Privacy Policy for the Processing of Personal Data
1. General Provisions
This personal data processing policy is drafted in accordance with the Federal Law of 27.07.2006 No. 152-FZ “On Personal Data” (hereinafter — the Personal Data Law) and defines the procedures for processing personal data and measures to ensure the security of personal data undertaken by Novex Group LLC (hereinafter — the Operator).
1.1. The Operator regards the observance of human and civil rights and freedoms in processing personal data, including the right to privacy, personal and family secrecy, as its most important goal and condition for conducting its activities.
1.2. This Policy regarding the processing of personal data (hereinafter — the Policy) applies to all information that the Operator may obtain about visitors to the website https://en-novexfood.ru.
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 — temporary cessation of personal data processing (except in cases where processing is necessary for clarification of personal data).
2.3. Website — a set of graphic and information materials, as well as computer programs and databases, ensuring their availability on the internet at https://en-novexfood.ru.
2.4. Personal data information system — a set of personal data contained in databases and IT solutions used for their processing.
2.5. Depersonalization of personal data — actions resulting in the inability to identify the subject of personal data without additional information.
2.6. Personal data processing — any action (operation) or set of actions performed with or without automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
2.7. Operator — a state or municipal body, legal or natural person that independently or jointly organizes and/or performs personal data processing and determines the purposes of processing, the content of personal data, and actions (operations) performed with them.
2.8. Personal data — any information directly or indirectly relating to an identified or identifiable user of the website https://en-novexfood.ru.
2.9. Personal data made publicly available by the subject — personal data for which the subject has granted access to an unlimited number of persons by providing consent under the Personal Data Law (hereinafter — publicly available personal data).
2.10. User — any visitor of the website https://en-novexfood.ru.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or group.
2.12. Dissemination of personal data — any actions aimed at disclosing personal data to an unlimited number of persons or allowing access to personal data, including their publication in media, internet, or any other means.
2.13. Cross-border transfer of personal data — transfer of personal data to the territory of a foreign country to a foreign authority, individual, or legal entity.
2.14. Destruction of personal data — actions rendering personal data irretrievable with no possibility of further recovery, including destruction of physical storage media.
3. Rights and Obligations of the Operator
3.1. The Operator has the right to:
— request accurate information/documents from the data subject;
— continue processing data even if consent is withdrawn, provided there are legal grounds under the Personal Data Law;
— independently determine the measures required for fulfilling legal obligations unless otherwise stipulated by federal law.
3.2. The Operator is obliged to:
— provide data subjects with information about data processing;
— organize data processing in accordance with applicable legislation;
— respond to data subject inquiries;
— report to the authorized agency upon request within 10 days;
— make this Policy publicly accessible;
— implement legal, organizational, and technical security measures;
— cease the dissemination and processing of data when legally required;
— fulfill other obligations under the Personal Data Law.
4. Rights and Obligations of Personal Data Subjects
4.1. Data subjects have the right to:
— access their personal data (except in cases specified by law);
— request clarification, blocking, or destruction of inaccurate, outdated, or unlawfully processed data;
— condition prior consent for data used in marketing;
— withdraw consent or demand termination of data processing;
— lodge complaints with the authorized agency or court;
— exercise other rights under Russian law.
4.2. Data subjects must:
— provide accurate personal data;
— inform the Operator of any changes to their personal data.
4.3. Persons who have provided inaccurate or unauthorized data about others are liable under Russian law.
5. Principles of Personal Data Processing
5.1. Data is processed lawfully and fairly.
5.2. Processing is limited to specified, lawful purposes.
5.3. Data collected for different purposes cannot be combined.
5.4. Only data necessary for the stated purposes is processed.
5.5. The scope and nature of the data must match the stated purposes.
5.6. Data must be accurate, complete, and updated when needed.
5.7. Data storage must allow identification only as long as needed for the stated purposes.
6. Purposes of Data Processing
Purpose: Informing the User via email.
Personal Data: Full name, email address, phone numbers.
Legal Basis: Federal Law “On Information, Information Technologies and Information Protection” No. 149-FZ dated 27.07.2006
Types of Processing: Collection, recording, systematization, accumulation, storage, destruction, depersonalization, email dispatch.
7. Conditions for Processing Personal Data
7.1. Processing is based on the subject’s consent.
7.2. Processing is required by law or international agreement.
7.3. Processing is necessary for legal proceedings.
7.4. Processing is required to fulfill a contract involving the data subject.
7.5. Processing is required to pursue legitimate interests without infringing on the subject’s rights.
7.6. Processing involves publicly available personal data.
7.7. Processing is required by federal law.
8. Procedure for Collection, Storage, and Transfer of Personal Data
Security of personal data is ensured through legal, organizational, and technical measures in accordance with applicable law.
8.1. The Operator ensures data confidentiality and protection from unauthorized access.
8.2. Personal data will not be shared with third parties unless required by law or with the subject's consent for contract performance.
8.3. Users can update data by emailing the Operator at info@novexfood.ru with the subject “Personal Data Update.”
8.4. Data is stored only as long as necessary to fulfill the stated purposes or as required by law. Users may revoke consent by sending an email to info@novexfood.ru with the subject “Withdrawal of Consent for Personal Data Processing.”
8.5. Data collected by third-party services (e.g., payment systems, communication tools) is processed by them in accordance with their policies. The Operator is not responsible for third-party actions.
8.6. Restrictions on dissemination or conditions of processing do not apply to publicly significant purposes defined by law.
8.7. The Operator ensures data confidentiality.
8.8. Data is stored in a form that allows subject identification only as long as needed.
9. Cross-border Transfer of Personal Data
9.1. Before initiating the cross-border transfer of personal data, the Operator must ensure that the foreign country where the transfer is intended provides reliable protection of the rights of personal data subjects.
9.2. Cross-border transfer of personal data to the territory of foreign countries that do not meet the above requirements may only be carried out with the written consent of the personal data subject for the cross-border transfer of their personal data and/or performance of an agreement to which the personal data subject is a party.
10. Final Provisions
10.1. The User can obtain any clarifications regarding the processing of their personal data by contacting the Operator via email at info@novexfood.ru.
10.2. This document will reflect any changes to the Operator’s personal data processing policy. The policy is valid indefinitely until replaced by a new version.
10.3. The current version of the Policy is publicly available online at https://en-novexfood.ru/privacy.