1. General Provisions

This Personal Data Processing Policy has been drafted in accordance with the requirements of Federal Law No. 152-FZ “On Personal Data” dated July 27, 2006, and defines the procedure for processing personal data and measures to ensure the security of personal data taken by LLC “Tobacco Trade” (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 objective and condition for conducting its activities.
1.2. This Operator’s policy 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 http://bonche.com.

2. Basic Terms Used in the Policy

2.1. Automated processing of personal data – processing of personal data using computing technology;
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 software and databases, ensuring their accessibility on the internet at the network address http://bonche.com;
2.4. Personal data information system – a set of personal data contained in databases and the technologies and technical means used to process them;
2.5. Anonymization of personal data – actions that make it impossible to determine the affiliation of personal data to a specific User or another subject without the use of additional information;
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), retrieval, use, transfer (distribution, provision, access), anonymization, blocking, deletion, destruction of personal data;
2.7. Operator – a state or municipal authority, legal or natural person, who independently or jointly with others organizes and/or performs personal data processing and 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 directly or indirectly related to a specific or identifiable User of the website http://bonche.com;
2.9. User – any visitor to the website http://bonche.com;
2.10. Provision of personal data – actions aimed at disclosing personal data to a specific individual or a specific group of individuals;
2.11. Dissemination of personal data – any actions aimed at disclosing personal data to an indefinite group of individuals (transferring personal data) or familiarizing an indefinite group of individuals with personal data, including making personal data public in mass media, placing it on information and telecommunications networks, or providing access to personal data in any other way;
2.12. Cross-border transfer of personal data – transfer of personal data to the territory of a foreign state, to a foreign government authority, a foreign natural or legal person;
2.13. Destruction of personal data – any actions resulting in the irrevocable destruction of personal data with no possibility of restoring its content in the personal data information system and/or resulting in the destruction of the material carriers of personal data.

3. The Operator May Process the Following User Personal Data

3.1. Surname, first name, patronymic;
3.2. Email address;
3.3. Phone numbers;
3.4. Year, month, date, and place of birth;
3.5. Photographs;
3.6. The website also collects and processes anonymized visitor data (including cookies) using internet statistics services (Yandex.Metrica, Google Analytics, and others).
3.7. The above-mentioned data is referred to as Personal Data in the text of this Policy.

4. Purpose of Processing Personal Data

4.1. The purpose of processing User personal data is to inform the User via email; conclude, execute, and terminate civil law contracts; provide the User with access to services, information, and/or materials contained on the website.
4.2. The Operator is also entitled to send the User notifications about new products, services, special offers, and various events. The User can always opt out of receiving informational messages by sending an email to info@bonche.com with the note “Unsubscribe from notifications about new products, services, and special offers.”
4.3. Anonymized User data collected using internet statistics services is used to gather information about User actions on the website, improve the website’s quality and content.

5. Legal Grounds for Processing Personal Data

5.1. The Operator processes personal data only when provided and/or submitted by the User independently through special forms located on the website http://bonche.com. By filling out the forms and/or submitting their personal data, the User consents to this Policy.
5.2. The Operator processes anonymized User data if allowed by the User’s browser settings (e.g., cookie storage and JavaScript technology are enabled).

6. Procedure for Collection, Storage, Transfer, and Other Types of Processing of Personal Data

The security of personal data processed by the Operator is ensured through the implementation of legal, organizational, and technical measures required to fully comply with applicable laws in the field of personal data protection.

6.1. The Operator ensures the confidentiality of personal data and takes all necessary measures to prevent unauthorized access.
6.2. Personal data will never be transferred to third parties, except as required by applicable law.
6.3. If inaccuracies in personal data are identified, the User can update them by sending a notification to info@bonche.ru marked “Update Personal Data.”
6.4. The processing period for personal data is unlimited. The User may revoke consent to personal data processing at any time by sending a notification to info@bonche.ru marked “Revocation of Consent to Personal Data Processing.”

7. Cross-Border Transfer of Personal Data

7.1. Before initiating cross-border personal data transfer, the Operator must ensure that the foreign state provides reliable protection of the rights of personal data subjects.
7.2. Cross-border transfer of personal data to foreign states that do not meet the above requirements can only occur with the subject’s written consent or for the execution of a contract involving the data subject.

8. Final Provisions

8.1. Users may obtain any clarification regarding the processing of their personal data by contacting the Operator via email at info@bonche.ru.
8.2. Any changes to this Policy will be reflected in this document. The Policy remains in effect indefinitely until replaced by a new version.
8.3. The current version of the Policy is freely available on the internet at http://bonche.com/privacy.