1. General Provisions
This personal data processing policy is prepared in accordance with the requirements of Federal Law No. 152-FZ "On Personal Data" dated July 27, 2006 (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 LFD Agency (hereinafter referred to as the "Operator").
1.1. The Operator considers the protection of human and civil rights and freedoms when processing personal data, including the protection of the right to privacy, personal and family secrets, to be of utmost importance.
1.2. This Policy applies to all information that the Operator may obtain about visitors to the website https://vip-massage-dubai.tilda.ws/dub
2. Basic Terms 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 software and databases, that ensure their availability on the Internet at https://vip-massage-dubai.tilda.ws/dub
2.4. Information system of personal data: A collection of personal data contained in databases and the information technologies and technical means that process them.
2.5. Depersonalization of personal data: Actions that make it impossible to determine the ownership of personal data by a specific user or other personal data subject without additional information.
2.6. Processing of personal data: Any action (operation) or a series 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), depersonalization, blocking, deletion, and destruction of personal data.
2.7. Operator: A state or municipal body, 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 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 https://vip-massage-dubai.tilda.ws/dub.
2.9. Personal data allowed by the personal data subject for distribution: Personal data to which the subject has provided access to an unlimited number of persons by giving consent to the processing of personal data allowed for distribution under the Personal Data Law.
2.10. User: Any visitor to the website https://vip-massage-dubai.tilda.ws/dub.
2.11. Provision of personal data: Actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Distribution of personal data: Any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or at familiarizing an unlimited number of persons with personal data, including publishing personal data in the media, placing them in information and telecommunication networks, or providing access to personal data by any other means.
2.13. Cross-border transfer of personal data: Transfer of personal data to the territory of a foreign state, to a foreign government authority, a foreign individual, or a foreign legal entity.
2.14. Destruction of personal data: Any actions that result in the irreversible destruction of personal data with the inability to further restore the content of personal data in the personal data information system and/or destruction of tangible personal data carriers.
3. Basic Rights and Obligations of the Operator
3.1. The Operator has the right to:

• Obtain reliable information and/or documents containing personal data from the personal data subject;
• Continue processing personal data without the consent of the personal data subject in cases stipulated by the Personal Data Law, even if the subject withdraws consent or submits a request to cease processing;
• Independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations under the Personal Data Law and regulations 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 personal data subject, upon request, with information related to the processing of their personal data;
• Organize the processing of personal data in accordance with the current legislation of the Russian Federation;
• Respond to requests from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
• Notify the authorized body for the protection of personal data subjects' rights upon request within 10 days from the receipt of such a request;
• Publish or otherwise ensure unrestricted access to this Policy regarding personal data processing;
• Take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, alteration, blocking, copying, provision, distribution, and other unlawful actions;
• Cease the transfer (distribution, provision, access) of personal data, cease processing, and destroy personal data in accordance with the Personal Data Law;
• Fulfill other obligations stipulated by the Personal Data Law.

4. Basic Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects have the right to:

• Obtain information related to the processing of their personal data, except in cases provided by federal laws. The information is provided to the personal data subject by the Operator in an accessible form, and it must not contain personal data relating to other personal data subjects, except in cases where there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it is established by the Personal Data Law;
• Request the Operator to clarify, block, or destroy their personal data if the personal 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;
• Demand prior consent when processing personal data for marketing purposes;
• Withdraw consent to the processing of personal data and demand the cessation of personal data processing;
• Complain to the authorized body for the protection of personal data subjects' rights or take legal action against unlawful actions or inaction by the Operator when processing their personal data;
• Exercise other rights provided by the legislation of the Russian Federation.

4.2. Personal data subjects are obliged to:

• Provide the Operator with accurate data about themselves;
• Notify the Operator of any updates (changes) to their personal data.

4.3. Individuals who have provided the Operator with inaccurate information about themselves or information about another personal data subject without their consent are liable in accordance with the legislation of the Russian Federation.
5. Principles of Personal Data Processing
5.1. The processing of personal data is carried out on a lawful and fair basis.
5.2. The processing of personal data is limited to achieving specific, pre-defined, and lawful purposes. The processing of personal data that is incompatible with the purposes of collecting personal data is not allowed.
5.3. It is not permitted to combine databases containing personal data that are processed for purposes incompatible with each other.
5.4. Only personal data that meets the purposes of its processing is subject to processing.
5.5. The content and volume of processed personal data must correspond to the stated purposes of processing. Excessive personal data processing in relation to the stated purposes is not allowed.
5.6. Personal data accuracy, sufficiency, and relevance must be ensured during processing. The Operator takes necessary measures and/or ensures that necessary measures are taken to delete or clarify incomplete or inaccurate data.
5.7. Personal data is stored in a form that allows the identification of the personal data subject for no longer than required by the purposes of personal data processing, unless a longer storage period is established by federal law or a contract, which benefits or guarantees the personal data subject. Processed personal data is destroyed or depersonalized upon reaching the processing goals or when it is no longer necessary to achieve these goals, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing
Purpose of Processing:

• Providing the User with access to the services, information, and/or materials on the website.

Personal Data:

• Phone numbers.

Legal Basis:

• Federal Law "On Information, Information Technologies, and Information Protection" No. 149-FZ of July 27, 2006.

Types of Personal Data Processing:

• Collection, recording, systematization, accumulation, storage, destruction, and depersonalization of personal data.

7. Conditions for Personal Data Processing
7.1. The processing of personal data is carried out with the consent of the personal data subject.
7.2. The processing of personal data is necessary to achieve the goals provided by international agreements of the Russian Federation or by law, for the performance of functions, powers, and duties imposed by the legislation of the Russian Federation on the Operator.
7.3. The processing of personal data is necessary for the administration of justice, execution of a judicial act, act of another authority, or an official subject to execution under the legislation of the Russian Federation on enforcement proceedings.
7.4. The processing of personal data is necessary for the execution of a contract to which the personal data subject is a party or beneficiary, or guarantor, as well as for concluding a contract on the initiative of the personal data subject.
7.5. The processing of personal data is necessary for the protection of the rights and legitimate interests of the Operator or third parties, or for the achievement of socially significant purposes, provided that this does not violate the rights and freedoms of the personal data subject.
7.6. Processing of personal data to which the personal data subject has given access to an unlimited number of persons (hereinafter referred to as "publicly available personal data") is carried out.
7.7. Processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.
8. Procedures for Collecting, Storing, Transferring, and Processing Personal Data
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 the current legislation on personal data protection.
8.1. The Operator ensures the safekeeping of personal data and takes all possible measures to prevent unauthorized access to personal data.
8.2. Personal data of the User will never, under any circumstances, be transferred to third parties, except in cases related to the fulfillment of current legislation or if the data subject has given consent to the Operator to transfer the 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 can update them independently by sending a notification to the Operator's email address premiumagenc@info.com with the subject line "Update of Personal Data."
8.4. The period for processing personal data is determined by the achievement of the purposes for which the personal data was collected, unless a different period is stipulated by a contract or current legislation. The User may withdraw their consent to the processing of personal data at any time by sending a notification to the Operator via email to premiumagenc@info.com with the subject line "Withdrawal of Consent for Personal Data Processing."
8.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by these entities (Operators) in accordance with their User Agreement and Privacy Policy. The data subject should review these documents. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this clause.
8.6. Restrictions set by the data subject on the transfer (other than granting access) or on the processing or conditions of processing (other than obtaining access) of personal data permitted for dissemination do not apply in cases of processing personal data in state, public, and other public interests as defined by Russian Federation legislation.
8.7. The Operator ensures the confidentiality of personal data during its processing.
8.8. The Operator retains personal data in a form that allows identification of the data subject no longer than necessary to achieve the purposes of processing personal data, unless the retention period is established by federal law, contract, or if the data subject is a party, beneficiary, or guarantor of the contract.
8.9. Conditions for terminating the processing of personal data may include achieving the purposes of processing, expiration of the data subject’s consent, withdrawal of consent by the data subject, or a request to cease processing personal data, as well as detection of unlawful processing of personal data.
9. List of Actions Performed by the Operator with Received Personal Data
9.1. The Operator performs the collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (dissemination, provision, access), anonymization, blocking, deletion, and destruction of personal data.
9.2. The Operator carries out automated processing of personal data, including the receipt and/or transmission of the received information via information and telecommunications networks or without such transmission.
10. Cross-Border Transfer of Personal Data
10.1. Before commencing cross-border transfer of personal data, the Operator must notify the authorized body responsible for protecting the rights of data subjects about its intention to carry out such transfer (this notification is to be sent separately from the notification of the intention to process personal data).
10.2. Prior to submitting the aforementioned notification, the Operator must obtain from the authorities of the foreign state, foreign individuals, or foreign legal entities to which the personal data is intended to be transferred, the relevant information.
11. Confidentiality of Personal Data
The Operator and other persons who have obtained access to personal data are obliged not to disclose or distribute personal data to third parties without the consent of the personal data subject unless otherwise provided by federal law.
12. Final Provisions
12.1. Other rights and obligations of the Operator as the personal data operator are determined by the legislation of the Russian Federation in the field of personal data.
12.2. The Operator has the right to make changes to this Policy without the consent of the personal data subject.
12.3. This Policy is an internal document of the Operator and must be published on the website.
12.4. This Policy comes into effect from the moment of its publication on the website and is valid indefinitely until replaced by a new version.
12.5. The current version of the Policy is freely available on the Internet at https://vip-massage-dubai.tilda.ws/dub.