Personal Data
Processing Policy
1. General Provisions
This Personal Data Processing Policy is prepared in accordance with the requirements of Federal Law No. 152-FZ dated July 27, 2006 "On Personal Data" (hereinafter referred to as the "Personal Data Law") and defines the procedure for processing personal data and measures to ensure the security of personal data taken by Boca Room (hereinafter referred to as the "Operator").
1.1. The Operator's most important goal and condition for its activities is the observance of human and citizen's rights and freedoms when processing their personal data, including the protection of privacy, personal and family secrets.
1.2. This Policy of the Operator regarding the processing of personal data (hereinafter referred to as the "Policy") applies to all information that the Operator may obtain about visitors to the website boca-room.com.
2. Basic Concepts Used in the Policy
2.1. Automated processing of personal data — processing of personal data using computer technology.
2.2. Blocking of personal data — temporary cessation of personal data processing (except in cases where processing is necessary to clarify personal data).
2.3. Website — a collection of graphical and informational materials, as well as computer programs and databases that ensure their availability on the internet at the network address boca-room.com.
2.4. Personal data information system — a set of personal data contained in databases and the information technologies and technical means that ensure their processing.
2.5. Depersonalization of personal data — actions that make it impossible to determine, without using additional information, the belonging of personal data to a specific User or other subject of personal data.
2.6. Processing of personal data — any action (operation) or set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
2.7. Operator — a state body, municipal body, legal entity, or individual that independently or jointly with other persons organizes and (or) carries out the processing of personal data, as well as determines the purposes of personal data processing, the composition of personal data to be processed, and the actions (operations) performed with personal data.
2.8. Personal data — any information relating directly or indirectly to a specific or identifiable User of the website boca-room.com.
2.9. Personal data permitted for distribution by the subject of personal data — personal data, access to which is granted to an unlimited number of persons by the subject of personal data by giving consent to the processing of personal data permitted for distribution in the manner prescribed by the Personal Data Law (hereinafter referred to as "personal data permitted for distribution").
2.10. User — any visitor to the website boca-room.com.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific circle of persons.
2.12. Distribution of personal data — any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or at familiarizing an unlimited circle of persons with personal data, including the publication of personal data in the media, placement in information and telecommunication networks, or providing access to personal data in any other way.
2.13. Cross-border transfer of personal data — the transfer of personal data to the territory of a foreign state to a foreign state authority, foreign individual, or foreign legal entity.
2.14. Destruction of personal data — any actions resulting in the irreversible destruction of personal data with the impossibility of further restoration of the content of personal data in the personal data information system and (or) the destruction of material carriers of personal data.
3. Basic Rights and Obligations of the Operator
3.1. The Operator has the right to:
— Receive reliable information and/or documents containing personal data from the subject of personal data;
— If the subject of personal data withdraws consent to the processing of personal data, the Operator has the right to continue processing personal data without the subject’s consent if there are grounds specified in the Personal Data Law;
— Independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations stipulated by the Personal Data Law and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.
3.2. The Operator is obliged to:
— Provide the subject of personal data, upon their request, with information concerning the processing of their personal data;
— Organize the processing of personal data in the manner established by the current legislation of the Russian Federation;
— Respond to appeals and requests from subjects of personal data and their legal representatives in accordance with the requirements of the Personal Data Law;
— Report to the authorized body for the protection of the rights of subjects of personal data, upon request of this body, the necessary information within 30 days from the date of receipt of such request;
— Publish or otherwise provide unrestricted access to this Policy regarding the processing of personal data;
— Take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other unlawful actions regarding personal data;
— Cease the transfer (distribution, provision, access) of personal data, cease processing, and destroy personal data in the manner and cases provided for by the Personal Data Law;
— Fulfill other duties stipulated by the Personal Data Law.
4. Basic Rights and Obligations of Subjects of Personal Data
4.1. Subjects of personal data have the right to:
— Obtain information concerning the processing of their personal data, except in cases provided for by federal laws. Information is provided to the subject of personal data by the Operator in an accessible form and should not contain personal data relating to other subjects of personal data, except in cases where there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
— Require the operator to clarify, block, or destroy their personal data if the data is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, as well as take legal measures to protect their rights;
— Impose a condition of prior consent when processing personal data for the purpose of promoting goods, works, and services on the market;
— Withdraw consent to the processing of personal data;
— Appeal to the authorized body for the protection of the rights of subjects of personal data or in court against unlawful actions or inaction of the Operator when processing their personal data;
— Exercise other rights provided for by the legislation of the Russian Federation.
4.2. Subjects of personal data are obliged to:
— Provide the Operator with reliable data about themselves;
— Notify the Operator about the clarification (updating, change) of their personal data.
4.3. Persons who provided the Operator with false information about themselves or information about another subject of personal data without the latter’s consent shall be liable in accordance with the legislation of the Russian Federation.
5. The Operator May Process the Following Personal Data of the User
5.1. Last name, first name, patronymic.
5.2. Email address.
5.3. Telephone numbers.
5.4. The website also collects and processes depersonalized data about visitors (including "cookies") using internet statistics services (Yandex Metrica and others).
5.5. The above data are hereinafter collectively referred to as Personal Data.
5.6. The Operator does not process special categories of personal data concerning race, nationality, political views, religious or philosophical beliefs, or intimate life.
5.7. Processing of personal data permitted for distribution, from among the special categories of personal data specified in Part 1 of Article 10 of the Personal Data Law, is allowed if the prohibitions and conditions provided for in Article 10.1 of the Personal Data Law are observed.
5.8. The User’s consent to the processing of personal data permitted for distribution is formalized separately from other consents to the processing of their personal data. In this case, the conditions provided for, in particular, by Article 10.1 of the Personal Data Law are observed. Requirements for the content of such consent are established by the authorized body for the protection of the rights of subjects of personal data.
5.8.1. The User provides consent for the processing of personal data permitted for distribution directly to the Operator.
5.8.2. The Operator is obliged, no later than three business days from the moment of receiving the specified consent of the User, to publish information about the processing conditions, the existence of prohibitions and conditions for the processing by an unlimited number of persons of personal data permitted for distribution.
5.8.3. The transfer (distribution, provision, access) of personal data permitted by the subject of personal data for distribution must be terminated at any time at the request of the subject of personal data. This request must include the last name, first name, patronymic (if any), contact information (phone number, email address, or postal address) of the subject of personal data, as well as a list of personal data whose processing is to be terminated. The personal data specified in this request may be processed only by the Operator to whom it is sent.
5.8.4. Consent to the processing of personal data permitted for distribution ceases to be effective from the moment the Operator receives the request specified in clause 5.8.3 of this Policy regarding the processing of personal data.
6. Principles of Personal Data Processing
6.1. Processing of personal data is carried out on a lawful and fair basis.
6.2. Processing of personal data is limited to achieving specific, predetermined, and lawful purposes. Processing of personal data incompatible with the purposes of collecting personal data is not allowed.
6.3. It is not allowed to combine databases containing personal data processed for incompatible purposes.
6.4. Only personal data that meet the purposes of their processing are subject to processing.
6.5. The content and volume of processed personal data correspond to the stated purposes of processing. Redundancy of processed personal data in relation to the stated purposes of their processing is not allowed.
6.6. When processing personal data, the accuracy of personal data, their sufficiency, and, where necessary, relevance in relation to the purposes of processing personal data are ensured. The Operator takes necessary measures and/or ensures their adoption to delete or clarify incomplete or inaccurate data.
6.7. Storage of personal data is carried out in a form that allows identification of the subject of personal data no longer than required by the purposes of processing personal data, unless the storage period for personal data is established by federal law, a contract to which the subject of personal data is a party, beneficiary, or guarantor. Processed personal data are destroyed or depersonalized upon achieving the purposes of processing or in case of loss of necessity to achieve these purposes, unless otherwise provided by federal law.

7. Purposes of Personal Data Processing
7.1. The purposes of processing the User's personal data are to provide information about the Operator's products/services, promotional campaigns, special offers, and other events potentially of interest to the User, through the following methods:
7.1.1. Direct communication channels:
• SMS mailings: Sending promotional messages to the phone number provided by the User.
• Social networks: Sending personal messages on social networks, targeting advertisements, and interacting through comments under the User's publications (if there is interaction).
• Email mailings: Sending promotional emails with promotions, news, special offers, as well as personalized offers based on analysis of the User's preferences and interests.
• Phone calls from managers: Making outgoing calls to the User with offers of promotions, special conditions, new products/services, and other promotional information.
• Postal mailings (offline): Sending promotional materials by postal address, including catalogs, brochures, letters with offers, and other informational materials.
• Push notifications: Sending notifications via mobile applications and/or browser (Web Push) with information about events, news, and updates.
• Chatbots and autoresponders: Sending automated promotional messages via chatbots in messengers.
7.1.2. Targeted advertising and affiliate programs:
• Retargeting and personalized advertising: Sending targeted advertising on social networks, search engines, and partner websites based on analysis of past visits to the Operator's Site/Application and interaction history with the Operator's content;
• Advertising through affiliate programs: Providing recommendations and personal offers through the Operator's partner companies based on analysis of the User's interests and preferences.
7.1.3. Personal offers in the personal account:
• Sending notifications about discounts, promotions, special offers in the User's Personal Account (if available).
7.2. The User can always refuse to receive informational messages by sending a letter to the Operator's email address info+1087198@boca.su with the note "Opt-out of notifications about new products and services and special offers."
7.3. Depersonalized User data collected using internet statistics services serve to collect information about Users' actions on the site, improve the quality of the site and its content.
8. Legal Grounds for Processing Personal Data
8.1. The legal grounds for processing personal data by the Operator are:
— The Operator’s charter (constituent) documents;
— Federal laws and other regulatory legal acts in the field of personal data protection;
— Users' consents to the processing of their personal data, to the processing of personal data permitted for distribution.
8.2. The Operator processes the User’s personal data only if they are filled in and/or sent by the User independently through special forms located on the website boca-room.com or sent to the Operator via email. By filling out the relevant forms and/or sending their personal data to the Operator, the User expresses their consent to this Policy.
8.3. The Operator processes depersonalized data about the User if this is allowed in the User’s browser settings (saving "cookies" and using JavaScript technology are enabled).
8.4. The subject of personal data independently decides to provide their personal data and gives consent freely, of their own will, and in their own interest.
9. Conditions for Processing Personal Data
9.1. Processing of personal data is carried out with the consent of the subject of personal data to the processing of their personal data.
9.2. Processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, for the performance of functions, powers, and duties imposed on the operator by the legislation of the Russian Federation.
9.3. Processing of personal data is necessary for the administration of justice, execution of a judicial act, act of another body, or official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
9.4. Processing of personal data is necessary for the performance of a contract to which the subject of personal data is a party, or a beneficiary or guarantor, as well as for concluding a contract on the initiative of the subject of personal data or a contract under which the subject of personal data will be a beneficiary or guarantor.
9.5. Processing of personal data is necessary for the exercise of the rights and legitimate interests of the operator or third parties, or for achieving socially significant goals, provided that the rights and freedoms of the subject of personal data are not violated.
9.6. Processing of personal data is carried out, access to which is granted to an unlimited number of persons by the subject of personal data or at their request (hereinafter referred to as publicly available personal data).
9.7. Processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.
10. Procedure for Collection, Storage, Transfer, and Other Types of Personal Data Processing
The security of personal data processed by the Operator is ensured by implementing legal, organizational, and technical measures necessary to fully comply with the requirements of current legislation in the field of personal data protection.
10.1. The Operator ensures the security of personal data and takes all possible measures to prevent unauthorized access to personal data.
10.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to the execution of current legislation or if the subject of personal data has given consent to the Operator to transfer data to a third party to fulfill obligations under a civil law contract.
10.3. If inaccuracies in personal data are identified, the User can update them independently by sending a notification to the Operator's email address info+1087198@boca.su with the note "Updating personal data."
10.4. The period of processing personal data is determined by the achievement of the purposes for which the personal data were collected, unless another period is provided for by the contract or current legislation.
The User can withdraw their consent to the processing of personal data at any time by sending a notification to the Operator via email to the Operator's email address info+1087198@boca.su with the note "Withdrawal of consent to the processing of personal data."
10.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by said persons (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data and/or the User is obliged to independently familiarize themselves with the specified documents in a timely manner. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.
10.6. Prohibitions established by the subject of personal data on the transfer (except for providing access), as well as on processing or conditions for processing (except for obtaining access) of personal data permitted for distribution, do not apply in cases of processing personal data in state, public, and other public interests defined by the legislation of the Russian Federation.
10.7. The Operator ensures the confidentiality of personal data when processing them.
10.8. The Operator stores personal data in a form that allows identification of the subject of personal data no longer than required by the purposes of processing personal data, unless the storage period for personal data is established by federal law, a contract to which the subject of personal data is a party, beneficiary, or guarantor.
10.9. Conditions for terminating the processing of personal data may include achieving the purposes of processing personal data, expiration of the subject's consent or withdrawal of consent by the subject of personal data, as well as identification of unlawful processing of personal data.
11. List of Actions Performed by the Operator with Received Personal Data
11.1. The Operator performs collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
11.2. The Operator performs automated processing of personal data with receipt and/or transmission of the received information via information and telecommunication networks or without it.
12. Cross-Border Transfer of Personal Data
12.1. Before commencing the cross-border transfer of personal data, the Operator is obliged to ensure that the foreign state to whose territory the transfer of personal data is intended provides reliable protection of the rights of subjects of personal data.
12.2. Cross-border transfer of personal data to the territories of foreign states that do not meet the above requirements may be carried out only if the subject of personal data gives written consent to the cross-border transfer of their personal data and/or for the performance of a contract to which the subject of personal data is a party.
13. Confidentiality of Personal Data
The Operator and other persons who have gained access to personal data are obliged not to disclose to third parties and not to distribute personal data without the consent of the subject of personal data, unless otherwise provided by federal law.
14. Final Provisions
14.1. The User can obtain any clarifications on issues of interest regarding the processing of their personal data by contacting the Operator via email at Info@boca-room.com.
14.2. This document will reflect any changes to the Operator's personal data processing policy. The Policy is valid indefinitely until replaced by a new version.
14.3. The current version of the Policy is freely available on the Internet at boca-room.com.