Privacy Policy
1. GENERAL PROVISIONS
1.1. This Policy sets out the procedure for processing and protecting the personal data of individuals (hereinafter, the “Users”) that the Operator may obtain when Users use the websites fenix-gsm.com and fenix-gsm.ru.
1.2. This Policy has been developed in accordance with Federal Law No. 152-FZ “On Personal Data” of 27 July 2006 (as amended in 2025) and constitutes the Operator’s policy on personal data processing within the meaning of Article 18.1 of that Law.
1.3. Personal data operator: the Site Administration. Contact for inquiries about personal data processing: admin@fenix-gsm.com
1.4. Consent to the processing of personal data is executed as a separate document, the Consent to the processing of personal data, and is not part of this Policy, any agreement or the offer.
2. PERSONAL DATA PROCESSED
2.1. The Operator may process the following User data:
- last name, first name, patronymic;
- email address;
- phone number;
- account login and password;
- Telegram ID (when an account is linked);
- data required to provide the services and configure the software (IP address, technical characteristics of the device, device identifiers);
- information about orders and payments (full bank card details are not stored);
- cookies and web analytics data (Yandex Metrica, etc.).
2.2. The Operator does not process special categories of personal data or biometric personal data. The Operator does not collect or store full bank card details: payments are processed by certified payment providers.
3. PURPOSES AND LEGAL GROUNDS FOR PROCESSING
3.1. Providing the services and performing the contract (the Public Offer). Legal ground: Article 6(1)(5) of Law No. 152-FZ (performance of a contract to which the data subject is a party).
3.2. Communicating with the User and sending confirmations and payment receipts. Legal ground: performance of the contract and the requirements of the laws of the Russian Federation.
3.3. Analytics of on-site activity and cookies used to improve the quality of the services. Legal ground: the User’s separate consent.
3.4. Compliance with the laws of the Russian Federation. Legal ground: the law.
4. PROCESSING PROCEDURE AND DATA PROTECTION
4.1. Processing is carried out by mixed means (automated and non-automated).
4.2. The recording, systematization, accumulation, storage, clarification and retrieval of personal data of citizens of the Russian Federation are carried out using databases located in the Russian Federation (Article 18(5) of Law No. 152-FZ). No cross-border transfer of personal data takes place.
4.3. Processing period: until the purposes of processing are achieved or until the User withdraws consent, unless a different period is established by law.
4.4. The Operator takes the necessary legal, organizational and technical measures to protect personal data against unauthorized access, destruction, modification, blocking and other unlawful actions, and maintains an incident (data breach) response procedure in accordance with the law.
5. PROCESSING BY THIRD PARTIES AND RECIPIENTS
5.1. The Operator may entrust the processing of personal data to third parties under a contract and subject to confidentiality (Article 6(3) of Law No. 152-FZ), to the extent necessary to fulfil an order:
- payment services, to process payments and refunds;
- parties that support the operation of the Site (hosting, technical support);
- web analytics services, limited to anonymized visit data.
5.2. The Operator does not sell personal data and does not transfer it to third parties for their own purposes, except where expressly required by law (upon requests from authorized public authorities).
6. RIGHTS OF THE DATA SUBJECT
6.1. The User has the right to: obtain information about the processing of their data; require the clarification, blocking or destruction of data that is incomplete, outdated, inaccurate or unlawfully obtained; withdraw consent to processing; and appeal the Operator’s actions to Roskomnadzor (the Russian data protection authority) or in court (Article 14 of Law No. 152-FZ).
6.2. To exercise these rights or to withdraw consent, the User sends a request to admin@fenix-gsm.com. The procedure for withdrawing consent and its consequences are set out in the Consent to the processing of personal data.
7. COOKIES AND ANALYTICS
7.1. The Site uses cookies and web analytics services to ensure the operation of the Site and improve the quality of the services. By continuing to use the Site, the User agrees to the use of cookies. The User can disable cookies in the browser settings.
8. CHANGES TO THIS POLICY
8.1. The Operator may amend this Policy. The current version is always published on this page and takes effect upon publication.