Personal Data Processing Policy

1. General Provisions
   This personal data processing policy has been developed 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 personal data processing and measures for ensuring the security of personal data taken by LE VIET NGUYEN (hereinafter referred to as the Operator).
   1.1. The Operator’s primary goal and condition for carrying out its activities is to ensure the rights and freedoms of individuals during the processing of personal data, including protecting the right to privacy and personal and family secrets.
   1.2. This policy of the Operator regarding personal data processing (hereinafter referred to as the Policy) applies to all information that the Operator may receive about visitors to the website https://vietcrococoltd.com.
2. Basic Concepts Used in the Policy
   2.1. Automated Processing of Personal Data – processing of personal data with the use of computing devices.
   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 combination of graphic and informational materials, as well as computer programs and databases that provide their availability on the internet at the network address https://vietcrococoltd.com.
   2.4. Information System of Personal Data – a set of personal data contained in databases and ensuring their processing through information technologies and technical means.
   2.5. Anonymization of Personal Data – actions that make it impossible to identify, without the use of additional information, to which specific User or other subject of personal data the personal data belongs.
   2.6. Processing of Personal Data – any action (operation) or set of actions (operations) performed using automated tools or without using such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (dissemination, provision, access), anonymization, blocking, deletion, destruction of personal data.
   2.7. Operator – a state body, municipal body, legal entity, or individual that independently or jointly with other individuals organizes and/or carries out personal data processing, as well as determines the purposes of personal data processing, the composition of the 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 definable User of the website https://vietcrococoltd.com.
   2.9. Personal Data Permitted by the Subject for Dissemination – personal data to which an unlimited number of persons have access, as permitted by the subject of personal data by giving consent for personal data processing, as provided for in the Personal Data Law (hereinafter – personal data permitted for dissemination).
   2.10. User – any visitor to the website https://vietcrococoltd.com.
   2.11. Provision of Personal Data – actions aimed at disclosing personal data to a specific person or a specific group of persons.
   2.12. Dissemination of Personal Data – any actions directed at disclosing personal data to an indefinite number of persons (transfer of personal data) or making personal data available to an unlimited number of persons, including publication of personal data in mass media, placement in information and telecommunications networks, or providing access to personal data in any other way.
   2.13. Cross-Border Transfer of Personal Data – transfer of personal data to the territory of a foreign state to a foreign government body, foreign individual, or foreign legal entity.
   2.14. Destruction of Personal Data – any actions that result in personal data being irretrievably destroyed with no possibility of further restoration of the contents of the personal data in the information system of personal data and/or the destruction of material carriers of personal data.
3. Main Rights and Obligations of the Operator
   3.1. The Operator has the right to:

• receive from the subject of personal data accurate information and/or documents containing personal data;
• in the event of the withdrawal by the subject of personal data of consent for processing personal data, as well as receiving a request to cease processing personal data, continue processing personal data without the consent of the subject of personal data if there are grounds specified in the Personal Data Law;
• independently determine the composition and list of measures necessary and sufficient to ensure compliance with the obligations established by the Personal Data Law and regulatory legal acts adopted in accordance with it unless otherwise provided for by the Personal Data Law or other federal laws.

3.2. The Operator is obliged to:

• provide the subject of personal data, upon request, with information regarding the processing of their personal data;
• organize the processing of personal data in the manner established by the current legislation of the Russian Federation;
• respond to appeals and requests of subjects of personal data and their legal representatives in accordance with the requirements of the Personal Data Law;
• notify the authorized body for protecting the rights of subjects of personal data upon request of this authority of the necessary information within 10 days from the date of receipt of such a request;
• publish or otherwise ensure unrestricted access to this Policy on personal data processing;
• take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, alteration, blocking, copying, provision, dissemination of personal data, as well as from other unlawful actions in relation to personal data;
• cease the transfer (dissemination, provision, access) of personal data, stopping processing and destroying personal data in the manner and cases provided for by the Personal Data Law;
• perform other duties established by the Personal Data Law.

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

• receive information regarding the processing of their personal data, except in cases specified by federal laws. The information is provided to the subject of personal data by the Operator in an accessible form, and it must not contain personal data relating to other subjects of personal data, except when there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
• demand from the Operator the clarification, blocking, or destruction of their personal data if the personal data is incomplete, outdated, inaccurate, illegally obtained, or not necessary for the stated purpose of processing, as well as take any legal measures to protect their rights;
• impose a condition for prior consent when processing personal data for marketing purposes;
• withdraw their consent for personal data processing, as well as submit a demand to cease the processing of personal data;
• appeal to the authorized body for protecting the rights of subjects of personal data or to a court to challenge unlawful actions or inaction of the Operator during the processing of their personal data;
• exercise other rights provided by the legislation of the Russian Federation.

4.2. Subjects of personal data are obliged to:

• provide the Operator with accurate data about themselves;
• notify the Operator of any clarification (updating, changes) to their personal data.

4.3. Persons who provide the Operator with inaccurate information about themselves or information about another subject of personal data without the latter’s consent shall bear responsibility in accordance with the legislation of the Russian Federation.

Final Provisions
12.1. Users can obtain any clarifications regarding issues related to the processing of their personal data by contacting the Operator at the email address info@vietcrococoltd.com.
12.2. This document will reflect any changes to the Operator’s personal data processing policy. 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://vietcrococoltd.com/privacy/.

Principles of Personal Data Processing
5.1. Personal data processing is carried out on a legal and fair basis.
5.2. The processing of personal data is limited to achieving specific, predetermined, and lawful goals. Processing of personal data incompatible with the purposes of personal data collection is not permitted.
5.3. Combining databases containing personal data, the processing of which is carried out for incompatible purposes, is not allowed.
5.4. Only personal data that meet the objectives of processing are subject to processing.
5.5. The content and volume of personal data processed must comply with the stated processing purposes. Excessive data in relation to the stated purposes of processing is not allowed.
5.6. Personal data processing ensures the accuracy, sufficiency, and, if necessary, relevance of personal data in relation to the purposes of processing. The Operator takes necessary measures and/or ensures their implementation for the deletion or clarification of incomplete or inaccurate data.
5.7. Personal data is stored in a form that allows identification of the subject of personal data for no longer than is necessary for the purposes of processing personal data unless otherwise specified by federal law, contract or other legal documents with the subject of personal data. Processed personal data shall be destroyed or anonymized upon achieving the processing objectives or when the necessity of achieving such objectives is lost unless otherwise specified by federal law.

Objectives of Personal Data Processing
Objective of processing: informing Users by sending emails.
Personal data: philosophical beliefs.
Legal basis: Federal Law “On Information, Information Technologies and Information Protection” dated July 27, 2006, N 149-FZ.
Types of personal data processing: transferring personal data.

Conditions for Personal Data Processing
7.1. Personal data processing is carried out with the consent of the subject of personal data for processing their personal data.
7.2. Personal data processing is necessary to achieve the goals provided for by international treaties of the Russian Federation or laws to fulfill the functions, powers, and obligations imposed by the legislation of the Russian Federation on the operator.
7.3. Personal data processing is necessary to administer justice, execute a court decision, or other acts of any body or official required to be executed under the legislation of the Russian Federation on enforcement proceedings.
7.4. Personal data processing is necessary for the execution of a contract to which the subject of personal data is a party, or for the conclusion of a contract at the initiative of the subject of personal data or for a contract in which the subject of personal data is a beneficiary or guarantor.
7.5. Personal data processing is necessary to protect the rights and legal interests of the operator or third parties or to achieve socially significant objectives provided that the rights and freedoms of the subject of personal data are not violated.
7.6. Processing is performed for personal data to which an unlimited number of persons have been granted access by the subject of personal data or at their request (hereinafter referred to as publicly available personal data).
7.7. Processing is carried out for personal data that must be published or disclosed under federal law.

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 regarding the protection of personal data.
8.1. The Operator ensures the safety of personal data and takes all possible measures to prevent unauthorized access to personal data.
8.2. Users’ personal data will never be transferred to third parties under any circumstances, except in cases related to compliance with applicable laws or if the subject of personal data has given consent to the Operator to transfer data to a third party for performing obligations under a civil contract.
8.3. If inaccuracies in personal data are identified, Users can update them independently by sending the Operator a notification to the Operator’s email address info@vietcrococoltd.com with the subject “Updating Personal Data.”
8.4. The duration of personal data processing is determined by the achievement of the objectives for which the personal data was collected, unless a different term is defined in the contract or applicable law. The User can withdraw their consent for the processing of personal data at any time by sending the Operator a notification via email to the Operator’s email address info@vietcrococoltd.com, marked “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 (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data and/or the mentioned documents are not the responsibility of the Operator for the actions of third parties, including those specified in this paragraph.
8.6. Any restrictions imposed by the subjects of personal data on their transfer (except for providing access), as well as on processing or conditions for processing (except for obtaining access) to personal data permitted for dissemination do not apply to cases of processing personal data in the state, public, and other public interests defined by Russian Federation legislation.
8.7. The Operator ensures the confidentiality of personal data during processing.
8.8. The Operator stores personal data in a form that allows identifying the subject of personal data no longer than required by the goals of personal data processing unless a longer storage period is established by federal law, a contract, or another legal document with the subject of personal data.
8.9. Conditions for the cessation of personal data processing may include the achievement of processing purposes, the expiration of the subject’s consent, withdrawal of consent by the subject, or request for the cessation of personal data processing, as well as the identification of unauthorized personal data processing.

Actions Performed by the Operator with Received Personal Data
9.1. The Operator carries out collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (dissemination, provision, access), anonymization, blocking, deletion, and destruction of personal data.
9.2. The Operator performs automated processing of personal data with the receipt and/or transfer of information received through information and telecommunications networks or without such networks.

Cross-Border Transfer of Personal Data
10.1. Before commencing cross-border transfer activities, the Operator must notify the authorized body for protecting the rights of subjects of personal data of its intention to carry out cross-border transfer of personal data (such notification is sent separately from the notification of the intention to carry out personal data processing).
10.2. Before submitting the aforementioned notification, the Operator must obtain the relevant information from the authorities of foreign states, foreign individuals, and foreign legal entities to which the cross-border transfer of personal data is planned.

Confidentiality of Personal Data
The Operator and others who have access to personal data are obliged not to disclose third parties and not to disseminate personal data without the consent of the subject of personal data unless otherwise provided by federal law.