Privacy and Personal Data Processing Policy
Version of 15 September 2026
1. General Provisions
1.1.
This Personal Data Processing Policy (hereinafter, the "Policy") sets out the procedure for the processing and security of personal data by Individual Entrepreneur Vadim Sergeevich Guminsky (hereinafter, the "Operator") obtained in connection with the use of the website:
hereinafter, the "Website".
1.2.
The Policy has been developed in accordance with Federal Law No. 152-FZ of 27.07.2006 "On Personal Data" and applies to personal data that the Operator receives from Website users, customers, order recipients and other persons contacting the Operator via the Website.
1.3.
The purpose of the Policy is to ensure the protection of the rights and freedoms of individuals and citizens in the processing of their personal data, including the protection of the right to privacy.
1.4.
This Policy is a publicly available document and is posted on the Website in accordance with Article 18.1 of Federal Law No. 152-FZ.
1.5.
This Policy does not constitute the personal data subject's consent to the processing of personal data.
Where the legal basis for processing is the consent of the personal data subject, such consent is given separately in a form that makes it possible to confirm that it has been obtained.
1.6.
The Operator processes only the personal data that is necessary for a specific stated purpose of processing and does not allow the processing of personal data that is excessive in relation to that purpose.
2. Key Definitions
Personal data: any information relating to a directly or indirectly identified or identifiable individual.
Personal data operator: a person who, independently or jointly with other persons, organises and/or carries out the processing of personal data and determines the purposes of processing, the composition of the personal data and the actions performed with it.
Processing of personal data: any action or set of actions performed with personal data, including collection, recording, systematisation, accumulation, storage, clarification, retrieval, use, transfer, depersonalisation, blocking, deletion and destruction.
Automated processing of personal data: processing of personal data by means of computer technology.
Provision of personal data: actions aimed at disclosing personal data to a specific person or a specific group of persons.
Blocking of personal data: temporary suspension of the processing of personal data, except where processing is necessary to clarify the data.
Destruction of personal data: actions as a result of which it becomes impossible to restore the content of personal data in the personal data information system and/or as a result of which the physical media containing personal data are destroyed.
Cookie: data stored by the user's browser when visiting a website and used, in particular, to ensure the website's operation and for web analytics.
3. Information About the Operator
Personal data operator:
Individual Entrepreneur Vadim Sergeevich Guminsky
INN: 920454923920
Address:
236016, Kaliningrad Region, Kaliningrad, Elovaya Alleya St., Building 5A, Block 2, Apt. 74
E-mail address for personal data processing enquiries:
Website:
4. Key Principles of Personal Data Processing
The Operator processes personal data on a lawful and fair basis.
Processing is limited to the achievement of specific, predetermined and lawful purposes.
Processing of personal data that is incompatible with the purposes for which it was collected is not permitted.
The content and volume of the personal data processed correspond to the stated purposes of processing.
The Operator takes measures to ensure the accuracy and relevance of personal data.
Personal data is stored for no longer than its processing purposes require, unless a different period is established by federal law or by contract.
Once the purpose of processing has been achieved, personal data is destroyed or depersonalised, unless there is another lawful basis for continuing to process it.
5. Purposes of Personal Data Processing
5.1. Receiving Order Requests
Purpose of processing: receiving and processing the user's request, contacting the user to clarify the order and to conclude an agreement at the user's initiative.
Categories of personal data subjects:
Website users who have submitted an order request on their own initiative.
Category of personal data:
other personal data not belonging to special categories of personal data or to biometric personal data.
List of personal data processed:
- telephone number;
- name, if provided by the user;
- order details and the user's wishes, if provided by the user.
Legal basis:
Clause 5, Part 1, Article 6 of Federal Law No. 152-FZ: processing necessary for the conclusion of an agreement at the initiative of the personal data subject.
List of actions:
collection, recording, systematisation, accumulation, storage, clarification, retrieval, use, blocking, deletion and destruction.
Method of processing:
automated processing and processing without the use of automation tools.
Processing period:
until the request has been processed and the agreement concluded, or until interaction with the user has ended if no agreement is concluded.
If, once the purpose has been achieved, there is no other legal basis for processing, the personal data is destroyed within a period not exceeding 30 days.
Retention period:
until the purpose of processing specified in this clause has been achieved. If an agreement is concluded as a result of the request, further storage of the personal data required to place and fulfil the order is carried out in accordance with Clause 5.2 of this Policy.
If no agreement is concluded and there is no other legal basis for further storage, the personal data is destroyed within a period not exceeding 30 days after interaction with the user has ended.
5.2. Placing and Fulfilling Orders
Purpose of processing: placing, confirming and fulfilling the user's order.
Categories of personal data subjects:
- customers;
- order recipients who are other individuals specified by the Customer as Recipients of the Order and who act as beneficiaries under an agreement for the benefit of a third party with respect to receiving the Order.
Category of personal data:
other personal data.
List of personal data processed:
- recipient's name;
- telephone number;
- details of the selected goods;
- quantity of goods;
- order value;
- date and time of receipt of the order;
- details of the order receipt method;
- details and wishes relating to the order provided by the customer on their own initiative.
Legal basis:
Clause 5, Part 1, Article 6 of Federal Law No. 152-FZ: processing of personal data necessary for the conclusion and performance of an agreement to which the Customer is a party or under which the Recipient of the Order is a beneficiary.
List of actions:
collection, recording, systematisation, accumulation, storage, clarification, retrieval, use, provision where necessary for the performance of the agreement, blocking, deletion and destruction.
Method of processing:
with and without the use of automation tools.
Processing period:
until the obligations under the order have been fully performed.
Personal data contained in accounting or tax records and subject to mandatory retention in accordance with the legislation of the Russian Federation is stored for the period established by law.
An individual entrepreneur is required to keep accounting and tax data and the documents necessary for calculating and paying taxes for five years, unless a different period is provided for by law.
Other personal data is destroyed within a period not exceeding 30 days after the purpose of processing has been achieved, unless there is another lawful basis for processing it.
Retention period:
Personal data contained in accounting or tax records and subject to mandatory retention in accordance with the legislation of the Russian Federation is stored for the period established by law.
An individual entrepreneur is required to keep accounting and tax data and the documents necessary for calculating and paying taxes for five years, unless a different period is provided for by law.
Other personal data is destroyed within a period not exceeding 30 days after the purpose of processing has been achieved, unless there is another lawful basis for processing it.
5.3. Arranging Order Delivery
Purpose of processing: arranging delivery of the order to the address specified by the customer.
Categories of personal data subjects:
- customers;
- order recipients who are other individuals specified by the Customer as Recipients of the Order and who act as beneficiaries under an agreement for the benefit of a third party with respect to receiving the Order.
Category of personal data:
other personal data.
List of personal data processed:
- recipient's name;
- telephone number;
- city;
- street;
- building number;
- entrance;
- apartment or office;
- door code;
- floor;
- delivery date and time;
- order details to the extent necessary for its delivery.
These are exactly the fields actually present in your cart: the website requests the city, street, building, entrance, apartment/office, door code, floor, and the recipient's name and telephone number.
Legal basis:
Clause 5, Part 1, Article 6 of Federal Law No. 152-FZ: processing of personal data necessary for the performance of an agreement to which the Customer is a party or under which the Recipient of the Order is a beneficiary.
List of actions:
collection, recording, systematisation, accumulation, storage, retrieval, use, provision to the person directly carrying out the delivery, blocking, deletion and destruction.
Method of processing:
automated and non-automated processing.
Processing period:
until the delivery obligations have been performed.
Once the purpose has been achieved, the data is destroyed within a period not exceeding 30 days, unless there is another lawful basis for its further storage.
In order to fulfil a specific order, personal data may be provided to a courier or delivery service only to the extent necessary to carry out the delivery.
Retention period:
until the obligations under the relevant delivery have been performed. Once the purpose of processing has been achieved, the personal data is destroyed within a period not exceeding 30 days, unless there is another legal basis for its further storage.
5.4. Handling User Enquiries and Feedback
Purpose of processing: reviewing the user's enquiry and providing a response.
Categories of personal data subjects:
persons who have contacted the Operator on their own initiative.
Category of personal data:
other personal data.
List of personal data:
- name, if provided;
- telephone number, if provided;
- e-mail address, if provided;
- information contained in the enquiry and voluntarily provided by the personal data subject.
Legal basis:
if the enquiry is directly related to the conclusion or fulfilment of an order: Clause 5, Part 1, Article 6 of Federal Law No. 152-FZ;
in other cases: the consent of the personal data subject in accordance with Clause 1, Part 1, Article 6 of Federal Law No. 152-FZ.
List of actions:
collection, recording, storage, clarification, retrieval, use, blocking, deletion and destruction.
Method of processing:
automated and non-automated processing.
Processing period:
until the review of the enquiry has been completed.
If there is no other basis for further processing, the data is destroyed within a period not exceeding 30 days after the purpose has been achieved.
Retention period:
until the review of the enquiry has been completed and a response provided. If there is no other legal basis for further storage, the personal data is destroyed within a period not exceeding 30 days after the purpose of processing has been achieved.
5.5. Analysis of Website Traffic and Performance
Purpose of processing: obtaining statistical information about visits to the Website, analysing the use of the Website and improving its performance.
Categories of personal data subjects:
Website visitors who have consented to the use of web analytics programs.
Category of personal data:
other personal data.
The Website uses:
Yandex Metrica;
Top.Mail.Ru.
When Yandex Metrica is used, the following may be processed:
- cookies;
- browser identifiers;
- information stored in localStorage;
- IP address;
- device information;
- information about the operating system and its version;
- information about the user's activity on the Website;
- pages visited;
- the user's actions on the pages;
- date and time of the visit;
- other technical data transmitted when the service is used.
The terms of Yandex Metrica expressly state that, with respect to website visitors' data, the Metrica user is the personal data operator, while YANDEX LLC acts as a person processing the data on behalf of the operator.
When Top.Mail.Ru is used, the following may be processed:
- IP address;
- browser type;
- device type and model;
- operating system;
- system language;
- screen resolution;
- technical identifiers;
- location information determined by technical means;
- internet service provider;
- date and time of access;
- cookies;
- data obtained through pixels and JavaScript tags;
- information about pages visited;
- clicks, transitions and other actions on the Website.
These are precisely the categories of technical information listed by VK LLC in the current Top.Mail.Ru policy.
Legal basis for processing:
the consent of the personal data subject in accordance with Clause 1, Part 1, Article 6 and Article 9 of Federal Law No. 152-FZ.
Consent is given separately by the user when visiting the Website.
Until consent has been obtained, Yandex Metrica and Top.Mail.Ru must not process the visitor's personal data for web analytics purposes.
Declining consent to web analytics does not prevent the use of the Website's main functions or the placing of an order.
List of actions:
collection, recording, systematisation, accumulation, storage, clarification, retrieval, use, provision to a person processing data on behalf of the Operator, depersonalisation, blocking, deletion and destruction.
Method of processing:
automated processing.
Processing period:
until the personal data subject withdraws the relevant consent or until the Operator stops using the relevant web analytics program.
Once consent has been withdrawn, further collection of data by means of the relevant web analytics program ceases, unless there is another legal basis for processing.
Retention period:
until the personal data subject withdraws the relevant consent or until the Operator stops using the relevant web analytics program, unless there is another legal basis for further storage of the relevant personal data.
Once consent has been withdrawn, further collection of personal data by means of the relevant web analytics program ceases.
6. Consent to the Processing of Personal Data
6.1.
Where Federal Law No. 152-FZ provides for processing on the basis of consent, such consent is given by the user freely, of their own will and in their own interest.
6.2.
Consent must be specific, substantive, informed, conscious and unambiguous.
6.3.
Consent is given separately from other information and documents confirmed by the user.
6.4.
The Operator ensures that it is possible to confirm that consent has been obtained.
6.5.
Consent may be withdrawn by the personal data subject by sending a corresponding request to:
6.6.
If, after consent has been withdrawn, the Operator has no other legal basis for processing the personal data, processing ceases and the data is destroyed in the manner and within the time limits provided for by the legislation of the Russian Federation.
7. Use of Cookies and Web Analytics Programs
7.1.
For web analytics, the Website uses Yandex Metrica and Top.Mail.Ru technologies.
7.2.
On their first visit to the Website, the user is provided with information about the use of the above web analytics programs and the processing of personal data by means of them.
7.3.
Web analytics programs are launched only after the user's consent has been obtained.
7.4.
The user may refuse web analytics.
Such refusal must not prevent the user from browsing the Website or placing an order.
7.5.
The user may also restrict or delete cookies using their browser settings. Restricting cookies may affect the operation of certain Website functions.
8. Parties Involved in the Processing of Personal Data
8.1. Yandex Metrica
The web analytics service is provided by:
YANDEX LLC
16 Lva Tolstogo St., Moscow, 119021.
In accordance with the current terms of Yandex Metrica, YANDEX LLC processes visitors' personal data on behalf of the user of the Metrica service.
8.2. Top.Mail.Ru
The Top.Mail.Ru web analytics service is provided by:
VK LLC
OGRN 1027739850962
39 Leningradsky Prospekt, Bldg. 79, Moscow, 125167.
8.3. Delivery
Where delivery is required, the Operator provides the person directly carrying out the specific delivery only with the data necessary to fulfil the order:
the recipient's name, telephone number, delivery address, delivery date and time, and the information necessary to identify the relevant order.
8.4.
The Operator may provide personal data to government authorities in the cases and in the manner provided for by the legislation of the Russian Federation.
8.5.
The Operator does not disseminate personal data to an indefinite number of persons without a basis provided for by law.
9. Methods of Personal Data Processing
The Operator carries out:
automated processing of personal data;
processing of personal data without the use of automation tools;
mixed processing of personal data.
Depending on the specific purpose, the Operator may perform the following actions:
collection, recording, systematisation, accumulation, storage, clarification, updating, modification, retrieval, use, provision, depersonalisation, blocking, deletion and destruction of personal data.
10. Confidentiality and Security of Personal Data
10.1.
The Operator and other persons who have obtained access to personal data are obliged not to disclose it to third parties or disseminate it without the consent of the personal data subject, unless otherwise provided for by federal law.
10.2.
The Operator takes the necessary legal, organisational and technical measures to protect personal data against:
unlawful or accidental access;
destruction;
modification;
blocking;
copying;
provision;
dissemination;
other unlawful actions.
10.3.
Access to personal data is granted only to the extent necessary to perform the relevant function or processing purpose.
11. Rights of the Personal Data Subject
The personal data subject has the right to:
- receive information about the processing of their personal data;
- access their personal data in the cases provided for by law;
- demand the clarification of incomplete, inaccurate or outdated data;
- demand the blocking or destruction of personal data that has been obtained unlawfully or is not necessary for the stated purpose;
- withdraw previously given consent;
- demand the cessation of personal data processing in the cases provided for by law;
- appeal against the Operator's actions or omissions to Roskomnadzor or in court.
Requests and enquiries may be sent to:
The Operator provides the information required by law to the personal data subject or their representative within 10 working days from the date of receipt of the relevant request.
This period may be extended by no more than 5 working days if the subject is sent a reasoned notice stating the reasons for the extension.
12. Clarification, Cessation of Processing and Destruction of Personal Data
12.1.
If the inaccuracy of personal data is confirmed, the Operator clarifies the data or ensures that it is clarified within 7 working days.
12.2.
If unlawful processing is detected, the Operator ceases such processing or ensures that it ceases within a period not exceeding 3 working days.
If it is impossible to ensure that the processing is lawful, the relevant personal data is destroyed within a period not exceeding 10 working days.
12.3.
Once the purpose of processing has been achieved, the Operator ceases processing and destroys the personal data within a period not exceeding 30 days, unless retention of the data is required on another legal basis.
12.4.
If consent is withdrawn, the personal data is destroyed within a period not exceeding 30 days, unless its further storage is permitted on another legal basis.
12.5.
Upon receipt of a demand from the subject to cease processing of personal data, the Operator ceases processing within a period not exceeding 10 working days, except for the exceptions established by federal law.
12.6.
If it is impossible to destroy the personal data within the period established by law, the data is blocked and destroyed within a period of no more than six months, unless otherwise provided for by federal law.
These time limits are taken directly from the current Article 21 of Law No. 152-FZ.
12.7.
Personal data is destroyed by performing actions as a result of which it becomes impossible to restore the content of the personal data in the personal data information system and/or as a result of which the physical media containing the personal data are destroyed.
12.8.
The destruction of personal data is confirmed in the manner established by the legislation of the Russian Federation.
Where personal data is processed without the use of automation tools, the document confirming the destruction of personal data is a personal data destruction certificate.
Where personal data is processed using automation tools, the destruction of personal data is confirmed by a personal data destruction certificate and an extract from the event log of the personal data information system.
Where personal data is processed both with and without the use of automation tools, destruction is confirmed by a personal data destruction certificate and an extract from the event log of the personal data information system.
12.9.
The personal data destruction certificate and the extract from the event log of the personal data information system are kept for three years from the date the personal data was destroyed.
13. Collection and Storage of Personal Data of Citizens of the Russian Federation
When collecting personal data of citizens of the Russian Federation, including via the Internet, the requirements of Part 5 of Article 18 of Federal Law No. 152-FZ regarding the recording, systematisation, accumulation, storage, clarification and retrieval of personal data using databases located in the territory of the Russian Federation must be complied with.
14. Amendments to the Policy
14.1.
The Operator may amend this Policy in the event of changes in legislation, in the methods of personal data processing used, in the composition of information systems and services, or in the procedure for carrying out the Operator's activities.
14.2.
The new version of the Policy enters into force upon its publication on the Website, unless the version itself provides otherwise.
14.3.
The current version of the Policy is permanently and freely available on the Website at:
https://vsetortynazakaz.ru/politika-konfidencialnosti-i-obrabotki-personalnyh-dannyh
The vsetortynazakaz.ru website uses cookies and the web analytics services Yandex Metrica and top.mail.ru to analyze traffic and improve the website. By clicking “I agree”, you consent to the processing of data using these services. Learn more in the Personal Data Processing Policy.
