02 October 2026

Elizaveta Vladimirovna Kimel, acting on the basis of the Charter
TIN: ____________________
Email: kimel_work@bk.ru

1. GENERAL PROVISIONS

1.1. This Personal Data Processing Policy (hereinafter referred to as the “Policy”) has been developed in accordance with Clause 2, Part 1, Article 18.1 of Federal Law No. 152-FZ dated July 27, 2006 “On Personal Data” (hereinafter referred to as the “Personal Data Law”) in order to ensure the protection of human and civil rights and freedoms during the processing of personal data, including the protection of the right to privacy, personal and family confidentiality.

1.2. This Policy applies to the following categories of personal data subjects whose data is processed by the Operator:
— The Operator’s clients;
— The Operator’s counterparties;
— Users of the Operator’s website.

1.3. Key terms used in this Policy:

Personal data — any information relating to a directly or indirectly identified or identifiable individual (personal data subject);

Personal Data Operator (Operator) — Elizaveta Vladimirovna Kimel, acting on the basis of the Charter, who independently or jointly with other persons organizes and/or carries out the processing of personal data, and determines the purposes of personal data processing, the scope of personal data to be processed, and the actions (operations) performed with personal data;

Processing of personal data — any action (operation) or set of actions (operations) performed with personal data using automation tools or without their use.

Personal data processing includes, but is not limited to: collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction;

Automated processing of personal data — processing of personal data using computer technology;

Distribution of personal data — actions aimed at disclosing personal data to an indefinite number of persons;

Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific group of persons;

Blocking of personal data — temporary suspension of personal data processing (except where processing is necessary to clarify personal data);

Destruction of personal data — actions as a result of which it becomes impossible to restore the content of personal data in a personal data information system and/or as a result of which material media containing personal data are destroyed;

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 personal data subject;

Personal data information system — a set of personal data contained in databases and information technologies and technical means ensuring their processing;

Cross-border transfer of personal data — transfer of personal data to the territory of a foreign state to a foreign state authority, foreign individual, or foreign legal entity;

Website — a set of computer programs and other information contained in an information system accessible via the Internet.
Operator’s Website — videoelizabeth.com

1.4. Rights and Obligations of the Operator

1.4.1. The Operator has the right to:

— independently determine the composition and list of measures necessary and sufficient to ensure compliance with 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;
— entrust the processing of personal data to another person with the consent of the personal data subject, unless otherwise provided by federal law, on the basis of a contract concluded with such person.
The person processing personal data on behalf of the Operator must comply with the principles and rules of personal data processing provided for by the Personal Data Law;
— continue processing personal data without the consent of the personal data subject in the event of withdrawal of consent, if there are grounds provided for by the Personal Data Law.

1.4.2. The Operator is obliged to:
— organize the processing of personal data in accordance with the requirements of the Personal Data 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 (Roskomnadzor) with the necessary information upon request within 30 days from the date of receipt of such request.

1.5. Rights of Personal Data Subjects

A personal data subject has the right to:

— receive information regarding the processing of their personal data, except in cases provided for by federal laws.
The information is provided by the Operator in an accessible form and must not contain personal data relating to other personal data subjects, except where there are legal grounds for disclosure of such data.
The list of information and the procedure for obtaining it are established by the Personal Data Law;
— demand clarification, blocking, or destruction of their personal data if the data is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, as well as to take legal measures to protect their rights;
— appeal unlawful actions or inaction of the Operator in processing their personal data to Roskomnadzor or in court.

1.6. A personal data subject may exercise their rights by submitting a relevant request to the Operator via email: kimel_work@bk.ru

1.7. Control over compliance with this Policy is carried out by the Operator.

1.8. Liability for violations of Russian Federation legislation and the Operator’s local acts in the field of personal data processing and protection is determined in accordance with the legislation of the Russian Federation.

2. PRINCIPLES OF PERSONAL DATA PROCESSING

2.1. Personal data processing is carried out by the Operator in accordance with the legislation of the Russian Federation and based on the following principles:
— legality and fairness;
— limitation of processing to achieving specific, predetermined, and lawful purposes;
— prohibition of processing incompatible with the purposes of personal data collection;
— prohibition of merging databases containing personal data processed for incompatible purposes;
— processing only personal data that meets the purposes of processing;
— compliance of the content and volume of personal data with the stated purposes of processing;
— prohibition of excessive personal data processing in relation to the stated purposes;
— ensuring accuracy, sufficiency, and relevance of personal data;
— destruction or depersonalization of personal data upon achievement of processing purposes or loss of necessity, unless otherwise provided by federal law.

3. LEGAL GROUNDS FOR PERSONAL DATA PROCESSING

3.1. The legal grounds for processing personal data include regulatory legal acts pursuant to which the Operator processes personal data, including:
— the Constitution of the Russian Federation;
— the Civil Code of the Russian Federation;
— the Tax Code of the Russian Federation;
— Federal Law No. 402-FZ dated December 6, 2011 “On Accounting”;
— other regulatory legal acts governing the Operator’s activities.

3.2. Legal grounds also include:
— contracts concluded with personal data subjects;
— consent of the personal data subject to the processing of personal data.

4. PURPOSES AND CONDITIONS OF PERSONAL DATA PROCESSING

4.1. Personal data processing is limited to achieving specific, predetermined, and lawful purposes. Processing incompatible with the purposes of data collection is not allowed.

4.2. The content and volume of processed personal data must correspond to the stated purposes and must not be excessive.

4.3. The Operator may process personal data of the following categories of subjects:
— counterparties;
— clients;
— website users.

4.3.1. Counterparties
The Operator processes personal data to conclude and perform contracts.
The following data may be processed: full name / company name, phone number, email address, TIN, OGRN/OGRNIP, and social media account data.
Biometric and special categories of personal data are not processed.
Cross-border transfer is not carried out.

4.3.2. Clients
Personal data is processed for contract execution, loyalty programs, and advertising communications (with consent where required).
Biometric and special categories of personal data are not processed.
Cross-border transfer is not carried out.

4.3.3. Website Users
Personal data is processed to handle website requests, advertising communications, and targeted services, subject to prior consent.
Cookies and statistical data may be collected.
Users may refuse cookies via browser settings, though some site functions may become unavailable.

5. PROCEDURE FOR COLLECTION AND STORAGE OF PERSONAL DATA

5.1. Personal data of Russian Federation citizens is recorded, stored, and processed using databases located in the Russian Federation.

5.2. Persons who provide data of another subject without consent are liable under Russian law.

5.3. Personal data is stored no longer than required for processing purposes unless otherwise provided by law or contract.

5.4. Personal data is destroyed upon achievement of processing purposes, withdrawal of consent, or other legal grounds.

6. PERSONAL DATA PROTECTION

6.1. The Operator implements legal, organizational, and technical measures to protect personal data from unauthorized access, destruction, modification, or disclosure.

7. UPDATING, CORRECTION, DELETION, AND DESTRUCTION OF PERSONAL DATA

7.1. The Operator provides information to personal data subjects upon request in accordance with the Personal Data Law.

7.2. In case of inaccuracies, personal data is blocked and corrected within seven business days.

7.3. Unlawfully processed personal data is blocked immediately upon detection.

7.4. Personal data is destroyed upon achievement of processing purposes or withdrawal of consent, unless otherwise provided by law or contract.

8. FINAL PROVISIONS

8.1. Advertising messages are sent only with prior consent in accordance with Federal Law No. 38-FZ “On Advertising.”
Consent may be withdrawn by following the unsubscribe link or by emailing: kimel_work@bk.ru

8.2. This Policy is published at the Operator’s location and publicly available on the Internet at the Operator’s Website.

Operator’s Details

Elizaveta Vladimirovna Kimel
TIN: ____________________
Phone: +995 591 078 211
Email: kimel_work@bk.ru

Elizaveta Vladimirovna Kimel, acting on the basis of the Charter
TIN: ____________________
Email: kimel_work@bk.ru

I hereby, acting on my own behalf, voluntarily and not under any misconception, by checking the box next to the text “I give my consent to the processing of personal data” and clicking the button to submit the completed form, give my consent to the following Personal Data Operator:
to Elizaveta Vladimirovna Kimel, acting on the basis of the Charter, hereinafter referred to as the “Operator,” for automated, non-automated, and mixed processing, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (provision, access), blocking, deletion, and destruction of the following personal data:


for the following purposes:
— concluding and performing contracts;
— organizing participation in a loyalty program;
— sending advertising information about goods and services;
— targeting goods and services according to the user’s interests (for users of the Operator’s website).

The term of this consent to the processing of personal data begins from the moment it is submitted to the Operator and ends upon the achievement of the purposes of personal data processing, upon receipt of a withdrawal of consent for personal data processing, or upon the removal of the Operator from the Unified State Register of Legal Entities.

This consent may be withdrawn by submitting a corresponding request to the Operator via email at kimel_work@bk.ru
In this case, the Operator will cease processing the personal data, and the personal data shall be destroyed, unless there are other legal grounds for processing established by the legislation of the Russian Federation.