Personal data processing policy

This personal data processing policy has been drawn up in accordance with Federal Law No. 152-FZ of 27 July 2006 «On Personal Data» and sets out the procedure for processing personal data and the measures to ensure the security of personal data of Aleksey Gennadievich Sharkov (the «Operator»).

• 1. The Operator considers observance of human and civil rights and freedoms in the processing of personal data — including the protection of the rights to privacy and to personal and family secrecy — to be the paramount objective and condition of its activity.
• 2. This policy of the Operator regarding the processing of personal data (the «Policy») applies to all information that the Operator may obtain about visitors of the website https://espanium.com

• 1. Automated processing of personal data — processing of personal data by means of computing equipment.
• 2. Blocking of personal data — temporary suspension of the processing of personal data (except where processing is necessary to correct the personal data).
• 3. Website — the set of graphic and information materials, computer programs and databases making them available on the internet at the address https://espanium.com
• 4. Personal data information system — the set of personal data contained in databases together with the information technologies and technical means ensuring their processing.
• 5. Anonymisation of personal data — actions after which it is impossible, without additional information, to attribute personal data to a particular User or other data subject.
• 6. Processing of personal data — any action (operation) or set of actions (operations) performed with or without automation means with personal data, including collection, recording, systematisation, accumulation, storage, correction (updating, modification), retrieval, use, transfer (distribution, provision, access), anonymisation, blocking, deletion and destruction of personal data.
• 7. Operator — a state body, a municipal body, a legal entity or a natural person that, alone or jointly with others, organises and (or) carries out the processing of personal data and determines the purposes of processing, the scope of personal data to be processed and the actions (operations) performed with personal data.
• 8. Personal data — any information relating directly or indirectly to an identified or identifiable User of the website https://espanium.com
• 9. User — any visitor of the website https://espanium.com
• 10. Provision of personal data — actions aimed at disclosing personal data to a particular person or a particular group of persons.
• 11. Distribution of personal data — any actions aimed at disclosing personal data to an indefinite group of persons or at making personal data available to an unlimited group of persons, including publication in mass media, placement in information and telecommunication networks or provision of access to personal data by any other means.
• 12. Cross-border transfer of personal data — the transfer of personal data to the territory of a foreign state, to a foreign public authority, a foreign natural person or a foreign legal entity.
• 13. Destruction of personal data — any actions as a result of which personal data are irreversibly destroyed with no possibility of further restoration of their content in the personal data information system, and (or) as a result of which the physical media of personal data are destroyed.

• 1. Surname, first name and patronymic.
• 2. Telephone numbers and/or messenger handle.
• 3. The site also collects and processes anonymised data about visitors (including cookies) by means of internet statistics services (Yandex Metrica, Google Analytics and others).
• 4. The data listed above are referred to further in the Policy by the general term Personal Data.

• 1. The purpose of processing the User’s personal data is to inform the User by sending emails.
• 2. The Operator is also entitled to send the User notices of new products and services, special offers and various events. The User may at any time refuse to receive information messages by sending the Operator an email to hola@espanium.com marked «Refusal of notices of new products, services and special offers».
• 3. Anonymised data about Users collected by means of internet statistics services are used to gather information about Users’ actions on the site and to improve the quality of the site and its content.

• 1. The Operator processes the User’s personal data only where the User fills in and/or submits them independently through the dedicated forms on the website https://espanium.com. By filling in the relevant forms and/or submitting personal data to the Operator, the User expresses consent to this Policy.
• 2. The Operator processes anonymised data about the User where this is permitted in the User’s browser settings (cookies enabled and JavaScript allowed).

• 1. The security of personal data processed by the Operator is ensured through legal, organisational and technical measures necessary to fully comply with the applicable data protection legislation.
• 2. The Operator ensures the safety of personal data and takes all possible measures to prevent access to personal data by unauthorised persons.
• 3. The Operator is entitled to transfer the User’s personal information to third parties in the following cases: 3.1. the transfer is necessary to perform obligations under a contract or for the operation of the site; 3.2. the transfer is provided for by Russian or other applicable law within the procedure established by law.
• 4. If inaccuracies are found in the personal data, the User may update them independently by sending the Operator a notice to hola@espanium.com marked «Update of personal data».
• 5. The period of processing of personal data is unlimited. The User may at any time withdraw consent to the processing of personal data by sending the Operator a notice by email to hola@espanium.com marked «Withdrawal of consent to the processing of personal data».
• 6. When processing Users’ personal data, the Operator is guided by the Federal Law of the Russian Federation «On Personal Data».

• 1. Before carrying out a cross-border transfer of personal data, the Operator must make sure that the foreign state to whose territory the data are to be transferred provides reliable protection of the rights of data subjects.
• 2. Cross-border transfer of personal data to the territory of foreign states that do not meet the above requirements may be carried out only with the written consent of the data subject to such transfer and/or for the performance of a contract to which the data subject is a party.

• 1. The User may obtain any clarifications on questions concerning the processing of their personal data by contacting the Operator at hola@espanium.com.
• 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. The current version of the Policy is freely available on the internet at https://espanium.com/legal/privacy