Personal Data Processing Policy

1. General Provisions
This Personal Data Processing Policy is prepared in accordance with the requirements of the Federal Law dated July 27, 2006, No. 152-FZ "On Personal Data" (hereinafter referred to as the Personal Data Law) and establishes the procedure for processing personal data and measures to ensure the security of personal data taken by PT GARDEN GROUP (hereinafter referred to as the Operator).
1.1. The Operator sets compliance with the rights and freedoms of individuals as its most important goal and condition when processing their personal data, including the protection of the rights to privacy, personal and family secrets.
1.2. This Policy of the Operator regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator may obtain about visitors of the website https://garden-group.pro/eng.
2. Basic Concepts 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 suspension of the processing of personal data (except cases when processing is necessary to clarify personal data).
2.3. Website - a collection of graphic and informational materials, as well as computer programs and databases ensuring their availability on the Internet at the network address https://garden-group.pro/eng.
2.4. Information system of personal data - a set of personal data contained in databases and ensuring their processing through information technologies and technical means.
2.5. Depersonalization of personal data - actions as a result of which it is impossible to determine without using additional information the belonging of personal data to a specific User or another subject of personal data.
2.6. Processing of personal data - any action (operation) or set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
2.7. Operator - a state body, a municipal body, a legal entity, or an individual who, either independently or jointly with others, organizes and/or carries out the processing of personal data, as well as determines the purposes of processing personal data, the composition of personal data subject to processing, actions (operations) performed with personal data.
2.8. Personal data - any information directly or indirectly related to a specific or identifiable User of the website https://garden-group.pro/eng.
2.9. Personal data permitted for distribution by the subject of personal data - personal data, the access of an unlimited number of persons to which is provided by the subject of personal data by giving consent to the processing of personal data permitted for distribution in accordance with the procedure established by the Personal Data Law (hereinafter referred to as personal data permitted for distribution).
2.10. User - any visitor of the website https://garden-group.pro/eng.
2.11. Provision of personal data - actions aimed at disclosing personal data to a specific person or a specific circle of persons.
2.12. Distribution of personal data - any actions aimed at disclosing personal data to an indefinite circle of persons (transferring personal data) or acquainting the public with personal data, including publication of personal data in mass media, placement on information and telecommunication networks or providing access to personal data in any other way.
2.13. Cross-border transfer of personal data refers to the transfer of personal data to the territory of a foreign state to a foreign government authority, foreign individual, or foreign legal entity.
2.14. Destruction of personal data refers to any actions that irreversibly destroy personal data, making it impossible to restore the content of personal data in the personal data information system and/or destroy the material carriers 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 data subject;
- in case the data subject withdraws their consent to the processing of personal data or submits a request to cease the processing of personal data, the Operator has the right to continue processing personal data without the consent of the data subject if there are grounds specified in the Personal Data Law;
- independently determine the set and list of measures necessary and sufficient to ensure the fulfillment of obligations stipulated by the Personal Data Law and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.

3.2. The Operator is obliged to:
- provide the data subject, upon their request, with information regarding the processing of their personal data;
- organize the processing of personal data in accordance with the current legislation of the Russian Federation;
- respond to inquiries and requests from data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
- provide the necessary information to the authorized body for the protection of the rights of data subjects within 10 days from the date of receiving such request;
- publish or otherwise ensure 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, alteration, blocking, copying, provision, dissemination of personal data, as well as other unlawful actions against personal data;
- terminate the transfer (distribution, provision, access) of personal data, cease processing, and destroy personal data in accordance with the cases and procedures provided by the Personal Data Law;
- fulfill other obligations stipulated by the Personal Data Law;
4. Rights and obligations of data subjects
4.1. Data subjects have the right to:
- receive information regarding the processing of their personal data, except for cases provided by federal laws. The information is provided to the data subject by the Operator in an accessible form and should not contain personal data related to other data subjects, except in cases where 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;
- request the Operator to clarify their personal data, block or destroy it if the personal data is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, as well as to take measures provided by law to protect their rights;
- impose a condition of prior consent when processing personal data for the purpose of promoting goods, works, or services on the market;
- withdraw consent to the processing of personal data and submit a request to cease the processing of personal data;
- appeal to the authorized body for the protection of the rights of data subjects or file a lawsuit against the Operator for unlawful actions or inaction in the processing of their personal data.
- Exercise other rights provided by the legislation of the Russian Federation.
4.2. Data subjects are obliged to:
- provide the Operator with accurate information about themselves;
- inform the Operator about any changes or updates to their personal data.
4.3. Individuals who provide the Operator with false information about themselves or information about another data subject without the latter's consent bear responsibility in accordance with the legislation of the Russian Federation.
5. Principles of personal data processing
5.1. Personal data processing is carried out on a lawful and fair basis.
5.2. Personal data processing is limited to specific, predetermined, and lawful purposes. Processing of personal data that is incompatible with the purposes of data collection is not permitted.
5.3. The merging of databases containing personal data, the processing of which is carried out for incompatible purposes, is not allowed.
5.4. Only personal data that corresponds to the stated purposes of processing is subject to processing.
5.5. The content and scope of processed personal data correspond to the declared purposes of processing. Redundancy of processed personal data in relation to the declared purposes of processing is not allowed.
5.6. When processing personal data, the Operator ensures the accuracy, sufficiency, and, if necessary, relevance of the personal data in relation to the purposes of processing. The Operator takes necessary measures and/or ensures their implementation to delete or correct incomplete or inaccurate data.
5.7. Storage of personal data is carried out in a form that allows identifying the data subject for no longer than necessary for the purposes of processing, unless the storage period is established by federal law, a contract, of which the data subject is a party, a beneficiary, or a guarantor. Processed personal data is destroyed or depersonalized upon achieving the purposes of processing or in case their further retention is no longer necessary for achieving those purposes, unless otherwise provided by federal law.
6. Purposes of personal data processing
Purpose of processing: informing the User through the sending of emails
Personal data:
- last name, first name, patronymic
- email address
- phone numbers
Legal basis: Federal Law "On Information, Information Technologies, and Information Protection" dated July 27, 2006, No. 149-FZ
Types of personal data processing: Transfer of personal data
7. Conditions for personal data processing
7.1. Personal data processing is carried out with the consent of the data subject to the processing of their personal data.
7.2. Personal data processing is necessary for the achievement of the purposes envisaged by an international treaty of the Russian Federation or by law, for the performance of functions, powers, and duties entrusted to the Operator by legislation of the Russian Federation.
7.3. Personal data processing is necessary for the administration of justice, the execution of a court judgment, an act of another authority or official subject to enforcement under the legislation of the Russian Federation on enforcement proceedings.
7.4. Personal data processing is necessary for the performance of a contract to which the data subject, the beneficiary, or the guarantor is a party or for the conclusion of a contract at the initiative of the data subject, under which the data subject will be the beneficiary or the guarantor.
7.5. Personal data processing is necessary for the protection of the rights and legitimate interests of the Operator or third parties or for the achievement of socially significant purposes, provided that the rights and freedoms of the data subject are not violated.
7.6. Processing of personal data for which the data subject has provided unrestricted access or has made it publicly available upon their request is carried out.
7.7. Processing of personal data subject to publication or mandatory disclosure is carried out in accordance with the federal law.
8. Procedure for the collection, storage, transmission, and other types of personal data processing
The security of personal data processed by the Operator is ensured through the implementation of legal, organizational, and technical measures necessary to fully comply with the requirements of the current legislation on the protection of personal data.
8.1. The Operator ensures the security 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 performance of applicable legislation or if the data subject has given consent to the Operator to transfer data to a third party for the performance of obligations under a civil law contract.
8.3. In case of inaccuracies in personal data, the User can update them independently by sending a notification to the Operator at the email address lb@garden-group.pro with the subject line "Updating Personal Data."
8.4. The processing period for personal data is determined by the achievement of the purposes for which the personal data was collected, unless otherwise provided by the contract or applicable legislation.
The User can revoke their consent to the processing of personal data at any time by sending a notification to the Operator via email to the Operator's email address lb@garden-group.pro with the subject line "Withdrawal of Consent to the Processing of Personal Data."
8.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by these entities (Operators) in accordance with their User Agreement and Privacy Policy. The data subject is advised to familiarize themselves with these documents. The Operator is not responsible for the actions of third parties, including service providers mentioned in this section.
8.6. The restrictions imposed by the data subject on the transfer (except for granting access) or processing (except for granting access) of personal data that is allowed for distribution do not apply in cases where personal data is processed for state, public, and other public interests as defined by Russian legislation.
8.7. The Operator ensures the confidentiality of personal data during its processing.
8.8. The Operator stores personal data in a form that allows identifying the data subject for no longer than necessary for the purposes of personal data processing unless the storage period is established by federal law, a contract of which the data subject is a party, a beneficiary, or a guarantor.
8.9. The processing of personal data may be terminated upon achieving the purposes of personal data processing, the expiration of the consent period of the data subject, the withdrawal of consent by the data subject, or a request to cease the processing of personal data, as well as the identification of unauthorized processing of personal data.
9. List of actions performed by the Operator with the obtained personal data
9.1. The Operator collects, records, organizes, accumulates, stores, clarifies (updates, modifies), extracts, uses, transfers (distributes, provides access), depersonalizes, blocks, deletes, and destroys personal data.
9.2. The Operator carries out automated processing of personal data, including the receipt and/or transmission of information obtained using information and telecommunication networks or without them.
10. Cross-border transfer of personal data.
10.1. The operator must notify the relevant authority for the protection of personal data of their intention to carry out cross-border transfer of personal data before commencing such activities (this notification is sent separately from the notification of intention to process personal data).
10.2. Prior to submitting the above-mentioned notification, the operator is obliged to obtain the necessary information from the authorities of the foreign state, foreign individuals, and foreign legal entities to whom the cross-border transfer of personal data is planned.
11. Confidentiality of personal data
The operator and other individuals who have access to personal data are obliged not to disclose or distribute personal data to third parties without the consent of the data subject, unless otherwise provided by federal law.
12. Final provisions
12.1. The user may obtain any clarifications on the questions regarding the processing of their personal data by contacting the Operator via email at lb@garden-group.pro.
12.2. Any changes to the Operator's policy on the processing of personal data will be reflected in this document. The policy is valid indefinitely until replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet at https://garden-group.pro/eng/policy.