1. General provisions
This Policy defines how personal data is processed and what measures protect it, as applied by the operator: Fairy Walls LLC (the “Operator”). The Policy covers all personal data the Operator receives from website users and in connection with the use of the website. The Russian version of this document is the legally binding one.
2. Key concepts
- Personal data: any information relating directly or indirectly to an identified or identifiable individual.
- Processing: any operation performed on personal data, with or without automation, including collection, recording, systematisation, accumulation, storage, amendment, use, transfer, blocking, deletion and destruction.
- Operator: a legal entity that organises processing and determines its purposes and scope.
- Data subject: the individual to whom the personal data relates.
- Anonymisation: actions that make it impossible to attribute data to a specific subject.
3. Legal grounds
- Federal Law No. 152-FZ of 27 July 2006 “On Personal Data” and other applicable Russian legislation.
- The data subject's consent to processing, given in a separate document, as well as consent given through the use of the website, including acknowledgement of the cookie notice.
- Processing necessary to perform a contract to which the subject is a party, or to conclude one at the subject's initiative.
4. Purposes of processing
The Operator processes personal data solely for the following purposes:
- responding to an enquiry submitted through the website's contact form;
- preparing and sending a commercial proposal at the subject's request;
- concluding and performing contracts to which the subject is a party;
- assessing the demand for the website's content from visit statistics and improving the website;
- keeping the website operational and secure.
5. Categories of subjects and scope of data
The Operator processes data of the following categories of subjects: website visitors, representatives of counterparties and those who contact us through the form. The scope is determined by the enquiry and includes a name, company name, contact detail (email or phone) and the text of the message. Where the web analytics service is used, technical visit data is also processed: cookie identifiers, the IP address, and information about the browser, device and pages viewed. The Operator does not process special categories of personal data, biometric data or data of minors.
6. How processing is carried out
Processing is carried out by mixed means, with and without automation. Data from the contact form is delivered to a secure corporate channel of the Operator. Form data is not stored on the website server: it is used only to the extent needed to answer the enquiry. The Operator does not make decisions producing legal consequences for the subject on the basis of automated processing alone.
7. Cookies
The website uses functional cookies required for its operation: remembering the chosen colour theme and language version. To assess demand for the content, the Yandex Metrica web analytics service is loaded: it processes the technical visit data listed in section 5. The website does not use advertising cookies. See the cookie notice for details.
8. Transfer to third parties
To keep visit statistics the Operator uses the Yandex Metrica service: the technical data listed in section 5 is shared with that service. Otherwise the Operator does not transfer personal data to third parties except where expressly required by Russian law, or where persons act on the Operator's instructions subject to confidentiality and data security requirements.
9. Localisation and cross-border transfer
When collecting personal data of Russian citizens, the Operator ensures that recording, systematisation, accumulation, storage, amendment and retrieval of such data use databases located in the territory of the Russian Federation. The Operator does not carry out cross-border transfer of personal data.
10. Retention and destruction
Personal data is processed until the purposes are achieved, until the subject withdraws consent, or until a period established by law expires. Once the purpose is achieved or consent is withdrawn, the data is destroyed or anonymised within thirty days, unless the law provides otherwise.
11. Rights of the data subject
The subject has the right to:
- obtain information concerning the processing of their personal data;
- require amendment, blocking or destruction of data that is incomplete, outdated, inaccurate, unlawfully obtained or unnecessary for the stated purpose;
- withdraw consent to the processing of personal data;
- appeal the Operator's actions to the authorised data protection authority or in court.
12. Security measures
The Operator takes the legal, organisational and technical measures needed to protect personal data from unlawful or accidental access, destruction, alteration, blocking, copying, disclosure and dissemination. Access is limited to those who need it to perform their duties.
13. Changes and contacts
The Operator may amend this Policy. The current version is always available on this page. Enquiries about personal data processing should be sent to the email address shown in the Operator's details below.