Personal Data Processing Policy

This translation is provided for convenience only. In case of any discrepancy, the Russian version shall prevail.

This Personal Data Processing Policy has been drawn up in accordance with the requirements of Federal Law No. 152-FZ of July 27, 2006 “On Personal Data” and sets out the procedure for processing personal data and the measures taken by BONSAI Limited Liability Company (hereinafter, the “Operator”) to ensure the security of personal data.

The Operator’s paramount objective and a condition for carrying out its activities is the observance of human and civil rights and freedoms in the processing of personal data, including the protection of the rights to the inviolability of private life and to personal and family secrecy.

This Policy of the Operator regarding the processing of personal data (hereinafter, the “Policy”) applies to all information that the Operator may obtain about visitors to the website bonsai-agency.com.

• Automated processing of personal data — processing of personal data by means of computer technology.
• Blocking of personal data — temporary suspension of the processing of personal data (except where processing is necessary to clarify the personal data).
• Website — a set of graphic and informational materials, together with the computer programs and databases that make them available on the internet at the network address bonsai-agency.com.
• Personal data information system — a set of personal data contained in databases, together with the information technologies and technical means that ensure its processing.
• Depersonalization of personal data — actions that make it impossible, without the use of additional information, to determine whether personal data belongs to a specific User or another data subject.
• Processing of personal data — any action (operation) or set of actions (operations) performed with personal data, with or without the use of automation tools, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (dissemination, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
• Operator — a state body, municipal body, 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 processing personal data, the scope of personal data to be processed, and the actions (operations) performed with personal data.
• Personal data — any information relating directly or indirectly to an identified or identifiable User of the website.
• User — any visitor to the website.
• Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific group of persons.
• Dissemination of personal data — any actions aimed at disclosing personal data to an indefinite group of persons.
• Cross-border transfer of personal data — the transfer of personal data to the territory of a foreign state, to an authority of that foreign state, or to a foreign individual or legal entity.
• Destruction of personal data — any actions as a result of which personal data is irreversibly destroyed, making it impossible to further restore the content of the personal data in the personal data information system, and/or as a result of which the physical media containing the personal data are destroyed.

• Full name (surname, first name, patronymic)
• Email address
• Telephone numbers
• The website also collects and processes depersonalized data about visitors (including cookies) using internet statistics services (Yandex Metrica and others)

Hereinafter in this Policy, the data listed above is collectively referred to as Personal Data.

The purpose of processing the User’s personal data is to inform the User by sending emails; to conclude, perform, and terminate civil-law contracts; and to provide the User with access to the services, information, and/or materials available on the website.

The Operator also has the right to send the User notifications about new products and services, special offers, and various events. The User may at any time opt out of receiving informational messages by sending the Operator an email at bonsai.main@mail.ru marked “Opt-out of notifications about new products and services and special offers.”

Depersonalized data of Users collected through internet statistics services is used to gather information about Users’ actions on the website and to improve the quality of the website and its content.

The Operator processes the User’s personal data only if the User has independently filled in and/or submitted such data through the special forms located on the website. By filling in the relevant forms and/or sending their personal data to the Operator, the User expresses their consent to this Policy.

The Operator processes depersonalized data about the User if this is permitted by the User’s browser settings (the saving of cookies and the use of JavaScript technology are enabled).

The security of personal data processed by the Operator is ensured through the implementation of the legal, organizational, and technical measures necessary to comply in full with the requirements of applicable legislation in the field of personal data protection.

The Operator ensures the safety of personal data and takes all possible measures to prevent access to personal data by unauthorized persons.

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 data subject has given the Operator consent to transfer the data to a third party for the performance of obligations under a civil-law contract.

If any inaccuracies are found in the personal data, the User may update the data independently by sending a notification to the Operator’s email address bonsai.main@mail.ru marked “Updating of personal data.”

The period of personal data processing is unlimited. The User may at any time withdraw their consent to the processing of personal data by sending the Operator a notification by email to the Operator’s email address bonsai.main@mail.ru marked “Withdrawal of consent to personal data processing.”

Before carrying out a cross-border transfer of personal data, the Operator must ensure that the foreign state to whose territory the personal data is to be transferred provides reliable protection of the rights of data subjects.

Cross-border transfer of personal data to the territories of foreign states that do not meet the above requirements may be carried out only with the written consent of the data subject to the cross-border transfer of their personal data and/or for the performance of a contract to which the data subject is a party.

The User may obtain any clarification on matters of interest regarding the processing of their personal data by contacting the Operator by email at bonsai.main@mail.ru.

Any changes to the Operator’s personal data processing policy will be reflected in this document. The Policy remains in effect indefinitely until it is replaced by a new version.

The current version of the Policy is freely available on the internet at bonsai-agency.com/privacy.

• BONSAI Limited Liability Company
• 5 Universitetskaya St., office 115, Innopolis, Republic of Tatarstan, 420500, Russia
• Email: bonsai.main@mail.ru
• Phone: +7 993 316-14-63
• OGRN: 1241600026095
• INN: 1683021380