We operate in Russia, the CIS, and internationally
This privacy policy on the processing of personal data is drafted in accordance with the requirements of Federal Law No. 152-FZ “On Personal Data” dated July 27, 2006 (hereinafter referred to as the Personal Data Law) and defines the procedure for processing personal data and the measures taken by Themis (hereinafter referred to as the Operator) to ensure the security of personal data.
1.1. The Operator considers the observance of human and civil rights and freedoms in the processing of personal data as one of its most important goals and conditions for carrying out its activities, including the protection of the right to privacy, personal and family secrecy.
1.2. This Privacy Policy (hereinafter referred to as the Policy) applies to all information that the Operator may receive about visitors to the website https://themis.su.
2.1. Automated processing of personal data – processing of personal data using computer technology.
2.2. Blocking of personal data – temporary suspension of the processing of personal data (except when processing is necessary to clarify personal data).
2.3. Website – a collection of graphic and informational materials, as well as software and databases that ensure their availability on the Internet at https://themis.su.
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. Depersonalization of personal data – actions that make it impossible to determine, without additional information, the affiliation of personal data to a specific user or another 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 on personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, 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 who, independently or jointly with others, organizes and/or carries out the processing of personal data, as well as determines the purposes of processing personal data, the composition of personal data subject to processing, and the actions (operations) performed with personal data.
2.8. Personal data – any information related directly or indirectly to an identified or identifiable user of the website https://themis.su.
2.9. Personal data authorized by the data subject for distribution – personal data that the data subject has made available to an unlimited number of persons by giving consent to the processing of such data in accordance with the Personal Data Law (hereinafter referred to as Personal Data Authorized for Distribution).
2.10. User – any visitor to the website https://themis.su.
2.11. Provision of personal data – actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Distribution of personal data – any actions aimed at disclosing personal data to an indefinite number of persons (transmission of personal data) or making personal data available to an indefinite number of persons, including publication in mass media, placement in information and telecommunication networks, or providing access to personal data in any other way.
2.13. Cross-border transfer of personal data – transfer of personal data to a foreign country, to a foreign government authority, a foreign individual, or a foreign legal entity.
2.14. Destruction of personal data – any actions resulting in the irreversible destruction of personal data, making it impossible to restore the content of personal data in the personal data information system and/or destroying the material media containing personal data.
3. Main Rights and Obligations of the Operator
3.1. The Operator has the right to:
— Receive accurate information and/or documents containing personal data from the data subject;
— In the event of the data subject withdrawing consent for the processing of personal data or submitting a request to cease processing, the Operator has the right to continue processing personal data without the subject’s consent if there are legal grounds as specified in the Personal Data Law;
— Independently determine the scope and list of necessary and sufficient measures to ensure compliance with the obligations established by the Personal Data Law and related regulatory legal acts unless otherwise provided by the Personal Data Law or other federal laws.
3.2. The Operator is obliged to:
— Provide the data subject, upon request, with information related to the processing of their personal data;
— Organize the processing of personal data in accordance with the applicable laws of the Russian Federation;
— Respond to inquiries and requests from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
— Provide the authorized body for the protection of personal data subjects’ rights with the necessary information within 10 days of receiving such a request;
— Publish or otherwise ensure unrestricted access to this Policy regarding personal data processing;
— Take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, alteration, blocking, copying, dissemination, or other unlawful actions;
— Cease the transfer (dissemination, provision, access) of personal data, stop processing, and destroy personal data in the manner and cases prescribed by the Personal Data Law;
— Fulfill other obligations stipulated by the Personal Data Law.
4. Main Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects have the right to:
— Obtain information regarding the processing of their personal data, except in cases provided by federal law. The information is provided by the Operator in an accessible form and must not contain personal data of other subjects unless there are legal grounds for disclosing such data. The list of information and the procedure for obtaining it is established by the Personal Data Law;
— Request that the Operator correct, block, or delete their personal data if it is incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the declared processing purpose, as well as take legal measures to protect their rights;
— Require prior consent for the processing of personal data for the purposes of marketing goods, works, and services;
— Withdraw consent for the processing of personal data and submit a request to stop processing their personal data;
— File complaints with the authorized body for the protection of personal data subjects’ rights or in court regarding unlawful actions or inactions of the Operator in processing their personal data;
— Exercise other rights provided by the laws of the Russian Federation.
4.2. Personal data subjects are obliged to:
— Provide the Operator with accurate information about themselves;
— Notify the Operator of any updates (corrections, changes) to their personal data.
4.3. Individuals who have provided the Operator with false information about themselves or data about another personal data subject without the latter’s consent are liable under Russian law.
5. Principles of Personal Data Processing
5.1. Personal data processing is carried out on a lawful and fair basis.
5.2. Personal data processing is limited to achieving specific, predetermined, and lawful purposes. The processing of personal data that is incompatible with the purposes of data collection is not allowed.
5.3. The combination of databases containing personal data, where processing is carried out for purposes incompatible with each other, is not allowed.
5.4. Only personal data that meets the purposes of its processing is subject to processing.
5.5. The content and scope of processed personal data must correspond to the declared purposes of processing. Processing excessive personal data in relation to the declared purposes is not allowed.
5.6. When processing personal data, its accuracy, sufficiency, and, when necessary, relevance to the purposes of processing must be ensured. The Operator takes necessary measures to delete or clarify incomplete or inaccurate data.
5.7. Personal data is stored in a form that allows the identification of the data subject for no longer than required for the processing purposes unless a different storage period is established by federal law, a contract, or another legal basis. Processed personal data is destroyed or anonymized upon achieving the processing goals or if the need for their achievement is lost unless otherwise provided by federal law.
6. Purposes of Personal Data Processing
| Purpose of Processing | Personal Data | Legal Grounds | Types of Processing |
|---|---|---|---|
| Order details clarification | Full name, email, phone number | Federal Law “On Information, Information Technologies, and Information Protection” No. 149-FZ of 27.07.2006 | Transfer of personal data |
7. Conditions for Personal Data Processing
7.1. Personal data processing is carried out with the consent of the personal data subject.
7.2. Personal data processing is necessary to achieve goals provided for by an international treaty of the Russian Federation or law, as well as for the Operator to fulfill functions, powers, and obligations established by Russian legislation.
7.3. Personal data processing is necessary for the administration of justice, enforcement of a judicial act, or execution of an act of another authority or official in accordance with the Russian law on enforcement proceedings.
7.4. Personal data processing is necessary for the performance of a contract where the data subject is a party, beneficiary, or guarantor, as well as for concluding a contract at the request of the data subject or a contract under which the data subject will be a beneficiary or guarantor.
7.5. Personal data processing is necessary for the realization of the Operator’s or third parties’ rights and legitimate interests or for achieving socially significant goals, provided that the rights and freedoms of the personal data subject are not violated.
7.6. Processing is carried out for personal data that has been made publicly available by the data subject or at their request (hereinafter referred to as publicly available personal data).
7.7. Processing is carried out for personal data subject to publication or mandatory disclosure under federal law.
8. Procedures for the 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 fully comply with the requirements of the current legislation in the field of personal data protection.
8.1. The Operator ensures the security of personal data and takes all possible measures to prevent unauthorized access to personal data.
8.2. The personal data of the User will never be transferred to third parties, except in cases related to the fulfillment of applicable laws or when the subject of the personal data has given consent to the Operator for the transfer of data to third parties for the fulfillment of obligations under a civil law contract.
8.3. In case of inaccuracies in personal data, the User can update them independently by sending a notification to the Operator’s email address at ok@themis.su with the subject “Update of Personal Data.”
8.4. The term for processing personal data is determined by the achievement of the goals for which the personal data were collected, unless a different term is provided by the contract or applicable law. The User may revoke their consent to the processing of personal data at any time by sending a notification to the Operator’s email address at ok@themis.su with the subject “Revocation of Consent to Process Personal Data.”
8.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by these entities (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data and/or the relevant documents are available to them. The Operator is not responsible for the actions of third parties, including those mentioned in this clause.
8.6. Any restrictions set by the subject of personal data on the transfer (except for access provision) or on the processing or conditions for processing (except for access) of personal data authorized for distribution do not apply in cases of processing personal data in the interests of the state, public, and other public interests defined by the legislation of the Russian Federation.
8.7. The Operator ensures the confidentiality of personal data when processing them.
8.8. The Operator stores personal data in a form that allows identification of the subject of personal data no longer than is required for the purposes of processing personal data unless the storage period is established by federal law, a contract, or a party, beneficiary, or guarantor of the contract involving the subject of personal data.
8.9. The condition for the termination of the processing of personal data may be the achievement of the goals of processing personal data, the expiration of the consent of the subject of personal data, the withdrawal of consent by the subject of personal data, or a request to terminate the processing of personal data, as well as the detection of unlawful processing of personal data.
9. List of Actions Performed by the Operator with Received Personal Data
9.1. The Operator carries out the collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (dissemination, provision, access), anonymization, blocking, deletion, and destruction of personal data.
9.2. The Operator performs automated processing of personal data, including the receiving and/or transferring of information through information and telecommunication networks or without such.
10. Cross-Border Transfer of Personal Data
10.1. Before beginning cross-border transfer activities, the Operator must notify the authorized body for the protection of the rights of personal data subjects about its intention to carry out cross-border transfer of personal data (this notification is sent separately from the notification about the intention to process personal data).
10.2. Before submitting the above notification, the Operator must obtain the corresponding information from the authorities of a foreign state, foreign individuals, and foreign legal entities to whom the cross-border transfer of personal data is intended.
11. Confidentiality of Personal Data
The Operator and other persons who have access to personal data are obligated not to disclose personal data to third parties or distribute them without the consent of the subject of the personal data, unless otherwise provided by federal law.
12. Final Provisions
12.1. The User can receive any clarifications regarding the processing of their personal data by contacting the Operator via email at ok@themis.su.
12.2. This document will reflect any changes in the Operator’s policy regarding the processing of personal data. The Policy is valid indefinitely until replaced by a new version.
12.3. The current version of the Policy is available in free access on the Internet at https://themis.su/privacy.
