Privacy Policy

1. General Provisions

This personal data processing policy has been drawn up in accordance with the requirements of the Federal Law No. 152-FZ “On Personal Data” from July 27, 2006 (hereinafter referred to as the Law on Personal Data), and determines the procedure for processing personal data and measures to ensure the security of personal data taken by Arto LLC (hereinafter referred to as the Operator).

1.1. The Operator sets as its most important goal and condition for the implementation of its activities the observance of the rights and freedoms of a person and a citizen in the processing of their personal data, including the protection of the rights to privacy, personal and family secrets.

1.2. The present Operator's policy regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information about visitors to the website https://aesthet.ae that the Operator can obtain.

2. Basic Terms Used in the Policy

2.1. Automated processing of personal data – processing of personal data using computer technology.

2.2. Blocking of personal data – a temporary suspension of the personal data processing (unless the processing is required to clarify personal data).

2.3. Website – a set of graphic and informational materials, as well as computer programs and databases that ensure their availability on the Internet at the network address https://aesthet.ae.

2.4. Personal data information system – a set of personal data contained in databases as well as information technologies and technical means that ensure their processing.

2.5. Depersonalization of personal data – actions by which one cannot determine, without the use of additional information, the ownership of personal data by 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, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion and 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 the personal data processing, the composition of personal data to be processed, the 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://aesthet.ae.

2.9. Personal data permitted for dissemination by the subject of personal data – personal data, access to which of an unlimited number of persons is provided by the subject of personal data by giving consent to the processing of personal data permitted by the subject of personal data for dissemination in the manner prescribed by the Law on Personal Data (hereinafter referred to as Personal Data Permitted for Dissemination).

2.10. User – any visitor to the website https://aesthet.ae.

2.11. Providing personal data – actions aimed at disclosing personal data to a certain person or a certain 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 with personal data of an unlimited number of persons, including the disclosure of personal data in the media, placement in the information and telecommunication networks or providing access to personal data in any other way.

2.13. Cross-border transfer of personal data – the 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 by which personal data is irretrievably destroyed with no possible further restoration of the content of personal data in the personal data information system, and (or) when material media bearing the personal data are destroyed.

3. Main Rights and Obligations of the Operator

3.1. The Operator has the right to:

– receive reliable information and/or documents containing personal data from the subject of personal data;

– in the event that the subject of personal data withdraws consent to the processing of personal data, the Operator has the right to continue processing personal data without the consent of the subject of personal data if there are grounds specified in the Law on Personal Data;

– independently determine the composition and list of measures required and sufficient to ensure the fulfillment of the obligations provided for by the Law on Personal Data and the connected regulatory legal acts, unless otherwise provided for by the Law on Personal Data or other federal laws.

3.2. The Operator is obliged to:

– provide the subject of personal data, at their request, with information regarding the processing of their personal data;

– arrange the processing of personal data in the manner prescribed by the current legislation of the Russian Federation;

– respond to appeals and requests from the subjects of personal data and their legal representatives in accordance with the requirements of the Law on Personal Data;

– report to the authorized body for the protection of the rights of personal data subjects, at the request of this body, the desired information within 30 days from the date of the request receipt;

– 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 unauthorized or accidental access, destruction, modification, blocking, copying, provision and distribution of personal data, as well as from other illegal actions in relation to personal data;

– stop the transfer (distribution, provision, access) of personal data and their processing, as well as destroy personal data in the manner and cases provided for by the Law on Personal Data;

– perform other duties stipulated by the Law on Personal Data.

4. Main Rights and Obligations of the Subjects of Personal Data

4.1. Subjects of personal data have the right to:

– receive information on the processing of their personal data, except for otherwise provided by federal laws. The Operator in an accessible form provides the information to the subject of personal data, and the information should not contain personal data related to other subjects of personal data, unless there are legal grounds for disclosing these personal data. The list of information and the obtaining procedure is established by the Law on Personal Data;

– require the Operator to clarify their personal data, block or destroy them if the personal data is incomplete, outdated, inaccurate, illegally obtained or not required for the stated purpose of processing, as well as take legal measures to protect their rights;

– put forward the requirement of prior consent when processing the personal data to promote goods, works and services in 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 illegal actions or inaction of the Operator in the processing of their personal data;

– exercise other rights stipulated by the legislation of the Russian Federation.

4.2. Subjects of personal data are obliged to:

– provide the Operator with accurate information about themselves;

– notify the Operator about the clarification (update, change) of their personal data.

4.3. Persons who have provided the Operator with inaccurate information about themselves or information about another subject of personal data without the consent of the latter are liable in accordance with the legislation of the Russian Federation.

5. The Operator may process the following personal data of the User

5.1. Full name.

5.2. Email address.

5.3. Phone numbers.

5.4. The website also collects and processes anonymous data about visitors (including cookies) using Internet statistics services (Yandex Metrika, Google Analytics, etc.).

5.5. The above data hereinafter are united by the general concept of Personal Data.

5.6. The Operator does not perform the processing of special categories of personal data relating to race, nationality, political views, religious or philosophical beliefs, and intimate life.

5.7. Processing of personal data permitted for dissemination from among the special categories of personal data specified in Part 1 of Article 10 of the Law on Personal Data is allowed if it complies with the prohibitions and requirements provided for in Article 10.1 of the Law on Personal Data.

5.8. The User's consent to the processing of personal data permitted for dissemination is issued separately from other consents to the processing of their personal data. At the same time, it should comply with the conditions stipulated, in particular, in Article 10.1 of the Law on Personal Data. Requirements for the content of such consent are established by the authorized body for the protection of the rights of personal data subjects.

5.8.1. Consent to the processing of personal data permitted for dissemination is provided by the User to the Operator directly.

5.8.2. The Operator is obliged, no later than three working days from the date of receipt of the specified consent of the User, to publish information on the conditions of processing, on the existence of prohibitions and requirements for the processing by an unlimited number of persons, of personal data permitted for dissemination.

5.8.3. The transfer (distribution, provision, access) of personal data permitted by the subject of personal data for dissemination must be terminated at any time at the request of the subject of personal data. This requirement should include the last name, first name, patronymic (if any), contact information (phone number, email address or postal address) of the subject of personal data, as well as the list of personal data, the processing of which is subject to termination. The personal data specified in this request can be processed only by the Operator to which it is addressed.

5.8.4. Consent to the processing of personal data permitted for dissemination terminates from the moment the Operator receives the request specified in clause 5.8.3 of this Policy regarding the processing of personal data.

6. Principles of Personal Data Processing

6.1. Processing of personal data is carried out on a legal and fair basis.

6.2. The processing of personal data is limited to the achievement of specific, predetermined and legitimate purposes. Processing of personal data incompatible with the purposes of collecting personal data is not allowed.

6.3. It is not allowed to combine databases containing personal data, the processing of which is carried out for purposes that are incompatible with each other.

6.4. Only personal data that meet the purposes of their processing are subject to processing.

6.5. The content and scope of the processed personal data correspond to the stated purposes of processing. The redundancy of the processed personal data in relation to the stated purposes of their processing is not allowed.

6.6. When processing personal data, the accuracy of personal data, their sufficiency, and, if necessary, relevance in relation to the purposes of personal data processing, are ensured. The Operator takes the necessary measures and/or ensures their adoption to remove or clarify incomplete or inaccurate data.

6.7. The storage of personal data is performed in a form that allows determining the subject of personal data, no longer than required by the purposes of personal data processing, if the period for storing personal data is not established by federal law or an agreement to which the subject of personal data is a party, beneficiary or guarantor. The processed personal data are destroyed or depersonalized upon reaching the goals of their processing or in the event of losing the need to achieve these goals, unless otherwise provided by federal 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 the services, information and/or materials contained on the website https://aesthet.ae.

7.2. The Operator also has the right to send the User notifications 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 [email protected] with the note “Refusal of notifications about new products, services and special offers”.

7.3. Anonymized data of Users collected using Internet statistics services are used to collect information about the Users’ actions on the website, improve the website quality and content.

8. Legal Grounds for Personal Data Processing

8.1. The legal grounds for the processing of personal data by the Operator are as follows:

– statutory (constituent) documents of the Operator;

– contracts concluded between the Operator and the subject of personal data;

– federal laws, other regulatory legal acts for personal data protection;

– consent of Users to the processing of their personal data, to the processing of personal data permitted for dissemination.

8.2. The Operator processes the User's personal data only if they are filled out and/or sent by the User independently through special forms on the website https://aesthet.ae or sent to the Operator by e-mail. 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 User’s data if it is allowed in the User's browser settings (if saving cookies and using JavaScript technology are enabled).

8.4. The subject of personal data independently decides on the provision of their personal data and gives consent freely, of his own free will and in his own interest.

9. Terms of Personal Data Processing

9.1. The processing of personal data is performed with the consent of the subject of personal data to the processing of their personal data.

9.2. The processing of personal data is required to achieve the goals stipulated by an international treaty of the Russian Federation or the law, to carry out the functions, powers and obligations assigned to the Operator by the legislation of the Russian Federation.

9.3. The processing of personal data is required for the administration of justice, the execution of a judicial act, an act of another body or official, subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.

9.4. The processing of personal data is required for the execution of an agreement to which the subject of personal data is a party or beneficiary or guarantor, as well as for the conclusion of an agreement on the initiative of the subject of personal data or an agreement under which the subject of personal data will be the beneficiary or guarantor.

9.5. The processing of personal data is required to exercise the rights and legitimate interests of the Operator or third parties, or to achieve socially significant goals, provided that the rights and freedoms of the subject of personal data are not violated.

9.6. It shall be performed the processing of personal data, the access of an unlimited number of persons to which is provided by the subject of personal data or at their request (hereinafter referred to as Publicly Available Personal Data).

9.7. It shall be performed the processing of personal data, subject to publication or mandatory disclosure in accordance with the federal law.

10. Procedure for Collection, Storage, Transfer and Other Types of Personal Data Processing

The security of personal data processed by the Operator is ensured through the implementation of legal, organizational and technical measures to fully comply with the requirements of the current legislation for 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 no circumstances, be transferred to third parties, except for the cases with the implementation of applicable law or if the subject of personal data has given consent to the Operator to transfer their data to a third party to fulfill obligations under a civil law contract.

10.3. In the event of detection of inaccuracies in personal data, the User can update them independently by sending the Operator a notification to the Operator’s e-mail address [email protected] with the note “Updating personal data”.

10.4. The period for the processing of personal data is determined by the achievement of the purposes for which the personal data were collected, unless a different period is provided by the contract or applicable law.

The User may withdraw at any time his consent to the processing of personal data by sending the Operator an email notification to the Operator’s e-mail address [email protected] with the note "Withdrawal of consent to the processing of personal data".

10.5. All information collected by third-party services, including payment systems, means of communication 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 should independently familiarize themselves with the specified documents in a timely manner. The Operator is not responsible for the actions of third parties, including the service providers specified in this paragraph.

10.6. The prohibitions established by the subject of personal data on the transfer (except for granting access), as well as on the processing or terms of processing (except for obtaining access) of personal data permitted for dissemination, do not apply in cases of processing personal data in state and public interests determined by the legislation of the Russian Federation.

10.7. When processing personal data, the Operator ensures the privacy of personal data.

10.8. The Operator stores personal data in a form that allows to determine the subject of personal data, no longer than required by the purposes of personal data processing, if the period for storing personal data is not established by the federal law or an agreement to which the subject of personal data is a party, beneficiary or guarantor.

10.9. The condition for terminating the processing of personal data may be the achievement of the purposes of personal data processing, the expiration of the consent of the personal data subject or the withdrawal of consent by the subject of personal data, as well as the identification of unlawful processing of personal data.

11. List of Actions Performed by the Operator with the Obtained Personal Data

11.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), extracts, uses, transfers (distributes, provides, accesses), depersonalizes, blocks, deletes and destroys personal data.

11.2. The Operator performs automated processing of personal data with the receipt and/or transfer of the received information via the information and telecommunication networks or without it.

12. Cross-border Transfer of Personal Data

12.1. Before the start of the cross-border transfer of personal data, the Operator must make sure that the foreign state, to the territory of which the transfer of personal data shall be performed, provides reliable protection of the rights of personal data subjects.

12.2. Cross-border transfer of personal data on the territory of foreign states that do not meet the above requirements can be carried out only if there is a written consent of the subject of personal data to the cross-border transfer of their personal data and/or execution of an agreement to which the subject of personal data is a party.

13. Personal Data Privacy

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

14. Final Provisions

14.1. The User can receive any clarifications regarding the processing of their personal data by contacting the Operator via email at: [email protected].

14.2. This document will reflect any changes in the policy of processing personal data by the Operator. The policy is valid indefinitely until it is updated with a new version.

14.3. The current version of the Policy is freely available on the Internet at https://aesthet.ae/en/privacy/.