Policy on personal data processing

1. General Provisions
This policy on processing of personal data is prepared in accordance with the generally accepted requirements of the Personal Data Law (hereinafter the "Personal Data Law") and defines the procedure for processing of personal data and the measures for ensuring security of personal data undertaken by AI Matuco Tobacco Company (hereinafter the "Operator").
1.1 The Operator's most important goal and condition for conducting its activities is to respect the rights and freedoms of individuals and citizens when processing their personal data, including protection of the rights to privacy, personal and family secrets.
1.2 This Operator's policy regarding the processing of personal data (hereinafter the "Policy") applies to all information which the Operator may receive about visitors to the almatuco.com website.

2. Basic concepts used in this Policy
2.1 Automated processing of personal data means processing of personal data by means of computer equipment.
2.2 Blocking of personal data means temporary termination of processing of personal data (except in cases where processing is necessary to clarify personal data).
2.3 Website means an aggregate of graphic and informational materials, as well as computer programs and databases, making them available on the Internet at the network address almatuco.com.
2.4 Personal data information system - a set of personal data contained in databases, and information technology and technical means ensuring their processing.
2.5 Anonymization of personal data - actions, as a result of which it is impossible to determine without the use of additional information, whether the personal data belongs to a particular User or another subject of personal data.
2.6 Processing of personal data - any action (operation) or set of actions (operations) performed with or without the use of automation means 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 means a state body, municipal authority, legal entity or individual, independently or jointly with other persons, arranging and (or) carrying out processing of personal data, as well as determining the purposes of processing of personal data, composition of personal data subject to processing, 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 almatuco.com.
2.9 Personal data, permitted by the subject of personal data for distribution, - personal data, access to which is granted to the general public by the subject of personal data by giving consent to the processing of personal data, permitted by the subject of personal data for distribution in the manner prescribed by law on personal data (hereinafter - personal data, permitted for distribution).
2.10. User - any visitor to almatuco.com.
2.11. Provision of personal data - actions aimed at disclosure of personal data to a certain person or a certain circle of persons.
2.12. Dissemination of personal data - any action aimed at disclosure of personal data to an indefinite range of persons (transfer of personal data) or to familiarize an unlimited number of persons with personal data, including the publication of personal data in the media, placing in information and telecommunications 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 a foreign state authority, a foreign individual or a foreign legal entity.
2.14. Destruction of personal data - any actions, as a result of which personal data is destroyed irretrievably with the impossibility of further restoration of the content of personal data in the information system of personal data and (or) destruction of material media of personal data.

3. Basic rights and obligations of the Operator
3.1 The operator has the right:
- receive from the subject of personal data reliable information and/or documents containing personal data;
- In case of revocation of the personal data subject's consent to the processing of personal data, the operator has the right to continue the processing of personal data without the consent of the personal data subject on the 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 regulations adopted in accordance therewith, unless otherwise provided by the Personal Data Law or other local laws.
3.2 The operator is obliged:
- provide to the subject of personal data, at his/her request, information relating to the processing of his/her personal data;
- Organize the processing of personal data in the manner prescribed by applicable laws of the Operator's country;
- to respond to requests and inquiries of personal data subjects and their legal representatives, in accordance with the requirements of the Law on personal data;
- to inform on request the authorized body on protection of personal data subjects' rights, within 30 days from the date of receipt of such request, the necessary information
- Publish or otherwise ensure unrestricted access to this Policy on personal data processing
- Take legal, organizational and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, distribution of personal data, as well as other illegal actions in relation to 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 subjects of personal data
4.1 The subjects of personal data have the right:
- To receive information relating to the processing of their personal data, except in cases provided for by local laws. The information is provided to the subject of personal data by the operator in an accessible form, and it must not contain personal data relating to other subjects of personal data, except in cases where there are legitimate grounds for disclosure of such personal data. The list of information and the procedure for obtaining it is established by the Personal Data Law;
- to require the operator to clarify his personal data, block or destroy them if the personal data is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing, as well as to take statutory measures to protect their rights;
- to put forward the condition of prior consent when processing personal data for the purpose of promoting goods, works and services on the market
- to withdraw the consent to the processing of personal data;
- to complain to the authorized body for protection of the rights of subjects of personal data or in court against unlawful acts or omissions of the Operator in the processing of his personal data
- To exercise other rights provided by the legislation of the Operator's country.
4.2 Subjects of personal data shall:
- provide the Operator with reliable data about themselves;
- Inform the Operator of the specification (updating, modification) of their personal data.
4.3 Persons, who provided the Operator with unreliable information about themselves, or information about another subject of personal data without the consent of the latter, shall be liable in accordance with the laws of the Operator's country.

5. The operator may process the following personal data of the User
Surname, first name, patronymic.
5.2 E-mail address.
5.3 Phone numbers.
5.4 The site also collects and processes visitors' anonymized data (including cookies) using Internet statistics services (Yandex Metrika and Google Analytics, etc.).
5.5 The above-mentioned data is hereinafter referred to in the Policy as Personal Data.
5.6 The Operator does not process special categories of personal data relating to race, ethnicity, political views, religious or philosophical beliefs, or intimate life.
5.7 The User's consent to the processing of personal data, which is allowed for distribution, is executed separately from other consents to the processing of his personal data. In this case, the conditions stipulated, in particular, by Article 10.1 of the Personal Data Law shall be observed. The requirements for the content of such consent shall be established by the competent authority for the protection of personal data subjects' rights.
5.7.1 The consent to the processing of personal data allowed for distribution, the User provides to the Operator directly.
5.7.2 The Operator is obliged within three working days from the receipt of the above consent of the User to publish information about the conditions of processing, the existence of prohibitions and conditions on the processing of personal data allowed for distribution to an unlimited number of persons.
5.7.3 Transfer (distribution, provision, access) of personal data, authorized by the subject of personal data for distribution, must be terminated at any time at the request of the subject of personal data. This requirement must include the surname, first name, patronymic (if any), contact information (telephone number, e-mail address or mailing address) of the subject of personal data, as well as a list of personal data, processing of which is to be terminated. The personal data specified in this request may only be processed by the Operator to which it is sent.
5.7.4 Consent to the processing of personal data authorized for dissemination shall cease to have effect from the moment the Operator receives the request, specified in paragraph 5.7.3 of this Policy in relation to the processing of personal data.

6. Principles of personal data processing
6.1 Processing of personal data shall be lawful and fair.
6.2 Processing of personal data is limited to achieving specific, predetermined and legitimate purposes. Processing of personal data that is incompatible with the purposes of personal data collection is not permitted.
6.3 Databases containing personal data, which are processed for purposes incompatible with each other, shall not be combined.
6.4 Only personal data that meets the purposes of processing shall be processed.
6.5 The content and scope of processed personal data shall comply with the stated processing purposes. Processed personal data shall not be excessive in relation to the stated processing purposes. 6.6.
When processing personal data, the accuracy of personal data, its sufficiency, and, if necessary, relevance in relation to the purpose of personal data processing shall be ensured. The operator shall take necessary measures and/or ensure that they are taken to remove or clarify incomplete or inaccurate data.
6.7 Personal data shall be stored in a form that identifies the personal data subject no longer than required by the purposes of personal data processing, unless a local law, contract, contract to which the personal data subject is a party, beneficiary or guarantor, establishes a storage period for the personal data. Processed personal data shall be destroyed or depersonalized upon attainment of the purposes of processing or when it is no longer necessary to attain those purposes, unless otherwise provided by law.

7. Purposes of personal data processing
7.1 The purpose of processing of personal data of the User:
- informing the User by sending emails;
- Conclusion, execution and termination of civil law contracts;
- giving the User access to the services, information and/or materials contained on the website almatuco.com.
7.2 Also the Operator has the right to send the User notifications about new products and services, special offers and different events. The User can always refuse receiving information messages by sending an email to Operator at Vinodkoul_vkoul@yahoo.com with a note "Refuse notifications about new products and services and special offers".
7.3 Anonymous User data collected via Internet statistics services is used to collect information about Users' actions on the site and to improve the quality of the site and its content.

8. Legal basis for processing of personal data
8.1 The legal basis for the processing of personal data by the Operator are:
- statutory documents of the Operator;
- Contracts concluded between the Operator and the subject of personal data;
- Local laws, other normative legal acts in the field of personal data protection;
- Users' consent to the processing of their personal data, to the processing of personal data allowed for distribution.
8.2 The operator processes the User's personal data only if the User fills in and/or sends the personal data via special forms on almatuco.com or via e-mail. By filling in the relevant forms and/or sending his personal data to the Operator the User expresses his consent to this Policy.
8.3 The Operator processes anonymised data about the User if this is permitted in the User's browser settings (cookie saving and the use of JavaScript technology are enabled).
8.4 The subject of personal data independently decides to provide his personal data and gives his consent freely, willingly and in his own interest.

9. Terms of personal data processing
9.1 Processing of personal data is carried out with the consent of the subject of personal data to the processing of their personal data.
9.2 Processing of personal data is necessary to achieve the goals stipulated by international treaties between countries in the field of personal data protection.
9.3 Processing of personal data is necessary for administration of justice, execution of a judicial act, act of another body or official to be executed in accordance with the legislation of the Operator's country.
9.4 Processing of personal data is necessary for execution of the contract, a party to which or a beneficiary or guarantor under which the subject of personal data is, as well as for conclusion of the contract on the initiative of the subject of personal data or the contract, under which the subject of personal data will be a beneficiary or guarantor.
9.5 Processing of personal data is necessary to exercise the rights and legitimate interests of the operator or third parties or to achieve socially important goals, provided that this does not violate the rights and freedoms of the subject of personal data.
9.6 Personal data shall be processed if access to such data is granted to an unlimited number of persons by or at the request of the personal data subject (hereinafter, "publicly available personal data").
9.7 Personal data subject to publication or compulsory disclosure in accordance with local law shall be processed.

10. Procedure for collection, storage, transfer and other processing of personal data
The security of personal data processed by the Operator is ensured by implementing legal, organizational and technical measures necessary to meet in full the requirements of current legislation in the field of personal data protection.
10.1 The operator provides safety of personal data and takes all possible measures which exclude access to personal data by unauthorized persons.
10.2 The personal data of the User shall never, under no circumstances be transferred to third parties, except in cases related to the implementation of the current legislation or if the subject of personal data has given consent to the Operator to transfer the data to a third party to fulfill obligations under a civil law contract.
10.3 In case of detected inaccuracies in the personal data, the User may update the personal data on their own, by sending a notice to the Operator's email address Vinodkoul_vkoul@yahoo.com with a note "Updating of personal data".
10.4 The period of processing of personal data is determined by the achievement of the purposes for which the personal data was collected, unless a different period is stipulated by the contract or by applicable law.
The user may withdraw his consent to the processing of personal data at any time by sending a notice via e-mail to the Operator's email address Vinodkoul_vkoul@yahoo.com with a note "Withdrawal of consent to the processing of personal data".
10.5 All information which is collected by third-party services, including payment systems, means of communication and other service providers, is stored and processed by the specified persons (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data and/or the User is obliged to get acquainted with the specified documents on his/her own in time. The Operator shall not be liable for the actions of third parties, including the service providers mentioned in this clause.
10.6 The prohibitions established by the personal data subject on the transfer (other than granting access), as well as on the processing or processing conditions (other than gaining access) of personal data allowed for distribution shall not apply in cases of processing of personal data in state, public and other public interests as defined by the legislation of the Operator's country.
10.7. The Operator ensures confidentiality of personal data when processing personal data.
10.8. The operator shall store personal data in a form which allows the identification of the subject of personal data, no longer than the purposes of personal data processing require, unless the period of storage of personal data is established by local law, contract, party to which, the beneficiary or guarantor of which is the subject of personal data.
10.9 The condition for termination of personal data processing may be achievement of personal data processing objectives, expiration of the personal data subject's consent or withdrawal of consent by the personal data subject, as well as identification of unlawful personal data processing.

11. The list of actions performed by the Operator with the received personal data
11.1. The operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), extracts, uses, transfers (distribution, provision, access), depersonalizes, blocks, deletes and destroys personal data.
11.2 The operator carries out automated processing of personal data with or without the receipt and/or transmission of received information via information and telecommunications networks.

12. Trans-border transfer of personal data
12.1 Before transborder transfer of personal data, the operator shall make sure that the foreign country, to the territory of which the transfer of personal data is intended, provides reliable protection of personal data subjects' rights.
12.2 The transborder transfer of personal data to foreign countries, which do not meet the above requirements, may take place only if the personal data subject consents in writing to the transborder transfer of his/her personal data and / or fulfillment of the contract, to which the personal data subject is a party.
13. Confidentiality of personal data
The operator and other persons who obtained access to personal data must not disclose to third parties and not disseminate personal data without the consent of the subject of personal data, unless otherwise provided by local law.
14. Final provisions
14.1 The user can obtain any clarifications on questions of interest regarding the processing of his or her personal data by contacting the Operator by e-mail at Vinodkoul_vkoul@yahoo.com.
14.2. This document will reflect any changes in the personal data processing policy of the Operator. The Policy is valid indefinitely until it is replaced by a new version.
14.3 The current version of the Policy is freely available on the Internet at almatuco.com.
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