Personal Data Processing Policy
This Personal Data Processing Policy has been prepared in accordance with the requirements of Federal Law No. 152-FZ dated July 27, 2006 “On Personal Data” (hereinafter — the Personal Data Law) and defines the procedure for processing personal data and the measures taken to ensure the security of personal data by ELVION MARKETING AGENCY – FZCO (hereinafter — the Operator).
1.1. The Operator considers compliance with human and civil rights and freedoms during the processing of personal data, including the protection of the right to privacy, personal and family secrecy, as its most important goal and condition for carrying out its activities.
1.2. This Policy of the Operator regarding the processing of personal data (hereinafter — the Policy) applies to all information that the Operator may obtain about visitors to the website https://elvion.world/.

2. Key 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 suspension of personal data processing (except where processing is necessary to clarify personal data).
2.3. Website — a set of graphic and informational materials, as well as computer programs and databases, ensuring their availability on the Internet at https://elvion.world/.
2.4. Personal data information system — a set of personal data contained in databases and information technologies and technical means used to process such data. 2.5. Depersonalization of personal data — actions as a result of which it becomes impossible to determine, without additional information, the ownership of personal data by a specific User or other personal data subject.
2.6. Processing of personal data — any action or set of actions performed with or without automation tools on personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
2.7. Operator — a legal entity or individual that independently or jointly with others organizes and/or processes personal data and determines the purposes of processing, the scope of personal data to be processed, and the actions performed with personal data.
2.8. Personal data — any information relating directly or indirectly to an identified or identifiable User of the website https://elvion.world/.
2.9. Personal data authorized by the data subject for dissemination — personal data to which access is granted to an unlimited number of persons by the subject’s consent in accordance with the Personal Data Law.
2.10. User — any visitor to the website https://elvion.world/.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or group of persons.
2.12. Dissemination of personal data — actions aimed at disclosing personal data to an indefinite group of persons or making it publicly available, including publication in mass media or placement in information and telecommunication networks.
2.13. Cross-border transfer of personal data — transfer of personal data to the territory of a foreign state to a foreign authority, individual, or legal entity.
2.14. Destruction of personal data — actions resulting in irreversible destruction of personal data with no possibility of further recovery.

3. Rights and Obligations of the Operator
3.1. The Operator has the right to: receive reliable personal data from the data subject; continue processing personal data without consent where permitted by law; independently determine sufficient measures to ensure compliance with legal requirements.
3.2. The Operator is obliged to: provide information on personal data processing upon request; organize processing in accordance with applicable law; respond to requests from data subjects and authorities; ensure public access to this Policy; take legal, organizational, and technical measures to protect personal data; terminate processing and destroy personal data where required; fulfill other obligations established by law.
3.3. The Operator may also send Users notifications about new products, services, special offers, and events. Users may opt out by sending an email to adm@elvion.world with the subject line: “Refusal to receive notifications about new products, services, and special offers.”

4. Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects have the right to: obtain information regarding processing of their personal data; require clarification, blocking, or destruction of inaccurate or unlawfully processed data; withdraw consent; object to processing for marketing purposes; appeal unlawful actions or inaction of the Operator; exercise other rights provided by law.
4.2. Personal data subjects are obliged to: provide accurate information to the Operator; notify the Operator of changes in personal data.
4.3. Persons providing false information or data of third parties without consent bear responsibility under applicable law.

5. Principles of Personal Data Processing
5.1. Processing is carried out on a lawful and fair basis.
5.2. Processing is limited to specific, predetermined, and lawful purposes; incompatible processing is not permitted.
5.3. Combining incompatible databases is not permitted.
5.4. Only data relevant to the processing purposes is processed.ч
5.5. Content and volume of processed data must correspond to purposes and not be excessive.
5.6. Accuracy, sufficiency, and relevance of data are ensured; measures are taken to clarify or delete incomplete or inaccurate data.
5.7. Personal data is stored no longer than required to achieve processing purposes and is destroyed or depersonalized after, unless otherwise required by law.

6. Purposes of Personal Data Processing

• Last name, first name, patronymic
• Email address
• Phone numbers

• Charter (founding) documents of the Operator

• Collection, recording, systematization, accumulation, storage, destruction, and depersonalization of personal data
• Sending informational emails to the email address

7. Conditions for Personal Data Processing
7.1. Personal data processing is carried out with the consent of the personal data subject to the processing of their personal data.
7.2. Personal data processing is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, or to perform the functions, powers, and duties imposed on the Operator by the legislation of the Russian Federation.
7.3. Personal data processing is necessary for the administration of justice, enforcement of a court decision, or an act of another authority or official that must be executed in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. Personal data processing is necessary to fulfill a contract, of which the personal data subject is a party, beneficiary, or guarantor, as well as for entering into a contract at the initiative of the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor.
7.5. Personal data processing is necessary to exercise the rights and lawful interests of the Operator or third parties, or to achieve socially significant purposes, provided that the rights and freedoms of the personal data subject are not violated.
7.6. Personal data processing is carried out for data made publicly available by the personal data subject or at their request (hereinafter — publicly available personal data).
7.7. Personal data processing is carried out for data subject to publication or mandatory disclosure in accordance with federal law.

8. Procedure for Collecting, Storing, Transferring, and Other Types of Personal Data Processing
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 current legislation on personal data protection.
8.1. The Operator ensures the safety of personal data and takes all possible measures to prevent access to personal data by unauthorized persons.
8.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to compliance with applicable law or if the personal data subject has given consent to the Operator to transfer data to a third party for the fulfillment of obligations under a civil law contract.
8.3. In case of inaccuracies in personal data, the User may update them independently by sending a notification to the Operator’s email address adm@elvion.world with the note “Personal Data Update.”
8.4. The duration of personal data processing is determined by the achievement of the purposes for which the personal data were collected, unless a different period is provided by a contract or applicable law. The User may withdraw their consent to the processing of personal data at any time by sending a notification via email to adm@elvion.world with the note “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 those entities in accordance with their User Agreement and Privacy Policy. The personal data subject agrees to these documents. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this clause.
8.6. Restrictions established by the personal data subject on the transfer (except for granting access), processing, or conditions of processing (except for granting access) of personal data authorized for dissemination do not apply in cases of personal data processing in the state, public, or other public interests as determined by Russian law.
8.7. The Operator ensures the confidentiality of personal data during its processing.
8.8. The Operator stores personal data in a form that allows the identification of the personal data subject no longer than required to achieve the purposes of processing, unless a longer storage period is established by federal law, a contract, or a legal agreement in which the personal data subject is a party, beneficiary, or guarantor.
8.9. Conditions for terminating the processing of personal data may include achieving the purposes of processing, expiration of the personal data subject’s consent, withdrawal of consent by the personal data subject, a request to terminate processing, or detection of unlawful processing of personal data.

9. List of Actions Performed by the Operator with the Received Personal Data
9.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, modifies), extracts, uses, transfers (distributes, provides, grants access), depersonalizes, blocks, deletes, and destroys personal data.
9.2. The Operator performs automated processing of personal data with the receipt and/or transfer of the obtained information via information and telecommunication networks or without using such networks.

10. Cross-Border Transfer of Personal Data
10.1. Before commencing cross-border transfer of personal data, the Operator must notify the authorized body for the protection of personal data subjects of its intention to perform a cross-border transfer (this notification is sent separately from the notification of intent to process personal data).
10.2. Prior to submitting the above notification, the Operator must obtain from the authorities of the foreign state, foreign individuals, or foreign legal entities to whom the personal data is to be transferred, the relevant information.

11. Confidentiality of Personal Data
The Operator and other persons who gain access to personal data are obliged not to disclose or disseminate personal data to third parties without the consent of the personal data subject, unless otherwise provided by federal law.

12. Final Provisions
12.1. The User may obtain any clarifications on issues concerning the processing of their personal data by contacting the Operator via email at adm@elvion.world.
12.2. Any changes to the Operator’s personal data processing policy will be reflected in this document. The Policy is valid indefinitely until replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet at https://elvion.world/.