info@aura-equipment.com
Personal Data Processing Policy
1. General Provisions
This Personal Data Processing Policy has been drawn up in accordance with the requirements of the General Data Protection Regulation (Regulation (EU) 2016/679) (hereinafter referred to as the Personal Data Law), and defines the procedure for processing personal data and the measures taken to ensure the security of personal data by Horeca Hub Catering Equipment Trading CO. L.L.C (hereinafter referred to as the Operator).
1.1. The Operator considers compliance with human and civil rights and freedoms in the processing of personal data, including the protection of the right to privacy, personal and family confidentiality, to be its most important goal and a mandatory condition for carrying out its activities.
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 https://aura-equipment.com.
2. Key Terms Used in the Policy
2.1. Automated processing of personal data — processing of personal data using computer equipment.
2.2. Blocking of personal data — temporary suspension of the processing of personal data (except in cases where processing is necessary to clarify personal data).
2.3. Website — a set of graphic and informational materials, as well as computer programs and databases, ensuring their availability on the Internet at the network address https://aura-equipment.com.
2.4. Personal data information system — a set of personal data contained in databases and the information technologies and technical means ensuring their processing.
2.5. Depersonalization of personal data — actions as a result of which it becomes impossible, without the use of additional information, to determine the ownership of personal data by a specific User or another personal data subject.
2.6. 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), depersonalization, blocking, deletion, and destruction of personal data.
2.7. Operator — a state authority, municipal authority, legal entity, or individual who independently or jointly with others organizes and/or carries out the processing of personal data, as well as determines the purposes of processing personal data, 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 https://aura-equipment.com.
2.9. Personal data authorized by the personal data subject for dissemination — personal data to which an unlimited number of persons are granted access by the personal data subject by giving consent to the processing of personal data authorized for dissemination in accordance with the procedure provided for by the Personal Data Law (hereinafter referred to as personal data authorized for dissemination).
2.10. User — any visitor to the website https://aura-equipment.com.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Dissemination of personal data — any actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or at making personal data available to an unlimited group of persons, including publication of personal data in mass 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 — transfer of personal data to the territory of a foreign state to a foreign state authority, a foreign individual, or a foreign legal entity.
2.14. Destruction of personal data — any actions as a result of which personal data are irreversibly destroyed with the impossibility of further restoration of the content of personal data in the personal data information system and/or physical media containing personal data are destroyed.
3. Main Rights and Obligations of the Operator
3.1. The Operator has the right to:
4. Main Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects have the right to:
5. Principles of Personal Data Processing
5.1. Personal data processing is carried out on a lawful and fair basis.
5.2. Personal data processing is limited to the achievement of specific, predetermined, and lawful purposes. Processing of personal data that is incompatible with the purposes of collecting personal data is not permitted.
5.3. The merging of databases containing personal data processed for purposes that are incompatible with one another is not permitted.
5.4. Only personal data that meet the purposes of their processing are subject to processing.
5.5. The content and scope of processed personal data correspond to the stated purposes of processing. Excessive processing of personal data in relation to the stated purposes of their processing is not permitted.
5.6. When processing personal data, their accuracy, sufficiency, and, where necessary, relevance to the purposes of personal data processing are ensured. The Operator takes necessary measures and/or ensures their implementation to delete or clarify incomplete or inaccurate data.
5.7. Personal data are stored in a form that allows identification of the personal data subject for no longer than required by the purposes of personal data processing, unless the retention period for personal data is established by federal law, a contract to which the personal data subject is a party, beneficiary, or guarantor. Processed personal data are destroyed or depersonalized upon achievement of the purposes of processing or in the event that the need to achieve such purposes is lost, unless otherwise provided for by federal law.
6. Purposes of Personal Data Processing
7. Conditions for Personal Data Processing
7.1. Personal data are processed with the consent of the personal data subject to the processing of their personal data.
7.2. Personal data processing is necessary to achieve the purposes provided for by law.
7.3. Personal data processing is necessary for the administration of justice and for the execution of a judicial act, an act of another authority, or an act of an official subject to enforcement in accordance with legislation on enforcement proceedings.
7.4. Personal data processing is necessary for the performance of a contract to which the personal data subject is a party, beneficiary, or guarantor, as well as for the conclusion of a contract at the initiative of the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor.
7.5. Personal data processing is necessary for the exercise of the rights and legitimate interests of the Operator or third parties, or for the achievement of socially significant goals, provided that this does not violate the rights and freedoms of the personal data subject.
7.6. Processing is carried out for personal data to which access is granted to an unlimited number of persons by the personal data subject or at their request (hereinafter referred to as *publicly available personal data*).
7.7. Processing is carried out for personal data subject to publication or mandatory disclosure in accordance with federal law.
8. Procedure for the Collection, Storage, Transfer, and Other Types of Personal Data Processing
The security of personal data processed by the Operator is ensured through the implementation of legal, organizational, and technical measures necessary to fully comply with the requirements of applicable personal data protection legislation.
8.1. The Operator ensures the safety of personal data and takes all possible measures to prevent unauthorized access to personal data.
8.2. The User’s personal data shall never, under any circumstances, be transferred to third parties, except in cases related to compliance with applicable legislation or where the personal data subject has given consent to the Operator to transfer data to a third party for the performance of obligations under a civil law contract.
8.3. If inaccuracies in personal data are identified, the User may update them independently by sending a notification to the Operator at the Operator’s email address info@aura-equipment.com with the subject line “Personal Data Update.”
8.4. The period of personal data processing is determined by the achievement of the purposes for which the personal data were collected, unless a different period is provided for by a contract or applicable law.
The User may withdraw their consent to the processing of personal data at any time by sending a notification to the Operator email info@aura-equipment.com with the subject line “Withdrawal of Consent to Personal Data Processing.”
8.5. All information collected by third-party services, including payment systems, communication services, and other service providers, is stored and processed by such parties (Operators) in accordance with their User Agreements and Privacy Policies. The personal data subject independently familiarizes themselves with these documents. The Operator shall not be responsible for the actions of third parties, including the service providers specified in this clause.
8.6. Restrictions established by the personal data subject on the transfer (except for granting access), as well as on the processing or conditions of processing (except for granting access) of personal data authorized for dissemination, shall not apply in cases of personal data processing carried out in state, public, or other public interests as determined by law.
8.7. When processing personal data, the Operator ensures the confidentiality of personal data.
8.8. The Operator stores personal data in a form that allows identification of the personal data subject for no longer than required by the purposes of personal data processing, unless the retention period for personal data is established by federal law or a contract to which the personal data subject is a party, beneficiary, or guarantor.
8.9. Grounds for termination of personal data processing may include achievement of the purposes of personal data processing, expiration of the personal data subject’s consent, withdrawal of consent by the personal data subject or a request to terminate personal data processing, as well as identification of unlawful personal data processing.
9. List of Actions Performed by the Operator with Received Personal Data
9.1. The Operator carries out the collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (dissemination, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
9.2. The Operator carries out automated processing of personal data with the receipt and/or transmission of the obtained information via information and telecommunication networks or without such networks.
10. Cross-Border Transfer of Personal Data
10.1. Prior to commencing activities related to the cross-border transfer of personal data, the Operator is obliged to notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out cross-border transfer of personal data (such notification is sent separately from the notification of intent to process personal data).
10.2. Before submitting the above-mentioned notification, the Operator is obliged to obtain relevant information from the authorities of a foreign state, foreign individuals, and foreign legal entities to whom the cross-border transfer of personal data is planned.
11. Confidentiality of Personal Data
The Operator and other persons who have gained access to personal data are obliged not to disclose personal data to third parties or distribute personal data without the consent of the personal data subject, unless otherwise provided for by federal law.
12. Final Provisions
12.1. The User may obtain any clarifications regarding issues related to the processing of their personal data by contacting the Operator at mail info@aura-equipment.com.
12.2. Any changes to the Operator’s personal data processing policy will be reflected in this document. The Policy is valid indefinitely until replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet at http://aura-equipment.com/personal-data-policy.
This Personal Data Processing Policy has been drawn up in accordance with the requirements of the General Data Protection Regulation (Regulation (EU) 2016/679) (hereinafter referred to as the Personal Data Law), and defines the procedure for processing personal data and the measures taken to ensure the security of personal data by Horeca Hub Catering Equipment Trading CO. L.L.C (hereinafter referred to as the Operator).
1.1. The Operator considers compliance with human and civil rights and freedoms in the processing of personal data, including the protection of the right to privacy, personal and family confidentiality, to be its most important goal and a mandatory condition for carrying out its activities.
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 https://aura-equipment.com.
2. Key Terms Used in the Policy
2.1. Automated processing of personal data — processing of personal data using computer equipment.
2.2. Blocking of personal data — temporary suspension of the processing of personal data (except in cases where processing is necessary to clarify personal data).
2.3. Website — a set of graphic and informational materials, as well as computer programs and databases, ensuring their availability on the Internet at the network address https://aura-equipment.com.
2.4. Personal data information system — a set of personal data contained in databases and the information technologies and technical means ensuring their processing.
2.5. Depersonalization of personal data — actions as a result of which it becomes impossible, without the use of additional information, to determine the ownership of personal data by a specific User or another personal data subject.
2.6. 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), depersonalization, blocking, deletion, and destruction of personal data.
2.7. Operator — a state authority, municipal authority, legal entity, or individual who independently or jointly with others organizes and/or carries out the processing of personal data, as well as determines the purposes of processing personal data, 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 https://aura-equipment.com.
2.9. Personal data authorized by the personal data subject for dissemination — personal data to which an unlimited number of persons are granted access by the personal data subject by giving consent to the processing of personal data authorized for dissemination in accordance with the procedure provided for by the Personal Data Law (hereinafter referred to as personal data authorized for dissemination).
2.10. User — any visitor to the website https://aura-equipment.com.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Dissemination of personal data — any actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or at making personal data available to an unlimited group of persons, including publication of personal data in mass 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 — transfer of personal data to the territory of a foreign state to a foreign state authority, a foreign individual, or a foreign legal entity.
2.14. Destruction of personal data — any actions as a result of which personal data are irreversibly destroyed with the impossibility of further restoration of the content of personal data in the personal data information system and/or physical media containing personal data are destroyed.
3. Main Rights and Obligations of the Operator
3.1. The Operator has the right to:
- obtain accurate information and/or documents containing personal data from the personal data subject;
- in the event that the personal data subject withdraws consent to the processing of personal data, as well as submits a request to terminate the processing of personal data, continue processing personal data without the consent of the personal data subject if there are grounds specified in the Personal Data Law;
- independently determine the composition and list of measures that are necessary and sufficient to ensure fulfillment of the obligations provided for 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.
- provide the personal data subject, at their request, with information relating to the processing of their personal data;
- organize the processing of personal data in accordance with the procedure established by applicable law;
- respond to requests and inquiries from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
- provide the authorized body for the protection of the rights of personal data subjects, upon its request, with the necessary information within 10 days from the date of receipt of such request;
- publish or otherwise ensure unrestricted access to this Personal Data Processing Policy;
- take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision, dissemination, as well as from other unlawful actions in relation to personal data;
- cease the transfer (dissemination, provision, access) of personal data, cease processing, and destroy personal data in the manner and in cases provided for by the Personal Data Law;
- fulfill other obligations provided for by the Personal Data Law.
4. Main Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects have the right to:
- receive information relating to the processing of their personal data, except in cases provided for by federal laws. Such information shall be provided by the Operator to the personal data subject in an accessible form and shall not contain personal data relating to other personal data subjects, except where there are lawful grounds for the disclosure of such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
- demand that the Operator clarify, block, or destroy their personal data if such data are incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, as well as to take measures provided for by law to protect their rights;
- require prior consent as a condition for the processing of personal data for the purposes of promoting goods, works, and services on the market;
- withdraw consent to the processing of personal data and submit a request to terminate the processing of personal data;
- appeal against unlawful actions or inaction of the Operator in the processing of their personal data to the authorized body for the protection of the rights of personal data subjects or in court;
- exercise other rights provided for by law.
- provide the Operator with accurate information about themselves;
- notify the Operator of any clarification (updating, modification) of their personal data.
5. Principles of Personal Data Processing
5.1. Personal data processing is carried out on a lawful and fair basis.
5.2. Personal data processing is limited to the achievement of specific, predetermined, and lawful purposes. Processing of personal data that is incompatible with the purposes of collecting personal data is not permitted.
5.3. The merging of databases containing personal data processed for purposes that are incompatible with one another is not permitted.
5.4. Only personal data that meet the purposes of their processing are subject to processing.
5.5. The content and scope of processed personal data correspond to the stated purposes of processing. Excessive processing of personal data in relation to the stated purposes of their processing is not permitted.
5.6. When processing personal data, their accuracy, sufficiency, and, where necessary, relevance to the purposes of personal data processing are ensured. The Operator takes necessary measures and/or ensures their implementation to delete or clarify incomplete or inaccurate data.
5.7. Personal data are stored in a form that allows identification of the personal data subject for no longer than required by the purposes of personal data processing, unless the retention period for personal data is established by federal law, a contract to which the personal data subject is a party, beneficiary, or guarantor. Processed personal data are destroyed or depersonalized upon achievement of the purposes of processing or in the event that the need to achieve such purposes is lost, unless otherwise provided for by federal law.
6. Purposes of Personal Data Processing
Purpose of processing | Informing the User by sending emails | |
Personal data processed | • name; • email address; • phone number. | |
Legal grounds | The General Data Protection Regulation (Regulation (EU) 2016/679). | |
Types of personal data processing | • Collection, recording, systematization, accumulation, storage, destruction, and depersonalization of personal data. • Sending informational emails to the email address. | |
7. Conditions for Personal Data Processing
7.1. Personal data are processed with the consent of the personal data subject to the processing of their personal data.
7.2. Personal data processing is necessary to achieve the purposes provided for by law.
7.3. Personal data processing is necessary for the administration of justice and for the execution of a judicial act, an act of another authority, or an act of an official subject to enforcement in accordance with legislation on enforcement proceedings.
7.4. Personal data processing is necessary for the performance of a contract to which the personal data subject is a party, beneficiary, or guarantor, as well as for the conclusion of a contract at the initiative of the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor.
7.5. Personal data processing is necessary for the exercise of the rights and legitimate interests of the Operator or third parties, or for the achievement of socially significant goals, provided that this does not violate the rights and freedoms of the personal data subject.
7.6. Processing is carried out for personal data to which access is granted to an unlimited number of persons by the personal data subject or at their request (hereinafter referred to as *publicly available personal data*).
7.7. Processing is carried out for personal data subject to publication or mandatory disclosure in accordance with federal law.
8. Procedure for the Collection, Storage, Transfer, and Other Types of Personal Data Processing
The security of personal data processed by the Operator is ensured through the implementation of legal, organizational, and technical measures necessary to fully comply with the requirements of applicable personal data protection legislation.
8.1. The Operator ensures the safety of personal data and takes all possible measures to prevent unauthorized access to personal data.
8.2. The User’s personal data shall never, under any circumstances, be transferred to third parties, except in cases related to compliance with applicable legislation or where the personal data subject has given consent to the Operator to transfer data to a third party for the performance of obligations under a civil law contract.
8.3. If inaccuracies in personal data are identified, the User may update them independently by sending a notification to the Operator at the Operator’s email address info@aura-equipment.com with the subject line “Personal Data Update.”
8.4. The period of personal data processing is determined by the achievement of the purposes for which the personal data were collected, unless a different period is provided for by a contract or applicable law.
The User may withdraw their consent to the processing of personal data at any time by sending a notification to the Operator email info@aura-equipment.com with the subject line “Withdrawal of Consent to Personal Data Processing.”
8.5. All information collected by third-party services, including payment systems, communication services, and other service providers, is stored and processed by such parties (Operators) in accordance with their User Agreements and Privacy Policies. The personal data subject independently familiarizes themselves with these documents. The Operator shall not be responsible for the actions of third parties, including the service providers specified in this clause.
8.6. Restrictions established by the personal data subject on the transfer (except for granting access), as well as on the processing or conditions of processing (except for granting access) of personal data authorized for dissemination, shall not apply in cases of personal data processing carried out in state, public, or other public interests as determined by law.
8.7. When processing personal data, the Operator ensures the confidentiality of personal data.
8.8. The Operator stores personal data in a form that allows identification of the personal data subject for no longer than required by the purposes of personal data processing, unless the retention period for personal data is established by federal law or a contract to which the personal data subject is a party, beneficiary, or guarantor.
8.9. Grounds for termination of personal data processing may include achievement of the purposes of personal data processing, expiration of the personal data subject’s consent, withdrawal of consent by the personal data subject or a request to terminate personal data processing, as well as identification of unlawful personal data processing.
9. List of Actions Performed by the Operator with Received Personal Data
9.1. The Operator carries out the collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (dissemination, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
9.2. The Operator carries out automated processing of personal data with the receipt and/or transmission of the obtained information via information and telecommunication networks or without such networks.
10. Cross-Border Transfer of Personal Data
10.1. Prior to commencing activities related to the cross-border transfer of personal data, the Operator is obliged to notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out cross-border transfer of personal data (such notification is sent separately from the notification of intent to process personal data).
10.2. Before submitting the above-mentioned notification, the Operator is obliged to obtain relevant information from the authorities of a foreign state, foreign individuals, and foreign legal entities to whom the cross-border transfer of personal data is planned.
11. Confidentiality of Personal Data
The Operator and other persons who have gained access to personal data are obliged not to disclose personal data to third parties or distribute personal data without the consent of the personal data subject, unless otherwise provided for by federal law.
12. Final Provisions
12.1. The User may obtain any clarifications regarding issues related to the processing of their personal data by contacting the Operator at mail info@aura-equipment.com.
12.2. Any changes to the Operator’s personal data processing policy will be reflected in this document. The Policy is valid indefinitely until replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet at http://aura-equipment.com/personal-data-policy.
