Personal Data Processing Policy
Moscow "June 27", 2025
Terms and definitions
Automated personal data processing – processing of personal data by means of computing equipment.
Personal data blocking – temporary cessation of personal data processing (except for cases when processing is necessary to clarify personal data).
Personal Data Information System – an information system representing a collection of personal data contained in databases, as well as information technologies and technical means allowing for the processing of such personal data using automation tools or without using such tools.
Personal data depersonalization – actions resulting in the impossibility to determine the ownership of personal data to a specific User or other personal data subject without the use of additional information.
Personal data processing – any action (operation) or set of actions (operations) performed using automation tools or without using such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
Personal data – any information relating directly or indirectly to a specific or identifiable User of the website: https://dicini.it/ (hereinafter referred to as the Website).
Personal data permitted by the personal data subject for distribution – personal data to which access is provided by the personal data subject to an unlimited number of persons by giving consent to the processing of personal data permitted by the personal data subject for distribution in the manner provided for by the Personal Data Law (hereinafter - personal data permitted for distribution).
User – any visitor to the Website of the following categories: an individual, including as an individual entrepreneur, a representative of a legal entity.
Provision of personal data – actions aimed at disclosing personal data to a specific person or a specific group of persons.
Distribution of personal data – any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or familiarizing an unlimited number of persons with personal data, including publication of personal data in mass media, placement in information and telecommunication networks or providing access to personal data in any other way.
Destruction of personal data – any actions resulting in the irreversible destruction of personal data with the impossibility of further restoration of the content of personal data in the personal data information system and (or) destruction of material carriers of personal data.
1. General provisions
1.1. The Personal Data Processing Policy (hereinafter referred to as the Policy) is compiled in accordance with the Constitution of the Russian Federation, the Civil Code of the Russian Federation, the Federal Law "On Information, Information Technologies and Information Protection", Federal Law No. 152-FZ of July 27, 2006 "On Personal Data" (hereinafter referred to as the Personal Data Law) and applies to all information that Individual Entrepreneur Dyachenko Yulia Konstantinovna, acting on the basis of a registration record as an individual entrepreneur (OGRNIP 313774623200621, INN 420534254799), registered at the address: 127576, Moscow, Novgorodskaya str., 13, apt./off. 46, may obtain about the user during their use of the Website and during the execution of the purchase and sale agreement.
1.2. Use of the Website implies the user's consent to the Policy. In case of disagreement with these conditions, the user must refrain from using the Website.
1.3. The Operator has the right to make changes to the Policy without the User's consent. The new version of the Policy comes into force from the moment of its placement on the Website, unless otherwise provided by the new version of the Policy. The current version of the Policy is freely available on the Website.
1.4. The purpose of developing the Policy is to determine the procedure for processing personal data of Website Users and other personal data subjects whose personal data is subject to processing, based on the operator's authority; ensuring the protection of human and civil rights and freedoms, including the buyer of goods, when processing their personal data, including protection of rights to privacy, personal and family secrets, as well as establishing responsibility of officials having access to personal data for non-compliance with requirements of norms regulating the processing and protection of personal data.
1.5. The confidentiality regime of personal data is removed in cases of their depersonalization and after the expiration of 75 years of their storage period, or is extended based on the conclusion of the Operator's expert commission, unless otherwise determined by law.
2. Rights and obligations of the Operator
2.1. The Operator has the right:
2.1.1. to receive reliable information and/or documents containing personal data from the personal data subject;
2.1.2. in case of withdrawal of consent for personal data processing by the personal data subject, the Operator has the right to continue processing personal data without the consent of the personal data subject if there are grounds specified in the Personal Data Law;
2.1.3. to independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations provided for 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.
2.2. The Operator is obliged:
2.2.1. to provide the personal data subject, upon their request, with information concerning the processing of their personal data;
2.2.2. to organize the processing of personal data in the manner established by the current legislation of the Russian Federation;
2.2.3. to respond to appeals and requests of personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
2.2.4. to report to the authorized body for the protection of rights of personal data subjects, upon request of this body, the necessary information within 30 days from the date of receipt of such request;
2.2.5. to publish or otherwise ensure unlimited access to this Policy regarding the processing of personal data;
2.2.6. to take legal, organizational and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other unlawful actions regarding personal data;
2.2.7. to stop the transfer (distribution, provision, access) of personal data, stop processing and destroy personal data in the manner and cases provided for by the Personal Data Law;
2.2.8. to fulfill other obligations provided for by the Personal Data Law.
3. Basic rights and obligations of personal data subjects
3.1. The personal data subject has the right:
3.1.1. to receive information concerning the processing of their personal data, except for cases provided for by federal laws of the Russian Federation. Information is provided to the personal data subject by the Operator in an accessible form and should not contain personal data relating to other personal data subjects, except for cases when there are legal grounds for disclosure of such personal data. The list of information and the procedure for obtaining it is established by the Personal Data Law;
3.1.2. to require from the operator clarification of their personal data, their blocking or destruction in case the personal data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated purpose of processing, as well as to take measures provided by law to protect their rights;
3.1.3. to put forward the condition of preliminary consent when processing personal data for the purpose of promoting goods, works and services in the market;
3.1.4. to withdraw consent for personal data processing;
3.1.5. to appeal to the authorized body for the protection of rights of personal data subjects or in court against unlawful actions or inaction of the Operator when processing their personal data;
3.1.6. to exercise other rights provided for by the legislation of the Russian Federation.
3.2. The personal data subject is obliged:
3.2.1. to provide the Operator with reliable data about themselves;
3.2.2. to inform the Operator about clarification (updating, modification) of their personal data;
3.2.3. Persons who have provided the Operator with unreliable information about themselves, or information about another personal data subject without the latter's consent, bear responsibility in accordance with the legislation of the Russian Federation.
4. The Operator may process the following personal data of the User
4.1. Last name, first name, middle name;
4.2. Phone number;
4.3. Contact information (e-mail);
4.4. Bank details when paying for services;
4.5. Delivery address for goods;
4.6. The Website collects and processes depersonalized data about visitors (including "cookie" files) using internet statistics services (Yandex Metrica and Google Analytics and others);
4.7. The above-mentioned data is hereinafter in the text of the Policy combined under the general concept of Personal Data;
4.8. Processing of special categories of personal data concerning racial, national origin, political views, religious or philosophical beliefs, intimate life is not carried out by the Operator;
4.9. Processing of personal data permitted for distribution from among special categories of personal data specified in part 1 of Article 10 of the Personal Data Law is allowed if the prohibitions and conditions provided for in Article 10.1 of the Personal Data Law are observed;
4.10. User consent for processing personal data permitted for distribution is formalized separately from other consents for processing their personal data. At the same time, conditions provided for, in particular, 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 rights of personal data subjects.
4.10.1. Consent for processing personal data permitted for distribution is provided by the User directly to the Operator;
4.10.2. The Operator is obliged, no later than three working days from the moment of receiving the specified User consent, to publish information about the conditions of processing, about the existence of prohibitions and conditions for processing by an unlimited number of persons of personal data permitted for distribution;
4.10.3. Transfer (distribution, provision, access) of personal data permitted by the personal data subject for distribution must be stopped at any time at the request of the personal data subject. This requirement must include the last name, first name, middle name (if any), contact information (phone number, email address or postal address) of the personal data subject, as well as a list of personal data whose processing is to be stopped;
4.10.4. Consent for processing personal data permitted for distribution ceases to be valid from the moment the Operator receives the requirement specified in paragraph 4.10.3 of this Policy regarding the processing of personal data.
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 achieving specific, predetermined and lawful purposes. Processing of personal data incompatible with the purposes of personal data collection is not allowed;
5.3. Combining databases containing personal data whose processing is carried out for incompatible purposes is not allowed;
5.4. Only personal data that meets the purposes of their processing is subject to processing;
5.5. The content and scope of processed personal data correspond to the stated purposes of processing. Redundancy of processed personal data in relation to the stated purposes of their processing is not allowed;
5.6. When processing personal data, the accuracy of personal data, their sufficiency, and when necessary, their relevance in relation to the purposes of personal data processing is ensured. The Operator takes necessary measures and/or ensures their adoption for the removal or clarification of incomplete or inaccurate data;
5.7. Storage of personal data is carried out in a form that allows identifying the personal data subject, no longer than required by the purposes of personal data processing, unless the period of personal data storage is established by federal law, contract of which the personal data subject is a party, beneficiary or guarantor. Processed personal data is destroyed or depersonalized upon achieving the processing purposes or in case of loss of necessity to achieve these purposes, unless otherwise provided by federal law.
6. Purposes of personal data processing
6.1. The purpose of processing User personal data: informing the User by sending emails; conclusion, execution and termination of civil law contracts; providing the User with access to services, information and/or materials contained on the Website; clarification of order details.
6.2. The Operator also has the right to send the User notifications about new products and services, special offers and various events. The User can always refuse to receive informational messages by sending the Operator a letter to the email address: Giuliarifelli@gmail.com (hereinafter referred to as the Operator's Electronic Address) with the note "Refusal of notifications about new products and services and special offers";
6.3. Depersonalized User data collected using internet statistics services serves to collect information about User actions on the website, improve the quality of the website and its content.
7. Legal grounds for personal data processing
7.1. The Operator processes User personal data only if they are filled out and/or sent by the User independently through special forms located on the Website or sent to the Operator via email. By filling out the corresponding forms and/or sending their personal data to the Operator, the User expresses their consent to this Policy;
7.2. The Operator processes depersonalized data about the User if this is allowed in the User's browser settings (saving "cookie" files and using JavaScript technology is enabled);
7.3. The personal data subject independently makes a decision about providing their personal data and gives consent freely, by their own will and in their own interest;
7.4. The personal data operator conducts personal data processing based on User consent.
8. Conditions for personal data processing
8.1. Personal data processing is carried out with the consent of the personal data subject for processing their personal data;
8.2. Personal data processing is necessary to achieve goals provided for by an international treaty of the Russian Federation or law, to perform functions, powers and duties imposed on the operator by the legislation of the Russian Federation;
8.3. Personal data processing is necessary for the administration of justice, 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 enforcement proceedings;
8.4. Personal data processing is necessary for the execution of a contract to which the personal data subject is a party, beneficiary or guarantor, as well as for concluding a contract on the initiative of the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor;
8.5. Personal data processing is necessary for the exercise of rights and legitimate interests of the operator or third parties or to achieve socially significant goals, provided that the rights and freedoms of the personal data subject are not violated;
8.6. Processing of personal data to which access is provided by the personal data subject or at their request to an unlimited number of persons (hereinafter - publicly available personal data) is carried out;
8.7. Processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.
9. Procedure for collection, storage, transfer and other types of personal data processing
9.1. Security of personal data processed by the Operator is ensured through the implementation of legal, organizational and technical measures necessary for full compliance with the requirements of current legislation of the Russian Federation in the field of personal data protection;
9.2. The Operator ensures the safety of personal data and takes all possible measures to exclude access to personal data by unauthorized persons;
9.3. User personal data will never, under any circumstances, be transferred to third parties, except for cases related to the execution of current legislation or in case the personal data subject has given consent to the Operator to transfer data to a third party for the fulfillment of obligations under a civil law contract;
9.4. In case of detection of inaccuracies in personal data, the User can update them independently by sending the Operator a notification to the Operator's email address with the note "Personal data update";
9.5. The period of personal data processing is determined by achieving the purposes for which personal data was collected, unless another period is provided for by contract or current legislation of the Russian Federation. The User can at any time withdraw their consent to personal data processing by sending the Operator a notification via email to the Operator's Electronic Address with the note "Withdrawal of consent to personal data processing";
9.6. All information collected by third-party services, including payment systems, communication means and other service providers, is stored and processed by the specified persons (Operators) in accordance with their User Agreement and Personal Data Processing Policy (privacy). The personal data subject and/or User is obliged to independently and timely familiarize themselves with the specified documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this paragraph;
9.7. Prohibitions established by the personal data subject on transfer (except for providing access), as well as on processing or conditions of processing (except for obtaining access) of personal data permitted for distribution, do not apply in cases of personal data processing in state, public and other public interests determined by the legislation of the Russian Federation;
9.8. The Operator ensures confidentiality of personal data when processing personal data;
9.9. The Operator stores personal data in a form that allows identifying the personal data subject, no longer than required by the purposes of personal data processing, unless the period of personal data storage is established by federal law, contract of which the personal data subject is a party, beneficiary or guarantor;
9.10. The condition for terminating personal data processing may be achieving the purposes of personal data processing, expiration of the personal data subject's consent or withdrawal of consent by the personal data subject, as well as detection of unlawful personal data processing.
10. List of actions performed by the Operator with received personal data
10.1. The Operator carries out collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion and destruction of personal data;
10.2. The Operator carries out automated processing of personal data with receipt and/or transmission of received information via information and telecommunication networks or without such;
10.3. Upon achieving the purpose of personal data processing, the Operator destroys personal data by deleting them without the possibility of their recovery; personal data located on the hard disk is deleted by means of the computer's operating system followed by clearing the recycle bin.
11. Confidentiality of personal data
11.1. The Operator and other persons who have gained access to personal data are obliged not to disclose to third parties and not to distribute personal data without the consent of the personal data subject, unless otherwise provided by federal law.
12. Feedback. Questions and suggestions
12.1. All suggestions or questions regarding this Policy should be sent to the Operator's address via Email.