Privacy Policy

General Provisions

This personal data processing policy has been developed in accordance with the requirements of Federal Law No. 152-FZ dated July 27, 2006 "On Personal Data" (hereinafter - the Personal Data Law) and defines the procedure for processing personal data and the measures to ensure the security of personal data taken by LLC “Colvate” (hereinafter – the Operator).
1.1. The Operator’s primary goal and condition for its activities is to ensure the rights and freedoms of individuals and citizens during the processing of their personal data, including protecting the rights to privacy, personal, and family secrets.
1.2. This policy of the Operator regarding the processing of personal data (hereinafter - the Policy) applies to all information that the Operator may obtain about visitors to the website https://www.colvate.com.

2. Basic Terms Used in the Privacy Policy

2.1. Automated processing of personal data – processing of personal data using computing technology.
2.2. Blocking of personal data – temporary cessation of personal data processing (except when processing is necessary to verify personal data).
2.3. Website – a set of graphical and informational materials, as well as computer programs and databases that provide access to them over the Internet via the network address https://www.colvate.com.
2.4. Information system of personal data – a set of personal data contained in databases, and the information technologies and technical means ensuring their processing.
2.5. Anonymization of personal data – actions that make it impossible to determine the ownership of personal data to a specific User or other subject of personal data without using additional information.
2.6. Personal data processing – any action (operation) or a set of actions (operations) performed with or without automation tools on personal data, including the collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
2.7. Operator – a government body, municipal body, legal entity, or individual, independently or together with others organizing and (or) performing personal data processing, as well as determining the purposes of personal data processing, the composition of personal data to be processed, and actions (operations) performed on personal data.
2.8. Personal data – any information related directly or indirectly to a specific or identifiable User of the website https://www.colvate.com.
2.9. Personal data allowed by the subject of personal data for distribution – personal data to which an unlimited circle of persons is provided access by the subject of personal data through consent to the processing of personal data permitted for distribution in the manner prescribed by the Personal Data Law (hereinafter - personal data allowed for distribution).
2.10. User – any visitor to the website https://www.colvate.com.
2.11. Provision of personal data – actions aimed at disclosing personal data to a specific person or group of persons.
2.12. Distribution of personal data – any actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or making personal data available to an unlimited group of persons, including publication in the media, placement in information and telecommunication networks, or providing access to personal data by other means.
2.13. Transborder transfer of personal data – transfer of personal data to a foreign country’s authority, foreign physical or legal person.
2.14. Destruction of personal data – any actions that result in the irreversible destruction of personal data with no possibility of further recovery of the content of personal data in the information system and (or) the destruction of physical media of personal data.

3. Main Rights and Obligations of the Operator

3.1. The Operator has the right:
  • to receive reliable information and/or documents containing personal data from the subject of personal data;
  • if the subject of personal data withdraws their consent to the processing of personal data, the Operator may continue processing personal data without the subject’s consent if there are grounds specified in the Personal Data Law;
  • to independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations under the Personal Data Law and the regulations adopted under it, unless otherwise provided by the Personal Data Law or other federal laws.
3.2. The Operator is obliged:
  • to provide the subject of personal data with information regarding the processing of their personal data upon request;
  • to organize the processing of personal data as established by the current legislation of the Russian Federation;
  • to respond to requests from subjects of personal data and their legal representatives in accordance with the requirements of the Personal Data Law;
  • to inform the authorized body on the protection of the rights of subjects of personal data, at the request of that body, with the necessary information within 30 days from the date of receipt of such a request;
  • to publish or otherwise ensure unlimited access to this Policy regarding the processing of personal data;
  • to take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, distribution, as well as from other illegal actions regarding personal data;
  • to stop transferring (distributing, providing, accessing) personal data, stop processing, and destroy personal data in the manner and cases prescribed by the Personal Data Law;
  • to perform other duties provided by the Personal Data Law.

4. Main Rights and Obligations of Subjects of Personal Data

4.1. Subjects of personal data have the right:
  • to receive information regarding the processing of their personal data, except in cases provided by federal laws. Information should be provided to the subject of personal data in an accessible form and should not contain personal data related to other subjects, except when there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
  • to require the Operator to clarify their personal data, block, or destroy it if the personal data is incomplete, outdated, inaccurate, illegally obtained, or not necessary for the stated purpose of processing, as well as to take the legal measures provided by law to protect their rights;
  • to require prior consent for processing personal data for the purpose of marketing goods, works, and services;
  • to withdraw consent to the processing of personal data;
  • to appeal to the authorized body for the protection of the rights of subjects of personal data or in court against the unlawful actions or inactions of the Operator in processing their personal data;
  • to exercise other rights provided by the legislation of the Russian Federation.
4.2. Subjects of personal data are obliged:
  • to provide the Operator with accurate data about themselves;
  • to inform the Operator about any changes or updates to their personal data.
4.3. Individuals who provided inaccurate information about themselves or another subject of personal data without their consent are responsible in accordance with the legislation of the Russian Federation.

5. The Operator may process the following personal data of the User:

5.1. Last name, first name, patronymic.
5.2. Email address.
5.3. Phone numbers.
5.4. The website also collects and processes anonymized data about visitors (including "cookie" files) using internet analytics services (Yandex Metrica and others).
5.5. The aforementioned data is collectively referred to as Personal Data in this Policy.
5.6. The Operator does not process special categories of personal data related to race, national origin, political views, religious or philosophical beliefs, intimate life.
5.7. Processing of personal data allowed for distribution from the special categories of personal data listed in part 1 of article 10 of the Personal Data Law is allowed if the prohibitions and conditions prescribed by article 10.1 of the Personal Data Law are complied with.
5.8. The User’s consent to process personal data allowed for distribution is provided separately from other consents to process their personal data. The conditions stipulated in article 10.1 of the Personal Data Law are observed. Requirements for the content of such consent are established by the authorized body for the protection of personal data rights.
5.8.1 The User gives consent to process personal data allowed for distribution directly to the Operator.
5.8.2 The Operator is required to publish information on the terms of processing, the presence of prohibitions, and conditions for processing personal data allowed for distribution no later than three working days from the moment of receiving the User’s consent.
5.8.3 The transfer (distribution, provision, access) of personal data, allowed for distribution by the subject, must be stopped at any time upon request of the subject of personal data.
5.8.4 The consent to process personal data allowed for distribution terminates upon receiving the request from the subject of personal data to stop processing it.


6. Principles of Personal Data Processing

6.1. Personal data is processed on a lawful and fair basis.
6.2. The processing of personal data is limited to achieving specific, pre-defined, and lawful purposes. Processing personal data incompatible with the purposes for which it was collected is not allowed.
6.3. It is not allowed to combine databases containing personal data, whose processing is carried out for incompatible purposes.
6.4. Only personal data necessary for the purposes of processing are processed.
6.5. The content and volume of processed personal data correspond to the declared processing purposes. The processing of personal data that exceeds the stated purposes is not allowed.
6.6. During the processing of personal data, the accuracy of the data, its sufficiency, and, if necessary, its relevance to the purposes of processing are ensured. The Operator takes the necessary measures and/or ensures their implementation to delete or clarify incomplete or inaccurate data.
6.7. Personal data is stored in a form that allows identifying the subject of personal data, for no longer than necessary to achieve the processing purposes, unless the retention period is established by federal law, contract, or by the subject of personal data as a party, beneficiary, or guarantor. Processed personal data is destroyed or anonymized when the processing goals are achieved or when there is no longer a need to achieve those goals unless otherwise provided by federal law.

7. Purposes of Personal Data Processing

7.1. The purpose of processing the User's personal data:
  • Informing the User via emails, text messages, and phone calls.
  • The conclusion, execution, and termination of civil law contracts.
  • Providing the User access to services, information, and/or materials on the website https://www.colvate.com.
7.2. The Operator also has the right to send the User notifications about new products and services, special offers, and various events. The User may always opt out of receiving informational messages by sending an email to the Operator at info@colvate.com with the subject "Opt-out of notifications about new products, services, and special offers."
7.3. Anonymized data collected from Users via internet statistics services serves to gather information about User activities on the site and improve the quality of the site and its content.

8. Legal Grounds for Personal Data Processing

8.1. The legal grounds for processing personal data by the Operator are:
  • Contracts between the Operator and the subject of personal data.
  • Federal laws and other regulatory legal acts in the field of personal data protection.
  • The Users' consent to the processing of their personal data and their consent to process personal data allowed for distribution.
8.2. The Operator processes personal data of the User only if filled in and/or sent by the User independently through special forms on the website https://www.colvate.com or sent to the Operator via email. By filling out the appropriate forms and/or sending their personal data to the Operator, the User consents to this Policy.
8.3. The Operator processes anonymized data about the User if allowed by the settings of the User’s browser (including the saving of "cookie" files and the use of JavaScript technology).
8.4. The subject of personal data independently decides whether to provide their personal data and gives consent freely, of their own will, and in their own interest.

9. Conditions for Personal Data Processing

9.1. Personal data is processed with the consent of the subject of personal data to process their personal data.
9.2. Personal data processing is necessary for achieving the goals set by international agreements of the Russian Federation or the law, for performing functions, powers, and duties assigned to the Operator under Russian Federation legislation.
9.3. Processing of personal data is necessary for the administration of justice, the execution of a court ruling, or an act of another body or official subject to enforcement under Russian Federation laws on enforcement proceedings.
9.4. Processing personal data is necessary for the fulfillment of a contract, one party to which is the subject of personal data, or for concluding a contract at the initiative of the subject of personal data or a contract under which the subject will be a beneficiary or guarantor.
9.5. Processing of personal data is necessary for protecting the rights and legitimate interests of the Operator or third parties or for achieving socially significant goals, provided that the rights and freedoms of the subject of personal data are not violated.
9.6. Personal data is processed if the subject has made it publicly available or upon their request (hereinafter - publicly available personal data).
9.7. Processing of personal data subject to publication or mandatory disclosure under federal law is carried out.

10. Procedure for Collecting, Storing, Transmitting, and Other Forms of Processing 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 applicable data protection laws.
10.1. The Operator ensures the security of personal data and takes all possible measures to prevent unauthorized access to personal data.
10.2. The personal data of the User will never, under any circumstances, be transferred to third parties, except in cases related to fulfilling applicable laws or if the subject of personal data gives consent to the Operator to transfer data to third parties to fulfill contractual obligations.
10.3. In the case of inaccuracies in personal data, the User can update their data by sending a notification to the Operator at info@colvate.com with the subject "Update of personal data."
10.4. The processing period for personal data is determined by the achievement of the goals for which the personal data was collected, unless a different period is established by the contract or applicable law.
The User can withdraw their consent to the processing of personal data at any time by sending a notification to the Operator via email to info@colvate.com with the subject "Withdrawal of consent for personal data processing."
10.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by those parties (Operators) according to their User Agreement and Privacy Policy. The subject of personal data and/or the User must independently review these documents. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this paragraph.
10.6. Restrictions set by the subject of personal data regarding the transfer (except for providing access) and the processing conditions (except for access provision) of personal data allowed for distribution do not apply in cases of processing such data for government, public, and other public interests defined by Russian legislation.
10.7. The Operator ensures the confidentiality of personal data during processing.
10.8. The Operator stores personal data in a form that allows identifying the subject of personal data, for no longer than necessary to achieve the purposes of processing, unless otherwise provided by federal law, contract, or a party, beneficiary, or guarantor involved in the contract.
10.9. The processing of personal data may be terminated once the goals of processing are achieved, the consent expires, or the subject withdraws consent, as well as if personal data processing is found to be unlawful.

11. Actions Performed by the Operator with Personal Data

11.1. The Operator collects, records, organizes, stores, updates (corrects, changes), retrieves, uses, transfers (distributes, provides access), anonymizes, blocks, deletes, and destroys personal data.
11.2. The Operator performs automated processing of personal data with the receiving and/or transmission of the obtained information through information and telecommunication networks or without such transmission.

12. Transborder Transfer of Personal Data

12.1. Before beginning transborder transfer of personal data, the Operator must ensure that the country to which the data will be transferred provides reliable protection of the rights of personal data subjects.
12.2. The transborder transfer of personal data to countries that do not meet the above requirements can only occur if the subject of personal data gives written consent for the transfer and/or for fulfilling a contract to which the subject is a party.

13. Confidentiality of Personal Data

The Operator and other individuals who have access to personal data are required not to disclose the data to third parties or distribute it without the consent of the subject, unless otherwise required by federal law.

14. Final Provisions

14.1. The User can get any clarifications regarding their personal data processing by contacting the Operator via email at info@colvate.com.
14.2. Any changes to the personal data processing policy will be reflected in this document. The Policy remains in effect indefinitely until replaced by a new version.
14.3. The current version of the Policy is freely available on the Internet at https://colvate.com/privacy_policy.
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