1. General Provisions
This personal data processing policy has been drawn up 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 the measures taken to ensure the security of personal data by Limited Liability Company “Global Dent” (hereinafter – the Operator).
1.1. The Operator considers the observance of human and civil rights and freedoms in the processing of personal data, including the protection of the right to privacy, personal and family secrets, as a primary goal and a condition for its activities.
1.2. This Operator’s policy regarding personal data processing (hereinafter – the Policy) applies to all information that the Operator may obtain about visitors to the website waterdent.ru.
2. Main Concepts Used in the Policy
2.1. Automated processing of personal data – processing of personal data using computing equipment.
2.2. Blocking of personal data – temporary suspension of personal data processing (except when processing is necessary to clarify personal data).
2.3. Website – a set of graphical and informational materials, as well as software and databases, ensuring their availability on the Internet at the network address waterdent.ru.
2.4. Personal data information system – a set of personal data contained in databases and the information technologies and technical means that ensure their processing.
2.5. Anonymization of personal data – actions that make it impossible to determine the ownership of personal data to a specific User or other subject of personal data without using additional information.
2.6. Processing of personal data – any action (operation) or 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), anonymization, blocking, deletion, destruction of personal data.
2.7. Operator – a state body, municipal body, legal entity, or individual who independently or jointly with others organizes and/or performs the processing of personal data and determines the purposes of personal data processing, the composition of personal data to be processed, and actions (operations) performed with personal data.
2.8. Personal data – any information relating directly or indirectly to a specific or identifiable User of the website waterdent.ru.
2.9. Personal data permitted by the subject of personal data for dissemination – personal data whose access by an unlimited circle of persons is provided by the subject of personal data by giving consent to the processing of personal data permitted for dissemination in the manner provided by the Personal Data Law (hereinafter – personal data permitted for dissemination).
2.10. User – any visitor to the website waterdent.ru.
2.11. Provision of personal data – actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Dissemination of personal data – any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or making personal data available to an unlimited circle of persons, including publication in mass media, placement in information and telecommunication networks, or providing access to personal data by any other means.
2.13. Cross-border transfer of personal data – transfer of personal data to the territory of a foreign state to a state body of a foreign state, foreign individual, or foreign legal entity.
2.14. Destruction of personal data – any actions as a result of which personal data are irreversibly destroyed with no possibility of further recovery of the contents in the personal data information system and/or the physical media containing personal data are destroyed.
3. Main Rights and Obligations of the Operator
3.1. The Operator has the right to:
obtain from the subject of personal data accurate information and/or documents containing personal data;
in the event of withdrawal by the subject of personal data of consent to the processing of personal data, as well as the submission of a request to terminate the processing of personal data, continue processing personal data without the consent of the subject if there are grounds specified in the Personal Data Law;
independently determine the composition and list of measures necessary and sufficient to ensure compliance with the obligations provided by the Personal Data Law and the 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 subject of personal data, at their request, with information regarding the processing of their personal data;
organize personal data processing in accordance with the procedure established by current Russian legislation;
respond to requests of personal data subjects and their legal representatives in accordance with the Personal Data Law;
provide the authorized body for the protection of personal data subjects, upon request, with the necessary information within 10 days of receiving such request;
publish or otherwise ensure unrestricted access to this Policy regarding personal data processing;
take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision, dissemination, as well as from other unlawful actions regarding personal data;
terminate the transfer (dissemination, provision, access) of personal data, cease processing, and destroy personal data in the manner and cases provided by the Personal Data Law;
perform other obligations provided 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 regarding the processing of their personal data, except in cases provided by federal laws. Information is provided in an accessible form and must not contain personal data related to other subjects, except when 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;
request the Operator to clarify their personal data, block, or destroy it if the personal data is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the declared purpose of processing, and take measures provided by law to protect their rights;
require prior consent for the processing of personal data for marketing purposes;
withdraw consent to the processing of personal data and request termination of personal data processing;
appeal to the authorized body for the protection of personal data or in court against unlawful actions or inaction of the Operator in processing their personal data;
exercise other rights provided by Russian legislation.
4.2. Personal data subjects are obliged to:
provide the Operator with accurate data about themselves;
notify the Operator of updates or changes to their personal data.
4.3. Persons who provide the Operator with inaccurate information about themselves or information about another personal data subject without their consent bear responsibility in accordance with Russian legislation.
5. Principles of Personal Data Processing
5.1. Personal data processing is carried out on a legal and fair basis.
5.2. Personal data processing is limited to achieving specific, predetermined, and lawful purposes. Processing of personal data incompatible with the purposes of data collection is not permitted.
5.3. The merging of databases containing personal data processed for incompatible purposes is not allowed.
5.4. Only personal data that meet the purposes of processing are subject to processing.
5.5. The content and scope of processed personal data must correspond to the stated purposes of processing. Excessive processing of personal data relative to the stated purposes is not allowed.
5.6. Personal data processing ensures accuracy, sufficiency, and, where necessary, relevance to the purposes of processing. The Operator takes necessary measures and/or ensures the adoption of measures to delete or clarify incomplete or inaccurate data.
5.7. Personal data is stored in a form that allows identification of the data subject no longer than required for the purposes of processing, unless the storage period is established by federal law, a contract to which the data subject is a party, beneficiary, or guarantor. Processed personal data is destroyed or anonymized upon achieving the purposes of processing or if they are no longer needed, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing
The purpose of processing the User’s personal data is to inform the User by sending emails and other types of messages regarding new product releases, promotional campaigns with reduced prices on e-commerce platforms, as well as educational content in the form of tutorials on the use of the Company’s products.
The Operator also has the right to send the User notifications about new products and services, special offers, and various events. The User can always opt out of receiving such notifications by sending an email to the Operator at info@globalwhite.com with the subject line “Opt-out of notifications about new products, services, and special offers.”
Anonymized User data collected via internet analytics services is used to gather information about User actions on the website and to improve the quality and content of the website.
7. Conditions of Personal Data Processing
7.1. Personal data processing is carried out with the consent of the data subject.
7.2. Processing is necessary to achieve the purposes provided by an international treaty of the Russian Federation or by law, for the exercise of functions, powers, and responsibilities assigned to the Operator under the legislation of the Russian Federation.
7.3. Processing is necessary for the administration of justice, execution of a court order, or the act of another authority or official that must be executed in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. Processing is necessary for the execution of a contract to which the data subject is a party, beneficiary, or guarantor, as well as for concluding a contract at the initiative of the data subject or a contract under which the data subject will be a beneficiary or guarantor.
7.5. Processing is necessary to exercise 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 data subject are not violated.
7.6. Personal data made publicly available by the data subject or accessible by request of the data subject (hereinafter — publicly available personal data) may be processed.
7.7. Personal data subject to publication or mandatory disclosure in accordance with federal law may be processed.
8. Procedure for Collecting, Storing, Transmitting, and Other Types of Personal Data Processing
The security of personal data processed by the Operator is ensured through legal, organizational, and technical measures necessary to fully comply with the requirements of current legislation on personal data protection.
8.1. The Operator ensures the safety of personal data and takes all possible measures to prevent unauthorized access.
8.2. The User’s personal data will never, under any circumstances, be transferred to third parties, except where required by law or if the data subject has consented to transfer the data to a third party to fulfill obligations under a civil law contract.
8.3. In case of inaccuracies in personal data, the User may update them independently by sending a notification to the Operator at info@globalwhite.com with the subject line “Update of Personal Data.”
8.4. The duration of personal data processing is determined by the achievement of the purposes for which the data were collected, unless a different period is established by contract or law.
The User may withdraw consent for personal data processing at any time by sending a notice via email to info@globalwhite.com with the subject line “Withdrawal of Consent for Personal Data Processing.”
8.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by these entities in accordance with their User Agreement and Privacy Policy. The Operator is not responsible for the actions of third parties, including the providers mentioned in this clause.
8.6. Restrictions established by the data subject on the transfer (other than access provision) or processing (other than access) of personal data allowed for dissemination do not apply in cases of processing for state, public, or other public interests defined by Russian law.
8.7. The Operator ensures the confidentiality of personal data during processing.
8.8. The Operator stores personal data in a form that allows identification of the data subject no longer than required for the purposes of processing, unless the storage period is established by federal law or contract.
8.9. Processing of personal data may cease upon achieving the processing purposes, expiration of the consent, withdrawal of consent by the data subject, a request to stop processing, or detection of unlawful processing.
9. List of Actions Performed by the Operator with Collected Personal Data
9.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), extracts, uses, transfers (distributes, provides, grants access), anonymizes, blocks, deletes, and destroys personal data.
9.2. The Operator carries out automated processing of personal data with the reception and/or transmission of obtained information via information and telecommunication networks or without them.
10. Cross-Border Transfer of Personal Data
10.1. Before carrying out cross-border personal data transfer, the Operator must notify the authorized body for the protection of personal data subjects of its intention to carry out such transfer (this notification is separate from the notice of intent to process personal data).
10.2. Before submitting the above notification, the Operator must obtain the relevant information from the authorities of the foreign state, foreign individuals, or foreign legal entities to which cross-border transfer is planned.
11. Confidentiality of Personal Data
The Operator and other persons who gain access to personal data are obliged not to disclose or distribute personal data to third parties without the consent of the data subject, unless otherwise provided by federal law.
12. Final Provisions
12.1. The User may obtain any clarifications regarding the processing of their personal data by contacting the Operator via email at info@globalwhite.com.
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 publicly available on the Internet at https://waterdent.ru/en/agreement/.