PRIVACY POLICY

This Privacy Policy (hereinafter referred to as the “Policy”) has been developed in accordance with the provisions of Federal Law No. 152-FZ dated July 27, 2006 “On Personal Data”, as well as other legislative and regulatory legal acts of the Russian Federation, and defines the requirements for the processing and protection of personal data by Anna Yuryevna Khomenko, Sole Proprietor, Tax ID (INN) 773127655631, Primary State Registration Number (OGRNIP) 318774600384469.
If a user of the Website does not agree with this Policy or any of its provisions, the user must refrain from further use of the Website.

1. TERMS AND DEFINITIONS
Automated Processing of Personal Data — processing of Personal Data using information technologies and technical means.
Blocking of Personal Data — temporary suspension of the processing of Personal Data (except where processing is necessary to clarify Personal Data).
Agreement / Agreements — a service agreement for furnishing (home staging) and/or a retail sales agreement for goods concluded or to be concluded remotely via the Website.
Pre-order / Order — a duly completed request submitted by the Buyer on the Website for the purchase of the selected Product.
Legislation — the applicable legislation of the Russian Federation.
Personal Data Information System — a set of Personal Data contained in the Operator’s databases and the information technologies and technical means used to process such data.
Confidentiality of Personal Data — the obligation of the Personal Data Operator not to disclose or distribute Personal Data to third parties without the consent of the Personal Data Subject, unless otherwise provided by Legislation.
Processing of Personal Data — any action (operation) or set of actions (operations) performed with or without the use of automation tools on Personal Data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction.
Anonymization of Personal Data — actions that make it impossible to determine, without the use of additional information, the association of Personal Data with a specific Personal Data Subject.
Operator / Personal Data Operator — Anna Yuryevna Khomenko, Sole Proprietor, Tax ID (INN) 773127655631, Primary State Registration Number (OGRNIP) 318774600384469, who independently or jointly with other persons organizes and/or carries out the processing of Personal Data, and determines the purposes of processing, the composition of Personal Data to be processed, and the actions (operations) performed on Personal Data.
Personal Data — any information relating directly or indirectly to an identified or identifiable individual (the Personal Data Subject).
Provision of Personal Data — actions aimed at disclosing Personal Data to a specific person or a specific group of persons.
Distribution of Personal Data — actions aimed at disclosing Personal Data to an indefinite number of persons.
Website — the Operator’s website located on the Internet at: http://khomestaging.ru
Personal Data Subject — an individual who is directly or indirectly identified or identifiable through the Personal Data provided by them.
Product / Products — home accessories offered for purchase (Pre-order) on the Website.
Destruction of Personal Data — actions that make it impossible to restore the content of Personal Data in the Personal Data Information System and/or result in the destruction of physical media containing Personal Data.

• Cookies — small pieces of data received and processed by the device used by the Personal Data Subject to access the Website.

2. RIGHTS AND OBLIGATIONS OF THE PERSONAL DATA OPERATOR
2.1. The Operator undertakes to process Personal Data in accordance with this Policy and applicable Legislation.
2.2. The Operator that has obtained access to Personal Data is obliged to ensure the confidentiality of Personal Data and not to disclose or distribute such data to third parties without the consent of the Personal Data Subject, unless otherwise provided by Federal Law No. 152-FZ dated July 27, 2006 “On Personal Data”.
2.3. When collecting Personal Data, the Operator shall, upon request of the Personal Data Subject, provide the information specified in Part 7 of Article 14 of Federal Law No. 152-FZ dated July 27, 2006 “On Personal Data”.
2.4. When collecting Personal Data, the Operator shall ensure the recording, systematization, accumulation, storage, clarification (updating, modification), and retrieval of Personal Data of Personal Data Subjects using databases located within the territory of the Russian Federation.
2.5. If unlawful processing of Personal Data is identified, the Operator shall cease processing such Personal Data. If lawful processing cannot be ensured, the Operator shall destroy or ensure the destruction of such Personal Data within the manner and timeframes established by Legislation.
2.6. If inaccuracies in Personal Data are identified, the Operator shall block or ensure the blocking of such Personal Data and clarify or ensure clarification thereof in accordance with the manner and timeframes established by Legislation.
2.7. The Operator has the right to transfer Personal Data of the Personal Data Subject to third parties with the consent of the Personal Data Subject, except in the following cases:
2.7.1. where the transfer is necessary for the performance of an Agreement;
2.7.2. where the transfer is made to government authorities, including inquiry and investigative bodies, and local authorities upon a reasoned request compliant with Legislation;
2.7.3. in other cases expressly provided for by Legislation.

3. RIGHTS OF THE PERSONAL DATA SUBJECT
3.1. The Personal Data Subject has the right, with respect to their Personal Data, to:
3.1.1. freely decide to provide Personal Data to the Operator and third parties and give consent to its processing of their own free will and in their own interest;
3.1.2. withdraw consent to the processing of Personal Data by sending a relevant notice to the Operator at the address specified in Section 10 of this Policy;
3.1.3. receive information from the Operator regarding the processing of Personal Data by submitting a relevant request;
3.1.4. demand clarification, blocking, or destruction of Personal Data if such data is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purposes of processing;
3.1.5. appeal actions or inaction of the Operator to the authorized authority for the protection of Personal Data Subjects’ rights or through judicial proceedings;
3.1.6. exercise other rights provided by Legislation.
3.2. The Personal Data Subject has the right to receive information regarding the processing of their Personal Data, including:
– confirmation of the fact of Personal Data processing by the Operator;
– legal grounds and purposes of Personal Data processing;
– methods of Personal Data processing used by the Operator;
– timeframes for Personal Data processing and storage;
– other information provided by Legislation.
3.3. To exercise the rights provided for in Clauses 3.1.3–3.1.5 and 3.2 of this Policy, the Personal Data Subject shall send a relevant request (claim, demand, or notice) to the Operator’s address or email specified in Section 10 of this Policy.

4. SCOPE OF PROCESSED PERSONAL DATA AND PURPOSES OF PROCESSING
4.1. Processing of Personal Data is limited to achieving specific, predetermined, and lawful purposes. Processing incompatible with the purposes of data collection is not permitted.
4.2. Personal Data is processed by the Operator for the purpose of concluding and performing Agreements in the following scope:
– types of Personal Data processed: full name, email address, date of birth, address, mobile phone number, Telegram messenger username;
– categories of Personal Data: Personal Data not classified as special categories or biometric data;
– methods of processing and storage: collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, transfer (provision, access), anonymization, blocking, deletion, destruction;
– processing and storage period: for the duration of the Agreement, unless consent is withdrawn earlier;
– procedure for destruction: deletion from electronic and physical storage media.
4.3. The content and scope of processed Personal Data correspond to the stated processing purposes and are not excessive.
4.4. The Operator does not process special categories of Personal Data or biometric Personal Data, including data related to race, nationality, political views, religious or philosophical beliefs, health, intimate life, or membership in public associations, except where expressly permitted by Legislation.

5. PROCEDURE AND CONDITIONS FOR PERSONAL DATA PROCESSING
5.1. Processing of Personal Data is carried out with or without automation tools based on the following principles:
– lawfulness and fairness;
– limitation to specific, lawful purposes;
– incompatibility of processing with stated purposes is not allowed;
– prohibition of combining databases with incompatible purposes;
– relevance and sufficiency of Personal Data;
– accuracy, relevance, and timeliness;
– storage limited to the period necessary to achieve processing purposes;
– application of appropriate technical and organizational security measures.
5.2. Personal Data processing is permitted:
5.2.1. with the consent of the Personal Data Subject;
5.2.2. without consent where permitted by Legislation.
5.3. Personal Data may be transferred to the Operator’s partners for the performance of Agreements. In other cases, transfer occurs only with the consent of the Personal Data Subject.
5.4. Personal Data is stored using databases located in the Russian Federation, except where otherwise provided by Legislation.

6. PERSONAL DATA SECURITY
6.1. The Operator implements necessary legal, organizational, and technical measures to protect Personal Data from unauthorized or accidental access, destruction, alteration, blocking, copying, provision, dissemination, and other unlawful actions.
6.2. Access to Personal Data Information Systems is secured by password protection established and managed by authorized employees.
6.3. Third parties may process Personal Data strictly in accordance with the Operator’s instructions and only if they apply security measures equivalent to those set out in this Policy.
6.4. The Operator maintains procedures for handling suspected Personal Data security breaches and notifies Personal Data Subjects and regulatory authorities where required by Legislation.

7. UPDATING, CORRECTION, DELETION, AND DESTRUCTION OF PERSONAL DATA
7.1. The Operator shall provide Personal Data Subjects or their representatives free access to their Personal Data. Corrections shall be made within 7 business days upon confirmation of inaccuracy or incompleteness. Unlawfully obtained or unnecessary data shall be destroyed within 7 business days, with notification to the Subject and reasonable efforts to inform third parties.
7.2. The Operator shall cease processing Personal Data:
– upon detection of unlawful processing (within 3 business days);
– upon withdrawal of consent;
– upon achievement of processing purposes, with destruction within 30 days, or blocking followed by destruction within 6 months if immediate destruction is not possible.

8. USE OF COOKIES AND SIMILAR TECHNOLOGIES
8.1. The Operator uses the following types of cookies:
– Essential cookies — required for Website functionality;
– Analytical cookies — used for anonymized analytics (e.g., Yandex.Metrica);
– Technical cookies — used for error detection and performance testing;
– Functional cookies — store user preferences;
– Marketing cookies — used to display relevant advertising (e.g., Yandex.Direct, VK Ads).

8.2. The Operator uses the information contained in cookies solely for the purposes specified above. The collected data is stored on the device of the Personal Data Subject for a period that may depend on the relevant type of cookies, but shall not exceed the period necessary to achieve their purpose, after which such data is automatically deleted from the Personal Data Subject’s system.
8.3. Upon the first visit to the Website, the Personal Data Subject’s consent to the use of cookies may be requested. If, after consenting to the use of cookies, the Personal Data Subject wishes to change their decision, they may do so by deleting the cookies stored in their browser (via browser settings). After that, a pop-up window requesting consent may be displayed again, allowing the Personal Data Subject to make a different choice.
If the Personal Data Subject refuses to use cookies, some Website functions may become unavailable, which may affect the use of the Website. The Personal Data Subject may also change browser settings to accept or reject all cookies by default or cookies from specific websites, including this Website.
8.4. The Operator may also use web beacons (pixel tags) to access cookies previously placed on the device of the Personal Data Subject for the following purposes:
8.4.1. determining the actions of the Personal Data Subject on the Website by accessing and using cookies stored on their device;
8.4.2. collecting statistical information related to the operation of the Website.

9. MISCELLANEOUS PROVISIONS9.1.
This Policy and the relations between the Personal Data Subject and the Operator arising in connection with the application of this Policy shall be governed by the laws of the Russian Federation.
9.2. Any disputes between the Personal Data Subject and the Operator related to this Policy shall be resolved in accordance with applicable Legislation.
9.3. If one or more provisions of this Policy are deemed invalid for any reason, this shall not affect the validity of the remaining provisions of the Policy.
9.4. The Operator has the right to amend this Policy without prior notice to the Personal Data Subject by publishing a new version of the Policy on the Website. The new version of the Policy shall enter into force on the day following its publication on the Website.
9.5. The Personal Data Subject undertakes to independently monitor changes to this Policy by reviewing the current version.

10. OPERATOR CONTACT INFORMATION
Anna Yuryevna Khomenko, Sole Proprietor
Tax ID (INN): 773127655631
Primary State Registration Number (OGRNIP): 318774600384469
Phone: +7 903 206 2010
Email: Khomenko.ana@gmail.com
Mailing Address: Moscow Region, Moscow, Belovezhskaya St., 15-3-57, 121353