1. General provisions and terms
The Policy applies to all personal data the data subject provides to the operator through site forms, messengers, phone calls, email, service bookings and other communication channels.
Personal data means any information relating directly or indirectly to an identified or identifiable individual. Such data may include name, phone number, email address, gender, date of birth and any other information you submit voluntarily.
If additional services, widgets or forms are connected, their use does not replace this Policy but supplements it to the extent it does not conflict with this document or applicable law.
2. Data we may collect
Through forms, messages, calls and other communication channels we may receive a name, phone number, email, gender, date of birth, request text, booking preferences, selected program, bonus or client flow data and any other information you submit yourself.
Technically, the site may record IP address, device type, browser, language, visit date and time, pages, cookies, on-site actions and other technical identifiers when needed for correct site operation and protection from errors, spam and abuse.
We do not request excessive information and do not intentionally process special categories of personal data unless such processing is required by law or separately agreed with the data subject.
3. Purposes and legal grounds
The usual grounds for processing are your consent, the need to perform your request or contract, and compliance with legal requirements.
When processing personal data, the operator follows the principles of lawfulness, fairness, minimization, purpose limitation, accuracy and avoiding excessive collection.
- feedback, consultation and request handling
- service booking, master selection, program selection and visit time arrangement
- customer support and loyalty or bonus flows
- site operation, saving preferences, protection from errors, spam and abuse
- compliance with legal requirements, contracts and other mandatory service rules
- meeting obligations required by law, contract or your request
4. How we process data
Processing may be automated or manual. Data may be stored and used through site forms, email, messengers, internal tables, backups and connected services.
We limit access to only the persons and services that actually need it for site operation, communication and service delivery.
If you include additional details in a request, we use them only to the extent needed to reply and fulfill the request. If necessary, data may be shared with contractors who help run the site, communication or request handling, but only within the scope of their task.
5. Storage periods and deletion
We keep data no longer than necessary to achieve the processing purpose, fulfill your request, provide the service or comply with legal and contractual requirements.
If data is no longer needed, we delete or anonymize it unless a longer retention period is required by law.
When retention is tied to a specific service or request, we may keep data until the request is closed and any mandatory legal retention period ends. After the purpose is achieved, the data is deleted or anonymized within a reasonable period.
6. Disclosure to third parties
Data may be shared only with contractors and services needed for the project: hosting, email, telephony, messengers, analytics, CRM and other connected tools.
If external widgets, maps, forms, video or analytics are connected, their own processing rules may supplement this policy.
Such services may process data under their own rules, so we recommend reviewing their policies and terms of use as well. If services with servers outside the Russian Federation are connected, cross-border transfer may occur to the extent needed for their operation.
7. Your rights
- receive information about the operator, contacts and requisites
- ask which data we store and how we use it
- request correction, update or deletion of data
- withdraw consent for processing and marketing messages
- request information about third-party transfers, if any
- contact the operator or the competent authority if you believe your rights are violated
8. Security and changes
We take organizational and technical measures to protect data from unauthorized access, alteration, disclosure and destruction.
We may update this policy if services, forms, processing methods or legal requirements change. The current version is always published on the site and applies from the moment it is posted unless otherwise stated.
For data-processing questions, contact the operator: ИП БЕЛЫХ НАТАЛЬЯ АНДРЕЕВНА, +7 999 032-36-17, efirspa@mail.ru, St. Petersburg, nab. Griboyedov Canal, 19, INN 5945078952, OGRN 3445985078952.
9. Final provisions
If any provision of this Policy conflicts with mandatory legal requirements, that provision applies only to the extent it does not conflict with the law, and the rest of the Policy remains valid.
This Policy applies to all versions of the site until a new version is published.
