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Personal data privacy policy

This Personal Data Privacy Policy (hereinafter referred to as the Privacy Policy) shall apply to all the information that The TORO spa website (hereinafter referred to as the Website) located at the domain name torospa.ru (as well as its sub-domains), can obtain about the User during the use of the torospa.ru website (as well as its sub-domains), its programs and products.

1. Definition of terms
1.1 The following terms are used in this Privacy Policy:
1.1.1. «Website administration» (hereinafter the Administration) is the authorized employees to manage The TORO spa website, which organizes and (or) carry out the processing of personal data, as well as determines the purpose of processing personal data, the composition of personal data to be processed, the actions (operations) performed with personal data.
1.1.2. «Personal data» means any information relating to a directly or indirectly identified or identifiable individual (the personal data subject).
1.1.3. «Personal data processing» means any action (operation) or a set of actions (operations) performed with or without the use of automation with personal data, including the collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, removal, destruction of personal data.
1.1.4. «Personal data confidentiality» is a mandatory requirement for the Operator or other person who has access to personal data to prevent their dissemination without the consent of the personal data subject or availability of other legitimate grounds.
1.1.5. «The TORO spa website» is a set of linked web pages located on the Internet at the unique address (URL): torospa.ru, as well as its sub-domains.
1.1.6. «Sub-domains» are pages or a set of pages located on third-level domains belonging to The TORO spa website, as well as other temporary pages, at the bottom of which is the contact information of the Administration.
1.1.5. «The TORO spa website user» (hereinafter the "User") means a person who accesses The TORO spa website through the Internet and uses information, materials, and products from The TORO spa website.
1.1.7. «Cookies» is a small piece of data sent by a web server and stored on the User's computer, which the web client or web browser sends to the web server each time it tries to open a page of the corresponding website.
1.1.8. «IP address» is the unique network address of the node in the computer network through which the User accesses the Website.
2. Main provisions
2.1. Use of The TORO spa website by the User signifies acceptance of this Privacy Policy and the terms of processing of the User's personal data.
2.2. If the User does not agree with the terms of the Privacy Policy, he/she must stop using The TORO spa website.
2.3. This Privacy Policy applies to The TORO spa website. The Website does not control and is not responsible for any third-party websites to which the User may access through links available on The TORO spa website.
2.4. The Administration does not verify the accuracy of the personal data provided by the User.

3. Privacy policy subject
3.1. This Privacy Policy establishes the obligations of the Administration of non-disclosure and protection of confidentiality of personal data that the User provides at the request of the Administration during the registration on the website The TORO spa or when subscribing to the e-mail newsletter.
3.2. The personal data permitted to be processed under this Privacy Policy is provided by the User by filling in forms on The TORO spa website and includes the following information:
3.2.1. last name, first name, patronymic of the User;
3.2.2. contact phone number of the User;
3.2.3. email address (e-mail)
3.2.4. place of residence of the User (if necessary)
3.2.5. photo (if necessary)
3.3. The Website protects the data that is automatically transmitted when pages are visited:
- IP address;
- information from cookies;
- browser information;
- access time;
- referrer (previous page address).
3.3.1. Disabling cookies may prevent you from accessing parts of the website that require authorization.
3.3.2. The Website collects statistics about the IP addresses of its visitors. This information is used to prevent, detect, and resolve technical problems.
3.4. Any other personal information not specified above (browsing history, browsers used, operating systems, etc.) shall be stored securely and shall not be disclosed, except as provided in clause 5.2. of this Privacy Policy.

4. Purposes for collecting personal information of the User
4.1. The Administration may use the User's personal data for the following purposes:
4.1.1. Identification of the User registered on The TORO spa website for further authorization.
4.1.2. Providing the User with access to personalized data on The TORO spa website.
4.1.3. Establishing feedback with the User, including sending notices, inquiries regarding the use of The TORO spa website, processing inquiries and requests from the User.
4.1.4. Determining the location of the User to ensure security and fraud prevention.
4.1.5. Confirming the accuracy and completeness of the personal data provided by the User.
4.1.6. Creating an account to use parts of The TORO spa website, if the User has agreed to create an account
4.1.7. User notifications by email.
4.1.8. Providing the User with effective technical support when problems arise with the use of The TORO spa website.
4.1.9. Providing special offers, newsletters, and other information on behalf of The TORO spa website to the User with their consent.

5. Methods and terms of personal information processing
5.1. Processing of personal data of the User is carried out without limitation of time, in any lawful way, including in information systems of personal data with or without the use of automation tools.
5.2. Personal data of the User may be transferred to the authorized state bodies of the Russian Federation only on the grounds and in the manner prescribed by the legislation of the Russian Federation.
5.3. If personal data is lost or disclosed, the Administration has the right not to inform the User about the loss or disclosure of personal data.
5.4. The Administration shall take the necessary organizational and technical measures to protect the User's personal information from unauthorized or accidental access, destruction, modification, blocking, copying, distribution, as well as from other unlawful actions of third parties.
5.5. The Administration together with the User shall take all necessary measures to prevent losses or other negative consequences caused by the loss or disclosure of personal data of the User.

6. Rights and obligations of the Parties
6.1. The User shall have the right to:
6.1.1. Decide freely to provide their personal data needed to use The TORO spa website and consent to their processing.
6.1.2. Update, supplement the provided information about personal data in case of changes in this information.
6.1.3. The User shall have the right to receive information from the Administration regarding the processing of their personal data unless such right is limited in accordance with federal laws. The User shall have the right to request the Administration to clarify their personal data, block or destroy it if the personal data is incomplete, outdated, inaccurate, illegally obtained, or is not necessary for the stated purpose of processing, as well as to take statutory measures to protect their rights. To do so, simply notify the Administration at the specified e-mail address.
6.2. The Administration is obligated to:
6.2.1. Use the information obtained solely for the purposes specified in clause 4 of this Privacy Policy.
6.2.2. Ensure the storage of confidential information in secret, not to disclose without prior written permission of the User, as well as not to sell, exchange, publish, or disclose in any other possible ways the personal data transmitted by the User, except for clause 5.2. of this Privacy Policy.
6.2.3. Take precautions to protect the confidentiality of the personal data of the User in accordance with the procedure generally used to protect this kind of information in the existing business conduct.
6.2.4. Carry out the blocking of the personal data relating to the relevant User, from the date of application or request of the User, or their legal representative or authorized body for the protection of the rights of personal data subjects for the period of verification, in case of unreliable personal data or misconduct.

7. Liability of the Parties
7.1. The Administration, which has not fulfilled its obligations, shall be liable for losses incurred by the User in connection with the unauthorized use of personal data in accordance with the legislation of the Russian Federation, except for cases stipulated by clauses 5.2. and 7.2. of this Privacy Policy.
7.2. In the case of loss or disclosure of the confidential information, the Administration shall not be liable if the Confidential Information:
7.2.1. Was in the public domain before its loss or disclosure.
7.2.2. Was obtained from a third party prior to its receipt by the Website Administration
7.2.3. Was disclosed with the consent of the User.
7.3. The User is fully responsible for compliance with the laws of the Russian Federation, including, but not limited to, laws on advertising, protection of copyright and related rights, protection of trademarks and service marks, including full responsibility for the content and form of the materials.
7.4. The User acknowledges that any information (including but not limited to: data files, texts, etc.) to which the User may have access as part of The TORO spa website is the responsibility of the person who provided such information.
7.5. The User agrees that the information made available to them as part of The TORO spa website may be an item of intellectual property, the rights to which are reserved and belong to other Users, partners, or advertisers who place such information on The TORO spa website.

The User shall not modify, rent, lease, loan, sell, distribute or create derivative works based on such Content (in whole or in part) unless such actions have been expressly authorized in writing by the owners of such Content pursuant to the terms of a separate agreement.
7.6. For textual materials (articles, publications in free public access on The TORO spa website), it is allowed to distribute them, as long as a link to the Website is provided.
7.7. The Administration shall not be liable to the User for any loss or damage suffered by the User as a result of the deletion, failure, or inability to retain any Content or other communication data contained on or transmitted through The TORO spa website.
7.8. The Administration shall not be liable for any direct or indirect damages resulting from the use or inability to use the website or separate services; unauthorized access to communications of the User; statements or behavior of any third party on the website.
7.9. The Administration shall not be liable for any information posted by the User on The TORO spa website, including but not limited to: information protected by copyright, without the express consent of the copyright owner.

8. Resolution of disputes
8.1. Before recourse to the court for disputes arising from the relationship between the User and the Administration, it is mandatory to submit a claim (proposal in written or electronic form on a voluntary settlement of the dispute).
8.2. The recipient of the claim, within 30 calendar days of receipt of the claim, shall notify the claimant in writing or electronically of the results of the claim consideration.
8.3. If no agreement is reached, the dispute will be referred to the Arbitration Court of St. Petersburg.
8.4. This Privacy Policy and the relationship between the User and the Administration is governed by the applicable laws of the Russian Federation.

9. Additional provisions
9.1. The Administration has the right to make changes to this Privacy Policy without the consent of the User.
9.2. The new Privacy Policy will be effective when posted on The TORO spa website unless the new Privacy Policy provides otherwise.
9.3. All suggestions or questions regarding this Privacy Policy should be addressed to: [email protected]
9.4. The current Privacy Policy is available at https://torospa.ru/privacy-policy


Updated: February 16, 2019

St. Petersburg


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