Policy on Personal Data Processing

1. General Provisions
This policy on personal data processing has been developed in compliance with Federal Law No. 152-FZ “On Personal Data” dated 27 July 2006 (hereinafter referred to as the “Law on Personal Data”). The policy outlines the procedures for processing personal data and the measures taken by the Sole Proprietor Makarovskaya Galina Aleksandrovna (hereinafter referred to as the 'Operator') to ensure the security of personal data in accordance with the Law on Personal Data.
1.1. The Operator's activities are guided by a commitment to upholding the rights and freedoms of individuals and citizens, with the protection of privacy, personal and family secrets being of paramount importance. In this regard, the Operator ensures that personal data is processed in accordance with the law and that appropriate measures are taken to safeguard the security and confidentiality of such data.
1.2. This policy applies to all personal data collected by the Operator from visitors to the welliving.co/en website.

2. Key Concepts
2.1. The term ‘Automated processing of personal data’ refers to the use of computer technology to process personal data.
2.2. The term ‘Blocking of personal data’ refers to the temporary suspension of the processing of personal data, unless processing is required to clarify personal data.
2.3. The term ‘Website’ refers to a set of graphic and informational materials, computer programs, and databases that ensure their availability on the Internet at the network address welliving.co/en.
2.4. The term ‘Personal data information system’ refers to a set of personal data contained in databases, and information technologies and technical means that ensure their processing.
2.5. The term ‘Depersonalization of personal data’ refers to actions taken to make it impossible to identify personal data ownership by a specific user or other subject of personal data without additional information.
2.6. The term ‘Processing of personal data’ refers to any action or set of actions performed 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, with or without the use of automation tools.
2.7. The term 'Operator' refers to a state body, municipal body, legal entity, or an individual who, independently or in conjunction with others, organizes and/or carries out the processing of personal data. The Operator also determines the purposes of processing personal data, as well as the composition of personal data to be processed and the actions (operations) to be performed with such personal data.
2.8. The term ‘Personal data' refers to any information related directly or indirectly to a specific or identifiable user of the welliving.co/en website.
2.9. The term 'Personal data allowed for distribution by the subject of personal data' refers to personal data that can be accessed by an unlimited number of persons, subject to the permission granted by the subject of personal data in the manner prescribed by the Law on Personal Data.
2.10. The term 'User' refers to any visitor to the welliving.co/en website.
2.11. The term 'Providing personal data' refers to actions that involve disclosing personal data to a specific person or a particular group of persons.
2.12. The term 'Dissemination of personal data' refers to any actions that involve disclosing personal data to an indefinite circle of persons or allowing an unlimited number of persons to access personal data. This includes disclosing personal data in the media, placing it on information and telecommunication networks, or providing access to personal data in any other way.
2.13. The term 'Cross-border transfer of personal data' refers to the transfer of personal data to the territory of a foreign state to an authority of a foreign state, a foreign individual, or a foreign legal entity.
2.14 The term ‘Destruction of Personal Data’ refers to any action resulting in the irreversible destruction of personal data with no possibility of further restoration of its content in the information system of personal data and/or destruction of material carriers of personal data.

3. Basic Rights and Obligations of the Operator
3.1 The Operator has the following rights:

• To receive from the subject of personal data reliable information and/or documents containing personal data.
• 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, in the event that the subject of personal data withdraws consent to the processing of personal data, as well as sending an appeal with a request to stop processing personal data.
• To independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of the obligations provided for by the Law on Personal Data and the regulatory legal acts adopted in accordance with it, unless otherwise provided by the Law on Personal Data or other federal laws.

3.2 The Operator is obliged to:

• Provide the subject of personal data, upon his request, with information regarding the processing of his personal data.
• Organize the processing of personal data in the manner prescribed by the current legislation of the Russian Federation.
• Respond to requests and appeals from personal data subjects 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 subjects of personal data, at the request of this body, the necessary information within 30 days from the date of receipt of such a request.
• 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 to them, destruction, modification, blocking, copying, provision, 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, stop processing and destroy personal data in the manner and cases provided for by the Law on Personal Data.
• Perform other duties provided for by the Law on Personal Data.

4. Basic Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects have the following rights:

• To receive information regarding the processing of their personal data, unless otherwise provided by federal laws. The Operator shall provide this information to the personal data subject in an accessible form and it should not contain personal data relating to other subjects of personal data, unless there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Law on Personal Data.
• To require the Operator to clarify their personal data, block or destroy it if it is incomplete, outdated, inaccurate, illegally obtained, or unnecessary for the stated purpose of processing. They may also take legal measures to protect their rights.
• To put forward the condition of prior consent when processing personal data in order to promote goods, works, and services on the market.
• To withdraw consent to the processing of personal data and to send a request to stop processing personal data.
• To appeal to the authorized body for the protection of the rights of personal data subjects or to file a lawsuit against illegal actions or inaction of the Operator when processing their personal data.
• To exercise any other rights provided for by the legislation of the Russian Federation.

4.2. Personal data subjects are obliged to:

• Provide the Operator with accurate and reliable information about themselves.
• Inform the Operator about any clarifications, updates, or changes to their personal data.

4.3. Individuals who provide the Operator with false information about themselves or information about another personal data subject without the latter's consent are liable in accordance with the legislation of the Russian Federation.

5. Principles of Personal Data Processing
5.1. Personal data processing shall be carried out on a legal and fair basis.
5.2. The processing of personal data shall be limited to achieving specific, predetermined, and legitimate purposes. Processing of personal data that is incompatible with the purposes of collecting personal data is strictly prohibited.
5.3. Combining databases containing personal data, which are processed for incompatible purposes, is prohibited.
5.4. Only personal data that meets the purposes of their processing shall be subject to processing.
5.5. The content and scope of processed personal data shall correspond to the stated purposes of processing. It is not allowed to process personal data redundantly in relation to the stated purposes of processing.
5.6. When processing personal data, the accuracy, sufficiency, and relevance of personal data with respect to the purposes of processing shall be ensured. The Operator shall take the necessary measures to remove or clarify incomplete or inaccurate data.
5.7. Personal data shall be stored in a form that allows identifying the subject of personal data for no longer than necessary for the purposes of processing, unless otherwise established by federal law, an agreement to which the subject of personal data is a party, beneficiary or guarantor. Processed personal data shall be destroyed or depersonalized upon reaching the goals of processing or in case of loss of the need to achieve these goals, unless otherwise provided by federal law.

6. Purposes of Personal Data Processing
The purpose of processing personal data is to inform the User by sending emails, and includes the surname, name, patronymic, second name, email address, and phone numbers. The legal grounds for processing personal data are based on the statutory (constituent) documents of the Operator. The processing of personal data includes collection, recording, systematization, accumulation, storage, destruction, and depersonalization. The Operator may send newsletters to the User's email address in accordance with the purposes of processing and the User's consent.

7. Conditions for the Processing of Personal Data
7.1. The processing of personal data is carried out with the consent of the subject of personal data to the processing of their personal data.
7.2. The processing of personal data is necessary to achieve the goals provided for by an international treaty of the Russian Federation or the law, to carry out the functions, powers, and duties assigned by the legislation of the Russian Federation to the Operator.
7.3. The processing of personal data is necessary 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 execution procedure.
7.4. The processing of personal data is necessary for the performance of an agreement to which the subject of personal data is a party, beneficiary, or guarantor, as well as to conclude 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.
7.5. The processing of personal data is necessary 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.
7.6. The processing of personal data is carried out, and access to an unlimited number of persons is provided by the subject of personal data or at their request (hereinafter referred to as publicly available personal data).
7.7. The processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.

8. Procedure for Collecting, Storing, Transferring, and Other Types of Processing of Personal Data
The Operator ensures the security of personal data processed by them through the implementation of legal, organizational, and technical measures necessary to fully comply with the requirements of current legislation in the field of personal data protection.
8.1. The Operator ensures the safety of personal data and takes all possible measures to prevent unauthorized access to personal data.
8.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to the implementation of applicable law or if the subject of personal data has given consent to the Operator to transfer data to a third party to fulfill obligations under a civil law contract.
8.3. In case of any inaccuracies found in personal data, the User may update them independently by sending a notification to the Operator at the email address hello@welliving.co, marked “Updating personal data”.
8.4. The term 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 their consent to the processing of personal data at any time by sending a notification to the Operator by e-mail to the address hello@welliving.co, marked "Withdrawal of consent to the processing of personal data".
8.5. All information collected by third-party services, including payment systems, means of communication, and other service providers, is stored and processed by these Operators in accordance with their user agreement and privacy policy. The Operator is not responsible for the actions of third parties, including the service providers specified in this paragraph.
8.6. The restrictions established by the subject of personal data on the transfer (except for granting access), as well as on the processing or processing conditions (except for obtaining access) of personal data permitted for distribution, do not apply in cases of processing personal data in state, public, and other public interests determined by Russian Federation law.
8.7. The Operator ensures the confidentiality of personal data when processing personal data.
8.8. Unless the period for storing personal data is established by federal law or an agreement to which the data subject is a party, beneficiary, or guarantor, the Operator shall store personal data in a form that enables the identification of the data subject no longer than necessary for the purposes of processing such data.
8.9. Termination of personal data processing may occur upon achieving the processing purposes, expiration of the data subject's consent, withdrawal of consent by the data subject, or upon identification of unlawful processing of personal data. Additionally, processing may be terminated upon the data subject's request to stop processing.

9. List of Actions Performed by the Operator with the Received Personal Data
9.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), extracts, uses, transfers (distributes, provides, accesses), depersonalizes, blocks, deletes, and destroys personal data.
9.2. The Operator may conduct automated processing of personal data, including the receipt and/or transmission of such data through information and telecommunication networks or otherwise.

10. Cross-Border Transfer of Personal Data
10.1. Prior to initiating cross-border transfer of personal data, the Operator shall notify the authorized body for the protection of personal data subjects' rights of their intention to transfer such data across borders. This notification shall be sent separately from any notification of the intention to process personal data.
10.2.Prior to submitting the above notification, the Operator shall obtain relevant information from foreign authorities, individuals, or legal entities to whom the cross-border transfer of personal data is planned.

11. Confidentiality of Personal Data
The Operator and any other persons who gain access to personal data shall not disclose such data to third parties or distribute it without the data subject's consent, unless otherwise provided by federal law.

12. Final Provisions
12.1. The data subject may obtain clarifications on any issues regarding the processing of their personal data by contacting the Operator via email at hello@welliving.co.
12.2. This document will reflect any changes to the Operator's policy on personal data processing. The policy shall remain in effect indefinitely until it is replaced by a new version.
12.3. The current version of the policy on personal data processing is publicly available on the internet at https://welliving.co/en/privacy.