PRIVACY POLICY

General Provisions

This Privacy Policy is drafted in accordance with the requirements of the Federal Law No. 152-FZ of July 27, 2006, “On Personal Data” and defines the procedure for the processing of personal data and the security measures undertaken by LLC «Sputnik Partnery» (OGRN 1187847380434, INN 7839110984, address: 190020, SAINT PETERSBURG, NABEREZHNAYA OBVODNOGO KANALA, HOUSE 199-201, LIT. K, ROOM 3N OFFICE 1) (hereinafter referred to as the Operator).

1.1. The Operator’s paramount goal and a fundamental condition for its operations is the observance of human and civil rights and freedoms when processing their personal data, including the protection of the rights to privacy, personal and family confidentiality.
1.2. This Operator’s policy regarding the processing of personal data (hereinafter – the Policy) applies to all information that the Operator may obtain about Users visiting and/or using the website located at: [Website URL].

Key Concepts Used in the Policy

2.1. Automated processing of personal data — processing of personal data by means of computer technology.
2.2. Blocking of personal data — temporary cessation of personal data processing (except for cases where processing is necessary to clarify personal data).
2.3. Website — an aggregate of graphic and informational materials, as well as computer programs and databases that ensure their availability on the Internet at the network address [Website URL].
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, 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 (update, change), 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, 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, the actions (operations) performed with personal data. In the context of this Policy, the Operator is LLC «Sputnik Partnery».
2.8. Personal data — any information relating directly or indirectly to a specific or identifiable User of the website [Website URL].
2.9. User — any individual visiting and/or using the website [Website URL].
2.10. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific circle of persons.
2.11. Dissemination of personal data — actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or at 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.
2.12. Cross-border transfer of personal data — the 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.
2.13. Destruction of personal data — any actions as a result of which personal data are destroyed irretrievably with the impossibility of further restoring the content of the personal data in the personal data information system and (or) as a result of which the material carriers of personal data are destroyed.

List of Processed Personal Data of the User

3.1. Last name, first name, patronymic (if applicable).
3.2. Email address.
3.3. Phone number.
3.4. Year, month, date, and place of birth.
3.5. Photographs.
3.6. Actual address of residence and registration at place of residence and/or place of stay.
3.7. Information about education, profession, specialty, and qualifications, details of educational documents.
3.8. Gender.
3.9. Username and password.
3.10. Payment details (credit/debit card number, bank account number, etc.).
3.11. The Website also collects and processes anonymized data about visitors (including “cookies”) using internet statistics services, as well as the following user data: location information; type and version of the operating system (OS); type and version of the browser; device type and screen resolution; the source from which the user arrived at the website; the referring website or advertisement; OS and browser language; pages opened and buttons clicked by the user; IP address.
3.12. The data listed above are hereinafter collectively referred to as Personal Data in this Policy.

Purposes of Personal Data Processing

4.1. The purpose of processing the User’s Personal Data is to inform the User via email; to conclude, execute, and terminate civil-law contracts; to provide the User with access to the services, information, and/or materials contained on the Website.
4.2. The Operator is also entitled to send the User notifications about new products and services, special offers, and various events. The User can always opt out of receiving informational messages by sending an email to the Operator at [Email Address] with the subject line “Opt-out of notifications about new products, services, and special offers.”
4.3. Anonymized User data collected through internet statistics services are used for gathering information about User activities on the Website, improving the quality of the Website and its content.
4.4. Compliance with and performance of contracts for the sale and purchase of goods acquired by you, or any other contracts between you and the Operator.
4.5. The personal data you provide may be used for the following purposes:
1) Responding to your inquiries.
2) Transfer to transport, courier, and/or logistics companies for the purpose of delivering goods.
3) Transfer to banks and other organizations and/or fiscal data operators for payment processing and sending receipts.
4) Providing you with information about products of LLC «Sputnik Partnery», sending commercial communications via email or other similar electronic channels (e.g., SMS), as well as making telephone calls.
5) If you provide us with personal data of a third party, you are responsible for informing them about the use of their data and for obtaining their explicit consent. If you have purchased a product or a gift card, the provided third-party data will be used for: (a) organizing delivery and/or verifying the correct receipt of the respective product; (b) responding to any of your inquiries or recommendations regarding the aforementioned product.
6) If you choose “cash on delivery” as the payment method, please note that in case of a return of purchased goods, you will need to provide some additional data (e.g., your bank account details), which will be processed solely for the purpose of refunding the cost of the goods. Where necessary, such bank details may be disclosed to third parties providing cross-border money transfer services, including but not limited to correspondent banks.
7) Activating mechanisms necessary to prevent and detect unauthorized use of the Website, for instance, during the purchase and return of goods, as well as potential fraudulent activities against you and/or the Operator. If a transaction is suspected to be fraudulent, or if unusual behavior indicating an attempt of fraudulent use of our components, products, or services is detected, such processing may lead to the transaction being blocked or your user account being deleted.
8) For invoicing and providing you with receipts and invoices for purchases made on the Website.
9) Personalizing the services we offer and enabling us to provide you with recommendations based on your interaction with the Website and the analysis of your user profile (e.g., based on your purchase history and browsing history). Similarly, for displaying online advertisements that you may see when visiting websites and applications, for example, on social networks. The advertisements you see may be random, but in some cases, they may be related to your preferences or your purchase and browsing history. If you use social networks, we may provide our partner companies with certain information to enable them to show you advertisements for LLC «Sputnik Partnery» and, in general, offer you and similar users advertisements that take into account your profile on those social networks. If you wish to learn more about the use of your data and how advertising works on social networks, we recommend reviewing the privacy policies of the social networks where you have profiles.
4.6. We also use your data for performing calculations and segment analysis of advertisements displayed to users on platforms of some of our partners. For this purpose, we cooperate with such third parties that provide us with the necessary technology (e.g., cookies, pixels, software development kits). Please note that while we do not provide these partners with personally identifiable data, we do provide them with a certain form of identification information each time (e.g., an advertising identifier linked to your device, a cookie-related identifier, etc.).
4.7. When we collect your personal data from various sources, we may, under certain circumstances, combine it to better understand your needs and preferences regarding our products and services (including for analysis, creating user profiles, marketing research, quality reviews, and improving our interactions with customers). This applies, for example, to how we combine your information if you have a registered account and, using the same email address linked to your account, you make a purchase without registration, or to information that is automatically compiled (such as IP and MAC addresses or metadata) and that we can link to data you provide directly through your actions on the Website (e.g., information related to your purchases, both in physical stores and online, your preferences, etc.).

Legal Grounds for Processing Personal Data

5.1. The Operator processes the User’s Personal Data only if it is provided and/or sent by the User independently through special forms located on the Website. By filling out the relevant forms and/or sending their Personal Data to the Operator, the User signifies their consent to this Policy.
5.2. The Operator processes anonymized data about the User if such processing is allowed in the User’s browser settings (saving “cookies” and using JavaScript technology are enabled).

Procedure for Collecting, Storing, Transferring, and Other Types of Processing of Personal Data

The security of Personal Data processed by the Operator is ensured through the implementation of legal, organizational, and technical measures necessary to fully comply with the requirements of current legislation in the field of personal data protection.
6.1. The Operator ensures the security of Personal Data and takes all conceivable measures to prevent unauthorized access to Personal Data.
6.2. The User’s Personal Data will under no circumstances be transferred to third parties, except for cases provided for by this Policy, cases related to the execution of a sales contract, or required by applicable law.
6.3. If inaccuracies in Personal Data are identified, the User may update them independently by sending a notification to the Operator’s email address [info@cosmodreams.com] with the subject line “Update of Personal Data.”
6.4. The period for processing Personal Data is unlimited. The User may at any moment withdraw their consent to the processing of Personal Data by sending a notification via email to the Operator at [info@cosmodreams.com] with the subject line “Withdrawal of consent to the processing of personal data.”

Cross-Border Transfer of Personal Data

7.1. Prior to commencing the cross-border transfer of Personal Data, the Operator is obliged to ensure that the foreign state, to whose territory the transfer of Personal Data is intended, provides adequate protection of the rights of personal data subjects.
7.2. Cross-border transfer of Personal Data to the territories of foreign states that do not meet the aforementioned requirements may be carried out only if the User provides written consent to the cross-border transfer of their Personal Data and/or in performance of a contract to which the User is a party.
7.3. By agreeing to this Policy, the User consents to the cross-border transfer of data, which is inherent due to the Operator being located (registered) in the Russian Federation.

Final Provisions

8.1. The User can obtain any clarifications on questions regarding the processing of their Personal Data by contacting the Operator via email at [info@cosmodreams.com].
8.2. This Policy is valid indefinitely until replaced by a new version.
8.3. The current version of the Policy is freely available on the Internet at [cosmodreams.com/privacy-policy/].