Privacy Policy

Last updated: May 14, 2025

Personal Data Processing Policy

1. General Provisions

This personal data processing policy has been developed in accordance with the requirements of the European Law “On the Protection of Personal Data” (hereinafter referred to as the Personal Data Law) and defines the procedures for processing personal data and the measures to ensure the security of personal data undertaken by GallaPlast OÜ (hereinafter referred to as the Operator).

1.1. The Operator considers the most important goal and condition for conducting its activities to be the observance of the rights and freedoms of individuals and citizens during the processing of their personal data, including the protection of the right to privacy, personal and family secrets.

1.2. This Operator’s policy regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator may obtain about visitors to the website https://gallaplast.com/.

2. Key Concepts 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 in cases where processing is necessary to clarify personal data).

2.3. Website — a collection of graphic and informational materials, as well as computer programs and databases that ensure their availability on the internet at the network address https://gallaplast.com/.

2.4. Personal data information system — a set of personal data contained in databases and the information technologies and technical means that ensure their processing.

2.5. Depersonalization of personal data — actions that result in the inability to determine, without the use of additional information, the ownership of personal data by a specific User or other personal data subject.

2.6. Processing of personal data — any action (operation) or set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (update, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.

2.7. Operator — a state body, municipal body, legal entity, or individual that independently or jointly with other persons organizes and/or carries out the processing of personal data, as well as determines the purposes of processing personal data, 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://gallaplast.com/.

2.9. Personal data permitted by the personal data subject for dissemination — personal data to which an unlimited circle of persons has been granted access by the personal data subject by giving consent to the processing of personal data permitted for dissemination in the manner provided by the Personal Data Law (hereinafter referred to as personal data permitted for dissemination).

2.10. User — any visitor to the website https://gallaplast.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 aimed at disclosing personal data to an unlimited circle of persons (transfer of personal data) or at familiarizing an unlimited circle of persons with personal data, including publication of personal data in the mass media, placement on information and telecommunication 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 state authority, foreign individual, or foreign legal entity.

2.14. Destruction of personal data — any actions as a result of which personal data is irretrievably destroyed, making it impossible to restore the content of personal data in the personal data information system and/or the material carriers of personal data are destroyed.

3. Main Rights and Obligations of the Operator

3.1. The Operator has the right:

— to obtain accurate information and/or documents containing personal data from the personal data subject;

— in case of withdrawal of consent by the personal data subject to the processing of personal data, as well as the submission of a request to terminate the processing of personal data, the Operator may continue processing personal data without the consent of the personal data subject if there are grounds specified in the Personal Data Law;

— to independently determine the composition and list of measures necessary and sufficient to fulfill the obligations provided 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.

3.2. The Operator is obliged:

— to provide the personal data subject with information regarding the processing of their personal data upon request;

— to organize the processing of personal data in accordance with the legislation of the European Union;

— to respond to requests and inquiries from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;

— to report to the authorized body for the protection of personal data subjects’ rights upon request of that body with the necessary information within 10 days from the date of receipt of such request;

— to publish or otherwise ensure unrestricted access to this Policy regarding the processing of personal data;

— to 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 other unlawful actions with personal data;

— to cease the transfer (dissemination, provision, access) of personal data, cease processing, and destroy personal data in the manner and cases provided by the Personal Data Law;

— to fulfill other obligations provided by the Personal Data Law.

4. Main Rights and Obligations of Personal Data Subjects

4.1. Personal data subjects have the right:

— to obtain information regarding 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 should not contain personal data relating to other personal data subjects, except in cases where there are lawful grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;

— to demand that the operator clarify their personal data, block or destroy it if the personal data is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, as well as to take measures provided by law to protect their rights;

— to set the condition of prior consent for the processing of personal data for the purpose of promoting goods, works, and services on the market;

— to withdraw consent to the processing of personal data, as well as to submit a request to terminate the processing of personal data;

— to appeal to the authorized body for the protection of personal data subjects’ rights or to the court regarding unlawful actions or inaction by the Operator in processing their personal data;

— to exercise other rights provided by the legislation of the European Union.

4.2. Personal data subjects are obliged:

— to provide the Operator with accurate data about themselves;

— to inform the Operator about the clarification (update, change) of their personal data.

4.3. Persons who have provided the Operator with inaccurate information about themselves or information about another personal data subject without the latter’s consent shall be liable in accordance with the legislation of the European Union.

5. Principles of Personal Data Processing

5.1. Processing of personal data is carried out on a lawful and fair basis.

5.2. Processing of personal data is limited to achieving specific, predefined, and lawful purposes. Processing of personal data incompatible with the purposes of collecting personal data is not permitted.

5.3. Combining databases containing personal data processed for purposes incompatible with each other is not permitted.

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 correspond to the stated purposes of processing. Excessiveness of processed personal data in relation to the stated purposes of processing is not permitted.

5.6. When processing personal data, the accuracy of the personal data, its sufficiency, and, where necessary, its relevance in relation to the purposes of processing personal data are ensured. The Operator takes necessary measures and/or ensures their implementation to remove or clarify incomplete or inaccurate data.

5.7. Storage of personal data is carried out in a form that allows identifying the personal data subject, no longer than required by the purposes of processing personal data, unless the storage period for personal data is established by federal law, a contract, of which the personal data subject is a party, beneficiary, or guarantor. Processed personal data is destroyed or depersonalized upon achieving the purposes of processing or in case of loss of necessity for achieving these purposes, unless otherwise provided by law.

6. Purposes of Personal Data Processing

Purpose of Processing	Providing the User with access to services, information, and/or materials contained on the website
Personal Data	Email address, name, company name
Legal Grounds	Personal Data Protection Law
Types of Personal Data Processing	Collection, recording, systematization, accumulation, storage, destruction, and depersonalization of personal data

7. Conditions for Processing Personal Data

7.1. Processing of personal data is carried out with the consent of the personal data subject to the processing of their personal data.

7.2. Processing of personal data is necessary to achieve the purposes provided by an international treaty of the Russian Federation or law, for the exercise of functions, powers, and duties imposed on the operator by the legislation of the Russian Federation.

7.3. Processing of personal data is necessary for the administration of justice, the execution of a judicial act, an act of another body or official, subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.

7.4. Processing of personal data is necessary for the performance of a contract, of which the personal data subject is a party, beneficiary, or guarantor, as well as for the conclusion of 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. Processing of personal data is necessary for the exercise of the rights and legitimate interests of the operator or third parties or for achieving socially significant goals, provided that this does not violate the rights and freedoms of the personal data subject.

7.6. Processing of personal data is carried out, to which an unlimited circle of persons has been granted access by the personal data subject or at their request (hereinafter referred to as publicly available personal data).

7.7. Processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.

8. Procedure for Collection, Storage, Transfer, and Other Types of Personal Data Processing

The security of personal data processed by the Operator is ensured by implementing legal, organizational, and technical measures necessary to fully comply with the requirements of current legislation in the field of personal data protection.

8.1. The Operator ensures the preservation of personal data and takes all possible measures to exclude access to personal data by unauthorized persons.

8.2. The personal data of the User will never, under any circumstances, be transferred to third parties, except in cases related to the execution of current legislation or if the personal data subject has given consent to the Operator to transfer data to a third party for the performance 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 info@gallaplast.com with the subject line “Personal Data Update.”

8.4. The processing period for personal data is determined by the achievement of the purposes for which the personal data was collected, unless a different period is provided by a contract or current legislation. The User may at any time withdraw their consent to the processing of personal data by sending a notification to the Operator’s email address info@gallaplast.com with the subject line “Withdrawal of Consent to 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 persons (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject and/or with the aforementioned documents. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this clause.

8.6. Prohibitions on the transfer (except for providing access), processing, or conditions of processing (except for obtaining access) of personal data permitted for dissemination, established by the personal data subject, do not apply in cases of processing personal data in state, public, and other public interests as defined by law.

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 personal data subject, no longer than required by the purposes of processing personal data, unless the storage period for personal data is established by federal law, a contract, of which the personal data subject is a party, beneficiary, or guarantor.

8.9. A condition for the termination of personal data processing may be the achievement of the purposes of processing personal data, the expiration of the consent of the personal data subject, the withdrawal of consent by the personal data subject or a request to terminate the processing of personal data, as well as the detection of unlawful processing of personal data.

9. List of Actions Performed by the Operator with Obtained Personal Data

9.1. The Operator carries out collection, recording, systematization, accumulation, storage, clarification (update, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.

9.2. The Operator carries out automated processing of personal data with the receipt and/or transmission of the obtained information via information and telecommunication networks or without such.

10. Cross-Border Transfer of Personal Data

10.1. The Operator must notify the authorized body for the protection of personal data subjects’ rights of its intention to carry out cross-border transfer of personal data before commencing such activities (such notification is sent separately from the notification of intent to process personal data).

10.2. Before submitting the aforementioned notification, the Operator must obtain relevant information from the foreign state authorities, foreign individuals, or foreign legal entities to which the cross-border transfer of personal data is planned.

11. Confidentiality of Personal Data

The Operator and other persons who have gained access to personal data are obliged not to disclose to third parties or disseminate personal data 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 regarding issues related to the processing of their personal data by contacting the Operator via email at info@gallaplast.com.

12.2. Any changes to the Operator’s personal data processing policy will be reflected in this document. The Policy remains in effect indefinitely until replaced by a new version.

12.3. The current version of the Policy is freely available on the internet at https://gallaplast.com/en/privacy-policy/.