PRIVACY POLICY AND PERSONAL DATA PROCESSING
Date of approval: 11.02.2026
Sole proprietor Karen Surikovich Yuzbashyan, hereinafter referred to as the "Seller" or "Operator", OGRNIP 317774600159966, INN 773124125756, place of business: 121354, Moscow, Kutuzova St., 11, bldg. 4, apt. 116, place of sale by pick-up (Seller's studio): Moscow, Bolshoy Kolobovsky per., 2, publishes on the website https://dirtyhands.ru/ "DirtyHands" this privacy policy and personal data processing policy (hereinafter referred to as the "Policy") in accordance with Federal Law No. 152-FZ of July 27, 2006 "On Personal Data".
This Policy has been developed in accordance with the requirements of Federal Law No. 152-FZ of July 27, 2006 "On Personal Data" (hereinafter referred to as "FZ-152"), the Civil Code of the Russian Federation, Law of the Russian Federation No. 2300-1 of February 7, 1992 "On Protection of Consumer Rights" and other regulatory legal acts of the Russian Federation.
The Policy defines the procedure for processing personal data and measures to ensure the security of personal data applied by the Operator, who is the seller within the framework of the public offer published on the website at https://dirtyhands.ru/ "DirtyHands" (hereinafter referred to as the "Offer" and "Online Store").
This Policy applies to personal data that the Seller receives directly from the Personal Data Subject (Buyer) when placing an order, registering, subscribing to newsletters, using feedback forms and other methods of interaction through the Online Store.
1. TERMS AND DEFINITIONS
1.1. Online Store — a set of pages of the website(s) and/or mobile applications on which the Seller conducts its activities and through which the Buyer can view the range of Products, place a sales order or a custom order for the manufacture of a product and pay for the order.
1.2. Personal data subject (Buyer) – an individual with legal capacity who purchases Goods exclusively for personal, family, household, and other needs not related to entrepreneurial activity, and who has duly accepted the terms of the Online Store Offer.
1.3. Personal data – any information relating to a directly or indirectly identified or determinable individual (Personal data subject) (Clause 1, Article 3, Federal Law No. 152).
1.4. Processing of personal data – actions (operations) or a set of actions (operations) performed with the use of automation tools or without the use of such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data (clause 3, Article 3 of Federal Law-152).
1.5. Confidentiality of personal data – a mandatory requirement for the Operator to prohibit the distribution, provision of and access to personal data by third parties without the consent of the Personal Data Subject, except for cases stipulated by the legislation of the Russian Federation.
1.6. Goods – ceramic and other products of the Seller's own production, presented in the assortment of the Online Store.
1.7. Custom Order — a product manufactured by the Seller based on the individual order of the Buyer, taking into account the specified specific requirements for shape, size, color, decor or other characteristics that are not provided for by the standard line of Products.
1.8. Purchase and Sale Agreement — a retail purchase and sale agreement for the Product concluded between the Seller and the Buyer in accordance with Article 492 of the Civil Code of the Russian Federation and the Law of the Russian Federation of 07.02.1992 No. 2300-1 "On Protection of Consumer Rights" (hereinafter referred to as the "Law on Protection of Consumer Rights").
1.9. Contract — a household contract for the manufacture of an Custom Order concluded between the Seller and the Buyer in accordance with Article 730 of the Civil Code of the Russian Federation and the Law on Protection of Consumer Rights.
2. PERSONAL DATA OPERATOR
2.1. The personal data operator is:
Sole proprietor Karen Surikovich Yuzbashyan
OGRNIP: 317774600159966
INN: 773124125756
Place of business, at the address where the personal data is processed: 121354, Moscow, Kutuzova St., 11, bldg. 4, apt. 116
Address of production and pick-up of Goods, at the address where the personal data is processed: Moscow, Bolshoy Kolobovsky Lane, 2
Address for sending correspondence: 121354, Moscow, Kutuzova St., 11, bldg. 4, apt. 116.
E-mail: order@dirtyhands.ru
Contact phone number: +7 916 319-51-86
2.2. Responsible for organizing the processing of personal data in accordance with Art. 22.1 of Federal Law 152 appoints the Operator itself.
3. LIST AND CATEGORIES OF PROCESSED PERSONAL DATA
3.1. The Operator processes the personal data of the Personal Data Subjects to the extent necessary for the performance of the Sale and Purchase Agreement or the Contract for Work concluded within the framework of the Online Store Offer:
last name, first name, patronymic (if any);
Goods delivery address;
contact telephone number, account in the messaging program;
e-mail address;
details of the ordered Goods or Individual Order;
details of the payment method and amount;
other information voluntarily provided by the Buyer when placing an order, in correspondence with the Operator or when filling out forms on the Online Store resources.
3.2. The Operator does not process special categories of personal data stipulated by paragraph 1 of Article 10 of Federal Law 152, as well as biometric personal data without obtaining the prior written consent of the Subject. 3.3.
Personal data of minors under the age of 14 are processed only with the consent of one of the parents or legal representative of the Personal Data Subject.
Personal data subjects aged 14 to 18 years process their personal data with the consent of one of the parents or legal representative. With the consent of a parent or legal representative, independent processing of data of a minor is allowed in the amount not exceeding that specified in this Policy.
3.4. The personal data subject transfers data for processing on all grounds specified in the Policy, free of charge.
4. PURPOSES OF PERSONAL DATA PROCESSING
4.1. Personal data shall be processed solely for the purposes of:
fulfilling the Operator's obligations under the Sale and Purchase Agreement or the Contract for work in accordance with the Online Store Offer;
placing and confirming an order for a Product or an Individual Order;
calculating and informing about the cost of delivery;
organizing delivery of the Product to the specified address;
informing the Buyer about the order status, including via e-mail, SMS or messaging programs;
processing payments and refunds;
ensuring warranty obligations in relation to the Product;
considering claims and appeals of the Buyer;
Supporting other communications with the Buyer, including sending advertising offers and newsletters about the activities of the Seller and its partners;
analyzing customer activity, improving service quality;
and complying with the requirements of Russian legislation.
4.2. Personal data is not processed for the purpose of automated decision-making that generates legal consequences for the Data Subject or otherwise affects their rights and legitimate interests.
4.3. In fulfilling obligations under contracts with the Buyer and this Policy, the Seller may transfer the Buyer's personal data to organizations and counterparties involved in the fulfillment of obligations (e.g., courier and transport companies, payment agents and settlement providers, communications service operators, and warehousing service providers). Such transfer is carried out only to the extent necessary to fulfill the obligation and solely for the purpose of fulfilling the terms of the contract (delivery of goods, payment processing, notifications to the Buyer, and other related services). Personal data may not be transferred for purposes unrelated to the fulfillment of the contract or obligations stipulated by law without the separate consent of the Buyer
. 4.4. In order to fulfill its obligations under the contract with the Buyer, and also with the Buyer's express consent to receive marketing information, the Seller may transfer personal data to partner organizations involved in fulfilling contractual obligations and/or counterparties providing marketing and communications services (e.g., mailing services, loyalty program partners). The Seller does not transfer personal data to third parties for the purpose of subsequent resale or use in databases for mass mailings, spam, or other activities unrelated to the operation of the Online Store.
The transfer of data for marketing purposes is carried out exclusively on the basis of the Buyer's separate, freely expressed consent to receive such information and only to the extent necessary to provide the agreed-upon marketing services. The Seller does not transfer personal data to third parties for arbitrary commercial purposes without the express consent of the Buyer.
In the event of withdrawal of consent to receive marketing messages, the Seller will cease transferring personal data to partners for such purposes and will cease sending mailings (messages) within the established timeframe.
5. LEGAL BASIS FOR PERSONAL DATA PROCESSING
5.1. The legal grounds for personal data processing are:
consent of the personal data subject to the processing of his personal data in the amount and for the purposes specified in this Policy (clause 1 of Article 6 of Federal Law No. 152);
the need to process personal data for the performance of an agreement to which the personal data subject is a party, beneficiary or guarantor (clause 2 of Article 6 of Federal Law No. 152);
the need to process personal data to exercise the rights and legitimate interests of the Operator, provided that this does not violate the rights and freedoms of the Personal Data Subject (Clause 4, Article 6, Federal Law 152).
5.2. Acceptance of the Offer of the Online Store by the Personal Data Subject (Buyer) by placing an order in the Online Store means the provision of consent to the processing of personal data in the amount and for the purposes necessary to fulfill the agreement.
6. PROCEDURE AND CONDITIONS FOR PROCESSING PERSONAL DATA
6.1. Personal data shall be processed in compliance with the principles and rules provided for in Article 5, Federal Law 152:
legality and fairness of processing;
the processing of personal data is limited to the achievement of specific, predetermined and legitimate purposes;
inadmissibility of combining databases containing personal data, the processing of which is carried out for incompatible purposes;
inadmissibility of processing personal data incompatible with the purposes of collection;
inadmissibility of combining personal data on health status with other personal data without the consent of the Personal Data Subject;
The processing of personal data is carried out using security tools that ensure the security of personal data.
6.2. Personal data is processed both with the use of automation tools (via the software of the Online store, including cookies, technologies to improve user interaction, e-mail, cloud services) and without the use of automation tools (paper documents).
6.3. Personal data is stored on the territory of the Russian Federation in accordance with the requirements of Part 5 of Article 18 of Federal Law No. 152.
7. CROSS-BORDER TRANSFER OF PERSONAL DATA
7.1. Cross-border transfer of personal data (transfer of personal data to the territory of a foreign state to an authority of a foreign state, a foreign individual or legal entity) is carried out exclusively if it is necessary to deliver the Goods outside the Russian Federation and only with the consent of the Personal Data Subject, if required by the legislation on personal data.
7.2. The transfer of personal data to carriers engaged in international transportation is permitted subject to the following conditions:
ensuring an adequate level of protection of the rights of personal data subjects in accordance with the requirements of Article 19 of Federal Law No. 152;
obtaining the prior consent of the personal data subject for such transfer when placing an order for delivery outside the Russian Federation;
concluding an agreement with the recipient of personal data that provides for obligations to ensure the confidentiality and security of personal data.
7.3. Personal data shall not be transferred to third parties who are not carriers or other persons necessary for the performance of the agreement, except for cases stipulated by the legislation of the Russian Federation.
8. PERIODS OF PERSONAL DATA STORAGE
8.1. Personal data shall be stored for the periods necessary to fulfill obligations under the agreement and in accordance with the requirements of the legislation of the Russian Federation:
during the term of the agreement and the warranty period for the Goods;
within 3 (three) years after fulfillment of obligations under the agreement - for tax and accounting purposes (in accordance with paragraph 1 of Article 23 of the Tax Code of the Russian Federation and paragraph 4 of Article 29 of the Federal Law of 06.12.2011 No. 402-FZ "On Accounting");
within 10 (ten) years after the fulfillment of obligations under the agreement - for the purpose of protecting the rights and legitimate interests of the Operator in the event of disputes (in accordance with Article 196 of the Civil Code of the Russian Federation).
8.2. Upon expiration of the specified periods, personal data are subject to destruction or anonymization in the absence of legal grounds for their further storage.
9. USE OF COOKIES AND OTHER DATA COLLECTION TECHNOLOGIES
9.1. Cookies are small text files placed on the Buyer's device when visiting the resources of the Online Store, designed to ensure the correct functioning of the site, storing session parameters, user preferences and collecting statistical information.
9.2. The Seller uses the following categories of cookies:
Technically necessary cookies - designed to ensure the basic functionality of the site, including authorization, operation of the "Cart" section, navigation. Storage period: until the end of the session / up to 1 year.
Analytical cookies – used to collect statistics on website traffic, user behavior, and the effectiveness of individual pages. Storage period: up to 2 years.
Functional cookies – used to store user settings, such as interface language, region, and other parameters. Storage period: up to 1 year.
Marketing cookies – used to personalize advertising offers, retargeting, and analyze the effectiveness of advertising campaigns. Storage period: up to 2 years.
9.3. Other data collection technologies:
9.3.1. The Seller has the right to use the following technologies to collect and process information about visits to and use of the Online Store resources:
Web beacons (pixels) – graphic objects embedded in web pages or emails to track user actions;
Local Storage (Session Storage) – technologies for storing data on the user’s device;
SDK (Software Development Kit) – software modules integrated into the Online Store’s mobile applications;
API integrations – interfaces for exchanging data with third-party services.
9.3.2. The specified technologies may be used for the following purposes:
ensuring the correct operation of the Online Store’s resources;
analyzing traffic and user behavior;
personalizing content and advertising offers;
preventing fraud and ensuring information security;
improving the quality of services.
9.4. Third-party services and analytics:
9.4.1. The Seller has the right to engage third parties to provide services for traffic analysis, marketing, advertising and other purposes. Such services may include, but are not limited to:
Yandex.Metrica;
Yandex.Direct;
VKontakte (advertising, pixel);
Google Analytics (provided that data is processed in the Russian Federation or in jurisdictions with an adequate level of protection);
other analytical and advertising platforms.
9.4.2. Third-party services may independently install cookies and other tracking technologies on the Buyer's device or browser. The Seller does not control and is not responsible for the privacy policies and data processing practices of such third parties.
Marketing tracking technologies may be used only with the Buyer's separate consent to receive marketing messages, advertising newsletters and personalized analytics for the purpose of offering relevant content, promotions and special offers. In the event of withdrawal of such consent, the relevant technical trackers used for marketing purposes may be deactivated.
9.4.3. Data is transferred to third-party services to the extent necessary to provide the relevant services and is governed by agreements with such parties.
9.5. Consent to the use of cookies:
9.5.1. By visiting the online store and using its functionality, the Buyer consents to the use of cookies and other data collection technologies to the extent and for the purposes specified in this section.
9.5.2. When first visiting the site, the Buyer may be presented with a banner with information about the use of cookies and the option to configure consent settings.
9.6. Cookie management:
9.6.1. The Buyer has the right to revoke their consent to the use of cookies (except for technically necessary ones) at any time by:
setting the consent banner on the Online Store website;
changing browser settings (blocking, deleting cookies);
using specialized programs and extensions.
The Buyer can manage the use of cookies and other data collection technologies through browser settings, plug-ins, extensions, or other privacy management tools (for example, in the Browser Settings section, select "Reject all cookies" or "Accept only necessary cookies"). Disabling some cookies may affect the proper functioning of some functions of the Online Store (for example, saving the state of the shopping cart, automatic authorization, or personal settings).
9.6.2. Revoking consent to the use of analytical and marketing cookies does not affect the ability to use the main functionality of the Online Store, but may limit the personalization of content and advertising offers.
9.6.3. Instructions for managing cookies in popular browsers are available at the following links:
Yandex Browser: settings → "Privacy";
Google Chrome: Settings → "Privacy and Security";
Safari: Settings → "Privacy";
Mozilla Firefox: Settings → "Privacy and Security".
9.7. Features of Use in Mobile Applications:
9.7.1. When using the Online Store's mobile applications, similar data collection technologies may be used, including:
device identifiers (IDFA, AAID, etc.);
location data (with consent);
information about the user's actions in the application.
9.7.2. The collection and processing of such data is carried out in accordance with the application settings and the permissions granted by the user in the device's operating system.
9.8. Information about cookies and other data collection technologies is an integral part of this Privacy Policy.
9.9. The Seller reserves the right to change the list of technologies and third-party services used without prior notice to the Buyer. The latest information is posted in this section of the Policy.
9.10. Questions regarding the use of cookies and other data collection technologies may be sent to the Operator at the addresses specified in this Policy.
10. RIGHTS OF THE PERSONAL DATA SUBJECT
10.1. The personal data subject has the right to:
Receive information on the processing of his personal data (Article 14 of Federal Law 152);
Request clarification, blocking or destruction of his personal data if they are incomplete, outdated, inaccurate, illegally obtained or are not necessary for the stated purpose of processing (Article 14 of Federal Law 152);
Revoke his consent to the processing of personal data (Article 9 of Federal Law 152);
Request termination of the processing of personal data in cases stipulated by the legislation of the Russian Federation;
Appeal the actions or inaction of the Operator to the authorized body for the protection of the rights of personal data subjects (Roskomnadzor) or in court.
10.2. To exercise his rights, the Personal Data Subject sends the Operator a written application in any of the following ways:
by e-mail specified in this Policy;
to the postal address specified in this Policy;
through the feedback form in the Online Store.
10.3. The request must contain the last name, first name, email address of the personal data subject, the essence of the request, a list of the requested actions (for example: provision of a copy of the data, clarification, blocking, deletion).
10.4. The Operator shall review the application of the personal data subject and send a response within a period not exceeding thirty calendar days from the date of receipt of the application (clause 6, Article 14 of Federal Law-152). If it is necessary to extend the response period for objective reasons, the Operator shall notify the personal data subject before the expiration of the specified period.
11. PROCEDURE FOR REVOCATION OF CONSENT TO THE PROCESSING OF PERSONAL DATA
11.1. The personal data subject has the right to revoke their consent to the processing of personal data by sending a written application to the Operator at the Operator's postal address.
11.2. Revocation of consent does not entail termination of the processing of personal data in cases where the processing is carried out on other legal grounds provided for in Article 6 of Federal Law-152 (in particular, for the performance of an agreement).
11.3. In the event of consent withdrawal and the absence of other legal grounds for processing, personal data shall be destroyed within a period of no more than 30 (thirty) days from the date of receipt of the consent withdrawal application.
12. MEASURES TO ENSURE THE SECURITY OF PERSONAL DATA
12.1. The operator shall take the necessary legal, organizational and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, distribution, as well as from other illegal actions of third parties in accordance with the requirements of Art. 19 of Federal Law 152 and the Requirements for the Protection of Personal Data during their Processing in Personal Data Information Systems, approved by RF Government Resolution No. 1119 of 01.11.2012 and other regulatory acts.
12.2. Such measures include:
appointment of persons responsible for organizing the processing of personal data;
application of rules for access to information systems and services;
use of information security tools (encryption, anti-virus protection);
assessment of the effectiveness of measures taken to ensure the security of personal data;
delimitation of employee access to personal data depending on their job responsibilities;
familiarization of employees with the provisions of the legislation on personal data and local acts on the processing and protection of personal data.
13. FINAL PROVISIONS
13.1. This Policy is a local regulatory act of the Operator and comes into force from the moment it is posted on the website of the Online Store.
13.2. The Operator has the right to make changes to this Policy unilaterally. The current version of the Policy is posted on the website of the Online Store at: https://dirtyhands.ru/ "DirtyHands" .
13.3. The legislation of the Russian Federation applies to relations related to the processing of personal data.
13.4. Subjects of personal data are obliged to independently familiarize themselves with the current version of this Policy before each order in the Online Store.
13.5. The invalidity of individual provisions of this Policy does not entail the invalidity of the entire Policy.
Date of approval: 11.02.2026
Sole proprietor Karen Surikovich Yuzbashyan, hereinafter referred to as the "Seller" or "Operator", OGRNIP 317774600159966, INN 773124125756, place of business: 121354, Moscow, Kutuzova St., 11, bldg. 4, apt. 116, place of sale by pick-up (Seller's studio): Moscow, Bolshoy Kolobovsky per., 2, publishes on the website https://dirtyhands.ru/ "DirtyHands" this privacy policy and personal data processing policy (hereinafter referred to as the "Policy") in accordance with Federal Law No. 152-FZ of July 27, 2006 "On Personal Data".
This Policy has been developed in accordance with the requirements of Federal Law No. 152-FZ of July 27, 2006 "On Personal Data" (hereinafter referred to as "FZ-152"), the Civil Code of the Russian Federation, Law of the Russian Federation No. 2300-1 of February 7, 1992 "On Protection of Consumer Rights" and other regulatory legal acts of the Russian Federation.
The Policy defines the procedure for processing personal data and measures to ensure the security of personal data applied by the Operator, who is the seller within the framework of the public offer published on the website at https://dirtyhands.ru/ "DirtyHands" (hereinafter referred to as the "Offer" and "Online Store").
This Policy applies to personal data that the Seller receives directly from the Personal Data Subject (Buyer) when placing an order, registering, subscribing to newsletters, using feedback forms and other methods of interaction through the Online Store.
1. TERMS AND DEFINITIONS
1.1. Online Store — a set of pages of the website(s) and/or mobile applications on which the Seller conducts its activities and through which the Buyer can view the range of Products, place a sales order or a custom order for the manufacture of a product and pay for the order.
1.2. Personal data subject (Buyer) – an individual with legal capacity who purchases Goods exclusively for personal, family, household, and other needs not related to entrepreneurial activity, and who has duly accepted the terms of the Online Store Offer.
1.3. Personal data – any information relating to a directly or indirectly identified or determinable individual (Personal data subject) (Clause 1, Article 3, Federal Law No. 152).
1.4. Processing of personal data – actions (operations) or a set of actions (operations) performed with the use of automation tools or without the use of such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data (clause 3, Article 3 of Federal Law-152).
1.5. Confidentiality of personal data – a mandatory requirement for the Operator to prohibit the distribution, provision of and access to personal data by third parties without the consent of the Personal Data Subject, except for cases stipulated by the legislation of the Russian Federation.
1.6. Goods – ceramic and other products of the Seller's own production, presented in the assortment of the Online Store.
1.7. Custom Order — a product manufactured by the Seller based on the individual order of the Buyer, taking into account the specified specific requirements for shape, size, color, decor or other characteristics that are not provided for by the standard line of Products.
1.8. Purchase and Sale Agreement — a retail purchase and sale agreement for the Product concluded between the Seller and the Buyer in accordance with Article 492 of the Civil Code of the Russian Federation and the Law of the Russian Federation of 07.02.1992 No. 2300-1 "On Protection of Consumer Rights" (hereinafter referred to as the "Law on Protection of Consumer Rights").
1.9. Contract — a household contract for the manufacture of an Custom Order concluded between the Seller and the Buyer in accordance with Article 730 of the Civil Code of the Russian Federation and the Law on Protection of Consumer Rights.
2. PERSONAL DATA OPERATOR
2.1. The personal data operator is:
Sole proprietor Karen Surikovich Yuzbashyan
OGRNIP: 317774600159966
INN: 773124125756
Place of business, at the address where the personal data is processed: 121354, Moscow, Kutuzova St., 11, bldg. 4, apt. 116
Address of production and pick-up of Goods, at the address where the personal data is processed: Moscow, Bolshoy Kolobovsky Lane, 2
Address for sending correspondence: 121354, Moscow, Kutuzova St., 11, bldg. 4, apt. 116.
E-mail: order@dirtyhands.ru
Contact phone number: +7 916 319-51-86
2.2. Responsible for organizing the processing of personal data in accordance with Art. 22.1 of Federal Law 152 appoints the Operator itself.
3. LIST AND CATEGORIES OF PROCESSED PERSONAL DATA
3.1. The Operator processes the personal data of the Personal Data Subjects to the extent necessary for the performance of the Sale and Purchase Agreement or the Contract for Work concluded within the framework of the Online Store Offer:
last name, first name, patronymic (if any);
Goods delivery address;
contact telephone number, account in the messaging program;
e-mail address;
details of the ordered Goods or Individual Order;
details of the payment method and amount;
other information voluntarily provided by the Buyer when placing an order, in correspondence with the Operator or when filling out forms on the Online Store resources.
3.2. The Operator does not process special categories of personal data stipulated by paragraph 1 of Article 10 of Federal Law 152, as well as biometric personal data without obtaining the prior written consent of the Subject. 3.3.
Personal data of minors under the age of 14 are processed only with the consent of one of the parents or legal representative of the Personal Data Subject.
Personal data subjects aged 14 to 18 years process their personal data with the consent of one of the parents or legal representative. With the consent of a parent or legal representative, independent processing of data of a minor is allowed in the amount not exceeding that specified in this Policy.
3.4. The personal data subject transfers data for processing on all grounds specified in the Policy, free of charge.
4. PURPOSES OF PERSONAL DATA PROCESSING
4.1. Personal data shall be processed solely for the purposes of:
fulfilling the Operator's obligations under the Sale and Purchase Agreement or the Contract for work in accordance with the Online Store Offer;
placing and confirming an order for a Product or an Individual Order;
calculating and informing about the cost of delivery;
organizing delivery of the Product to the specified address;
informing the Buyer about the order status, including via e-mail, SMS or messaging programs;
processing payments and refunds;
ensuring warranty obligations in relation to the Product;
considering claims and appeals of the Buyer;
Supporting other communications with the Buyer, including sending advertising offers and newsletters about the activities of the Seller and its partners;
analyzing customer activity, improving service quality;
and complying with the requirements of Russian legislation.
4.2. Personal data is not processed for the purpose of automated decision-making that generates legal consequences for the Data Subject or otherwise affects their rights and legitimate interests.
4.3. In fulfilling obligations under contracts with the Buyer and this Policy, the Seller may transfer the Buyer's personal data to organizations and counterparties involved in the fulfillment of obligations (e.g., courier and transport companies, payment agents and settlement providers, communications service operators, and warehousing service providers). Such transfer is carried out only to the extent necessary to fulfill the obligation and solely for the purpose of fulfilling the terms of the contract (delivery of goods, payment processing, notifications to the Buyer, and other related services). Personal data may not be transferred for purposes unrelated to the fulfillment of the contract or obligations stipulated by law without the separate consent of the Buyer
. 4.4. In order to fulfill its obligations under the contract with the Buyer, and also with the Buyer's express consent to receive marketing information, the Seller may transfer personal data to partner organizations involved in fulfilling contractual obligations and/or counterparties providing marketing and communications services (e.g., mailing services, loyalty program partners). The Seller does not transfer personal data to third parties for the purpose of subsequent resale or use in databases for mass mailings, spam, or other activities unrelated to the operation of the Online Store.
The transfer of data for marketing purposes is carried out exclusively on the basis of the Buyer's separate, freely expressed consent to receive such information and only to the extent necessary to provide the agreed-upon marketing services. The Seller does not transfer personal data to third parties for arbitrary commercial purposes without the express consent of the Buyer.
In the event of withdrawal of consent to receive marketing messages, the Seller will cease transferring personal data to partners for such purposes and will cease sending mailings (messages) within the established timeframe.
5. LEGAL BASIS FOR PERSONAL DATA PROCESSING
5.1. The legal grounds for personal data processing are:
consent of the personal data subject to the processing of his personal data in the amount and for the purposes specified in this Policy (clause 1 of Article 6 of Federal Law No. 152);
the need to process personal data for the performance of an agreement to which the personal data subject is a party, beneficiary or guarantor (clause 2 of Article 6 of Federal Law No. 152);
the need to process personal data to exercise the rights and legitimate interests of the Operator, provided that this does not violate the rights and freedoms of the Personal Data Subject (Clause 4, Article 6, Federal Law 152).
5.2. Acceptance of the Offer of the Online Store by the Personal Data Subject (Buyer) by placing an order in the Online Store means the provision of consent to the processing of personal data in the amount and for the purposes necessary to fulfill the agreement.
6. PROCEDURE AND CONDITIONS FOR PROCESSING PERSONAL DATA
6.1. Personal data shall be processed in compliance with the principles and rules provided for in Article 5, Federal Law 152:
legality and fairness of processing;
the processing of personal data is limited to the achievement of specific, predetermined and legitimate purposes;
inadmissibility of combining databases containing personal data, the processing of which is carried out for incompatible purposes;
inadmissibility of processing personal data incompatible with the purposes of collection;
inadmissibility of combining personal data on health status with other personal data without the consent of the Personal Data Subject;
The processing of personal data is carried out using security tools that ensure the security of personal data.
6.2. Personal data is processed both with the use of automation tools (via the software of the Online store, including cookies, technologies to improve user interaction, e-mail, cloud services) and without the use of automation tools (paper documents).
6.3. Personal data is stored on the territory of the Russian Federation in accordance with the requirements of Part 5 of Article 18 of Federal Law No. 152.
7. CROSS-BORDER TRANSFER OF PERSONAL DATA
7.1. Cross-border transfer of personal data (transfer of personal data to the territory of a foreign state to an authority of a foreign state, a foreign individual or legal entity) is carried out exclusively if it is necessary to deliver the Goods outside the Russian Federation and only with the consent of the Personal Data Subject, if required by the legislation on personal data.
7.2. The transfer of personal data to carriers engaged in international transportation is permitted subject to the following conditions:
ensuring an adequate level of protection of the rights of personal data subjects in accordance with the requirements of Article 19 of Federal Law No. 152;
obtaining the prior consent of the personal data subject for such transfer when placing an order for delivery outside the Russian Federation;
concluding an agreement with the recipient of personal data that provides for obligations to ensure the confidentiality and security of personal data.
7.3. Personal data shall not be transferred to third parties who are not carriers or other persons necessary for the performance of the agreement, except for cases stipulated by the legislation of the Russian Federation.
8. PERIODS OF PERSONAL DATA STORAGE
8.1. Personal data shall be stored for the periods necessary to fulfill obligations under the agreement and in accordance with the requirements of the legislation of the Russian Federation:
during the term of the agreement and the warranty period for the Goods;
within 3 (three) years after fulfillment of obligations under the agreement - for tax and accounting purposes (in accordance with paragraph 1 of Article 23 of the Tax Code of the Russian Federation and paragraph 4 of Article 29 of the Federal Law of 06.12.2011 No. 402-FZ "On Accounting");
within 10 (ten) years after the fulfillment of obligations under the agreement - for the purpose of protecting the rights and legitimate interests of the Operator in the event of disputes (in accordance with Article 196 of the Civil Code of the Russian Federation).
8.2. Upon expiration of the specified periods, personal data are subject to destruction or anonymization in the absence of legal grounds for their further storage.
9. USE OF COOKIES AND OTHER DATA COLLECTION TECHNOLOGIES
9.1. Cookies are small text files placed on the Buyer's device when visiting the resources of the Online Store, designed to ensure the correct functioning of the site, storing session parameters, user preferences and collecting statistical information.
9.2. The Seller uses the following categories of cookies:
Technically necessary cookies - designed to ensure the basic functionality of the site, including authorization, operation of the "Cart" section, navigation. Storage period: until the end of the session / up to 1 year.
Analytical cookies – used to collect statistics on website traffic, user behavior, and the effectiveness of individual pages. Storage period: up to 2 years.
Functional cookies – used to store user settings, such as interface language, region, and other parameters. Storage period: up to 1 year.
Marketing cookies – used to personalize advertising offers, retargeting, and analyze the effectiveness of advertising campaigns. Storage period: up to 2 years.
9.3. Other data collection technologies:
9.3.1. The Seller has the right to use the following technologies to collect and process information about visits to and use of the Online Store resources:
Web beacons (pixels) – graphic objects embedded in web pages or emails to track user actions;
Local Storage (Session Storage) – technologies for storing data on the user’s device;
SDK (Software Development Kit) – software modules integrated into the Online Store’s mobile applications;
API integrations – interfaces for exchanging data with third-party services.
9.3.2. The specified technologies may be used for the following purposes:
ensuring the correct operation of the Online Store’s resources;
analyzing traffic and user behavior;
personalizing content and advertising offers;
preventing fraud and ensuring information security;
improving the quality of services.
9.4. Third-party services and analytics:
9.4.1. The Seller has the right to engage third parties to provide services for traffic analysis, marketing, advertising and other purposes. Such services may include, but are not limited to:
Yandex.Metrica;
Yandex.Direct;
VKontakte (advertising, pixel);
Google Analytics (provided that data is processed in the Russian Federation or in jurisdictions with an adequate level of protection);
other analytical and advertising platforms.
9.4.2. Third-party services may independently install cookies and other tracking technologies on the Buyer's device or browser. The Seller does not control and is not responsible for the privacy policies and data processing practices of such third parties.
Marketing tracking technologies may be used only with the Buyer's separate consent to receive marketing messages, advertising newsletters and personalized analytics for the purpose of offering relevant content, promotions and special offers. In the event of withdrawal of such consent, the relevant technical trackers used for marketing purposes may be deactivated.
9.4.3. Data is transferred to third-party services to the extent necessary to provide the relevant services and is governed by agreements with such parties.
9.5. Consent to the use of cookies:
9.5.1. By visiting the online store and using its functionality, the Buyer consents to the use of cookies and other data collection technologies to the extent and for the purposes specified in this section.
9.5.2. When first visiting the site, the Buyer may be presented with a banner with information about the use of cookies and the option to configure consent settings.
9.6. Cookie management:
9.6.1. The Buyer has the right to revoke their consent to the use of cookies (except for technically necessary ones) at any time by:
setting the consent banner on the Online Store website;
changing browser settings (blocking, deleting cookies);
using specialized programs and extensions.
The Buyer can manage the use of cookies and other data collection technologies through browser settings, plug-ins, extensions, or other privacy management tools (for example, in the Browser Settings section, select "Reject all cookies" or "Accept only necessary cookies"). Disabling some cookies may affect the proper functioning of some functions of the Online Store (for example, saving the state of the shopping cart, automatic authorization, or personal settings).
9.6.2. Revoking consent to the use of analytical and marketing cookies does not affect the ability to use the main functionality of the Online Store, but may limit the personalization of content and advertising offers.
9.6.3. Instructions for managing cookies in popular browsers are available at the following links:
Yandex Browser: settings → "Privacy";
Google Chrome: Settings → "Privacy and Security";
Safari: Settings → "Privacy";
Mozilla Firefox: Settings → "Privacy and Security".
9.7. Features of Use in Mobile Applications:
9.7.1. When using the Online Store's mobile applications, similar data collection technologies may be used, including:
device identifiers (IDFA, AAID, etc.);
location data (with consent);
information about the user's actions in the application.
9.7.2. The collection and processing of such data is carried out in accordance with the application settings and the permissions granted by the user in the device's operating system.
9.8. Information about cookies and other data collection technologies is an integral part of this Privacy Policy.
9.9. The Seller reserves the right to change the list of technologies and third-party services used without prior notice to the Buyer. The latest information is posted in this section of the Policy.
9.10. Questions regarding the use of cookies and other data collection technologies may be sent to the Operator at the addresses specified in this Policy.
10. RIGHTS OF THE PERSONAL DATA SUBJECT
10.1. The personal data subject has the right to:
Receive information on the processing of his personal data (Article 14 of Federal Law 152);
Request clarification, blocking or destruction of his personal data if they are incomplete, outdated, inaccurate, illegally obtained or are not necessary for the stated purpose of processing (Article 14 of Federal Law 152);
Revoke his consent to the processing of personal data (Article 9 of Federal Law 152);
Request termination of the processing of personal data in cases stipulated by the legislation of the Russian Federation;
Appeal the actions or inaction of the Operator to the authorized body for the protection of the rights of personal data subjects (Roskomnadzor) or in court.
10.2. To exercise his rights, the Personal Data Subject sends the Operator a written application in any of the following ways:
by e-mail specified in this Policy;
to the postal address specified in this Policy;
through the feedback form in the Online Store.
10.3. The request must contain the last name, first name, email address of the personal data subject, the essence of the request, a list of the requested actions (for example: provision of a copy of the data, clarification, blocking, deletion).
10.4. The Operator shall review the application of the personal data subject and send a response within a period not exceeding thirty calendar days from the date of receipt of the application (clause 6, Article 14 of Federal Law-152). If it is necessary to extend the response period for objective reasons, the Operator shall notify the personal data subject before the expiration of the specified period.
11. PROCEDURE FOR REVOCATION OF CONSENT TO THE PROCESSING OF PERSONAL DATA
11.1. The personal data subject has the right to revoke their consent to the processing of personal data by sending a written application to the Operator at the Operator's postal address.
11.2. Revocation of consent does not entail termination of the processing of personal data in cases where the processing is carried out on other legal grounds provided for in Article 6 of Federal Law-152 (in particular, for the performance of an agreement).
11.3. In the event of consent withdrawal and the absence of other legal grounds for processing, personal data shall be destroyed within a period of no more than 30 (thirty) days from the date of receipt of the consent withdrawal application.
12. MEASURES TO ENSURE THE SECURITY OF PERSONAL DATA
12.1. The operator shall take the necessary legal, organizational and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, distribution, as well as from other illegal actions of third parties in accordance with the requirements of Art. 19 of Federal Law 152 and the Requirements for the Protection of Personal Data during their Processing in Personal Data Information Systems, approved by RF Government Resolution No. 1119 of 01.11.2012 and other regulatory acts.
12.2. Such measures include:
appointment of persons responsible for organizing the processing of personal data;
application of rules for access to information systems and services;
use of information security tools (encryption, anti-virus protection);
assessment of the effectiveness of measures taken to ensure the security of personal data;
delimitation of employee access to personal data depending on their job responsibilities;
familiarization of employees with the provisions of the legislation on personal data and local acts on the processing and protection of personal data.
13. FINAL PROVISIONS
13.1. This Policy is a local regulatory act of the Operator and comes into force from the moment it is posted on the website of the Online Store.
13.2. The Operator has the right to make changes to this Policy unilaterally. The current version of the Policy is posted on the website of the Online Store at: https://dirtyhands.ru/ "DirtyHands" .
13.3. The legislation of the Russian Federation applies to relations related to the processing of personal data.
13.4. Subjects of personal data are obliged to independently familiarize themselves with the current version of this Policy before each order in the Online Store.
13.5. The invalidity of individual provisions of this Policy does not entail the invalidity of the entire Policy.