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(«Yana Besfamilnaya», «YB», «Yana Besfamilnaya Store», «we», «our», «us») is a
trading name of GATO Limited. We respect the privacy rights of its online
visitors ("you", "your", "yours") and recognize
the importance of protecting the information collected about them. We have
use the information that you provide us with.
What personal information do we collect from you and how?
YANA BESFAMILNAYA collects personal information in several ways when you place an order, buy a gift voucher for a friend or register for a service offered by YANA BESFAMILNAYA. By registering, you are consenting to the collection of your personal data. If an order is placed with us, we need to hold personal information including your name, email address, phone numbers, home address, shipping and credit/debit card billing address(es) so that we can process and fulfill your order.
Saved card details will never be shared with third parties and will only be used to process your order, using our payment partner's systems PayPal. Additionally we may also obtain information as a result of authentication or identity checks. Sometimes we may ask for your telephone number. This number may be given to our courier for delivery services. These details allow us to process your order and to let you know the status of your order.
What about cookies?
There are four types of cookies:
Website functionality cookies: these cookies enable you to browse the website and use our features such as shopping baskets and wish lists
Website analytics cookies: we use these cookies to measure and analyze how our customers use the website. This allows us to continuously improve our website and your shopping experience.
Customer preference cookies: when browsing or shopping online, the website will remember preferences you make (for example your user name, language or location). This makes your browsing experience simpler, easier and more personal to you.
Targeting cookies or advertising cookies: these cookies are used to deliver adverts relevant to you. In addition, they limit the number of times you see an advertisement as well as helping us measure the effectiveness of our advertising campaigns.
By using our website you agree that we can place these types of cookies on your device and access them when you visit the site in the future.
If you want to delete any cookies that are already on your computer, please refer to the help and support area on your internet browser for instructions on how to locate the file or directory that stores cookies.
Information on deleting or controlling cookies is available at www.aboutcookies.org. Please note that by deleting our cookies or disabling future cookies you may not be able to access certain areas or features of our site.
How this information may be used, including anyone it might be shared with
YANA BESFAMILNAYA may use your personal information for the processing of orders, payments and to provide you with a personalized shopping experience. We will also use your details to fulfill and deliver your orders and manage your account. Personal information that you provide may be disclosed to a credit reference or fraud prevention agency, which may keep a record of that information. Your personal information may also be shared with other trading divisions within GATO Limited. Where there is a legal obligation to do so, we may disclose your information to any relevant regulatory body.
We may also use your personal information to send you marketing updates but only ever in accordance with your preferences (as detailed in the next section). We do not sell your details to third party marketing companies.
We do collate information about site traffic, sales, wish lists, and other commercial information which we may pass on to third parties but this information does not include any information which can identify you personally.
Finally, we may use your personal information for our internal marketing and demographic studies, together with non-personal data to monitor customer patterns so we can consistently improve our site design to better meet our visitors' needs.
From time to time YANA BESFAMILNAYA may employ third party business partners to collect personal information on YANA BESFAMILNAYA's behalf. YANA BESFAMILNAYA may also share your data with third party business partners to provide you with targeted advertising. In such cases, these third parties will be subject to confidentiality agreements and instructed by YANA BESFAMILNAYA to comply with applicable data protection law.
Marketing opt-in and opt-out provision
When you register, you will be given the option to opt-out of subscribing to our regular update service which will send you:
(i) Email alerts for new products, features, enhancements, special offers, upgrade opportunities, contests, events of interest, and one-off marketing promotions.
(ii) Direct mail alerts for new products, features, enhancements, special offers, upgrade opportunities, contests, events of interest, and one-off marketing promotions.
Marketing communications you subscribe to will only be sent by GATO Limited.
At all times, we will offer you the opportunity to unsubscribe out of any service or update to which you have subscribed, if you change your mind. Any e-mail we send you will contain an easy automated unsubscribe link so that you can opt-out of that particular mailshot. Simply follow the indications in the e-mail. Alternatively you can change your email preferences or opt out of all emails by logging into My Account. To opt out of direct mail service or updates, please contact a www.yanabesfamilnaya.com customer care representative by email at email@example.com.
How you can access and if necessary, change the personal information YANA BESFAMILNAYA maintains
If for any reason you are concerned that the personal information held by YANA BESFAMILNAYA is not correct, please visit the website and, after logging into the site using the "Sign In" menu on the home page, your personal information will be made available for review and change in the "My Account" section. Only you or, upon your request, the Customer Care department, may access your personal data from the website using your password and User ID. Information may be changed online within My Details, Shipping Details, and My Email Preferences. You can change or delete saved credit/debit card details each time you make a purchase. You will also be able to delete saved credit/debit card details by adding or editing a shipping/billing address. If you change your billing or shipping address while your order is still being processed, the order will be re-processed through security validation checks. If you prefer, you may contact us by email at firstname.lastname@example.org. and we will amend your personal details.
Safeguarding your personally identifiable information
We will take reasonable care to maintain appropriate safeguards to ensure the security, integrity and privacy of the information you have provided us with. When you place an order or access your account information, we use a Secure Socket Layer (SSL) encryption which encrypts your information before it is sent to us to protect it from unauthorized use. In addition, we will take reasonable steps to ensure that third party business partners' to whom we transfer any data will provide sufficient protection of that personal information.
Where and how to ask questions or file complaints
If you require more information please go to the Contact Us section of the web site and send us an email email@example.com.
RUSSIA PERSONAL DATA POLICY
1. General Provisions
1.1. GATO Limited ("YANA BESFAMILNAYA" or "Operator") respects the privacy rights of its customers and recognizes the importance of protecting the information collected about them.
1.2. The present YANA BESFAMILNAYA Privacy and Confidentiality Policy ("Policy"), which constitutes a public document, covers all personal data ("PD") processed by YANA BESFAMILNAYA and has been developed in line with the applicable laws ("Law") related to PD.
1.3. The purpose of the Policy is to inform PD owners ("Data Subject/s") and other persons engaged in PD processing of YANA BESFAMILNAYA adherence to the fundamental principles of legitimacy, justice, non-redundancy, correlation of the content and scope of the PD processed to the declared processing purposes.
2.1. The following definitions apply to PD protection:
2.1.1. "Personal data": data which relates to a living individual who can be identified a) from that data or, b) from that data and other information in our possession or likely to come into our possession).
2.1.2. "Data subject": an individual who is the subject of PD. Data subjects have legal rights in relation to handling and processing of their PD.
2.1.3."Operator" a person who (either alone or jointly with other persons) determines the purpose for which, and the manner in which, any PD is to be processed. They have a responsibility to establish practices and policies in line with the Law.
2.1.4."Data processors" any person, other than an employee of the Operator) who processes PD on behalf of an Operator, i.e. third parties that process or handle PD on our behalf.
2.1.5."Processing" any activity that involves the use of PD. It includes obtaining, recording or holding the data, or carrying out any operation or set of operations on the data including organizing, amending, retrieving, using, disclosing, erasing or destroying. Processing also includes transferring PD to third parties.
2.1.6. "Sensitive Personal data" includes information about a person's racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health,condition,sexual life, or about the commission of, or proceedings for, any offence committed or alleged to have been committed by that person, the disposal of such proceedings or the sentence of any court in such proceedings. Sensitive Personal data can only be processed under strict conditions, and usually requires the express consent of the Data Subject.
3. Objectives of PD Processing
3.1. YANA BESFAMILNAYA legal obligations and requirements under the Law for the processing of PD are to ensure that all PD processed by YANA BESFAMILNAYA in the course of its activities is:
3.1.1. collected, stored and processed for justifiable reasons;
3.1.2. processed by authorized persons with a legitimate reason;
3.1.3. stored safely;
3.1.4. retained only for the defined time period after which it is appropriately destroyed;
3.1.5. not disclosed to unauthorized persons.
3.2. YANA BESFAMILNAYA will actively seek to meet its obligations and duties in accordance with the Law and in so doing will not infringe the rights of its employees, customers, third parties or others.
4. Legal Grounds for PD Processing
4.1. PD are processed by YANA BESFAMILNAYA:
4.1.1. upon acquisition of appropriate consent of the Data Subject to the processing of his/her PD;
4.1.2. for the purpose of being compliant with the Law;
4.1.3. for the purpose of performing an agreement of which the Data Subject is a party or beneficiary.
4.2. PD may only be processed for the specific purpose notified to the Data Subject when it was first collected, or for purposes specifically permitted by the Law. PD must not be collected for one purpose and subsequently used for another. If it becomes necessary to change the purpose for which the data is being processed, the Data Subject must be informed of the new purpose before any processing occurs.
5. Consent and Processed PD
5.1. YANA BESFAMILNAYA processes PD for the following purposes:
5.1.1. comply with Law requirements, organize its activities and its employees’ activities;
5.1.2. verify the identity of customers and their eligibility to register as users on the YANA BESFAMILNAYA website;
5.1.3. process users’ registrations, providing customers with a sign in ID for the YANA BESFAMILNAYA website and maintain and manage such registrations;
5.1.4. provide customers with relevant customer care and respond to their queries, feedback, claims or disputes;
5.1.5. perform research or statistical analysis for marketing and promotional purposes in order to improve the content and layout of the YANA BESFAMILNAYA website and improve the YANA BESFAMILNAYA product offerings and services;
5.1.6. subject to obtaining consent in such form as may be required under the Law, YANA BESFAMILNAYA may use PD from its customers to provide them with notices, surveys, product alerts, communications and other marketing materials relating to goods and services offered by YANA BESFAMILNAYA sites including its exclusive membership programs, value added services ancillary to the memberships, and other products and services offered by YANA BESFAMILNAYA from time to time to its registered users.
5.2. If the customer voluntarily submits any information for publication on the YANA BESFAMILNAYA website through the publishing tools, including but not limited to, Company Profile, Product Catalog, Trade Leads, Trust Pass Profile and any discussion forum, then the customer is deemed to have given consent to the publication of such information.
5.3. YANA BESFAMILNAYA may employ third party business partners to collect and process PD on its behalf. YANA BESFAMILNAYA may also share PD with third party business partners to provide the customer with targeted advertising and other services. In such cases, these third parties will be subject to confidentiality agreements as outlined in articles 7.6 and 11 below and accordingly instructed by YANA BESFAMILNAYA to comply with the Law and YANA BESFAMILNAYA internal regulations.
5.4. YANA BESFAMILNAYA may collate information about site traffic, sales, wish lists, and other commercial information which can be transferred to third parties. This information cannot lead to the customer being identified and it is therefore not regarded as PD.
6. Consent and Processed PD
6.1. YANA BESFAMILNAYA collects PD in several ways when the customer places an order, buys a gift card for a friend or registers for a service. By registering, the customer expresses their consent to the collection of his/her PD.
6.2. In order to process and fulfill a customer’s order, YANA BESFAMILNAYA needs to collect the following information: name, surname, email address, phone numbers, home address, shipping and credit/debit card billing address(es).
6.3. PD can be accepted from a person other than the Data Subject, provided that the Data Subject has provided their consent to submit their PD to YANA BESFAMILNAYA for processing.
6.4. Saved bank card details are never shared with third parties and are only used to process the customer’s order using YANA BESFAMILNAYA partners’ payment systems. YANA BESFAMILNAYA may also ask further information as a result of authentication or identity checks.
7. PD processing
7.1. YANA BESFAMILNAYA will maintain an inventory of categories of PD it processes relating to its employees and customers, and for the purposes of which each category is used. The inventory shall indicate high-risk categories of PD processed in accordance with the Law, including but not limited to:
7.1.1. sensitive PD;
7.1.2. personal bank accounts, credit/debit cards and other financial information;
7.1.3. national identifiers, i.e. National Insurance or National Identity Numbers;
7.1.4. material relating to meetings, interviews or negotiations which could adversely affect individuals if such information were to be divulged.
7.2. YANA BESFAMILNAYA is responsible for ensuring that all PD processed within its systems are adequate, relevant and not excessive and are only collected on the basis of a real and justifiable business reason. Periodic reviews of YANA BESFAMILNAYA technology, processes and procedures implemented for PD processing are to be conducted to ensure they continue to be adequate and fit-for-purpose. Any anomalies identified are to be recorded and appropriate action must be taken to address the findings.
7.3. Processed PD must correspond to real and justifiable business reasons, for this purpose:
7.3.1. YANA BESFAMILNAYA will only process the minimum amount of PD required to meet its legitimate purposes;
7.3.2. additional information which is not relevant or is excessive for the stated purpose is not processed;
7.3.3. new systems and processes involving PD are to be developed and reviewed to ensure their compliance with the Law and YANA BESFAMILNAYA internal regulations.
7.4. YANA BESFAMILNAYA implements appropriate technical and organizational measures to prevent unauthorized or unlawful processing, accidental loss, destruction and damage to PD. Such measures align to the basic information security principles of:
7.4.1. Confidentiality - only those persons specifically authorized can access and or use PD;
7.4.2. Integrity - PD shall be accurate and relied upon for the purpose for which it is being processed;
7.4.3. Availability - PD are only provided to authorized persons upon receipt of a validated request;
7.4.4. Security - PD are stored in accordance with technical/security requirements provided by the Law and are not disclosed orally, in writing or in any electronic form to any unauthorized person, either deliberately or accidentally.
8. Storage Period and PD Retention
8.1. YANA BESFAMILNAYA is to ensure that PD is not kept for any longer than necessary and will adhere to any legal, regulatory or specific business reason justifying PD processing.
8.2. PD relating to customers' is only to be retained for as long as a business justification remains. PD relating to employees is normally retained for six years after the individual leaves the company. Some information however will be kept for longer; this could include information necessary in respect of pensions, taxation, potential/current disputes or litigation regarding the employment and information required for job references.
8.3. Appropriate processes and procedures are applied to ensure the regular backup of PD, and backups can be restored when required, irrespective of the period for which relevant PD have been retained
9. Rights of Data Subjects
9.1. Everyone has the right to request access to any PD about them that is held or processed by YANA BESFAMILNAYA.
9.2. YANA BESFAMILNAYA complies with requests for access to PD as established by the Law. The supplied information shall be in an intelligible form that is easily understood by everyone..
9.3. YANA BESFAMILNAYA is allowed to require further information to determine whether the person submitting the request is the Data Subject (this is to avoid PD about one individual being send to another, inadvertently, or as a result of deception).
9.4. The Data Subject is entitled to modify their own PD by signing in to their account on the YANA BESFAMILNAYA site. The customer is able to delete saved credit/debit card details. If the customer changes their billing or shipping address while an order is still being processed, the order will be re-processed through security validation checks. PD can be also amended by the YANA BESFAMILNAYA customer care team by emailing firstname.lastname@example.org.
9.5. At all times the customer has the right to opt-out of subscribing to YANA BESFAMILNAYA regular service updates which may be sent to them: (i) email alerts for new products, features, enhancements, special offers, upgrade opportunities, contests, events of interest, and one-off marketing promotions; and (ii) direct mail alerts for new products, features, enhancements, special offers, upgrade opportunities, contests, events of interest, and one-off marketing promotions. Any email sent by YANA BESFAMILNAYA to the customer contains an easy automated unsubscribe link. Alternatively the customer can change their email preferences or opt out of all emails by signing in to their account on the YANA BESFAMILNAYA site or emailing email@example.com.
9.6. YANA BESFAMILNAYA sites and their contents are not targeted to minors (those under the age of 18). However, YANA BESFAMILNAYA cannot ascertain the age of individuals who access its site. If a minor has provided YANA BESFAMILNAYA with PD without parental or guardian consent, the parent or guardian should contact YANA BESFAMILNAYA to have the relevant information removed.
10. Transfer and Cross-border Transfer (“CBT”) of PD
10.1. YANA BESFAMILNAYA performs transfer and CBT of PD, i.e. transmission of PD to a recipient located in a foreign jurisdiction, in conformity with the rules established by the Law and exclusively for the purposes of PD processing indicated in par. 5 above.
10.2. PD can be transferred without written consent of the Data Subject to foreign countries that ensure proper protection of Data Subjects’ rights in conformity with the Law.
10.3. PD can be transmitted across the borders to the countries that are incapable of ensuring proper protection of PD owner rights:
10.3.1. upon written consent of the Data Subject to CBT of their PD given as established by the Law;
10.3.2. for the purpose of performing an agreement of which both the Data Subject and the Operator are parties;
10.3.3. in other cases established by the Law.
10.4. The Operator could transfer PD to recipients located in foreign countries, including but not limited to: the United Kingdom of Great Britain and Northern Ireland, the United States of America and Italy.
10.5. In case YANA BESFAMILNAYA shares PD with any (national or foreign) third party a Confidentiality Agreement (“NDA”) shall be stipulated with such subject. In this case: (i) the NDA shall clearly indicate and describe the purposes for which the information may be used by the recipient and any eventual limitation or restriction to the possibility to use the information; and (ii) the recipient must provide an undertaking or other form of evidence of its commitment to process the information in a manner that will not contravene the Law and YANA BESFAMILNAYA applicable internal regulations.
11. Information on Third Parties Engaged in PD processing
11.1. Upon consent of the Data Subject, and unless otherwise provided by the Law, YANA BESFAMILNAYA is entitled to charge a third party ("Processor") with performing PD processing activities by virtue of a Data Processor Agreement ("DPA") to be mandatorily concluded with this subject.
11.2. The DPA shall define the list of actions (operations) with PD to be conducted by the Processor, the processing purposes, the confidentiality obligations towards the PD assumed by the Processor, as well as the obligations to protect PD as they are processed, and the requirements for the protection of the processed PD.
11.3. The Processor shall not be obliged to obtain consent from the Data Subject for the processing of their PD.
12. Information on Applicable Requirements to PD Protection
12.1. In the course of PD processing, YANA BESFAMILNAYA shall take all required legal, organizational and technical measures provided by the Law to protect PD from unlawful or accidental access, destruction, adjustment, blocking, copying, submission, sharing or other unlawful actions.
12.2. Namely, but not exclusively, PD shall be protected by means of the following:
12.2.1. appointment of persons responsible for organizing PD processing and safety;
12.2.2. issuance of internal regulations/procedures on PD processing and protection focused on prevention and tracing violations of the Law, elimination of respective consequences;
12.2.3. make employees engaged in PD processing aware of their participation in personal data processing, as well as the rules for personal data processing and protection set by YANA BESFAMILNAYA regulatory acts;
12.2.4. registration and recording of operations with PD;
12.2.5. internal transmission of PD solely among the persons holding positions included in the list of positions that require PD processing of the persons filling such positions;
12.2.6. organization of PD processing procedures within protected areas and with the use of required technology and systems, as well as ensuring physical protection of PD storage media, locations and tools for their processing;
12.2.7. setting access rules to PD, tracing cases of unauthorized access to PD and taking relevant measures;
12.2.8. implement a process for assessing the level of risk to individuals associated with processing PD;
12.2.9. organize periodic internal controls/audits over compliance of the PD protection measures taken in accordance with the Law and internal regulations of YANA BESFAMILNAYA.
13. The Data Protection Officer
13.1. YANA BESFAMILNAYA is responsible through its Data Protection Officer (“DPO”) for the implementation of the present Policy and all operations connected with the processing of PD. In particular, the DPO is responsible for:
13.1.1. ensuring that YANA BESFAMILNAYA complies with the Law;
13.1.2. ensuring that appropriate ‘fair processing’ statements are made when YANA BESFAMILNAYA, its agents, contractors or service providers collect or process PD on its behalf, and that these reflect the purposes for which the information may be used and any other parties to whom the information may be revealed;
13.1.3. ensuring that PD is only obtained for specified and lawful business purposes indicated in this Policy and is not subsequently processed in a manner incompatible with those purposes;
13.1.4. ensuring that Data Subjects provide appropriate consent to their PD being held and processed by YANA BESFAMILNAYA;
13.1.5. ensuring YANA BESFAMILNAYA conducts periodic reviews of computer and hard copy records to verify that PD held is: (i) adequate, relevant, and not excessive for its purpose; (ii) accurate and up to date; and (iii) not kept longer than is necessary;
13.1.6. ensuring that YANA BESFAMILNAYA complies with article 9 of the present Policy in case of requests submitted by Data Subjects;
13.1.7. ensuring YANA BESFAMILNAYA applies all appropriate technical and organisational measures provided for by the Law to safeguard against unauthorised or unlawful processing of PD and against any accidental loss or destruction of, or damage to PD;