Policy on Personal Data Processing
1. General Provisions
This Personal Data Processing Policy defines the procedure for processing personal data and
measures to ensure the security of personal data undertaken by White Garnet SAC
(hereinafter referred to as the Operator).
1.1
The Operator sets as its most important goal and condition of its
activity the observance of human and citizen's rights and freedoms in the processing of
personal data, including the protection of the rights to privacy, personal and family
secrecy.
1.2
This Operator's policy on personal data processing (hereinafter
referred to as the Policy) applies to all information that the Operator may obtain about
visitors to the https://en.whitegarnet.com
website.
2. Basic Concepts Used in the Policy
2.1
Automated processing of personal data — processing
of personal data with the help of computer equipment;
2.2
Blocking of personal data — temporary cessation of
personal data processing (except for cases when processing is necessary to clarify personal
data);
2.3
Website — 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://en.whitegarnet.com;
2.4
Personal data information system — a set of personal
data contained in databases and information technologies and technical means ensuring their
processing;
2.5
Personal data depersonalization — actions as a result
of which it is impossible to determine, without using additional information, the belonging
of personal data to a particular User or other subject of personal data;
2.6
Processing of personal data — any action (operation)
or set of actions performed with or without the use of automation means with personal data,
including collection, recording, systematization, accumulation, storage, clarification
(update, change), extraction, use, transfer (distribution, provision, access),
depersonalization, blocking, deletion, and destruction of personal data;
2.7
Operator — a state authority, municipal authority,
legal entity or natural person, independently or jointly with other persons organizing
and/or carrying out processing of personal data, as well as determining the purposes of
personal data processing, composition of personal data subject to processing, and actions
performed with personal data;
2.8
Personal Data — any information relating directly
or indirectly to a specific or identifiable User of the website;
2.10
Provision of personal data — actions aimed at
disclosure of personal data to a certain person or a certain group of persons;
2.11
Dissemination of personal data — any actions aimed
at disclosure of personal data to an indefinite number of persons, including disclosure in
mass media, placement in information and telecommunication networks, or providing access to
personal data in any other way;
2.12
Cross-border transfer of personal data — transfer
of personal data to the territory of a foreign country to a foreign government authority,
a foreign individual, or a foreign legal entity;
2.13
Destruction of personal data — any actions as a
result of which personal data are irretrievably destroyed with the impossibility of further
recovery from the information system and/or material carriers of personal data are
destroyed.
3. Personal Data the Operator May Process
3.1
Last name, first name, patronymic;
3.2
Phone number;
3.3
E-mail address;
3.4
The site also collects and processes anonymized data about visitors
(including cookies) using Internet statistics services (Yandex Metrica, Google Analytics,
and others).
3.5
The above-mentioned data are hereinafter in the text of the Policy
referred to by the general term Personal Data.
4. Purposes of Personal Data Processing
4.1
The purpose of processing the User's personal data is to inform the
User by sending e-mails, as well as the conclusion, execution, and termination of civil law
contracts.
4.2
The Operator also has the right to send the User notifications about
new products and services, special offers, and various events. The User may refuse to
receive such notifications at any time by sending a message to
info@whitegarnet.com with the subject
"Unsubscribe from notifications".
4.3
Anonymized data collected via 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.
5. Legal Basis for Personal Data Processing
5.1
The Operator processes the User's personal data only if it is
submitted by the User themselves via 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.
5.2
The Operator processes anonymized data about the User if it is
permitted by the User's browser settings (cookies storage and JavaScript technology are
enabled).
6. Collection, Storage, Transfer, and Other Processing of Personal Data
The security of personal data processed by the Operator is ensured by implementing legal,
organizational, and technical measures necessary for full compliance with the requirements
of the applicable legislation in the field of personal data protection.
6.1
The Operator shall ensure the safety of personal data and take all
possible measures to exclude access to personal data by unauthorized persons.
6.2
The User's personal data will never, under any circumstances, be
disclosed to third parties, except in cases related to the execution of applicable
law.
6.3
If inaccuracies in personal data are identified, the User may update
them by sending a notice to
info@whitegarnet.com with the subject
"Personal Data Update".
6.4
The period of personal data processing is unlimited. The User may
withdraw consent to the processing of personal data at any time by sending a notice to
info@whitegarnet.com with the subject
"Withdrawal of consent to personal data processing".
7. Cross-Border Transfer of Personal Data
7.1
Before commencing the cross-border transfer of personal data, the
Operator shall ensure that the foreign state to which the transfer is intended provides
reliable protection of the rights of personal data subjects.
7.2
Cross-border transfer of personal data to foreign countries that do
not meet the above requirements may be carried out only with the written consent of the
personal data subject to the cross-border transfer and/or for the performance of a contract
to which the personal data subject is a party.
8. Final Provisions
8.1
The User may obtain any clarifications regarding the processing of
their personal data by contacting the Operator via e-mail at
info@whitegarnet.com.
8.2
This document will reflect any changes to the Operator's personal
data processing policy. The Policy is valid indefinitely until it is replaced by a new
version.