This Policy defines the procedure and conditions for the processing of personal data, establishes provisions aimed at compliance with the legislation of the United Arabic Emirates concerning the processing of personal data.
All issues related to the processing of personal data that are not regulated by this Policy are resolved in accordance with the current legislation of the United Arabic Emirates in the field of personal data.
1. DEFINITION OF TERMS
1.1. Personal data (PD) – any data relating to an identified natural person, or a natural person who can be identified, directly or indirectly, through the linking of data, by reference to an identifier such as his name, voice, image, identification number, online identifier, geographical location, or one or more physical, physiological, economic, cultural or social characteristics;
1.2. Controller - an establishment or natural person who has Personal Data and who, given the nature of his/her activity, specifies the method, criteria and purpose of Processing such Personal Data, whether individually or jointly with other persons or establishments.
1.3. Processing - any operation or set of operations which is performed on Personal Data using any electronic means, including Processing and other means. This process includes collection, storage, recording, organization, adaptation, alteration, circulation, modification, retrieval, exchange, sharing, use, or classification or disclosure of Personal Data by transmission, dissemination or distribution, or otherwise making it available, or aligning, combining, restricting, blocking, erasing or destroying Personal Data or creating models therefor.
1.4. Cross-Border Processing - dissemination, use, display, transmission, receipt, retrieval, sharing or Processing of Personal Data outside the territory of the State.
1.5. Cookies are files installed on the user's computer, phone, tablet or any other device in order to register his actions while browsing on the website. With the help of cookies, the server recognizes the browser used by the user, providing, for example, a registered user with access to areas and services without the need to register at each visit and remembering his preferences of language, country, etc. for future visits. Cookies are also used to calculate the audience and traffic parameters, track progress and the number of entries.
2. REGULATORY FRAMEWORK
When developing this Regulation, the requirements and recommendations of the following regulatory legal acts of the United Arabic Emirates were taken into account:
• Personal Data Protection Law
• Federal Decree Law No. 45 of 2021
• The Federal Law No. 15 of 2020 on Consumer Protection
• Data Protection Law, DIFC Law No 5 of 2020
3. GENERAL PROVISIONS
3.3. Processing is organized on the principles of:
• legality of the purposes and methods of processing personal data, integrity and fairness in the Operator's activities;
• the reliability of personal data, their sufficiency for the purposes of processing, the inadmissibility of processing personal data that are redundant in relation to the purposes stated when collecting personal data;
• processing only those personal data that meet the purposes of their processing. The processed personal data should not be redundant in relation to the stated purposes of their processing;
• compliance of the content and volume of the processed personal data with the stated purposes of processing;
• the inadmissibility of combining databases containing personal data, the processing of which is carried out for purposes incompatible with each other;
• ensuring the accuracy of personal data, their sufficiency, and, if necessary, relevance in relation to the purposes of personal data processing. The operator takes the necessary measures or ensures that they are taken to delete or clarify incomplete or inaccurate data;
• storing personal data in a form that allows you to identify the subject of personal data for no longer than the purposes of personal data processing require;
• ensuring the recording, systematization, accumulation, storage, clarification (updates, changes), extraction of personal data of citizens of the United Arabic Emirates using databases located on the territory of the United Arabic Emirates.
3.5. The site administration does not verify the accuracy of the personal data provided by the User of the Online Store website.
4. LIST OF PERSONAL DATA AND METHODS OF THEIR COLLECTION
NIKITA EFREMOV may collect the following personal information of website users using the appropriate forms:
• last name, first name, patronymic;
• phone number;
• email addresses (e-mail);
• date of birth;
• Credit card (PAN + CVV2) in accordance with PCI DSS standards or bank account number;
Only personal data that meets the purposes of their processing are subject to processing. The content and volume of the processed personal data correspond to the stated purposes of processing, redundancy of the processed data is not allowed.
Personal data is collected in the following ways:
Direct interaction. You can provide us with your personal data by posting them on our website. When a user visits a website, registers, makes an online order, contacts NIKITA EFREMOV or takes part in promotions, surveys.
All information collected using cookies does not imply identification of an individual. This information will not be transferred to third parties without authorization.
The data that is requested through the website is necessary to ensure proper user service. If the user does not provide the requested data, NIKITA EFREMOV does not guarantee that the information and services provided will fully meet the user's needs.
5. PURPOSES OF COLLECTING USER'S PERSONAL INFORMATION
We use your personal data only in cases provided for by law. As the main condition for processing your personal data, we use your consent to the processing of personal data.
In the case of receiving personal data through another channel, NIKITA EFREMOV will not process or use them for the purposes set out in the following section, except as provided by law.
We plan to use your personal data for the following purposes:
• in order to collect information about consumers of NIKITA EFREMOV products, consumers' opinions about NIKITA EFREMOV products, in particular about their quality;
• in order to disseminate information about NIKITA EFREMOV products;
• in order to inform participants about NIKITA EFREMOV products, as well as about events held and (or) organized by NIKITA EFREMOV;
• in order to serve customers, fulfill orders, provide answers to customer requests;
• in order to provide users with access to the NIKITA EFREMOV website (nikitaefremov.com /);
• in order to optimize the user's work with the NIKITA EFREMOV website (nikitaefremov.com /);
• in order to organize the purchase and delivery of goods on the NIKITA EFREMOV website (nikitaefremov.com /);
• in order to arrange a refund when buying goods on the NIKITA EFREMOV website (nikitaefremov.com /).
• in order to provide access to the user's account on the NIKITA EFREMOV website (nikitaefremov.com /)
6. METHODS AND TERMS OF PROCESSING PERSONAL INFORMATION
6.1. The processing of the User's personal data is carried out without time limit, in any legal way, including in personal data information systems using automation tools or without the use of such tools.
6.2. The User agrees that the Site Administration has the right to transfer personal data to third parties, in particular, courier services, postal organizations, telecommunication operators, solely for the purpose of fulfilling the User's order placed on the Website of the Online store of limited clothing for the whole NIKITA EFREMOV family, including the delivery of Goods.
6.3. The User's personal data may be transferred to the authorized state authorities of the United Arabic Emirates only on the grounds and in accordance with the procedure established by the legislation of the United Arabic Emirates.
6.4. In case of loss or disclosure of personal data, the Site Administration informs the User about the loss or disclosure of personal data.
6.5. The Site Administration takes the necessary organizational and technical measures to protect the User's personal information from unauthorized or accidental access, destruction, modification, blocking, copying, distribution, as well as from other illegal actions of third parties.
6.6. The Site Administration, together with the User, takes all necessary measures to prevent losses or other negative consequences caused by the loss or disclosure of the User's personal data.
7. OBLIGATIONS OF THE PARTIES
7.1. The User is obliged to:
7.1.1. Provide information about personal data necessary for using the Website of the online store.
7.1.2. Update, supplement the provided information about personal data in case of changes in this information.
7.2. The site administration is obliged to:
7.2.3. Take precautions to protect the confidentiality of the User's personal data in accordance with the procedure usually used to protect this kind of information in the existing business turnover.
7.2.4. To block personal data related to the relevant User from the moment of the request or request of the User or his legal representative, or the authorized body for the protection of the rights of personal data subjects for the period of verification, in case of identification of false personal data or illegal actions.
8. LIABILITY OF THE PARTIES
8.2. In case of loss or disclosure of Confidential Information, the Site Administration is not responsible if this confidential information:
8.2.1. Became public domain before its loss or disclosure.
8.2.2. It was received from a third party before it was received by the Site Administration.
8.2.3. Was disclosed with the consent of the User.
9. ORDER FOR THE PROCESSING OF PERSONAL DATA
NIKITA EFREMOV may entrust the processing of PD to third parties, subject to obtaining the consent of the PD subject, as well as in other cases provided for by the legislation of the United Arabic Emirates. NIKITA EFREMOV ensures that such an order complies with the requirements of the legislation on personal data to its content.
This may be required in order to supply and sell goods, make credit/debit card payments, check creditworthiness, collect debts, control to detect fraud, as well as to fulfill all obligations assumed to their customers.
NIKITA EFREMOV keeps records of all third parties who are being betrayed or who process PD on behalf of NIKITA EFREMOV.
When processing PD on behalf of NIKITA EFREMOV, the following conditions are met:
• Legal grounds for processing personal data by third parties;
• Third parties have assumed the obligation to ensure the security and confidentiality of personal data, as well as to apply legal, organizational and technical data protection measures.
NIKITA EFREMOV does not grant the right and in no other way gives permission to third-party service providers to use your personal data for their own purposes. NIKITA EFREMOV allows them to process your personal data strictly for certain purposes and in accordance with the instructions.
10. CROSS-BORDER DATA TRANSFER
Your personal data may be transferred outside the United Arabic Emirates. Personal data may be transferred to countries where the level of privacy protection, according to the legislation, may differ from the level provided in the United Arabic Emirates. Personal data may also be jointly processed by companies belonging to the NIKITA EFREMOV group located in different countries and third parties located in a different country.
NIKITA EFREMOV carries out cross-border transfer of personal data strictly in accordance with the requirements of current legislation.
11. PERSONAL DATA SECURITY
We have implemented measures to ensure the security of your personal data.
Third parties will process your personal data strictly in accordance with our instructions and in cases where they agree to maintain confidentiality when processing information and keep it safe.
We have implemented appropriate security measures to prevent accidental loss, use or availability of your personal data for unauthorized use, modification or disclosure. In addition, we restrict access to your personal data only to those employees, agents, contractors and other third parties who require it. They will process your personal data strictly in accordance with our instructions, and are obliged to respect the confidentiality of such data.
We have implemented procedures to deal with any suspected violations of personal data security requirements, and we will also notify you and any relevant regulatory authorities of such violations in cases where required by law.
12. STORAGE OF YOUR PERSONAL DATA
The storage of your personal data is carried out in a form that allows you to be identified, no longer than the purposes of their processing and the requirements of regulatory legal acts of the United Arabic Emirates related to the storage of documents require.
We will store your personal data only for as long as it is necessary to fulfill the purposes for which we collected it, including to meet any legal requirements, accounting or reporting requirements.
13. YOUR RIGHTS REGARDING PERSONAL DATA
You, as a subject of personal data, have the following rights with respect to your personal data:
• make a decision to provide your personal data to NIKITA EFREMOV and third parties and consent to their processing freely, of your own free will and in your own interest;
• withdraw your consent to the processing of personal data;
• receive information from NIKITA EFREMOV regarding the processing of their personal data by sending a corresponding request;
• require NIKITA EFREMOV to clarify personal data, block or destroy them if they are incomplete, outdated, inaccurate, illegally obtained or are not necessary for the stated purposes of processing;
• demand the termination of the processing of their personal data in order to promote goods, works and services on the market by making direct contacts with them using communication means;
• to object to a decision made solely on the basis of automated processing of personal data;
• appeal the actions or omissions of NIKITA EFREMOV to the authorized body for the protection of the rights of personal data subjects or in court if the personal data subject believes that NIKITA EFREMOV processes his personal data in violation of the requirements of the legislation of the United Arabic Emirates or otherwise violates his rights and freedoms;
• exercise other rights provided for by the legislation of the United Arabic Emirates.
14. USE OF OUR WEBSITE
Users agree to use the content of the Website properly and undertake to: (i) provide reliable and accurate information requested in the registration form or when placing an order, and ensure its relevance throughout the use of the Website; (ii) not to carry out activities that are prohibited, illegal or contrary to the principles of good faith and public order; (iii) not to publish content or propaganda of a racist, xenophobic or discriminatory nature with respect to race, gender, ideology and religion, as well as not to take actions in any way contrary to morality, public order, fundamental rights, civil liberties, honor, confidentiality or image of third parties and applicable law in general; (iv) not to damage the physical and logical systems of the Website or NIKITA EFREMOV suppliers or third parties, as well as not to introduce or distribute computer viruses on the network or any other physical or logical systems that may lead to the aforementioned damage; (v) not to use the content of the Website and the information contained therein information for sending advertisements or sending messages for any other commercial purpose, as well as not collecting or storing personal data of third parties; (vi) not attempt to access other users' email accounts and, if applicable, not attempt to use them, nor modify or forge their messages.
NIKITA EFREMOV reserves the right to make any changes to its Website at its sole discretion without prior notice, and may also change, delete or add content and services that are provided through this Website and the way they are presented or posted on the Website.
15. INTELLECTUAL AND INDUSTRIAL PROPERTY
All intellectual and industrial property rights to the Website and its content, including, as an example, images, sound, audio, video, design, texts, graphics, logos, icons, color combinations, structure, buttons, as well as software, trade names, trademarks, works, illustrations, photographs, technical drawings, and any other symbols for industrial and commercial use belong to NIKITA EFREMOV or its affiliated companies or third parties who have given proper permission for their placement on the Website.
Reproduction, distribution and public communication, including the provision of part or all of the content of the Website for commercial purposes, on any medium and using any technical means, is strictly prohibited without the permission of NIKITA EFREMOV.
Users agree to respect the intellectual and industrial property rights owned by NIKITA EFREMOV. Users can use the Website and its content for their own personal and private purposes. Any other use is prohibited, and for it the user must obtain the express written permission of NIKITA EFREMOV. Users are prohibited from deleting, modifying, circumventing or attempting to hack any security devices or security systems implemented on the Website.
16. LIABILITY ARISING FROM THE USE OF THE SITE
NIKITA EFREMOV is under no circumstances liable for damages of any kind that may result from such factors as, for example: errors or omissions in the content, unavailability of the Website or transmission of viruses or malicious software, despite the fact that the company has taken all technological measures to prevent this. Users may be redirected from the Website to third-party websites. Since the service provider does not have the ability to constantly monitor the content posted on its website by third parties, it cannot assume any responsibility in relation to the aforementioned content.
In any case, NIKITA EFREMOV declares that it will immediately remove any content that contradicts national and international legislation, morality or public order by immediately removing the redirect to the aforementioned website, and will report such content to the competent authorities.
NIKITA EFREMOV is not responsible for the stored information and content, including, for example, forums, chat rooms, blog generators, comments, social networks or any other means that allow third parties to publish content independent of the Website. Nevertheless, NIKITA EFREMOV is ready to cooperate with all users, authorities and law enforcement services, as well as to actively assist in the removal or blocking of any content that may affect or violate national or international legislation, the rights of third parties, the principles of morality or public order. If users believe that there is such content on the Website, we ask them to immediately inform the Website administrator about it.
The website has been reviewed and tested to ensure its proper functioning. In principle, its proper functioning can be guaranteed around the clock, 7 days a week, throughout the year. However, NIKITA EFREMOV cannot exclude the possible presence of programming errors or that access to the Website may be prevented by force majeure, natural disasters, industrial lawsuits or other circumstances.
Placing hyperlinks on third-party websites for commercial purposes that allow access to the Website is prohibited without the prior written permission of NIKITA EFREMOV. NIKITA EFREMOV is not responsible for the use or content of third-party websites that may be linked to the Website.
WHO USES THE INFORMATION STORED IN COOKIES?
The information stored in cookies from the Web is used by NE SHOE TRADING LLC, a company duly organized and existing under the laws of the UAE with its reg.nr. 1772128 registered at: UAE, Dubai, Mall of the Emirates, Al Barsha1, Unit J21C, 1st fl.
Email address: email@example.com
The information stored in cookies managed by third parties is used by external organizations, which is described in detail below.
WHY ARE COOKIES NOT USED ON THIS WEBSITE?
The cookies we use do not store confidential information identifying your identity, including your address, password, etc.
WHAT TYPE OF COOKIES DOES NIKITA EFREMOV USE?
The following are the types of cookies used on the NIKITA EFREMOV Website, depending on the use of these files, as well as on the organization that manages them (own and third-party cookies).
Performance Cookies These allow us to count the visits to the Web and traffic sources, quantify the number of users, and therefore measure and conduct statistical analysis on the use made by users.
Functional Cookies These allow you to access the service with predefined characteristics in accordance with a series of criteria, for example, the language, the type of browser used to access the service, the regional configuration where the service is being accessed from, etc.
Strictly Necessary Cookies These are necessary for the browsing and the optimal performance of our Web. For example, they make it possible to monitor the traffic and communication of data, access restricted areas, perform the purchasing procedure for an order, use security elements, store content in order to broadcast videos or share content via social networks.
Targeted Cookies These cookies store information on the behaviour of users obtained through their browsing on the Web so that we can show you advertising related to your browsing profile.
Social Media Cookies These consist of a series of social media services we have added to the webpage to allow you to share our content with your friends and networks.
First-party cookies These are cookies that are created or managed by NIKITA EFREMOV, with responsibility for the Web.
Third-party cookies These are cookies that are managed by service providers external to NIKITA EFREMOV. The third parties are listed in the "Set cookies" panel.
HOW TO DISABLE COOKIES IN THE MOST COMMONLY USED BROWSERS
In the settings of your web browser, you can allow, block or delete cookies installed on your computer. If you block them, some services that require their use may not be available to you.
18. STORAGE PERIOD
NIKITA EFREMOV Company stores personal data only for a period that is rationally necessary, taking into account the requirements to respond to emerging issues or solve problems, make improvements, activate its services and comply with the requirements of applicable legislation. This means that it can store personal data for a reasonable period of time, including after the interested party stops using NIKITA EFREMOV's services or stops using the WEBSITE. After this period, personal data in all NIKITA EFREMOV systems are blocked.
19. DISPUTE RESOLUTION
19.1. Before filing a lawsuit on disputes arising from the relationship between the User of the Online Store site and the Site Administration, it is mandatory to submit a claim (a written proposal for a voluntary settlement of the dispute).
19.2. The recipient of the claim within 30 calendar days from the date of receipt of the claim, notifies the applicant of the claim in writing about the results of the consideration of the claim.
19.3. If an agreement is not reached, the dispute will be referred to a judicial authority in accordance with the current legislation of the United Arabic Emirates.
20. ADDITIONAL TERMS