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Privacy Policy (POLICY ON THE PROCESSING OF PERSONAL DATA)


This policy on the processing of personal data (hereinafter referred to as the "Policy") is drafted in accordance with the requirements of Federal Law No. 152-FZ dated July 27, 2006, "On Personal Data" (hereinafter referred to as the "Personal Data Law") and defines the procedure for processing personal data and the measures taken to ensure the security of personal data by Little Big People LLC (hereinafter referred to as the "Operator").
The Operator reserves the right to make changes to this Policy. When changes are made, the date of the last update is indicated in the current version. The new version of the Policy comes into force from the moment it is published, unless otherwise specified in the new version. The current version is always available on the Operator's website at: www.peekabooorganic.com.
KEY DEFINITIONS

1.1. Automated processing of personal data — the processing of personal data using computer technology.

1.2. Website — the website www.peekabooorganic.com, through which Little Big People LLC sells its goods/services.

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

1.4. Operator — the entity that processes personal data and determines the purposes of processing, the composition of personal data to be processed, and the actions (operations) performed with personal data. For the purposes of this Policy, the Operator of personal data is the owner of the Website — Little Big People LLC.

1.5. Personal data — any information relating directly or indirectly to an identified or identifiable individual (the "Data Subject").

1.6. User — any visitor to the Website.

1.7. Customer — an individual who purchases goods or services on the Website.

1.8. Data Subject — an individual who is directly or indirectly identified or identifiable using Personal Data.

1.9. Cross-border transfer of personal data — the transfer of personal data to the territory of a foreign state to a foreign government authority, foreign individual, or foreign legal entity.


KEY RIGHTS AND OBLIGATIONS OF THE OPERATOR

2.1. The Operator has the right to:

— Receive from the Data Subject accurate information and/or documents containing Personal Data;
— Independently determine the composition and list of measures necessary and sufficient to fulfill the obligations stipulated by the Personal Data Law and related regulatory legal acts, unless otherwise provided by the Personal Data Law or other legal acts;
— Continue processing personal data without the Data Subject's consent if there are grounds specified in the Personal Data Law, in case the Data Subject withdraws consent or requests the termination of processing.

2.2. The Operator is obliged to:

— Provide the Data Subject, upon request, with information regarding the processing of their personal data;
— Organize the processing of personal data in accordance with the current legislation of the Russian Federation;
— Respond to inquiries and requests from Data Subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
— Provide the authorized body for the protection of Data Subjects' rights with the necessary information within 10 (ten) days of receiving such a request;
— Publish or otherwise ensure unrestricted access to this Policy;
— Take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision, or distribution, as well as from other unlawful actions;
— Terminate the transfer (distribution, provision, access) of personal data, cease processing, and destroy personal data in the cases and manner prescribed by the Personal Data Law;
— Fulfill other obligations stipulated by the Personal Data Law.


KEY RIGHTS AND OBLIGATIONS OF DATA SUBJECTS

3.1. Data Subjects have the right to:

— Obtain information regarding the processing of their personal data, except in cases provided by law. The information is provided by the Operator in an accessible form and must not contain personal data of other Data Subjects, unless there are legal grounds for disclosing such data;
— Request the Operator to clarify, block, or destroy their personal data if the data is incomplete, outdated, inaccurate, or unnecessary for the stated processing purposes, and take legal measures to protect their rights;
— Withdraw consent to the processing of personal data and submit a request to terminate processing;
— Appeal to the authorized body for the protection of Data Subjects' rights or to a court against unlawful actions or inaction of the Operator in processing their personal data;
— Exercise other rights provided by the legislation of the Russian Federation.

3.2. Data Subjects are obliged to:

— Provide the Operator with accurate information about themselves;
— Notify the Operator of any updates or changes to their personal data.

3.3. Individuals who provide the Operator with inaccurate information about themselves or about another Data Subject without the latter's consent bear full responsibility for the accuracy of such information.


PRINCIPLES OF PERSONAL DATA PROCESSING

4.1. The processing of personal data is carried out on a lawful and fair basis.

4.2. The processing of personal data is limited to achieving specific, predetermined, and lawful purposes. Processing of personal data incompatible with the purposes of collection is not permitted.

4.3. The merging of databases containing personal data processed for incompatible purposes is not allowed.

4.4. Only personal data that meets the purposes of processing is processed.

4.5. The content and scope of processed personal data correspond to the stated purposes of processing. Excessive processing of personal data relative to the stated purposes is not permitted.

4.6. The Operator ensures the accuracy, sufficiency, and, where necessary, the relevance of personal data in relation to the purposes of processing. The Operator takes necessary measures to delete or clarify incomplete or inaccurate data.

4.7. The retention period of personal data may not exceed what is required for the purposes of processing, unless a different period is established by federal law, contract, or agreement where the Data Subject is a party, beneficiary, or guarantor. Processed personal data is destroyed or anonymized upon achieving the purposes of processing or when such purposes are no longer necessary, unless otherwise provided by federal law.


LIST OF ACTIONS PERFORMED BY THE OPERATOR WITH PERSONAL DATA

5.1. The Operator performs the following actions with personal data: collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction.

5.2. The Operator carries out automated processing of personal data with or without the transmission of the obtained information via telecommunication networks.


6. COMPOSITION AND PURPOSES OF PROCESSING PERSONAL DATA

6.1. The User's personal data includes, but is not limited to, the following information: last name, first name, patronymic, date of birth, address, phone number, and email address.

6.2. The Operator processes personal data for the following purposes:

— Sale of goods and provision of services: last name, first name, patronymic, bank details, account number, payment amount and purpose, transaction date and time, delivery address, order number, contact phone number, email address, details of purchased goods, loyalty program membership number;
— Organization of order delivery services: last name, first name, patronymic, phone number, email address, order details, delivery address;
— Improving the Website, enhancing products and services, and determining User preferences: device IP address, device data (type, model, name, ID), operating system data (type, version), browser data (name, version), user location, clicks on webpage elements, website referral source, viewed pages, form field inputs (excluding information directly entered into these fields), banner and video views, audience segment parameters, session data, visit time, user identifiers stored in cookies.

6.3. The legal basis for processing Users' personal data is the User Agreement, consent to the distribution of personal data (where provided for in this Policy), and the Offer for the purchase of goods/provision of services.

6.4. The User agrees that for the stated processing purposes, the Operator may grant access to personal data to the following parties under confidentiality and security conditions:

— inSales Rus LLC (TIN 7714843760), the owner of the inSales platform hosting the Website;
— Transport companies, agents, assembly and courier delivery services, etc.

The User agrees that these parties process personal data in accordance with their own personal data processing policies.

6.5. The User consents to receiving additional information and newsletters at the email address and phone number provided during order placement. The information and newsletters may include order details and marketing materials.


PROCEDURE FOR COLLECTION, STORAGE, TRANSFER, AND OTHER FORMS OF PROCESSING PERSONAL DATA

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

The Operator ensures the confidentiality of personal data and takes all possible measures to prevent unauthorized access.

The User's personal data will never be disclosed to third parties, except as required by law or as provided for in this Policy.

If inaccuracies in personal data are identified, the User may update them independently by notifying the Operator via email at yo@peekabooorganic.com.

The User may withdraw consent to the processing of personal data at any time by notifying the Operator via email.

All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by these parties (Operators) in accordance with their User Agreements and Privacy Policies. The Operator is not responsible for the actions of these parties.

The Operator ensures the confidentiality of personal data during processing.

The processing of personal data may be terminated upon achieving the processing purposes, expiration of the Data Subject's consent, withdrawal of consent, or a request to terminate processing, as well as upon identifying unlawful processing.

9. The Operator and other parties with access to personal data are prohibited from disclosing or distributing personal data to third parties without the Data Subject's consent, unless otherwise provided by federal law.

7.10. In the case of cross-border transfer of personal data, the Operator ensures compliance with the requirements of Russian legislation.


8. FINAL PROVISIONS

8.1. The User may obtain clarification on any questions regarding the processing of their personal data by contacting the Operator via email at yo@peekabooorganic.com.

8.2. The current version of the Policy is freely available on the Internet at www.peekabooorganic.com.


9. CONTACTS

Seller: Little Big People LLC

Email: yo@peekabooorganic.com

Legal address: 127015, Moscow, Bolshaya Novodmitrovskaya St., 36, bldg. 12.

TIN: 7726732582

TRRC: 771501001

PSRN: 1137746984462

Bank Details

Bank: Tinkoff Bank JSC, Moscow

BIC: 044525974

Account: 40702810410000734991

Correspondent account: 30101810145250000974