Privacy Policy wohclub_af

Privacy Policy regarding the processing of personal

data

1 General Provisions
This Privacy Policy for the processing of personal data is prepared in accordance with the requirements of the Law "On Personal Data" (hereinafter – the Personal Data Law) and determines the procedure for processing personal data and measures to ensure the security of personal data undertaken by FILINA PROSPERITY MANAGEMENT - FZCO (hereinafter – the Operator).
1.1. The Operator sets as its most important goal and condition for the implementation of its activities the observance of human and citizen's rights and freedoms when processing their personal data, including the protection of the rights to privacy, personal and family secrets.
1.2. This Policy of the Operator regarding the processing of personal data (hereinafter – the Policy)
applies to all information that the Operator can obtain about visitors to the
website https://allafilinaprosperity.com/wohclub_af_uae .
2 Basic Concepts Used in the Policy
2.1. Automated processing of personal data – processing of personal data using computer technology.
2.2. Blocking of personal data – temporary cessation of processing of personal data (except for cases where processing is necessary to clarify personal data).
2.3. Website – a set of graphical and informational materials, as well as computer programs and databases that ensure their availability on the Internet at the network
address https://allafilinaprosperity.com/wohclub_af_uae .
2.4. Information system of personal data — a set of personal data contained in databases and information technologies and technical means ensuring their processing.
2.5. Depersonalization of personal data — actions as a result of which it is impossible to determine, without the use of additional information, the belonging of personal data to a specific User or other subject of personal data.
2.6. Processing of personal data – any action (operation) or a 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), depersonalization, blocking, deletion, destruction of personal data.
2.7. Operator – a state body, municipal body, legal entity, or individual, independently or jointly with other
persons, organizing and/or carrying out the processing of personal data, as well as determining the purposes of processing personal data, the composition of personal data to be processed, 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 https://allafilinaprosperity.com/wohclub_af_uae .
2.9. Personal data permitted by the subject of personal data for dissemination - personal data, access to which has been provided to an unlimited number of persons by the subject of personal data by giving consent to the processing of personal data permitted for dissemination in the manner prescribed by the Personal Data Law (hereinafter - personal data permitted for dissemination).
2.10. User – any visitor to the website https://allafilinaprosperity.com/wohclub_af_uae .
2.11. Provision of personal data – actions aimed at disclosing personal data to a specific person or a
specific circle 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 familiarizing an unlimited circle of persons with personal data, including the publication of personal data in the mass media, posting in information and telecommunication 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 an authority of a foreign state, a foreign individual, or a foreign legal entity.
2.14. Destruction of personal data – any actions as a result of which personal data are destroyed irrevocably with the impossibility of further restoring the content of personal data in the information system of personal data and/or material carriers of personal data are destroyed.

3. Basic Rights and Obligations of the Operator

3.1. The Operator has the right to:

Receive from the subject of personal data reliable information and/or documents containing personal data; in case of withdrawal by the subject of personal data of consent to the processing of personal data, continue processing without the subject's consent if there are 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 regulatory legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Law or other laws.

3.2. The Operator is obliged to:

Provide the subject of personal data, upon request, with information concerning the processing of their personal data; Organize the processing of personal data in the manner established by current legislation; Respond to appeals and requests from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law; Publish or otherwise provide unrestricted access to this Policy regarding the processing of personal data; 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; 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 other duties provided by the Personal Data Law.

4 Basic Rights and Obligations of Personal Data
Subjects

4.1. Subjects of personal data have the right to: Receive information regarding the processing of their personal data, except in cases provided by law. The information is provided to the subject by the Operator in an accessible form and shall not contain personal data relating to other subjects, except in cases where 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; Require the operator to clarify, block, or destroy their personal data if the data is incomplete, outdated, inaccurate, illegally obtained, or not necessary for the stated purpose of processing, and take legal measures to protect their rights; Impose a condition of prior consent when processing personal data for the purpose of promoting goods, works, and services on the market; Withdraw consent to the processing of personal data; Appeal to the authorized body for the protection of the rights of personal data subjects or in court against unlawful actions or inaction of the Operator during the processing of their personal data; Exercise other rights provided by law.

4.2. Subjects of personal data are obliged to:
Provide the Operator with accurate data about themselves; Inform the Operator about the clarification (update, change) of their personal data.

5. The Operator may process the following Personal
Data of the User
5.1. Last name, first name, patronymic.
5.2. Email address.
5.3. Phone numbers.
5.4. The site also collects and processes anonymized data about visitors (including "cookies") using Internet statistics services (Yandex Metrica, Google Analytics, and others).
5.5. The above data are collectively referred to as Personal Data in this Policy.
5.6. The Operator does not process special categories of personal data concerning race, nationality, political views, religious or philosophical beliefs, or intimate life.
5.7. Processing of personal data permitted for dissemination from among special categories of
personal data is carried out in compliance with the requirements of the Personal Data Law.
5.8. The User's consent to the processing of personal data permitted for dissemination is issued separately from other consents for the processing of their personal data.
5.8.1 Consent to the processing of personal data permitted for dissemination is provided by the User
directly to the Operator.
5.8.2 The transfer (distribution, provision, access) of personal data permitted by the subject for dissemination must be ceased at any time at the request of the subject. This request must include the last name, first name, patronymic (if any), contact information (phone number, email address, or postal address) of the subject, as well as a list of personal data whose processing is to be ceased. The personal data specified in this request can only be processed by the Operator to whom it is sent.
5.8.3 Consent to the processing of personal data permitted for dissemination ceases from the moment the Operator receives the aforementioned request.

6. Principles of Personal Data Processing
6.1. The processing of personal data is carried out on a lawful and fair basis.
6.2. The processing of personal data is limited to achieving specific, predetermined, and lawful purposes. Processing incompatible with the purposes of collecting personal data is not permitted.
6.3. It is not allowed to combine databases containing personal data processed for incompatible purposes.
6.4. Only personal data that meets the purposes of processing is subject to processing.
6.5. The content and volume of processed personal data correspond to the stated purposes of processing. Redundancy of processed personal data relative to the stated purposes is not allowed.
6.6. During processing, the accuracy of personal data, their sufficiency, and, where necessary, relevance
relative to the purposes of processing are ensured. The Operator takes necessary measures to remove or clarify incomplete or inaccurate data.

6.7. Storage of personal data is carried out in a form that allows identification of the subject for no longer than required by the purposes of processing, unless the storage period is established by law or contract. Processed personal data is destroyed or anonymized upon achieving the processing purposes or in case of loss of necessity, unless otherwise provided by law.

7. Purposes of Personal Data Processing
7.1. The purpose of processing the User's personal data: Informing the User by sending emails;
Conclusion, execution, and termination of civil law contracts;
Providing the User with access to services, information, and/or materials contained on the
website https://allafilinaprosperity.com/wohclub_af_uae .
7.2. The Operator also has the right to send notifications to the User about new products and services, special offers, and various events. The User can always refuse to receive informational messages by sending an email to the Operator at info@allasfilina.ru with the subject "Opt-out of notifications about new products and services and special offers."
7.3. Anonymized User data collected using Internet statistics services is used to collect information about User actions on the site, improve the quality of the site, and its content.

8. Legal Grounds for Processing Personal Data
8.1. The legal grounds for the processing of personal data by the Operator are:
The Operator's constituent documents; Contracts concluded between the operator and the
subject of personal data; Laws and other regulatory legal acts in the field of
personal data protection; Users' consent to the processing of their personal data,
and to the processing of personal data permitted for dissemination.
8.2. The Operator processes the User's personal data only if they are filled in and/or sent by the User independently through special forms located on the site https://allafilinaprosperity.com/wohclub_af_uae or sent to the Operator via email. By filling out the relevant forms and/or sending their personal data to the Operator, the User expresses their consent to this Policy.
8.3. The Operator processes anonymized data about the User if it is allowed in the User's browser settings (saving "cookies" and using JavaScript technology are enabled).
8.4. The subject of personal data independently decides to provide their personal data and gives consent freely, by their own will, and in their interest.

9. Conditions for Processing Personal Data
9.1. The processing of personal data is carried out with the consent of the subject to the processing of their personal data.
9.2. The processing of personal data is necessary for the performance of a contract to which the subject is a party, beneficiary, or guarantor, as well as for concluding a contract on the initiative of the subject or a contract under which the subject will be a beneficiary or guarantor.
9.3. The processing of personal data is necessary for the exercise of the rights and legitimate interests of the operator or third parties, or for achieving socially significant goals, provided that the rights and freedoms of the subject are not violated.
9.4. Processing of personal data is carried out, access to which has been provided by the subject or at their request to an unlimited number of persons (hereinafter – publicly available personal data).
9.5. Processing of personal data subject to publication or mandatory disclosure in accordance with the law is carried out.

10 Procedure for Collection, Storage, Transfer, and

Other Types of Processing of Personal Data

The security of personal data processed by the Operator is ensured by implementing legal, organizational, and technical measures necessary to fully comply with the requirements of current legislation in the field of personal data protection.
10.1. The Operator ensures the safety of personal data and takes all possible measures to exclude access to personal data by unauthorized persons.
10.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to the execution of current legislation or if the subject 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 inaccuracies in personal data, the User can update them independently by sending a notification to the Operator's email address info@allasfilina.ru with the subject "Update of personal data."
10.4. The period for processing personal data is determined by the achievement of the purposes for
which the personal data were collected, unless a different period is provided for by contract or current
legislation. The User can withdraw their consent to the processing of personal data at any time by sending a notification to the Operator via email to the Operator's email address
info@allasfilina.ru with the subject "Withdrawal of consent to the processing of personal data."
10.5. All information collected by third-party services, communication tools, and other service providers is stored and processed by these persons (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data and/or the User is obliged to familiarize themselves with the said documents in a timely manner independently. The Operator is not responsible for the actions of third
parties, including the service providers mentioned in this clause.
10.6. Prohibitions established by the subject on the transfer (except for providing access), as well as on the processing or conditions of processing (except for obtaining access) of personal data permitted for
dissemination, do not apply in cases of processing personal data in state, public, and other public interests.
10.7. The Operator ensures the confidentiality of personal data during their processing.
10.8. The Operator stores personal data in a form that allows identification of the subject for no longer than required by the purposes of processing, unless the storage period is established by law or contract.
10.9. The termination of processing of personal data may be conditioned by the achievement of the
processing purposes, the expiration of the subject's consent, the withdrawal of consent by the subject, or the identification of unlawful processing of personal data.

11. List of Actions Performed by the Operator with the
Received Personal Data
11.1. The Operator performs collection, recording, systematization, accumulation, storage, clarification
(updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization,
blocking, deletion, and destruction of personal data.
11.2. The Operator performs automated processing of personal data with or without receipt and/or
transmission of the received information via information and telecommunication networks.

12. Cross-Border Transfer of Personal Data
12.1. Before commencing the cross-border transfer of personal data, the Operator is obliged to ensure that the foreign state to whose territory the transfer is intended provides reliable protection of the rights of personal data subjects.
12.2. Cross-border transfer of personal data to the territories of foreign states that do not meet the above requirements can only be carried out with the written consent of the subject to the cross-border transfer of their personal data and/or performance of a contract to which the subject is a party.

13. Confidentiality of Personal Data
The Operator and other persons who have gained access to personal data are obliged not to disclose or distribute personal data to third parties without the consent of the subject, unless otherwise provided by law.

14. Final Provisions
14.1. The User can obtain any clarifications on questions regarding the processing of their personal data
by contacting the Operator via email at info@allasfilina.ru
14.2. This document will reflect any changes to the Operator's personal data processing policy. The Policy is valid indefinitely until replaced by a new version.
14.3. The current version of the Policy is freely available on the Internet

at https://allafilinaprosperity.com/wohclub_af_uae .