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 Da- ta 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 ob- servance of human and citizen's rights and freedoms when processing their personal data, including the pro- tection of the rights to privacy, personal and family se- crets.
1.2. This Policy of the Operator regarding the pro- cessing of personaldata (hereinafter – the Policy)ap- plies to all information that the Operator can obtain about visitors to the web-
site https://allafilinaprosperity.com/prozvetsnie_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 pro- cessing is necessary to clarify personal data).
2.3. Website – a set of graphical and informational ma- terials, as well as computerprograms and databasesthat ensure their availability on the Internet at the network address https://allafilinaprosperity.com/prozvetsnie_uae.
2.4. Information systemof personal data — a set of per- sonal data contained in databases and information tech- nologies and technical means ensuring theirprocessing.
2.5. Depersonalization of personal data — actions as a result of which it is impossible to determine, withoutthe 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 with- out the use of automation tools with personal data, in- cluding collection, recording, systematization, accumu- lation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of per- sonal data.
2.7. Operator – a state body, municipal body, legal enti- ty, or individual, independently or jointly with other persons, organizing and/or carrying out the processing of personaldata, as well as determining the purposes of processing personal data, the composition of personal data to be processed, actions (operations) performed with personal data.
Personal data – any information relating directly or indirectly to a specific or identifiable User of the web- site https://allafilinaprosperity.com/prozvetsnie_uae .
2.8. 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).
2.9. User – any visitor to the web- site https://allafilinaprosperity.com/prozvetsnie_uae .
2.10. Provision of personal data – actionsaimed at dis- closing personal data to a specific person or a specific circle of persons.
2.11. Dissemination of personal data – any actions aimed at disclosing personal data to an indefinite circle of persons (transferof personal data) or familiarizing an unlimited circle of persons with personal data, including the publication of personal data in the mass media, post- ing in information and telecommunication networks, or providing access to personal data in any other way.
2.12. Cross-border transferof personal data – transferof personal data to the territory of a foreign state to an au- thority of a foreign state, a foreign individual, or a for- eign legal entity.
2.13. Destruction of personal data – any actions as a re- sult of which personal data are destroyed irrevocably with the impossibility of further restoringthe content of personal data in the information systemof personal data and/or material carriers of personal data are destroyed.
3. Basic Rights and Obligations of the Operator
3.1. The Operatorhas the right to:
Receive from the subject of personal data reliable in- formation 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 pro- cessing 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 fulfill- ment 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 subjectof 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 sub- jects and their legal representatives in accordance with the requirements of the Personal Data Law;
Publish or otherwiseprovide 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 ac- cess, destruction, modification, blocking, copying, pro- vision, 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 datain the manner and casesprovided by the Personal Data Law;
Perform other duties provided by the PersonalData Law.
4. Basic Rights and Obligations of Personal Data Sub- jects
4.1. Subjects of personal data have the right to: Receive information regarding the processing of their personal data, exceptin cases providedby law. The in- formation 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 groundsfor 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, inaccu- rate, illegally obtained, or not necessary for the stated purpose of processing, and take legal measures to pro- tect their rights;
Impose a condition of prior consentwhen 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 un- lawful actions or inaction of the Operator during the processing of their personal data;
Exercise other rightsprovided by law.
4.2. Subjects of personal data are obliged to: Provide the Operatorwith accurate data about them- selves;
Inform the Operatorabout the clarification (update, change) of their personal data.
5. The Operatormay process the following PersonalDa- ta 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") usingInternet statistics services (Yandex Metrica, Google Analytics, and others).
5.5. The above data are collectively referredto as Per- sonal 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 dissemi- nationfrom among specialcategories of personaldata 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 consentsfor the processing of their personal data.
5.8.1 Consent to the processing of personal data permit- ted for dissemination is providedby the User directly to the Operator.
5.8.2 The transfer (distribution, provision, access) of personaldata permitted by the subjectfor dissemination must be ceased at any time at the request of the subject. This request must includethe last name, first name, pat- ronymic (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 permit- ted for dissemination ceases from the momentthe Oper- ator receives the aforementioned request.
6. Principles of PersonalData Processing
6.1. The processing of personal data is carriedout on a lawful and fair basis.
6.2. The processing of personal data is limitedto achiev- ing specific, predetermined, and lawful purposes. Pro- cessing incompatible with the purposes of collecting personal data is not permitted.
6.3. It is not allowedto combine databases containing personal data processed for incompatible purposes.
6.4. Only personaldata that meetsthe purposes of pro- cessing is subject to processing.
6.5. The contentand volume of processed personal data correspond to the stated purposes of processing. Redun- dancy 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 rela- tive to the purposes of processing are ensured. The Op- erator takesnecessary measures to remove or clarify in- complete or inaccurate data.
6.7. Storage of personal data is carriedout in a form that allows identification of the subject for no longer than required by the purposes of processing, unless the stor- age period is established by law or contract. Processed personal data is destroyed or anonymized upon achiev- ing the processing purposes or in case of loss of necessi- ty, unless otherwise provided by law.
7. Purposes of PersonalData Processing
7.1. The purposeof processing the User's personaldata: Informing the User by sending emails;
Conclusion, execution, and termination of civil law con- tracts;
Providing the User with access to services,information, and/or materials contained on the web-
site https://allafilinaprosperity.com/prozvetsnie_uae
7.2. The Operator also has the right to send notifications to the User about new products and services, special of- fers, and various events. The User can always refuse to receive informational messages by sending an email to the Operator at yourgreatlife2025@gmail.com with the subject "Opt-out of notifications about new productsand services and special offers."
7.3. Anonymized User data collectedusing Internet sta- tistics services is used to collectinformation about User actions on the site, improve the quality of the site, and its content.
8. Legal Groundsfor Processing PersonalData
8.1. The legalgrounds for the processing of personal data by the Operator are:
The Operator's constituent documents;
Contracts concluded betweenthe operator and the subject of personal data;
Laws and otherregulatory legal acts in the field of personal data protection;
Users' consent to the processing of their personaldata, and to the processing of personal data permitted for dissemination.
8.2. The Operatorprocesses the User'spersonal data on- ly if they are filled in and/or sent by the User inde- pendently through special forms located on the
site https://allafilinaprosperity.com/prozvetsnie_uae or sent to the Oper- ator 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 Operatorprocesses 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 subjectof 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 carriedout 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 contracton the initiative of the subject or a contract under which the subjectwill 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 carriedout, access to which has been provided by the subject or at their request to an unlimited numberof 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 Operatorensures the safety of personaldata 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 executionof current legislation or if the subjecthas given consentto 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 yourgreat- life2025@gmail.com with the subject "Update of per- sonal 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 periodis provided for by contractor current legislation.
The User can withdraw their consent to the processing of personaldata at any time by sending a notification to the Operator via email to the Operator's email address yourgreatlife2025@gmail.com with the subject "With- drawal 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 providersmentioned 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 otherpublic interests.
10.7. The Operatorensures the confidentiality of personal data during their processing.
10.8. The Operatorstores personal data in a form that allows identification of the subject for no longerthan 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 Operatorwith 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 receivedinformation via information and telecommunication networks.
12. Cross-Border Transferof 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 reliableprotection 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 theirpersonal data and/or performance of a contractto which the subject is a party.
13. Confidentiality of PersonalData
The Operator and other personswho 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 ques- tions regarding the processing of their personaldata by contacting the Operator via email
at yourgreatlife2025@gmail.com
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.