privacy policy by dephan llc
1. General Provisions
This Personal Data Processing Policy (hereinafter — the "Policy") is formulated in compliance with the requirements of Federal Law No. 152-FZ dated July 27, 2006, "On Personal Data" (hereinafter — the "Personal Data Law") and establishes the procedure for processing personal data and the security measures implemented by DEFAN LLC (hereinafter — the "Operator").
1.1. The Operator prioritizes the observance of human and civil rights and freedoms when processing personal data, including the protection of privacy, personal, and family confidentiality, as a fundamental condition of its operations.
1.2. This Policy applies to all information obtained by the Operator about visitors to the website https://www.dephan.com.
2. Key Definitions Used in the Policy
2.1. Automated Processing of Personal Data: Processing using computer technologies.
2.2. Blocking of Personal Data: Temporary suspension of processing (except where necessary to clarify data).
2.3. Website: A collection of graphical, informational materials, software, and databases accessible at https://www.dephan.com.
2.4. Personal Data Information System: A set of personal data databases and technologies enabling their processing.
2.5. Anonymization of Personal Data: Actions rendering data unidentifiable without additional information.
2.6. Processing of Personal Data: Any operation(s) performed on personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, or destruction.
2.7. Operator: A state/municipal authority, legal entity, or individual organizing and/or executing data processing, including defining its purposes and scope.
2.8. Personal Data: Any information directly or indirectly identifying a User of https://www.dephan.com.
2.9. Personal Data Permitted for Dissemination: Data disclosed to an unlimited audience by the subject’s consent under the Personal Data Law.
2.10. User: Any visitor to https://www.dephan.com.
2.11. Provision of Personal Data: Disclosure to specific individuals.
2.12. Dissemination of Personal Data: Disclosure to an indefinite audience (e.g., media, online networks).
2.13. Cross-Border Transfer of Personal Data: Transfer to foreign states, authorities, or entities.
2.14. Destruction of Personal Data: Irreversible deletion making recovery impossible.
3. Operator’s Rights and Obligations
3.1. Rights:
4. Rights and Obligations of Personal Data Subjects
4.1. Rights:
5. Principles of Personal Data Processing
5.1. Lawful and fair basis.
5.2. Limited to predefined, legitimate purposes.
5.3. Prohibition of incompatible database merging.
5.4. Processing only relevant data.
5.5. No excess beyond stated purposes.
5.6. Ensure accuracy, sufficiency, and relevance.
5.7. Storage only as long as necessary.
6. Purposes of Processing
6.1. Purpose: User communication via email.
7. Processing Conditions
7.1. Subject’s consent.
7.2. Legal obligations under Russian/international law.
7.3. Judicial/executive proceedings.
7.4. Contract fulfillment or initiation.
7.5. Operator’s legitimate interests (without infringing rights).
7.6. Publicly accessible data.
7.7. Mandatory disclosure per law.
8. Data Handling Procedures
8.1. Security measures against unauthorized access.
8.2. No third-party transfer except for legal compliance or contractual obligations.
8.3. Users may update data via mail@dephan.com (subject: “Updating Personal Data”).
8.4. Processing duration aligns with purposes or legal requirements.
8.5. Third-party services (e.g., payment systems) governed by their policies.
8.6. Exceptions for public interest cases.
8.7. Confidentiality ensured.
8.8. Storage limited to necessary periods.
8.9. Termination upon goal achievement, consent expiration, or unlawful processing.
9. Actions Performed by the Operator
9.1. Collection, recording, systematization, storage, clarification, use, transfer, anonymization, blocking, deletion, destruction.
9.2. Automated processing with/without IT network transmission.
10. Cross-Border Data Transfer
10.1. Notify authorized bodies prior to cross-border transfers.
10.2. Obtain required information from foreign recipients beforehand.
11. Confidentiality
The Operator and authorized parties must not disclose data without consent, unless legally mandated.
12. Final Clauses
12.1. Inquiries: mail@dephan.com.
12.2. Policy updates effective immediately upon publication.
12.3. Current version available at http://dephan.com/policy.
This Personal Data Processing Policy (hereinafter — the "Policy") is formulated in compliance with the requirements of Federal Law No. 152-FZ dated July 27, 2006, "On Personal Data" (hereinafter — the "Personal Data Law") and establishes the procedure for processing personal data and the security measures implemented by DEFAN LLC (hereinafter — the "Operator").
1.1. The Operator prioritizes the observance of human and civil rights and freedoms when processing personal data, including the protection of privacy, personal, and family confidentiality, as a fundamental condition of its operations.
1.2. This Policy applies to all information obtained by the Operator about visitors to the website https://www.dephan.com.
2. Key Definitions Used in the Policy
2.1. Automated Processing of Personal Data: Processing using computer technologies.
2.2. Blocking of Personal Data: Temporary suspension of processing (except where necessary to clarify data).
2.3. Website: A collection of graphical, informational materials, software, and databases accessible at https://www.dephan.com.
2.4. Personal Data Information System: A set of personal data databases and technologies enabling their processing.
2.5. Anonymization of Personal Data: Actions rendering data unidentifiable without additional information.
2.6. Processing of Personal Data: Any operation(s) performed on personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, or destruction.
2.7. Operator: A state/municipal authority, legal entity, or individual organizing and/or executing data processing, including defining its purposes and scope.
2.8. Personal Data: Any information directly or indirectly identifying a User of https://www.dephan.com.
2.9. Personal Data Permitted for Dissemination: Data disclosed to an unlimited audience by the subject’s consent under the Personal Data Law.
2.10. User: Any visitor to https://www.dephan.com.
2.11. Provision of Personal Data: Disclosure to specific individuals.
2.12. Dissemination of Personal Data: Disclosure to an indefinite audience (e.g., media, online networks).
2.13. Cross-Border Transfer of Personal Data: Transfer to foreign states, authorities, or entities.
2.14. Destruction of Personal Data: Irreversible deletion making recovery impossible.
3. Operator’s Rights and Obligations
3.1. Rights:
- Obtain accurate data/documents from the subject.
- Continue processing after consent withdrawal if lawful under the Personal Data Law.
- Determine necessary measures to comply with legal obligations.
- Provide processing-related information upon request.
- Organize processing per Russian legislation.
- Respond to subjects’ inquiries lawfully.
- Disclose information to authorized bodies within 10 days.
- Publish this Policy openly.
- Implement legal, organizational, and technical safeguards.
- Terminate processing/destroy data as required by law.
4. Rights and Obligations of Personal Data Subjects
4.1. Rights:
- Request processing details (excluding data of others).
- Demand correction, blocking, or destruction of inaccurate data.
- Impose prior consent for marketing purposes.
- Withdraw consent or demand termination of processing.
- Appeal unlawful actions to authorized bodies/courts.
- Provide accurate information.
- Notify the Operator of data updates.
5. Principles of Personal Data Processing
5.1. Lawful and fair basis.
5.2. Limited to predefined, legitimate purposes.
5.3. Prohibition of incompatible database merging.
5.4. Processing only relevant data.
5.5. No excess beyond stated purposes.
5.6. Ensure accuracy, sufficiency, and relevance.
5.7. Storage only as long as necessary.
6. Purposes of Processing
6.1. Purpose: User communication via email.
- Data: Email, name, company.
- Legal Basis: Operator’s statutory documents; agreements.
- Processing Types: Collection, storage, anonymization, emails.
- Data: Email, name, company.
- Legal Basis: Operator’s statutory documents; agreements.
- Processing Types: Collection, storage, anonymization, emails.
7. Processing Conditions
7.1. Subject’s consent.
7.2. Legal obligations under Russian/international law.
7.3. Judicial/executive proceedings.
7.4. Contract fulfillment or initiation.
7.5. Operator’s legitimate interests (without infringing rights).
7.6. Publicly accessible data.
7.7. Mandatory disclosure per law.
8. Data Handling Procedures
8.1. Security measures against unauthorized access.
8.2. No third-party transfer except for legal compliance or contractual obligations.
8.3. Users may update data via mail@dephan.com (subject: “Updating Personal Data”).
8.4. Processing duration aligns with purposes or legal requirements.
8.5. Third-party services (e.g., payment systems) governed by their policies.
8.6. Exceptions for public interest cases.
8.7. Confidentiality ensured.
8.8. Storage limited to necessary periods.
8.9. Termination upon goal achievement, consent expiration, or unlawful processing.
9. Actions Performed by the Operator
9.1. Collection, recording, systematization, storage, clarification, use, transfer, anonymization, blocking, deletion, destruction.
9.2. Automated processing with/without IT network transmission.
10. Cross-Border Data Transfer
10.1. Notify authorized bodies prior to cross-border transfers.
10.2. Obtain required information from foreign recipients beforehand.
11. Confidentiality
The Operator and authorized parties must not disclose data without consent, unless legally mandated.
12. Final Clauses
12.1. Inquiries: mail@dephan.com.
12.2. Policy updates effective immediately upon publication.
12.3. Current version available at http://dephan.com/policy.
© 2025 DEPHAN LLC.
ALL RIGHTS RESERVED.
ALL RIGHTS RESERVED.
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