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YANA BESFAMILNAYA
(«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
adopted a corporate wide Privacy Policy that guides how we collect, store, and
use the information that you provide us with.
The following information is provided by YANA BESFAMILNAYA to enable our online visitors to be fully informed of our Privacy Policies. By visiting www.yanabesfamilnaya.com, you are accepting and consenting to the practices described in this Privacy Policy and the Terms and Conditions.
If you are under 16,
we require that you inform a parent or guardian about YANA BESFAMILNAYA's
Privacy Policy and Terms and Conditions as well as requiring their consent to
the Privacy Policy and Terms and Conditions before registering or placing an
order with YANA BESFAMILNAYA.
This Privacy Policy
does not apply to websites maintained by other companies or organizations to
which we link and YANA BESFAMILNAYA is not responsible for any personal
information you submit to third parties via our website. Please ensure that you
read the Privacy Policy of such other companies or organizations before
submitting your details.
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?
Our site uses cookies
(very small files that are sent by us to your computer or other access device)
which we can access when you visit our site in future.
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 yanabesfamilnayaofficial@gmail.ru.
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 yanabesfamilnayaofficial@gmail.com. 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 yanabesfamilnayaofficial@gmail.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. Definitions
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 yanabesfamilnayaofficial@gmail.com.
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 yanabesfamilnayaofficial@gmail.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;