Privacy Policy for the Processing of Personal Data Collected
Privacy Policy for the Processing of Personal Data Collected (Processed) by Travel Retail LLC Through Information and Telecommunication Networks (via the Website http://www.trs-dutyfree.ru )
This Privacy Policy regarding the processing of personal data (hereinafter the “Policy”) has been prepared in accordance with Federal Law No. 152-FZ dated 27 July 2006 “On Personal Data” and sets forth the policy of Travel Retail LLC (hereinafter the “Operator”) with respect to the processing of Personal Data of users of the product pre-order service website located under the domain name trs-dutyfree.ru (hereinafter the “Website”).
1.1. Website means the website of the product pre-order service available via the Internet under the domain name trs-dutyfree.ru and owned by the Operator.
1.2. User means a Personal Data subject (an individual) who has accessed, visited, or performed any action on the Website, as well as any other individual whose Personal Data is collected, stored, or otherwise processed by the Operator.
1.3. Operator means Travel Retail LLC (TIN 5047270266, PSRN 1225000134600, registered office: Building 1/2, Novaya Street, Chashnikovo, Khimki Urban District, Moscow Region, 141592, Russian Federation), being a legal entity independently or jointly with other persons organizing and/or carrying out the processing of Personal Data, as well as determining the purposes of processing Personal Data, the scope of Personal Data subject to processing, and the actions (operations) performed in relation thereto.
1.4. User Account, or the “Account”, means a section of the Website intended for authorized users, access to which is provided through the creation and use of the User’s account credentials on the Website. The Account stores the User’s Personal Data, information regarding product pre-orders, Website browsing history and various profile settings.
1.5. Informational Messages means messages containing information necessary for placing a product pre-order on the Operator’s Website (including a code required for login to the User’s Account on the Website), as well as information regarding the completeness, status and other details relating to the User’s submitted product pre-order, sent by the Operator to the email address provided by the User on the Website.
1.6. Personal Data means any information relating directly or indirectly to an identified or identifiable individual (the personal data subject), including publicly available as well as special categories of data, including, without limitation:
1.6.1. Personal Data provided by the User during registration, editing of profile information in the Account, or placement of a product pre-order through completion of designated data entry fields without registration or authorization, including:
1.6.2. Data automatically transmitted during use of the Website through software installed on the User’s device, including, without limitation:
1.8. This Policy applies to any and all information obtained by the Operator regarding the User during the User’s visit to and use of the Website.
1.8.1. Use of the Website through provision of Personal Data thereon, including by means of registration or placement of a product pre-order without registration or authorization, shall constitute the User’s unconditional acceptance of this Policy and consent to the processing of the User’s Personal Data in accordance with the terms hereof. In the event of disagreement with these terms, the User shall refrain from visiting and using the Website.
1.8.2. By entering Personal Data on the Website and clicking the “Register”, “All correct, send Pre-Order”, or any other button necessary for creation and processing of the User’s product pre-order, the User consents to the following:
The User may also unsubscribe from Informational Messages by clicking the “Unsubscribe” link contained in such messages or by sending a corresponding request to preorder@trs-dutyfree.ru.
Should the User have any questions regarding unsubscribing from Informational Messages, the User may contact the Operator’s support service by telephone at +7 (495) 229-32-12 or by email at preorder@trs-dutyfree.ru.
Withdrawal of consent to receive Informational Messages shall not be possible where the User continues to use the Website or where an active product pre-order remains submitted and not cancelled by the User.
Where the User or the User’s representative withdraws consent to the processing of Personal Data, the Operator may continue processing Personal Data without such consent where grounds specified in clauses 2–11 of part 1 of article 6, part 2 of article 10, and part 2 of article 11 of Federal Law No. 152-FZ “On Personal Data” apply. Processed Personal Data shall be destroyed or anonymized upon achievement of the purposes of processing or where such purposes cease to be necessary, unless otherwise required by applicable federal law.
1.10. The Operator does not verify the accuracy of Personal Data provided by the User and does not monitor the User’s legal capacity, relying on the assumption that the User provides accurate and sufficient Personal Data.
The Operator processes Users’ Personal Data in accordance with:
3.1. The Operator processes Personal Data necessary for:
3.2.1. Identification of Users accessing and using the Website;
3.2.2. Communication with the User, including for purposes of:
3.2.4. Creation of User Accounts and provision of access thereto;
3.2.5. Provision of personalized offers, pricing information and other information to the User;
3.2.6. Provision of access to partner websites through links placed on the Website;
3.2.7. Cross-border transfer of data where the User specifies an email address hosted on servers located outside the Russian Federation or belonging to a foreign individual or legal entity, for the purposes specified in clauses 3.2.1–3.2.6 of this Policy. Collection of Personal Data shall in such case be carried out in accordance with article 3 of Federal Law No. 152-FZ “On Personal Data” and applicable international treaties of the Russian Federation.
3.3. For each of the purposes specified in clause 3.2 of this Policy, the Operator may process the following categories of Personal Data:
3.3.1. Personal Data provided by the User during registration, editing of profile information within the Account, or placement of a product pre-order through designated data entry fields without registration or authorization, including:
3.3.3. Any other information relating to the User necessary for processing in accordance with the Rules governing the Pre-Order Service.
3.4. The Operator uses cookies and web beacons (including pixel tags) for the collection of Personal Data.
3.5. The Operator collects and processes information constituting Personal Data within the meaning of clause 1.6 of this Policy, including for all purposes specified in clause 3.2 hereof, provided, however, that the Operator does not intentionally collect special categories of sensitive Personal Data, including:
4.1. The confidentiality of Users’ Personal Data shall be maintained, except where otherwise provided by applicable law.
4.2. The Operator shall process Personal Data where at least one of the following conditions applies:
4.2.1. The User has provided consent to the processing of their Personal Data;
4.2.2. Processing of Personal Data is necessary to ensure operation of the Website and performance of the Rules governing the Pre-Order Service, as well as for the exercise and performance by the Operator of functions, powers and obligations imposed under the legislation of the Russian Federation;
4.2.3. Processing of Personal Data is necessary for the exercise of the Operator’s or third parties’ rights and legitimate interests, or for the achievement of socially significant purposes, provided that such processing does not violate the rights and freedoms of Personal Data subjects.
4.3. The Operator shall be entitled to transfer Users’ Personal Data to third parties in the following cases:
4.3.1. The User has expressed consent by any of the means specified in clause 1.8 of this Policy;
4.3.2. Such transfer is necessary in connection with the User’s use of the Website, placement of a product pre-order, conclusion and performance of a retail sale and purchase agreement, compliance with Federal Law No. 152-FZ “On Personal Data”, informing the User regarding the status of the User’s pre-order and implementation of the Rules governing the Pre-Order Service;
4.3.3. Such transfer is required under Russian law or other applicable legislation pursuant to the procedure established thereby.
4.4. The Operator shall not make decisions producing legal effects in relation to the User or otherwise affecting the User’s rights and legitimate interests solely on the basis of automated processing of Personal Data, nor shall the Operator publish the User’s Personal Data in publicly accessible sources without the User’s prior consent.
4.5. Pursuant to paragraph 7 of article 14 of Federal Law No. 152-FZ dated 27 July 2006, the User shall have the right to obtain information concerning the processing of their Personal Data.
4.6. The Operator shall process (including store) Personal Data provided by the User during the following periods:
4.6.1. For the entire period of the User’s registration on the Website;
4.6.2. For the period necessary to fulfil the User’s product pre-order where the User has not registered on the Website or has placed a pre-order without authorization in the Account;
4.6.3. For the period necessary for the Operator to comply with obligations imposed by applicable legislation.
4.7. The Website may contain links enabling access to third-party websites on the Internet. The Operator shall bear no responsibility for information published on such websites and provides such links solely for the convenience of Users.
4.8. The Operator shall store Personal Data in a form permitting identification of the Personal Data subject for no longer than required by the purposes of processing and the User’s consent, unless a longer retention period is required by law.
4.9. When collecting Personal Data by any means, the Operator shall ensure that any cross-border transfer of Users’ Personal Data is carried out only after collection and primary processing thereof in compliance with localization requirements, including the use of databases located within the territory of the Russian Federation.
4.10. Should the User refuse to provide Personal Data and/or refuse to consent to the processing thereof, the Operator shall be unable to provide the User with access to the product pre-order service.
5.1. The User shall have the right at any time to amend (update or supplement) the Personal Data provided by the User by:
5.2.1. Sending a written withdrawal request by mail to: Building 1/2, Novaya Street, Chashnikovo, Khimki Urban District, Moscow Region, 141592, Russian Federation.
5.2.2. Sending a withdrawal request in the form of an electronic document to: preorder@trs-dutyfree.ru, subject to subsequent provision of the original signed request.
5.2.3. Should the User have any questions concerning withdrawal of consent to processing of Personal Data, the User may contact the Operator’s support service by telephone at +7 (495) 229-32-12 or by email at preorder@trs-dutyfree.ru.
5.2.4. A User utilizing an Account on the Website may withdraw consent to the processing of Personal Data by deleting the User’s Account on the Website.
5.2.5. A recommended form of withdrawal request for consent to processing of Personal Data, including consent to processing of Personal Data collected through analytical and metric software, is available via the following hyperlink.
6.1. Information relating to Users’ Personal Data which becomes known to the Operator shall be deemed confidential unless otherwise provided by law.
6.2. The Operator shall implement necessary and sufficient legal, organizational and technical measures aimed at preventing violations of the legislation of the Russian Federation on Personal Data and protecting Users’ Personal Data against unauthorized or accidental access, destruction, modification, blocking, copying, dissemination and other unlawful actions by third parties, including, without limitation:
6.2.1. Implementation of legal, organizational and technical measures to ensure security of Personal Data;
6.2.2. Appointment of a person responsible for the processing of Personal Data;
6.2.3. Adoption by the Operator of internal documents governing the Operator’s policy with respect to Personal Data processing and local regulations concerning Personal Data processing;
6.2.4. Restriction of access to Personal Data solely to persons requiring such access for performance of their employment duties;
6.2.5. Familiarization of employees directly involved in Personal Data processing with the provisions of the legislation of the Russian Federation concerning Personal Data, including requirements relating to protection of Personal Data and documents defining the Operator’s policy regarding processing of Users’ Personal Data;
6.2.6. Implementation of restricted access procedures for premises in which Personal Data processing is carried out.
6.3. The Operator shall destroy Personal Data in the following cases and within the following periods:
6.3.1. Within seven (7) business days following receipt from the User of information confirming the unlawful receipt of Personal Data or absence of necessity for processing Personal Data for the stated purposes of processing;
6.3.2. Within ten (10) business days following identification of unlawful processing of Personal Data where it is impossible to ensure lawfulness of such processing;
6.3.3. Within thirty (30) days following achievement of the purposes of processing Personal Data;
6.3.4. Within thirty (30) days following receipt of withdrawal of the User’s consent to processing of Personal Data, provided retention of such Personal Data is no longer required for processing purposes.
6.4. The Operator shall destroy Personal Data through erasure and/or deletion from storage media of information constituting Personal Data without the possibility of recovery thereof.
7.1. This Policy shall constitute a publicly available document and shall be published on the Operator’s Website at www.trs-dutyfree.ru for unrestricted access.
7.2. The Operator reserves the right to amend this Policy without obtaining Users’ consent or providing prior notice thereto by publishing an updated version of the Policy on the Website.
7.3. Any revised version of the Policy shall enter into force upon publication on the Website unless otherwise provided therein.
7.4. This Policy and all relations arising between the User and the Operator in connection with application of this Policy shall be governed by and construed in accordance with the laws of the Russian Federation.
This Privacy Policy regarding the processing of personal data (hereinafter the “Policy”) has been prepared in accordance with Federal Law No. 152-FZ dated 27 July 2006 “On Personal Data” and sets forth the policy of Travel Retail LLC (hereinafter the “Operator”) with respect to the processing of Personal Data of users of the product pre-order service website located under the domain name trs-dutyfree.ru (hereinafter the “Website”).
1. General Provisions
1.1. Website means the website of the product pre-order service available via the Internet under the domain name trs-dutyfree.ru and owned by the Operator.
1.2. User means a Personal Data subject (an individual) who has accessed, visited, or performed any action on the Website, as well as any other individual whose Personal Data is collected, stored, or otherwise processed by the Operator.
1.3. Operator means Travel Retail LLC (TIN 5047270266, PSRN 1225000134600, registered office: Building 1/2, Novaya Street, Chashnikovo, Khimki Urban District, Moscow Region, 141592, Russian Federation), being a legal entity independently or jointly with other persons organizing and/or carrying out the processing of Personal Data, as well as determining the purposes of processing Personal Data, the scope of Personal Data subject to processing, and the actions (operations) performed in relation thereto.
1.4. User Account, or the “Account”, means a section of the Website intended for authorized users, access to which is provided through the creation and use of the User’s account credentials on the Website. The Account stores the User’s Personal Data, information regarding product pre-orders, Website browsing history and various profile settings.
1.5. Informational Messages means messages containing information necessary for placing a product pre-order on the Operator’s Website (including a code required for login to the User’s Account on the Website), as well as information regarding the completeness, status and other details relating to the User’s submitted product pre-order, sent by the Operator to the email address provided by the User on the Website.
1.6. Personal Data means any information relating directly or indirectly to an identified or identifiable individual (the personal data subject), including publicly available as well as special categories of data, including, without limitation:
1.6.1. Personal Data provided by the User during registration, editing of profile information in the Account, or placement of a product pre-order through completion of designated data entry fields without registration or authorization, including:
- surname, first name and patronymic (if applicable);
- contact telephone number;
- email address;
- flight information, including flight number, date, time, and departure or arrival terminal at Sheremetyevo International Airport.
1.6.2. Data automatically transmitted during use of the Website through software installed on the User’s device, including, without limitation:
- electronic identifiers within the Operator’s, Google’s and Yandex’s systems;
- UTM tags;
- URL and page title;
- information regarding devices used;
- operating system;
- browser and other software information;
- screen resolution;
- geolocation data;
- IP address;
- MAC address;
- IDFA identifiers;
- cookie data;
- information regarding pages visited;
- information entered into search forms and other Website forms;
- access time;
- requested page address;
- date and time of Website visits;
- data concerning any actions performed by the User on the Website;
- search queries;
- pages visited;
- number of page visits;
- duration of user sessions;
- composition of the User’s product pre-order;
- data contained within the User Account;
- analytical and metric data;
- Website-assigned User identifiers;
- username and password;
- referral and exit points;
- network traffic data.
1.8. This Policy applies to any and all information obtained by the Operator regarding the User during the User’s visit to and use of the Website.
1.8.1. Use of the Website through provision of Personal Data thereon, including by means of registration or placement of a product pre-order without registration or authorization, shall constitute the User’s unconditional acceptance of this Policy and consent to the processing of the User’s Personal Data in accordance with the terms hereof. In the event of disagreement with these terms, the User shall refrain from visiting and using the Website.
1.8.2. By entering Personal Data on the Website and clicking the “Register”, “All correct, send Pre-Order”, or any other button necessary for creation and processing of the User’s product pre-order, the User consents to the following:
- processing of Personal Data, including for the purpose of service provision through direct communication with the User by means of communication channels (email and telephone), as well as for improving the functioning of the Website and conducting statistical research and surveys using relevant services;
- receipt of SMS messages and telephone calls from representatives of the Operator;
- transfer of Personal Data to third parties acting pursuant to agreements concluded in the interests of the Operator, including, without limitation, organizations hosting the Operator’s data storage and processing centers and the Operator’s business partners.
- by mail to: Building 1/2, Novaya Street, Chashnikovo, Khimki Urban District, Moscow Region, 141592, Russian Federation;
- in the form of an electronic document sent to: preorder@trs-dutyfree.ru, subject to subsequent provision of the original signed withdrawal request.
The User may also unsubscribe from Informational Messages by clicking the “Unsubscribe” link contained in such messages or by sending a corresponding request to preorder@trs-dutyfree.ru.
Should the User have any questions regarding unsubscribing from Informational Messages, the User may contact the Operator’s support service by telephone at +7 (495) 229-32-12 or by email at preorder@trs-dutyfree.ru.
Withdrawal of consent to receive Informational Messages shall not be possible where the User continues to use the Website or where an active product pre-order remains submitted and not cancelled by the User.
Where the User or the User’s representative withdraws consent to the processing of Personal Data, the Operator may continue processing Personal Data without such consent where grounds specified in clauses 2–11 of part 1 of article 6, part 2 of article 10, and part 2 of article 11 of Federal Law No. 152-FZ “On Personal Data” apply. Processed Personal Data shall be destroyed or anonymized upon achievement of the purposes of processing or where such purposes cease to be necessary, unless otherwise required by applicable federal law.
1.10. The Operator does not verify the accuracy of Personal Data provided by the User and does not monitor the User’s legal capacity, relying on the assumption that the User provides accurate and sufficient Personal Data.
2. Legal Basis for Processing Personal Data
The Operator processes Users’ Personal Data in accordance with:
- the Constitution of the Russian Federation;
- Federal Law No. 152-FZ dated 27 July 2006 “On Personal Data”;
- other applicable laws and regulations governing the Operator’s activities; and
- consents provided by Users for the processing of their Personal Data.
3. Purposes and Categories of Processed Personal Data
3.1. The Operator processes Personal Data necessary for:
- provision of the Website’s product pre-order service;
- possible subsequent conclusion and performance of a retail sale and purchase agreement at the Order Pickup Point;
- notification regarding the status of product pre-orders submitted via the Website;
- sending Informational Messages to the User; and
- processing of Personal Data collected through analytical and metric software.
3.2.1. Identification of Users accessing and using the Website;
3.2.2. Communication with the User, including for purposes of:
- enabling placement of product pre-orders on the Website;
- notifying the User regarding the status of submitted pre-orders;
- possible subsequent conclusion and performance of retail sale and purchase agreements; and
- processing User inquiries and requests;
3.2.4. Creation of User Accounts and provision of access thereto;
3.2.5. Provision of personalized offers, pricing information and other information to the User;
3.2.6. Provision of access to partner websites through links placed on the Website;
3.2.7. Cross-border transfer of data where the User specifies an email address hosted on servers located outside the Russian Federation or belonging to a foreign individual or legal entity, for the purposes specified in clauses 3.2.1–3.2.6 of this Policy. Collection of Personal Data shall in such case be carried out in accordance with article 3 of Federal Law No. 152-FZ “On Personal Data” and applicable international treaties of the Russian Federation.
3.3. For each of the purposes specified in clause 3.2 of this Policy, the Operator may process the following categories of Personal Data:
3.3.1. Personal Data provided by the User during registration, editing of profile information within the Account, or placement of a product pre-order through designated data entry fields without registration or authorization, including:
- surname, first name and patronymic (if applicable);
- contact telephone number;
- email address;
- flight information, including flight number, date, time and departure or arrival terminal at Sheremetyevo International Airport.
3.3.3. Any other information relating to the User necessary for processing in accordance with the Rules governing the Pre-Order Service.
3.4. The Operator uses cookies and web beacons (including pixel tags) for the collection of Personal Data.
3.5. The Operator collects and processes information constituting Personal Data within the meaning of clause 1.6 of this Policy, including for all purposes specified in clause 3.2 hereof, provided, however, that the Operator does not intentionally collect special categories of sensitive Personal Data, including:
- health-related information (including disability status, medical diagnoses and certificates);
- racial or ethnic origin;
- religious, philosophical or political beliefs;
- information regarding sexual orientation or intimate life;
- criminal records or information regarding criminal prosecution; and
- any other sensitive Personal Data affecting the User’s private, intimate or socially significant sphere of life.
4. Procedure and Conditions for Processing Personal Data. Refusal to Provide Personal Data and/or Consent to Processing
4.1. The confidentiality of Users’ Personal Data shall be maintained, except where otherwise provided by applicable law.
4.2. The Operator shall process Personal Data where at least one of the following conditions applies:
4.2.1. The User has provided consent to the processing of their Personal Data;
4.2.2. Processing of Personal Data is necessary to ensure operation of the Website and performance of the Rules governing the Pre-Order Service, as well as for the exercise and performance by the Operator of functions, powers and obligations imposed under the legislation of the Russian Federation;
4.2.3. Processing of Personal Data is necessary for the exercise of the Operator’s or third parties’ rights and legitimate interests, or for the achievement of socially significant purposes, provided that such processing does not violate the rights and freedoms of Personal Data subjects.
4.3. The Operator shall be entitled to transfer Users’ Personal Data to third parties in the following cases:
4.3.1. The User has expressed consent by any of the means specified in clause 1.8 of this Policy;
4.3.2. Such transfer is necessary in connection with the User’s use of the Website, placement of a product pre-order, conclusion and performance of a retail sale and purchase agreement, compliance with Federal Law No. 152-FZ “On Personal Data”, informing the User regarding the status of the User’s pre-order and implementation of the Rules governing the Pre-Order Service;
4.3.3. Such transfer is required under Russian law or other applicable legislation pursuant to the procedure established thereby.
4.4. The Operator shall not make decisions producing legal effects in relation to the User or otherwise affecting the User’s rights and legitimate interests solely on the basis of automated processing of Personal Data, nor shall the Operator publish the User’s Personal Data in publicly accessible sources without the User’s prior consent.
4.5. Pursuant to paragraph 7 of article 14 of Federal Law No. 152-FZ dated 27 July 2006, the User shall have the right to obtain information concerning the processing of their Personal Data.
4.6. The Operator shall process (including store) Personal Data provided by the User during the following periods:
4.6.1. For the entire period of the User’s registration on the Website;
4.6.2. For the period necessary to fulfil the User’s product pre-order where the User has not registered on the Website or has placed a pre-order without authorization in the Account;
4.6.3. For the period necessary for the Operator to comply with obligations imposed by applicable legislation.
4.7. The Website may contain links enabling access to third-party websites on the Internet. The Operator shall bear no responsibility for information published on such websites and provides such links solely for the convenience of Users.
4.8. The Operator shall store Personal Data in a form permitting identification of the Personal Data subject for no longer than required by the purposes of processing and the User’s consent, unless a longer retention period is required by law.
4.9. When collecting Personal Data by any means, the Operator shall ensure that any cross-border transfer of Users’ Personal Data is carried out only after collection and primary processing thereof in compliance with localization requirements, including the use of databases located within the territory of the Russian Federation.
4.10. Should the User refuse to provide Personal Data and/or refuse to consent to the processing thereof, the Operator shall be unable to provide the User with access to the product pre-order service.
5. Amendment of Personal Data by the User; Withdrawal of Consent to Processing
5.1. The User shall have the right at any time to amend (update or supplement) the Personal Data provided by the User by:
- submitting a written request to the Operator in the form of an electronic document to preorder@trs-dutyfree.ru, subject to subsequent provision of the original signed request; or
- independently updating the relevant information through the Account on the Website.
5.2.1. Sending a written withdrawal request by mail to: Building 1/2, Novaya Street, Chashnikovo, Khimki Urban District, Moscow Region, 141592, Russian Federation.
5.2.2. Sending a withdrawal request in the form of an electronic document to: preorder@trs-dutyfree.ru, subject to subsequent provision of the original signed request.
5.2.3. Should the User have any questions concerning withdrawal of consent to processing of Personal Data, the User may contact the Operator’s support service by telephone at +7 (495) 229-32-12 or by email at preorder@trs-dutyfree.ru.
5.2.4. A User utilizing an Account on the Website may withdraw consent to the processing of Personal Data by deleting the User’s Account on the Website.
5.2.5. A recommended form of withdrawal request for consent to processing of Personal Data, including consent to processing of Personal Data collected through analytical and metric software, is available via the following hyperlink.
6. Personal Data Security Measures; Procedure and Conditions for Destruction of Personal Data
6.1. Information relating to Users’ Personal Data which becomes known to the Operator shall be deemed confidential unless otherwise provided by law.
6.2. The Operator shall implement necessary and sufficient legal, organizational and technical measures aimed at preventing violations of the legislation of the Russian Federation on Personal Data and protecting Users’ Personal Data against unauthorized or accidental access, destruction, modification, blocking, copying, dissemination and other unlawful actions by third parties, including, without limitation:
6.2.1. Implementation of legal, organizational and technical measures to ensure security of Personal Data;
6.2.2. Appointment of a person responsible for the processing of Personal Data;
6.2.3. Adoption by the Operator of internal documents governing the Operator’s policy with respect to Personal Data processing and local regulations concerning Personal Data processing;
6.2.4. Restriction of access to Personal Data solely to persons requiring such access for performance of their employment duties;
6.2.5. Familiarization of employees directly involved in Personal Data processing with the provisions of the legislation of the Russian Federation concerning Personal Data, including requirements relating to protection of Personal Data and documents defining the Operator’s policy regarding processing of Users’ Personal Data;
6.2.6. Implementation of restricted access procedures for premises in which Personal Data processing is carried out.
6.3. The Operator shall destroy Personal Data in the following cases and within the following periods:
6.3.1. Within seven (7) business days following receipt from the User of information confirming the unlawful receipt of Personal Data or absence of necessity for processing Personal Data for the stated purposes of processing;
6.3.2. Within ten (10) business days following identification of unlawful processing of Personal Data where it is impossible to ensure lawfulness of such processing;
6.3.3. Within thirty (30) days following achievement of the purposes of processing Personal Data;
6.3.4. Within thirty (30) days following receipt of withdrawal of the User’s consent to processing of Personal Data, provided retention of such Personal Data is no longer required for processing purposes.
6.4. The Operator shall destroy Personal Data through erasure and/or deletion from storage media of information constituting Personal Data without the possibility of recovery thereof.
7. Final Provisions
7.1. This Policy shall constitute a publicly available document and shall be published on the Operator’s Website at www.trs-dutyfree.ru for unrestricted access.
7.2. The Operator reserves the right to amend this Policy without obtaining Users’ consent or providing prior notice thereto by publishing an updated version of the Policy on the Website.
7.3. Any revised version of the Policy shall enter into force upon publication on the Website unless otherwise provided therein.
7.4. This Policy and all relations arising between the User and the Operator in connection with application of this Policy shall be governed by and construed in accordance with the laws of the Russian Federation.