1. Key Definitions

• Personal Data Operator (Operator): Individual Entrepreneur Iuliia Vladimirovna Kumicheva.
• User: An individual with access to the Website via the Internet and using the Website.
• Personal Data: Any information directly or indirectly related to an identified or identifiable individual (User).
• Confidentiality of Personal Data: A mandatory requirement for the Operator not to disclose or distribute personal data without the User's consent unless otherwise required by federal law.
• Processing of Personal Data: Any action or combination of actions performed with personal data, with or without the use of automated tools, including collection, recording, organization, storage, updating, retrieval, use, transfer (distribution, provision, access), anonymization, blocking, deletion, or destruction.
• Automated Processing of Personal Data: Processing personal data using computing technology.
• Distribution of Personal Data: Actions aimed at disclosing personal data to an indefinite circle of persons.
• Provision of Personal Data: Actions aimed at disclosing personal data to a specific individual or group.
• Blocking of Personal Data: Temporary suspension of the processing of personal data (except in cases where processing is necessary to update personal data).
• Anonymization of Personal Data: Actions rendering it impossible to determine the ownership of personal data without additional information.
• Destruction of Personal Data: Actions rendering it impossible to restore personal data content in the system or leading to the destruction of personal data storage media.

2. General Provisions
2.1. Using the Website by the User constitutes their unconditional agreement with the Privacy Policy and terms of personal data processing.
2.2. If the User disagrees with the terms of the Privacy Policy, they must discontinue using the Website.
2.3. The Operator does not verify the accuracy of personal data provided by the User and assumes the User provides accurate and sufficient personal data and keeps it up to date. The User bears full responsibility for the consequences of providing inaccurate or invalid personal data.
2.4. The User confirms that by providing personal data and consenting to its processing, they act voluntarily, of their own free will, and in their interest, and they confirm their legal capacity.
2.5. By providing personal data, the User agrees that the personal data provided will be processed by the Operator, both with and without the use of automated tools.
2.6. Consent to personal data processing is valid from the moment it is provided to the Operator until the date the Operator ceases to operate as an individual entrepreneur or until the User withdraws consent.
3. Types of Personal Data and Purposes of Processing
3.1. Personal data permitted for processing under this Privacy Policy is provided by the User through special forms on the Website in the course of receiving services and includes:

• Last name, first name;
• Contact information (phone number, email);
• Bank details for service payments.

3.2. The purposes of personal data processing include:

• Fulfillment of contractual obligations;
• Sending promotional emails (subject to separate consent for mailings);
• Posting reviews and recommendations from the User (subject to separate consent).

4. Measures to Ensure the Security of Personal Data During Processing
4.1. The Operator takes all necessary and sufficient organizational and technical measures to protect the User's personal data from unauthorized or accidental access, destruction, modification, blocking, distribution, or other unlawful actions, including:

• Identifying threats to personal data security when processing it in information systems.
• Assessing the effectiveness of measures taken to ensure personal data security before deploying the information system.
• Detecting unauthorized access to personal data and taking appropriate actions.
• Restoring personal data that has been modified or destroyed due to unauthorized access.
• Establishing rules for access to personal data processed in the information system.
• Recording and monitoring all actions involving personal data in the information system.
• Monitoring measures to ensure personal data security and the level of protection in information systems.

4.2. Access to personal data processed by the Operator is granted only to individuals whose job responsibilities involve working with such information. The Operator provides personal data to its employees following the procedures established by Russian legislation and restricts this information solely to what is necessary for fulfilling specific tasks.

5. Rights and Obligations of the User and the Operator5.1. User Rights
The User has the right to:

• Request the Operator to clarify, block, or delete their personal data if the data is incomplete, outdated, inaccurate, or unlawfully obtained, or if it is no longer necessary for the stated purposes of processing.
• Withdraw their consent to personal data processing by sending an email to the Operator at julia@cupofelt.info.
• Access information regarding their personal data processing, including:
• Confirmation of personal data processing;
• Legal grounds and purposes for data processing;
• Methods of data processing used by the Operator;
• Information about the persons who have access to personal data or to whom data may be disclosed under a contract or legal requirement;
• Processed personal data related to the User, the source of its receipt, unless other procedures for providing such data are established by federal law;
• Terms of personal data processing, including storage periods.

5.2. Operator Obligations
The Operator is obligated to:

• Use the information received exclusively for the purposes specified in this Privacy Policy.
• Ensure the confidentiality of personal data and not disclose it without the User’s prior written consent, except as required by law.
• Take appropriate measures to protect personal data confidentiality, following the procedure established by current legislation.
• Block personal data related to the User upon their request or upon receiving a complaint, for the period of verification.
• Provide the User with information regarding the processing of their personal data upon request.

6. Liability
6.1. In case of loss or disclosure of personal data, the Operator is not liable if such data:

• Became public domain prior to its loss or disclosure;
• Was received from a third party before it was obtained by the Operator;
• Was disclosed with the User's consent.

6.2. The Operator complies with federal legislation concerning the processing of personal data. Any disputes are subject to resolution following the applicable laws of the Russian Federation.
7. Additional Terms
7.1. The Operator reserves the right to amend this Privacy Policy without the User’s consent. Updates take effect upon their publication on the Website unless stated otherwise in the new version of the Privacy Policy.
7.2. For questions or suggestions about this Privacy Policy, the User may contact the Operator at julia@cupofelt.info.
7.3. This Privacy Policy is a public document available on the Website.