This policy on processing of personal data is prepared in accordance with the requirements of the Federal Law of 27.07.2006. No. 152-FZ “On Personal Data” (hereinafter, the “Personal Data Law”) and defines the procedure for processing personal data and measures to ensure security of personal data taken by INME Holistic Co. (hereinafter the “Operator”).
1.1 The Operator’s most important goal and condition for its activities is to respect the rights and freedoms of individuals and citizens when processing their personal data, including protection of the rights to privacy, personal and family secrets.
1.2 The present Policy of the Operator regarding the processing of personal data (hereinafter – the Policy) applies to all information which the Operator can obtain about the visitors of the website https://inmewellness.com/privacy.
2 Basic concepts used in the Policy
2.1 Automated processing of personal data – processing of personal data by means of computer equipment.
2.2 Blocking of personal data – is temporary termination of processing of personal data (except when the 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://inmewellness.com
2.4 Personal Data Information System – a set of personal data contained in databases of personal data, and information technology and technical means ensuring their processing.
2.5 Anonymization of personal data – actions, as a result of which it is impossible to determine, without using additional information, what personal data belongs to a particular User or other subject of personal data.
2.6 Processing of personal data – any action (operation) or set of actions (operations) performed with or without the use of automation means with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
2.7 Operator means a state body, municipal authority, legal entity or individual, independently or jointly with other persons, arranging and (or) carrying out processing of personal data, as well as determining the purposes of processing of personal data, composition of personal data subject to processing, actions (operations) performed with personal data.
2.8 Personal data – any information relating directly or indirectly to a particular or defined User of the website https://inmewellness.com
2.9. Personal data, authorized by the subject of personal data for distribution – personal data, access to which is provided by the subject of personal data by giving consent to the processing of personal data, authorized by the subject of personal data for distribution in the manner prescribed by law on personal data (hereinafter – personal data, authorized for distribution).
2.10. User – any visitor to the https://inmewellness.com website.
2.11. Provision of personal data – actions aimed at disclosure of personal data to a certain person or a certain circle of people.
2.12. Dissemination of personal data – any action aimed at disclosure of personal data to an indefinite range of persons (transfer of personal data) or to familiarize the general public with personal data, including publication 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 – transfer of personal data to the territory of a foreign state to a foreign state authority, a foreign individual or a foreign legal entity.
2.14. Destruction of personal data – any action, as a result of which personal data is destroyed irretrievably with impossibility to further restore the content of personal data in the information system of personal data and (or) destroyed material media of personal data.
3 The basic rights and obligations of the Operator
3.1 The operator has the right:
– Receive from the subject of personal data reliable information and/or documents containing personal data;
– In case of revocation of the personal data subject’s consent to the processing of personal data, the operator may continue the processing of personal data without the consent of the personal data subject on the 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 by the Personal Data Law and regulations adopted in accordance therewith, unless otherwise provided by the Personal Data Law or other federal laws.
3.2 The operator shall:
– Provide the subject of personal data, at his/her request, with information relating to the processing of his/her personal data;
– Organize processing of personal data in the manner prescribed by applicable laws of the Russian Federation;
– to respond to requests and inquiries of subjects of personal data and their legal representatives, in accordance with the requirements of the Law on Personal Data;
– Inform the authorized body for protection of the rights of subjects of personal data, at the request of such body, the necessary information within 30 days from the date of receipt of such request
– Publish or otherwise ensure unrestricted access to this Policy on personal data processing
– Take legal, organizational and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, distribution of personal data, as well as other illegal 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 cases provided by the Personal Data Law
– Perform any other duties prescribed by the Personal Data Law.
4 The basic rights and obligations of subjects of personal data
4.1 The subjects of personal data have the right:
– To receive information relating to the processing of his personal data, except in cases provided for by federal laws. The information is provided to the subject of personal data by the operator in an accessible form, and it must not contain personal data relating to other subjects of personal data, except in cases where there are legitimate grounds for disclosure of such personal data. The list of information and the procedure for obtaining it is established by the Personal Data Law;
– to require the operator to clarify his personal data, block or destroy them if the personal data is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing, as well as to take statutory measures to protect their rights;
– to put forward the condition of prior consent when processing personal data for the purpose of promoting goods, works and services on the market
– to withdraw the consent to the processing of personal data;
– To complain to the authorized body for protection of the rights of subjects of personal data or in court against unlawful acts or omissions of the Operator in the processing of his personal data
– To exercise other rights provided by the legislation of the Russian Federation.
4.2 Personal data subjects shall:
– provide the Operator with reliable data about himself;
– Inform the Operator of the clarification (update, change) of his personal data. 4.3.
4.3 Persons who provided the Operator with false information about themselves, or information about another subject of personal data without the consent of the latter, shall be liable in accordance with the laws of the Russian Federation.
5. The operator may process the following personal data of the User
Surname, first name, middle name. 5.1.
E-mail address. 5.2.
5.4 The site also collects and processes visitors’ anonymized data (including cookies) using Internet statistics services (Yandex Metrika and Google Analytics, etc.).
5.5 The above-mentioned data is further combined in the text of this Policy with the general concept of Personal Data.
5.6 The Operator does not process special categories of personal data relating to race, ethnicity, political views, religious or philosophical beliefs, or intimate life.
5.7 Processing of personal data, allowed for dissemination, from 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.
5.8 The User’s consent to the processing of personal data that is permitted for dissemination shall be executed separately from other consents to the processing of their personal data. In this case, the conditions stipulated, in particular, by Article 10.1 of the Personal Data Law shall be observed. The requirements for the content of such consent shall be established by the competent authority for the protection of personal data subjects’ rights.
5.8.1 The consent to the processing of personal data allowed for distribution, the User provides to the Operator directly.
5.8.2 The Operator is obliged within three working days from the receipt of the above consent of the User to publish information about the conditions of processing, the existence of prohibitions and conditions on the processing of personal data allowed for distribution to an unlimited number of persons.
5.8.3 Transfer (distribution, provision, access) of personal data, authorized 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 surname, first name, patronymic (if any), contact information (telephone number, e-mail address or mailing address) of the subject of personal data, as well as a list of personal data, processing of which is to be terminated. The personal data specified in this request may only be processed by the Operator to which it is sent.
5.8.4 The consent to the processing of personal data permitted for dissemination shall cease to have effect from the moment of receipt by the Operator of the request, specified in paragraph 5.8.3 of this Policy in relation to the processing of personal data.
6. Principles of Personal Data Processing
6.1 Processing of personal data is carried out on a lawful and fair basis.
6.2 Processing of personal data is limited to achieving specific, predetermined and legitimate purposes. Processing of personal data that is incompatible with the purposes of personal data collection is not permitted.
6.3 Databases containing personal data, which are processed for purposes incompatible with each other, shall not be combined.
6.4 Only personal data that meets the purposes of processing shall be processed.
6.5 The content and scope of processed personal data shall comply with the stated processing purposes. Processed personal data shall not be excessive in relation to the stated processing purposes. 6.6.
When processing personal data, the accuracy of personal data, its sufficiency, and, if necessary, relevance in relation to the purpose of personal data processing shall be ensured. The operator shall take necessary measures and/or ensure that they are taken to remove or clarify incomplete or inaccurate data.
6.7 Personal data shall be stored in a form that makes it possible to identify the subject of personal data, no longer than required by the purposes of personal data processing, unless the storage period of personal data is established by federal law, a contract to which the subject of personal data is a party, a beneficiary or a guarantor. Processed personal data shall be destroyed or depersonalized upon attainment of processing objectives or if it is no longer necessary to attain such objectives, unless otherwise provided for by federal law.
7. Purposes of processing of personal data
7.1 The purpose of processing of personal data of the User:
– Informing the User by sending emails.
7.2 The Operator also has the right to send the User notifications about new products and services, special offers and different events. The User can always refuse to receive information messages by sending an email to the Operator at firstname.lastname@example.org with the note “Refuse notifications about new products and services and special offers”.
7.3 The anonymized data of the Users, collected with the help of the Internet statistics services, serves for collecting information about the Users’ actions on the Website, improving the quality of the Website and its content.
8. Legal Basis for Processing of Personal Data
8.1 The legal basis for processing of personal data by the operator are:
– List the laws and regulations governing relations related to your activities, for example, if your activities are related to information technology, in particular the creation of websites, here you can specify the Federal Law “On Information, Information Technology and Information Protection” of 27.07.2006 N 149-FZ;
– The operator’s bylaws;
– Contracts entered into between the operator and the subject of personal data;
– Federal laws, other laws and regulations in the sphere of personal data protection;
– Users’ consent to the processing of their personal data, to the processing of personal data allowed for dissemination.
8.2. The Operator processes the User’s personal data only if the User fills in and/or sends them independently through the special forms located on the website https://inmewellness.com or sent to the Operator via e-mail. By filling out the relevant forms and/or sending his personal data to the Operator the User expresses his consent to this Policy.
8.4 The subject of personal data independently decides to provide his personal data and gives consent freely, willingly and in his own interest.
9. Conditions for the processing of personal data
9.1 Processing of personal data is carried out with the consent of the subject of personal data to the processing of their personal data.
9.2 Processing of personal data is necessary for achievement of the objectives envisaged by an international treaty of the Russian Federation or by law, for implementation of the functions, powers and duties imposed on the operator by the legislation of the Russian Federation.
9.3 Processing of personal data is necessary for administration of justice, execution of a judicial act, act of another body or official to be executed in accordance with the legislation of the Russian Federation on enforcement proceedings.
9.4 Processing of personal data shall be necessary for execution of an agreement, a party to which or a beneficiary or guarantor under which the personal data subject is a party, as well as for conclusion of an agreement on the initiative of the personal data subject or an agreement, under which the personal data subject will be a beneficiary or guarantor.
9.5 Processing of personal data is necessary to exercise the rights and legitimate interests of the operator or third parties or to achieve socially important goals, provided that this does not violate the rights and freedoms of the subject of personal data.
9.6 Personal data shall be processed to which the subject of personal data has access by the general public or at the subject’s request (hereinafter, “publicly available personal data”).
9.7 Processing of personal data subject to publication or mandatory disclosure in accordance with federal law.
10. Procedure for collection, storage, transfer and other processing of personal data
Security of personal data processed by the Operator is ensured by implementing legal, organizational and technical measures necessary to comply fully with the requirements of applicable laws in the field of personal data protection.
10.1 The operator provides safety of personal data and takes all possible measures which exclude access to personal data by unauthorized persons.
10.2 The personal data of the User shall never, under no circumstances be transferred to third parties, except in cases related to the implementation of the current legislation or if the subject of personal data has given consent to the Operator to transfer data to a third party to fulfill obligations under a civil law contract.
10.3 In case of identification of inaccuracies in personal data, the User may update them on their own, by sending a notice to the Operator’s e-mail address email@example.com with a note “Updating of personal data”.
10.4 The term of processing of personal data is determined by achieving the purposes for which the personal data was collected, unless a different term is stipulated by the contract or by applicable law.
The User may withdraw their consent to the processing of personal data at any time by sending a notice via e-mail to the Operator’s e-mail address firstname.lastname@example.org, marked “Withdrawal of consent to the processing of personal data”.
10.6 The prohibitions established by the personal data subject on the transfer (other than granting access), as well as on the processing or processing conditions (other than gaining access) of personal data permitted for distribution shall not apply in cases of processing of personal data in state, public and other public interests as defined by Russian legislation.
10.7. The Operator ensures the confidentiality of personal data when processing personal data.
10.8. The operator shall store personal data in a form that allows to identify the subject of personal data, no longer than the purposes of personal data processing require it, unless the period of personal data storage is established by federal law, a contract, a party to which, a beneficiary or a guarantor under which the subject of personal data is a party.
10.9 A condition for termination of personal data processing may be achievement of personal data processing objectives, expiration of the personal data subject’s consent or withdrawal of consent by the personal data subject, as well as detection of unlawful personal data processing.
11. List of actions performed by the operator with received personal data
11.1 The operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), extracts, uses, transfers (distribution, provision, access), depersonalizes, blocks, deletes and destroys personal data.
11.2 The operator carries out automated processing of personal data with or without receipt and/or transfer of received information via information and telecommunications networks.
12. cross-border transfer of personal data
12.1 Before transborder transfer of personal data, the operator shall make sure that the foreign country, to the territory of which the transfer of personal data is supposed to take place, provides reliable protection of personal data subjects’ rights.
12.2 The transborder transfer of personal data to foreign countries, which do not meet the above requirements, may be carried out only if the personal data subject consents in writing to the transborder transfer of his/her personal data and/or the performance of an agreement, to which the personal data subject is a party.
13. Confidentiality of personal data
The operator and other persons who obtained access to personal data must not disclose to third parties and not disseminate personal data without the consent of the subject of personal data, unless otherwise provided by federal law.
14. Final provisions
14.1 The User can obtain any clarifications on questions of interest regarding the processing of their personal data by contacting the Operator by e-mail at email@example.com
14.2 This document will reflect any changes in the personal data processing policy of the Operator. The Policy is valid indefinitely until it is replaced by a new version.
14.3. The current version of the Policy is freely available on the Internet at https://inmewellness.com/privacypolicy.