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Personal data processing policy

In accordance with Federal Law No. 152-FZ of 27 July 2006 “On Personal Data”.

Version dated 16 June 2026

1. General provisions

1.1. This Personal Data Processing Policy (the “Policy”) has been prepared in accordance with the requirements of Federal Law No. 152-FZ of 27 July 2006 “On Personal Data” (the “Law”) and sets out the procedure for processing personal data and the personal data security measures taken by Arcobalena LLC (the “Operator”).

1.2. The Operator regards respect for human and civil rights and freedoms in the processing of personal data — including the right to privacy and to personal and family confidentiality — as a paramount objective and a condition of its activities.

1.3. This Policy applies to all information the Operator may obtain about visitors to the website arcobalena-poshiv.ru (hereinafter the “Website”).

2. Key terms used in this Policy

  • Personal data — any information relating to a directly or indirectly identified or identifiable natural person (the data subject).
  • Processing of personal data — any action (operation) or set of actions performed on personal data, with or without automated means: collection, recording, organisation, accumulation, storage, rectification, retrieval, use, transfer, anonymisation, blocking, deletion and destruction.
  • Operator — Arcobalena LLC, which independently or jointly with others organises and/or carries out the processing of personal data and determines the purposes and categories of personal data processed.
  • Data subject (User) — a visitor to the Website whose personal data is processed by the Operator.
  • Cookie — a small piece of data sent by a web server and stored on the user’s device.
  • Anonymisation — actions that make it impossible to attribute personal data to a specific data subject without the use of additional information.

3. Categories of data subjects and data processed

3.1. The Operator processes personal data that the User provides voluntarily when completing forms on the Website (the request form, the quiz cost calculator and the contact form), as well as when contacting us through the channels listed.

3.2. Categories of personal data processed:

  • surname, first name;
  • contact phone number;
  • email address;
  • message content / parameters of the requested order;
  • anonymised visitor data collected via web analytics services (Yandex.Metrica and others): IP address, cookie data, browser and operating system information, date and time of visit, and the addresses of requested pages.

3.3. The Operator does not process special categories of personal data (race, ethnicity, political views, health status, etc.) or biometric personal data.

4. Purposes of processing personal data

  • handling the User’s enquiries and requests, preparing a commercial offer and cost estimate;
  • communication with the User, including sending notifications and information on request;
  • conclusion and performance of contracts for garment manufacturing;
  • improving the Website, its usability and traffic analysis (anonymised data).

5. Legal grounds for processing personal data

5.1. The legal grounds for processing personal data are:

  • the data subject’s consent to the processing of their personal data (Art. 6(1)(1) of Federal Law No. 152-FZ), given by ticking the relevant box when submitting forms on the Website;
  • contracts concluded between the Operator and the data subject;
  • Federal Law No. 152-FZ “On Personal Data” and other regulations in the field of personal data protection.

6. Procedure and conditions for processing personal data

6.1. Personal data is processed with the data subject’s consent, and without such consent in the cases provided for by law.

6.2. The Operator processes personal data both using automated means and without them.

6.3. Processing of personal data ceases when the purposes of processing are achieved, when consent expires, when the data subject withdraws consent, or when unlawful processing of personal data is identified.

6.4. Personal data is stored no longer than necessary to achieve the purposes of processing. Once those purposes are achieved, or upon withdrawal of consent, personal data is destroyed or anonymised.

7. Use of cookies

7.1. The Website uses cookies to ensure it functions properly, to improve usability and to collect anonymised visit statistics.

7.2. By continuing to use the Website after the cookie notice (banner) is displayed, the User consents to the processing of cookies. The User may disable cookie storage in their browser settings or delete stored cookies at any time.

7.3. The Website uses the Yandex.Metrica web analytics service to analyse traffic; it collects anonymised data using cookie technology.

8. Transfer of personal data

8.1. The Operator does not transfer personal data to third parties, except in cases provided for by law or where such transfer is necessary to perform a contract with the data subject.

8.2. Cross-border transfer of personal data is carried out only where the foreign state ensures adequate protection of data subjects’ rights, or with the data subject’s consent.

9. Rights of the data subject

9.1. The data subject has the right to:

  • receive information concerning the processing of their personal data;
  • require the rectification, blocking or destruction of personal data where it is incomplete, outdated, inaccurate, unlawfully obtained or not necessary for the stated purpose of processing;
  • withdraw consent to the processing of personal data;
  • appeal against the Operator’s actions or inaction to the authorised body for the protection of data subjects’ rights or in court.

9.2. To exercise these rights, or to withdraw consent to the processing of personal data, the data subject may send the Operator a request to the following email address: kg_arcobalena@mail.ru.

10. Personal data protection measures

10.1. The Operator takes the necessary legal, organisational and technical measures to protect personal data from unlawful or accidental access, destruction, alteration, blocking, copying, distribution and other unlawful actions.

11. Final provisions

11.1. The User may obtain any clarification regarding the processing of their personal data by contacting the Operator using the contact details provided.

11.2. This Policy may be amended. A new version of the Policy takes effect from the moment it is published on the Website, unless the new version provides otherwise.

12. Operator details