This privacy policy has been created to define the rules for processing personal data and the measures taken by Tabac Evgheni (hereinafter referred to as the Operator) to ensure the security of personal data. The policy is based on applicable data protection laws and regulations.
1.1. The Operator considers the protection of human rights and freedoms, including the right to privacy and the confidentiality of personal and family information, as a primary goal and essential condition for its activities.
1.2. This Policy applies to all information that the Operator may receive about visitors to its services and applications.
2.1. Automated processing of personal data — processing of personal data using computer systems and technology.
2.2. Blocking of personal data — temporary suspension of personal data processing (except when processing is necessary to update or clarify personal data).
2.3. Website — a collection of graphic and informational materials, as well as software and databases that make them accessible online through the Operator’s services and applications.
2.4. Personal data information system — a set of databases containing personal data and the technologies and tools that ensure their processing.
2.5. Anonymization of personal data — actions that make it impossible to determine the ownership of personal data to a specific user or other subject without additional information.
2.6. Personal data processing — any action or set of actions carried out with or without automation involving personal data, including collection, recording, systematization, accumulation, storage, updating (modification, change), retrieval, use, transfer (distribution, provision, access), anonymization, blocking, deletion, or destruction of personal data.
2.7. Operator — an individual or legal entity that independently or jointly with others organizes and/or carries out the processing of personal data and determines the purposes of data processing, the types of personal data being processed, and the actions performed on personal data.
2.8. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.9. Dissemination of personal data — any actions aimed at disclosing personal data to an indefinite group of people (transfer of personal data) or making personal data available to the public, including publication in media, online networks, or by other means.
2.10. Cross-border transfer of personal data — transfer of personal data to authorities, individuals, or legal entities in a foreign country.
2.11. Destruction of personal data — any actions resulting in the irreversible deletion of personal data in a way that makes it impossible to recover the information, including the destruction of physical data carriers.
3.1. The Operator has the right to: — receive accurate information and/or documents containing personal data from the data subject; — continue processing personal data even if the data subject withdraws consent, provided there are lawful grounds for doing so; — independently determine the necessary measures to ensure compliance with applicable personal data protection requirements.
3.2. The Operator is obliged to: — provide the data subject with information about the processing of their personal data upon request; — respond to inquiries and requests from data subjects and their legal representatives regarding personal data processing; — make this Policy publicly available and ensure unrestricted access to it; — take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, alteration, disclosure, copying, distribution, or destruction; — cease processing, dissemination, or access to personal data, and destroy it in accordance with applicable legal requirements; — fulfill any other obligations related to personal data protection as required by law.
4.1. Data subjects have the right to: — receive information about the processing of their personal data. Information should be provided in an accessible form and must not contain personal data of other individuals, except when there are lawful grounds for disclosure; — request the Operator to correct, block, or delete their personal data if it is incomplete, outdated, inaccurate, or unlawfully obtained, or if it is unnecessary for the stated purpose of processing, and to take measures to protect their rights; — provide prior consent when personal data is processed for marketing purposes; — withdraw consent for personal data processing or request cessation of processing; — appeal against unlawful actions or inactions of the Operator regarding their personal data.
4.2. Data subjects are obliged to: — provide accurate information about themselves to the Operator; — notify the Operator of any updates or changes to their personal data.
4.3. Individuals who provide false information about themselves, or information about another person without their consent, are responsible under applicable law.
5.1. Personal data processing is carried out on a lawful and fair basis.
5.2. Personal data processing is limited to achieving specific, predetermined, and lawful purposes. Processing personal data for purposes incompatible with the original intent is not allowed.
5.3. Combining databases containing personal data for purposes that are incompatible with each other is not allowed.
5.4. Only personal data that is relevant and necessary for the intended purposes of processing may be processed.
5.5. The content and volume of processed personal data correspond to the declared purposes of processing. Excessive collection of personal data beyond the intended purposes is not allowed.
5.6. Accuracy, sufficiency, and, when necessary, relevance of personal data must be ensured in relation to the purposes of processing. The Operator takes necessary measures to correct or update incomplete or inaccurate data.
5.7. Personal data is stored in a form that allows the identification of the data subject no longer than necessary for the purposes of processing. Once the purposes are achieved or if processing is no longer necessary, personal data is either anonymized or deleted.
| Purpose of Processing | Personal Data | Legal Basis | Types of Processing |
|---|---|---|---|
| Providing the User with access to services, information, and/or materials available on the website | Full name Email address |
Founding documents of the Operator | Collection, recording, systematization, accumulation, storage, deletion, and anonymization of personal data |
7.1. Personal data is processed only with the consent of the data subject for the processing of their personal data.
7.2. Personal data processing is necessary for achieving purposes defined by agreements or laws applicable to the Operator and for performing functions and obligations of the Operator.
7.3. Personal data processing may be necessary for the exercise of justice, enforcement of court decisions, or other lawful acts requiring execution.
7.4. Personal data processing is necessary for the performance of a contract, where the data subject is a party, beneficiary, or guarantor, as well as for entering into a contract at the initiative of the data subject or where the data subject will be a beneficiary or guarantor.
7.5. Personal data processing may be necessary for the protection of the rights and legitimate interests of the Operator or third parties, or for achieving socially significant goals, provided that it does not violate the rights and freedoms of the data subject.
7.6. Processing may include publicly available personal data, which the data subject has made accessible to an unlimited number of people or at their request.
7.7. Processing may include personal data intended for publication or mandatory disclosure in accordance with applicable laws.
The security of personal data processed by the Operator is ensured through legal, organizational, and technical measures necessary to fully comply with data protection requirements.
8.1. The Operator ensures the safety of personal data and takes all possible measures to prevent unauthorized access.
8.2. User personal data will never, under any circumstances, be transferred to third parties, except with the consent of the data subject for the purpose of fulfilling obligations under a contract.
8.3. If inaccuracies in personal data are identified, the User can update them independently by sending a notice to the Operator via email at meditationapp128@gmail.com with the subject "Personal Data Update".
8.4. The duration of personal data processing is determined by the purposes for which the data were collected, unless otherwise specified by contract. The User may withdraw their consent to personal data processing at any time by sending a notice to the Operator via email at meditationapp128@gmail.com with the subject "Withdrawal of Consent to Personal Data Processing".
8.5. Any information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by those parties in accordance with their respective Privacy Policies. The Operator is not responsible for the actions of these third parties.
8.6. Restrictions set by the data subject on the transfer or processing of personal data that is allowed for public disclosure do not apply in cases where data processing is necessary for public interest purposes.
8.7. The Operator ensures the confidentiality of personal data during processing.
8.8. Personal data is stored in a form that allows identifying the data subject only as long as required for the purposes of processing. Once the purpose is achieved, personal data is either deleted or anonymized.
8.9. The processing of personal data ceases upon achieving its intended purposes, expiration of the consent period, withdrawal of consent by the data subject, or upon identification of unauthorized processing.
9.1. The Operator may perform collection, recording, systematization, accumulation, storage, updating (modification, change), retrieval, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data only with the consent of the User or as necessary to fulfill contractual obligations.
9.2. The Operator may perform automated processing of personal data, including the transmission and/or receipt of such information over information and telecommunication networks, only in accordance with the User's consent or as required for service operation.
10.1. The User may obtain any clarifications regarding the processing of their personal data by contacting the Operator via email at meditationapp128@gmail.com.
10.2. This document may be updated by the Operator at any time. The policy is effective indefinitely until replaced by a new version.
10.3. The current version of this Policy is publicly available online.