Moscow August 10, 2021
determines the procedure for the processing and protection of personal data of the
Website Users and applies to all information that the website
https://nakedshoulders.com/, Individual Entrepreneur Anastasia Vladimirovna
Kravets, TIN 771775466047 (hereinafter referred to as the Website) can be obtained
about the User (the person gaining access to the information posted on the Website)
during the use of any of the services, facilities or products of the Website.
The usage of services of the Website means the User’s unconditional agreement with
this Policy and the conditions for processing their personal information specified
therein; in case of disagreement with the terms, the User must refrain from using
1. GENERAL PROVISIONS
1.1. Within this Policy the “End User Personal Information” means:
1.1.1. Personal information that the User provides about himself/herself when
registering (creating an account) or in the process of using the Services, including the
User’s personal data (including e-mail address; ID or passport number; landline
(mobile) phone number; postal address; payment details (credit/debit card number,
bank account number, etc.); username (login) and password; age (date of birth).
Information required for the provision of the Services is marked in a special way.
Other information is provided by the User in its sole discretion.
1.1.2. Data that are automatically transmitted to the services of the Website in the
course of their use using the software installed on the User’s device, including the IP
address, cookie data, information about the User’s browser (or other program through
which the services are accessed), technical characteristics of the equipment and
software used by the User, date and time of access to the services, addresses of the
requested pages and other similar information.
1.1.3. Other information about the User, the processing of which is provided for by the
Agreement on the use of the Website.
The Website does not control and is not responsible for third-party sites to which the
User can click on the links available on the Website.
2. PURPOSES OF PROCESSING OF PERSONAL INFORMATION OF USERS
2.1. The Website collects and stores only that personal information that is necessary
for the provision of services or the execution of agreements and contracts with the
User, except for cases where the legislation provides for the mandatory storage of
personal information for a period specified by law.
2.2. The Website processes the User’s personal information for the following
2.2.1. Identification of the User registered on the Website to place an order/service
and (or) conclude the Remote Sale and Purchase Agreement.
2.2.2. Providing the User with access to the personalized resources of the Website.
2.2.3. Establishing feedback with the User, including sending notifications, requests
regarding the use of the Website, delivery of goods, processing requests and
applications from the User.
2.2.4. Confirmation of the accuracy and completeness of the personal data provided by
2.2.5. Providing the User with effective customer and technical support in case of
problems related to the use of the Website and the delivery of purchased goods.
2.2.6. Implementation of promotional activities with the consent of the User.
3. TERMS OF PROCESSING OF PERSONAL INFORMATION OF USERS
AND ITS TRANSFER TO THIRD PARTIES
3.1. The Website stores personal information of Users in accordance with the internal
regulations of specific services.
3.2. The confidentiality of the User’s personal data is preserved unless the User
voluntarily provides access to personal information to the wide public. When using
certain services, the User agrees that a certain part of his personal information
becomes publicly available.
3.3. The Website may transfer the User’s personal information to third parties in the
3.3.1. The user has agreed to such actions.
3.3.2. The transfer is necessary for the User to use a certain service or to perform a
certain agreement or contract with the User.
3.3.4. The transfer is provided for by Russian or other applicable legislation within the
framework of the procedure established by law.
3.3.5. In the event of the sale of the Website, the acquirer assumes all obligations to
comply with the terms of this Policy in relation to the personal information received.
3.4. The processing of the User’s personal data is carried out without any time limit in
any legal way, including in personal data information systems using automation tools
or without using such tools. The processing of personal data of Users is carried out in
accordance with Federal Law No. 152-FZ dated July 27, 2006 “On Personal Data”.
3.5. In case of loss or disclosure of personal data, the Website Administration shall
inform the User about the loss or disclosure of personal data.
3.6. The Website Administrator shall take all necessary and sufficient organizational
and technical measures to protect the User Personal Information from misuse or
accidental access, destruction, modification, blocking, copying, distribution, and other
illegal actions of third parties with it.
3.7. The Website Administration together with the User shall take all necessary
measures to prevent losses or other negative consequences caused by the loss or
disclosure of the User’s personal data.
3.8. The User agrees that the Website Administration has the right to transfer
personal data to third parties, in particular, courier services, postal organizations,
telecommunication operators, solely for the purpose of fulfilling the User’s order
placed on the Website.
3.9. If the User wants to withdraw his consent to the processing of personal data, they
must send a free-form application to the email address: firstname.lastname@example.org with
the subject line “Withdrawal of consent to the processing of personal data”.
4. OBLIGATIONS OF THE PARTIES
4.1. The User shall:
4.1.1. Provide information about personal data required to use the Website.
4.1.2. Update, supplement the information provided on personal data in case of
changes in this information.
4.2. The Website Administration shall:
4.2.1. Use the information received solely for the purposes specified in this Privacy
4.2.2. Ensure that confidential information is kept secret, not disclosed without the
prior written permission of the User, and not to sell, exchange, publish or disclose in
other possible ways the transferred personal data of the User, except as provided for
4.2.3. Take precautions to protect the confidentiality of the User’s personal data in
accordance with the procedure usually used to protect this type of information in the
existing business turnover.
4.2.4. Block personal data pertaining to the relevant User from the moment of request
of the User or their legal representative or an authorized agency for protection of
rights of personal data subjects for the verification period, in the event that unreliable
personal data or illegal actions have been revealed.
5. LIABILITY OF THE PARTIES
5.1. The Website Administration, which has not fulfilled its obligations, shall be liable
for losses incurred by the User in connection with the misuse of personal data, in
accordance with the legislation of the Russian Federation.
5.2. In case of loss or disclosure of confidential information, the Website
Administration shall not be liable if this confidential information:
5.2.1. Became public domain before its loss or disclosure.
5.2.2. Was received from a third party prior to its receipt by the Website
5.2.3. Was disclosed with the consent of the User.
6. SETTLING OF DISPUTES
6.1. Before applying to the court for settling disputes arising out of relationships
between the User of the Website and the Website Administration, filing a claim (i.e., a
written proposal for voluntary dispute settlement) shall be mandatory.
6.2. The recipient of the claim shall notify the claimant in writing of the results of the
consideration of the claim within 10 calendar days from the date of receipt of the
6.3. If an agreement is not reached, the dispute will be referred to the court in
accordance with the current legislation of the Russian Federation.
relationships between the User and the Website Administration.
7. ADDITIONAL TERMS
7.1. The Website Administration has the right to make modifications to this Privacy
Policy without the User’s consent.
mail address: email@example.com.
Updated on August 10, 2021.