PRIVACY AND PERSONAL DATA PROCESSING POLICY

(as amended on April 2, 2020)

1. GENERAL PROVISIONS

1.1. This Privacy and Personal Data Processing Policy (hereinafter referred to as the Privacy Policy) applies to all information that the FASHION HOUSE Outlet Center Sheremetyevo website, located at fashionhouseoutlet.com (and its subdomains), may receive about the User during their use of the fashionhouseoutlet.com Website (and its subdomains), its programs, and its products (hereinafter referred to as the Website), as well as in other cases provided for in this Privacy Policy. 1.2. This Privacy Policy has been developed taking into account the provisions of current Russian Federation legislation, including in accordance with the requirements of Federal Law No. 152-FZ of July 27, 2006, "On Personal Data," and defines the procedure for processing personal data and measures to ensure the security of personal data when processed by the Operator. 1.3. Use of the Website by the User constitutes their full and unconditional consent to this Privacy Policy and the terms of processing the User's personal data.
1.4. If the User disagrees with the terms of the Privacy Policy, they must stop using the Website. If the User is already or plans to become a member of the Operator's loyalty programs, they must cancel their registration and participation in such loyalty programs.
1.5. The Operator and the Website Administration do not control and are not responsible for third-party websites that the User may access via links available on the FASHION HOUSE Outlet Center Sheremetyevo website, nor for goods purchased and paid for by the User using the Website and/or by clicking on links to third-party websites.
1.6. The Operator and the Website Administration do not verify the veracity of the personal data provided by the User. All responsibility for the veracity of such data, including the provision of inaccurate data by the User, as well as the provision by the User of personal data of third parties (personal data other than the User's own data), lies entirely with the User.

2. TERMS AND DEFINITIONS

2.1. The following terms and definitions are used in this Privacy and Personal Data Processing Policy:
2.1.1. The Personal Data Operator or Operator is HF HOLDING MOSCOW LIMITED, a limited liability company incorporated under the laws of the Republic of Cyprus under registration number NE 206400, operating through its branch in the Russian Federation (a branch of HF HOLDING MOSCOW LIMITED), Republic of Cyprus, located in the Russian Federation at the following address: 141580, Moscow Region, Solnechnogorsk microdistrict, rural settlement Lunevskoye, in the area of ​​the village of Chernaya Gryaz, ul. Torgovoy-Promyshlennaya, building No. 6 B, premises No. 88, accreditation record number (NZA): 1127747052971, taxpayer identification number (TIN) 9909312300, independently or jointly with other persons, organizing and/or processing the personal data of Website Users, as well as determining the purposes of personal data processing, the composition of personal data subject to processing, and actions (operations) performed with personal data.
2.1.2. Website Administration (hereinafter referred to as the Administration) – employees authorized to manage the Website, acting on behalf of the Operator.
2.1.3. Personal data - any information relating directly or indirectly to an identified or identifiable individual (personal data subject).
2.1.4. Personal data processing - any action (operation) or set of actions (operations) performed with or without the use of automated means with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
2.1.5. Automated processing of personal data - the processing of personal data using computer technology;
2.1.6. Blocking of personal data - the temporary cessation of the processing of personal data (except in cases where processing is necessary to clarify the personal data);
2.1.7. Anonymization of personal data — actions that make it impossible to determine the attribution of personal data to a specific User or other personal data subject without the use of additional information;
2.1.8. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific group of persons;
2.1.9. Dissemination of personal data — any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or making personal data available to an unlimited number of persons, including disclosing personal data in the media, posting it on information and telecommunications networks, or providing access to personal data in any other way;
2.1.10. Cross-border transfer of personal data — the transfer of personal data to the territory of a foreign state to a government body of a foreign state, a foreign individual, or a foreign legal entity;
2.1.11. Destruction of personal data – any action resulting in the irreversible destruction of personal data, making it impossible to restore the contents of the personal data in the personal data information system, and/or the destruction of tangible media containing the personal data.
2.1.12. Confidentiality of personal data – a mandatory requirement for the Operator or other person who has access to personal data to prevent its dissemination without the consent of the personal data subject or other legal grounds.
2.1.13. The Website is a collection of interconnected web pages, graphic and informational materials, as well as computer programs and databases, located on the Internet at a unique address (URL): fashionhouseoutlet.com, as well as its subdomains.
2.1.14. Subdomains are pages or sets of pages located on third-level domains belonging to the Website, as well as other temporary pages, at the bottom of which the Operator's contact information is indicated.
2.1.15. Website User or User – an individual who accesses the Website via the Internet and uses the information, materials, and products of the Website.
2.1.16. Cookies are small pieces of data sent by a web server and stored on the User's computer. The web client or web browser sends these cookies to the web server in an HTTP request each time it attempts to open a page on the corresponding website.
2.1.17. IP address — the unique network address of the node in a computer network through which the User accesses the Website.
2.1.18. Product — the product that the User orders on the Website and pays for through payment systems.

3. SUBJECT OF PRIVACY POLICY

3.1. This Privacy Policy sets forth the obligations of the Operator, the Administration, and any third parties engaged by the Operator to process Users' personal data to maintain confidentiality and ensure the protection of the privacy of personal data provided by the User upon registration on the Website, in the Loyalty Program, by subscribing to an email newsletter, or by placing an order.
3.2. Personal data permitted for processing under this Privacy Policy is provided by the User by completing registration forms on the Website, including in its various sections, and include the following information:
• the User's last name, first name, and patronymic (if any and if necessary);
• the User's contact phone number;
• email address;
• date of birth (if necessary);
• the User's actual residential address (if necessary);
• the Goods delivery address (if necessary).
The term "necessity" in relation to the provision of the individual data or information specified above means the provision of such data and information in cases where the registration forms on the Site require the provision of such data and information, marked as mandatory with the special symbol "*".
The above data is hereinafter collectively referred to as "Personal Data."
3.3. The Website also collects and processes anonymized data about visitors (including cookies) using internet statistics services (including Yandex Metrica, Google Analytics, and others).
3.3. The Website may also process other data (both personalized and, in some cases, potentially considered personal data, and non-personalized data) that is automatically transferred to the Operator and the Website Administration when the User visits the Website pages, including:
- IP address;
- cookie information;
- browser information;
- access time;
- referrer (address of the previous page);
- Website visit history;
- operating systems used by the User's devices when visiting the Website.
3.3.1. Disabling cookies may prevent access to parts of the Website that require authorization. 3.3.2. The Website collects statistics on the IP addresses of its visitors. This information is used to prevent, detect, and resolve technical problems. 3.3.3. Any such data will also be securely stored and will not be distributed, except as provided in paragraphs 5.2 and 5.3 of this Privacy Policy.

4. PURPOSES OF PROCESSING USERS' PERSONAL DATA AND OTHER INFORMATION

4.1. Персональные данные Пользователя могут использоваться Оператором и Администрацией Сайта в целях:
4.1.1. Identifying the User registered on the Website for subsequent authorization, order placement, and other actions.
4.1.2. Providing the User with access to services, information, and/or materials contained on the Website, including personalized Website data.
4.1.3. Establishing feedback with the User, including sending notifications and requests regarding the use of the Fashion House Outlet Center Moscow Website, the provision of services, and the processing of requests and applications from the User.
4.1.4. Determining the User's location to ensure security, prevent fraud when placing orders through the Website, and to generate personalized offers.
4.1.5. Confirming the accuracy and completeness of the personal data provided by the User.
4.1.6. Creating an account to use parts of the Fashion House Outlet Center Moscow Website, if the User has consented to the account creation by submitting registration forms through the Website in the cases provided for this purpose.
4.1.7. Notifying the User via email, SMS messages (in cases expressly provided for this in other documents posted on the Website), and push notifications.
4.1.8. Providing the User with effective technical support in the event of problems related to the use of the Website.
4.1.9. Fulfilling the User's order placed on the Website, including delivery of the Product and/or documentation, including with the involvement of third parties.
4.1.10. Including the User in loyalty programs announced through the Website in accordance with the rules of such programs, incl. To enable Users to take advantage of the opportunities provided by participating in such programs.
4.1.11. Providing the User, with their consent, with special offers, pricing information, newsletters, information about various events held at the FASHION HOUSE Outlet Center, and other information.
The User may always opt out of receiving informational messages by sending an email to the Operator at promotions@fashionhouseoutlet.com with the subject line "Opt-out of notifications about new products and services and special offers," or, for email newsletters, by clicking the "Unsubscribe" link in the email.
4.2. The Operator, the Website Administration, and other third parties engaged by the Operator process the User's personal data only if the User independently completes and/or submits it through special (registration and other) forms located on the Website. By completing the appropriate forms and/or submitting their personal data through the Website, the User expresses their unconditional and irrevocable consent to this Privacy Policy.
4.3. Anonymized User data collected through internet statistics services is used to collect information about User actions on the Website and to improve the quality of the Website and its content. Anonymized User data is processed if permitted in the User's browser settings (cookies and JavaScript are enabled).

5. METHODS AND TERMS OF PERSONAL DATA PROCESSING.

5.1. The processing of the User's personal data, as well as other data specified in Section 3.3. of this Privacy Policy, is carried out indefinitely, by any legal means, including in personal data information systems, with or without the use of automated means.
5.2. The User agrees that the Operator has the right to transfer personal and other data to third parties, in particular, courier services, postal service organizations (including electronic postal services), and telecommunications operators, solely for the purpose of fulfilling the User's order placed on the Website, including the delivery of the Product and/or documentation, as well as for sending emails, SMS messages, and push notifications in cases provided for in this Privacy Policy. The Operator also has the right to engage and entrust the processing of the User's personal and other data to third parties for other purposes stipulated in Section 4 of this Privacy Policy, unless otherwise expressly prohibited by the current legislation of the Russian Federation.
5.3. The User's personal data may be transferred to authorized government bodies of the Russian Federation only on the grounds and in the manner established by Russian legislation.
5.4. The Operator takes the necessary organizational and technical measures to protect the User's personal and other data from unauthorized or accidental access, destruction, modification, blocking, copying, distribution, and other illegal actions by third parties.
5.5. The Operator, 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 and other data.

6. RIGHTS AND RESPONSIBILITIES OF THE PARTIES

6.1. The User has the right to:
6.1.1. Make a free decision to provide their personal data for the purposes specified in this Privacy Policy and consent to its processing.
6.1.2. Update or supplement the personal data provided should this information change. The User is aware and agrees that failure to provide such information or the late provision of such information by the User may directly affect their access to certain features of the Website or those provided through the Website, their ability to receive certain privileges under loyalty programs if the User is a member of such programs, and their ability to place orders for Products through the Website and their delivery. If inaccuracies in personal data are discovered or clarification is required due to changes, the User may update it independently through the Personal Account on the Website or by sending a notification to the Operator's email address promotions@fashionhouseoutlet.com with the subject "Updating personal data."
6.1.3. The User has the right to receive information from the Operator regarding the processing of their personal data, unless such right is limited in accordance with federal laws of the Russian Federation. The User has the right to request that the Operator clarify their personal data, block it, or destroy it if the personal data is incomplete, outdated, inaccurate, illegally obtained, or is not necessary for the stated purpose of processing, and also to take other measures to protect their rights as stipulated by current Russian legislation.
6.1.4. The User may revoke their consent to the processing of their personal data at any time by sending a notification to the Operator via email to promotions@fashionhouseoutlet.com with the subject line "Revocation of Consent to the Processing of Personal Data."
6.2. The User is obligated to:
6.2.1. When filling out any registration forms on the Website, provide only information that is directly relevant to the User, is accurate and complete, is not fictitious or borrowed, and is not current at the time of its entry in such forms;
6.2.2. Not provide the Operator with any data (including personal data) of third parties without their corresponding written consent, and without separately notifying the Operator that such data is the data of third parties.
6.2.3. Use the Site in good faith, without violating the laws of the Russian Federation, the rights and freedoms of third parties, or ethical, moral, and ethical standards. Refrain from insults, the use of obscene language, the production or dissemination of information containing calls for mass riots, extremist activity, participation in mass (public) events held in violation of established procedures, or the dissemination of information that could lead to the illegal acquisition of intellectual property.
6.3. The Operator is obliged to:
6.3.1. Use the information and data received solely for the purposes specified in Section 4 of this Privacy Policy.
6.3.2. Ensure the confidentiality of the User's personal data, and not disclose it without the prior written consent of the User, and not sell, exchange, publish, or otherwise disclose the User's personal data transferred, with the exception of Sections 5.2 and 5.3 of this Privacy Policy.
6.3.3. Take or ensure that necessary legal, organizational, and technical measures are taken to protect the confidentiality of personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, or distribution of personal data, as well as from other illegal actions in relation to personal data in accordance with the procedure generally applied to protect such information.
6.3.4. Block personal data related to the relevant User, from the moment of the User's request or appeal, or of their legal representative or authorized body for the protection of the rights of personal data subjects during the verification period, if inaccurate personal data or illegal actions are detected.

7. LIABILITY OF THE PARTIES

7.1. The Operator, if it fails to properly fulfill its obligations, shall be liable for any damages incurred by the User in connection with the unauthorized use of personal data, in accordance with the legislation of the Russian Federation, except for cases provided for in paragraphs 5.2, 5.3, and 7.2 of this Privacy Policy.
7.2. The User acknowledges that responsibility for any information (including, but not limited to, data files, texts, etc.) to which the User may have access as part of the Website lies with the person who provided such information.
7.3. The User agrees that any information provided to the User as part of the Website or in any other form (including through email newsletters, SMS newsletters, and/or push notifications) is intellectual property, the rights to which are protected and belong to the relevant copyright holders. The User may not modify, lease, loan, sell, distribute, or create derivative works based on such information (in whole or in part), unless such actions have been expressly permitted to the User in writing by the relevant copyright holders under separate agreements.
7.4. Distribution of text materials (articles, publications freely available to the public on the Website) is permitted provided that a link to the Website is provided, and provided that such distribution is carried out by the User in unchanged form (in the form in which such materials are posted on the Website) and not for commercial purposes (not for the purpose of deriving material profit from the distribution of such information).
7.5. The Website Operator and Administration shall not be liable for any direct or indirect damages caused to or incurred by the User as a result of the use or inability to use the Website or individual services, or as a result of participation or inability to participate in loyalty programs. Under no circumstances will the Website Operator or Administration be liable for the quality of Products ordered by the User through the Website. Such liability lies entirely with the manufacturers and sellers of such Products. The User acknowledges and agrees that the Website Operator and Administration are not the direct sellers of Products that Users can order or pre-order through the Website.
7.6. The Website Operator and Administration are not liable for any information posted by the User on or through the Website.

8. DISPUTE RESOLUTION

8.1. Before filing a claim in court regarding disputes arising from the relationship between the User and the Operator/Site Administration, it is mandatory to submit a claim (a written or electronic proposal for voluntary dispute resolution).
8.2. The recipient of the claim shall, within 30 calendar days from the date of receipt of the claim, notify the claimant in writing or electronically of the results of the claim review.
8.3. If no agreement is reached, the dispute may be referred to the Moscow Arbitration Court.
8.4. The current legislation of the Russian Federation applies to this Privacy Policy and the relationship between the User and the Operator.

9. OTHER CONDITIONS

9.1. The Operator reserves the right to unilaterally amend or supplement this Privacy Policy at any time without the consent or separate notice of the User. Any changes, including a new version of the Privacy Policy, will be posted on the Website. Amendments/additions, including a new version of the Privacy Policy, shall enter into force and be binding on all parties from the moment they are published on the Website.
The Operator and the Website Administration recommend that Users regularly check the terms of this Privacy Policy for changes and/or additions by independently familiarizing themselves with such changes/additions, including a new version of the Privacy Policy, on the Website. The User's continued use of the Website after changes and/or additions to this Privacy Policy have been made, including Submitting a new version of the Privacy Policy constitutes the User's unconditional acceptance and consent to such amendments and/or additions.
9.2. Any suggestions or questions regarding this Privacy Policy can be sent by email to the Operator at promotions@fashionhouseoutlet.com.
9.4. The current Privacy Policy is available at https://fashionhouseoutlet.com/confidentiality/confidentiality.php ;
9.5. All rights to the Website and the use of its network address (domain and subdomain names) belong to the Website Operator.
9.6. The Website may contain links to other websites on the Internet (third-party websites). The Operator and the Website Administration do not check the third parties listed above and their content for compliance with any requirements (accuracy, completeness, legality, etc.). The Operator and the Website Administration are not responsible for any information or materials posted on third-party websites accessed by the User through the Website, including any opinions or statements expressed on third-party websites, advertising, etc., nor for the availability of such websites or content or the consequences of their use by the User.
9.7. The Operator and the Website Administration do not guarantee that the Website meets the User's requirements or that access to the Website will be uninterrupted, fast, secure, or error-free. The parties agree that software and hardware errors, whether on the Operator's side, the Website Administration's side, or on the User's side, that result in the User's inability to access the Website constitute force majeure circumstances and grounds for exemption from liability.