terminating personal data processing may be the achievement of the purposes of personal data processing, expiration of the personal data subject’s consent, withdrawal of consent by the personal data subject or a request to terminate the processing of personal data, as well as identification of unlawful processing of personal data.
9. List of Actions Performed by the Operator with the Received Personal Data
9.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, modifies), extracts, uses, transfers (distributes, provides, grants access to), depersonalizes, blocks, deletes, and destroys personal data.
9.2. The Operator carries out automated processing of personal data with receipt and/or transfer of the received information through information and telecommunications networks or without such transfer.
10. Cross-Border Transfer of Personal Data
10.1. Before starting activities involving the cross-border transfer of personal data, the Operator is obliged to notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out the cross-border transfer of personal data. Such notification shall be sent separately from the notification of the intention to process personal data.
10.2. Before submitting the above notification, the Operator is obliged to obtain the relevant information from the authorities of the foreign state, foreign individuals, and foreign legal entities to which the cross-border transfer of personal data is planned.
11. Confidentiality of Personal Data
The Operator and other persons who have gained access to personal data are obliged not to disclose personal data to third parties and not to distribute personal data without the consent of the personal data subject, unless otherwise provided by federal law.
12. Final Provisions
12.1. The User may receive any clarifications on issues of interest concerning the processing of their personal data by contacting the Operator by email at cco@himalayangold.co.
12.2. 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.
12.3. The current version of the Policy is freely available on the internet at https://himalayangold.co/privacy/.