Stargift

    Privacy Policy

    PERSONAL DATA PROCESSING POLICY OF STARGIFT

    Edition dated 28.05.2026

    1. General Provisions

    1.1. This Personal Data Processing Policy (hereinafter — the "Policy") is developed by Individual Entrepreneur Vashik Agasievich Martirosyan (the "Stargift" brand) in compliance with clause 2 of part 1 of Article 18.1 of Federal Law No. 152-FZ of 27.07.2006 "On Personal Data" (hereinafter — the "Personal Data Law"), taking into account the specifics of the Operator's activity: retail and corporate sale of VIP gifts, artworks signed by celebrities, original art objects and gift certificates via the website https://stargift.ru/ and three physical galleries in Moscow — "Vremena Goda" (Kutuzovsky Avenue), "Gimeney" (Pokrovka Street), and Dream House (Dream House Shopping Mall).

    The Operator is registered in the Registry of Operators processing personal data, maintained by the Federal Service for Supervision of Communications, Information Technology and Mass Media (Roskomnadzor), under registration number 77-25-281902. The registry entry is available at: https://pd.rkn.gov.ru/operators-registry/operators-list/?id=77-25-281902.

    Date when the Operator commenced processing of personal data: 28.12.2006 (consistent with the registry of operators). Termination condition: cessation of the Operator's activities (liquidation, reorganization).

    1.2. This Policy applies to the following categories of personal data subjects whose data is processed by the Operator in the course of its activity:

    • retail clients — individuals placing orders via the website cart, by phone, through messengers or directly at Stargift galleries;
    • representatives of corporate clients — employees of legal entities applying for corporate gifts, sets, event organisation and gift selection via the "For Business" form;
    • the Operator's counterparties — artists, authors of art objects, autograph authentication experts, restorers, suppliers, courier and logistics partners;
    • gift recipients — third parties to whom a retail or corporate client addresses a gift with delivery (the customer provides the recipient's name and address);
    • participants of events held at the "Vremena Goda", "Gimeney" and Dream House galleries (presentations, meetings with artists, private viewings);
    • subjects contacting the Operator via website forms (callback, "Ask a Question", Premium/VIP consultation, "For Business", "For Interior", "Gift Selection"), as well as via WhatsApp (Wazzup24 integration), the Telegram bot @stargiftgallerybot, e-mail info@stargift.ru and phone +7 495 233-51-11;
    • subjects submitting requests, complaints, queries and claims to the Operator, including those related to the purchase of artworks and the issuance of autograph authenticity certificates.

    1.3. Key terms used in the Policy:

    Personal Data — any information relating directly or indirectly to an identified or identifiable natural person (the subject of personal data).

    Personal Data Operator (Operator) — Individual Entrepreneur Vashik Agasievich Martirosyan (INN 771573239771, OGRNIP 306770000570551), operating under the "Stargift" brand;

    Website — a set of computer programmes and other information contained in the Stargift information system, accessible via the internet at: https://stargift.ru/, including all subdomains, the client personal account, the CRM interface for employees, and Stargift's official accounts in Telegram, VKontakte and WhatsApp.

    1.4. Main rights and obligations of the Operator.

    1.4.1. The Operator has the right to:

    • independently determine the composition and list of measures necessary and sufficient to ensure fulfilment of the obligations stipulated by the Personal Data Law and related regulations, unless otherwise provided by the Personal Data Law or other federal laws;
    • entrust the processing of personal data to another party with the consent of the personal data subject, unless otherwise provided by federal law, on the basis of an agreement concluded with such party (hosting provider, payment service, telecom operator, etc.);
    • in case the personal data subject withdraws consent, the Operator may continue processing without consent on the grounds set out in part 2 of Article 9 and part 5 of Article 21 of the Personal Data Law (performance of contract, protection of the rights and legitimate interests of the Operator, requirements of accounting and tax legislation).

    1.4.2. The Operator is obliged to:

    • provide the Subject with information about the processing of their personal data upon request;
    • use personal data exclusively for the purposes specified in this Policy — sale of goods, fulfilment of orders, issuance of authenticity certificates, organisation of events, CRM communication, accounting and tax reporting;
    • maintain the confidentiality of personal data, not disclose it to third parties or distribute it without the Subject's consent, except as expressly provided by law;
    • take legal, organisational and technical measures to ensure the confidentiality and security of personal data (storage of databases on Beget LLC servers in the Russian Federation, role-based access control for employees in CRM, secure HTTPS connection, action logging in crm_activity_log);
    • block personal data relating to the relevant Subject from the moment of the Subject's request or that of their legal representative for the period of verification;
    • clarify personal data in case of confirmed inaccuracy;
    • cease processing personal data or ensure its cessation and destroy the personal data within thirty days from the date of achieving the processing purpose, subject to mandatory retention periods established by accounting and tax legislation.

    1.5. Main rights of personal data Subjects. The personal data Subject has the right to:

    • receive information regarding the processing of their personal data, except in cases provided by federal laws;
    • demand that the Operator clarify, block or destroy the subject's personal data if they are incomplete, outdated, inaccurate, unlawfully obtained, or no longer necessary for the stated purpose of processing;
    • lodge an appeal with Roskomnadzor or a court against unlawful actions or inaction of the Operator in the processing of their personal data.

    The personal data Subject may exercise their rights by contacting the Operator at the e-mail address vashik@stargift.ru

    1.6. Compliance with this Policy and organization of personal data processing is carried out by Vashik Agasievich Martirosyan (vashik@stargift.ru), appointed as the person responsible for organizing personal data processing in accordance with Article 22.1 of the Personal Data Law. The Operator may, by internal order, designate additional persons responsible for organizing personal data processing in respect of specific activities; information about such persons is provided to the Subject upon request.

    1.7. Liability for violation of the requirements of the legislation of the Russian Federation and the Operator's local acts in the area of personal data processing and protection is determined in accordance with the legislation of the Russian Federation.

    2. Principles of Personal Data Processing

    2.1. Personal data processing is carried out by the Operator in accordance with the requirements of the legislation of the Russian Federation and on the basis of the following principles:

    • lawfulness and fairness;
    • limitation of personal data processing to specific, predetermined and lawful purposes (order fulfilment, certificate issuance, event organisation, accounting);
    • prevention of personal data processing incompatible with the purposes of collection (for example, corporate clients' data is not used for retail mailings without separate consent);
    • prevention of combining databases containing personal data processed for purposes incompatible with each other;
    • processing only such personal data as corresponds to the purposes of processing;
    • correspondence of the content and volume of personal data processed to the stated purposes;
    • prevention of processing of excessive personal data in relation to the stated purposes (Stargift does not request passport details when placing a delivery order unless this is required by the delivery service or payment provider);
    • ensuring the accuracy, sufficiency and relevance of personal data in relation to the processing purposes;
    • destruction or de-identification of personal data upon achievement of the processing purposes or upon loss of the need to achieve them.

    3. Legal Grounds for Personal Data Processing

    3.1. The legal grounds for personal data processing comprise a set of regulatory legal acts, including:

    • the Constitution of the Russian Federation;
    • the Civil Code of the Russian Federation (in respect of retail purchase, supply and service contracts for event organisation);
    • the Tax Code of the Russian Federation;
    • Federal Law No. 402-FZ of 06.12.2011 «On Accounting» (regarding the retention of primary accounting documents — cash, settlement, invoice and other records related to the performance of contracts with Buyers — for 5 years);
    • Federal Law No. 54-FZ of 22.05.2003 "On the Use of Cash Registers" (in connection with fiscal receipt issuance via YooKassa) and other regulatory legal acts governing relations connected with the Operator's activity.

    3.2. The legal grounds for personal data processing also include:

    • retail purchase, supply and service contracts concluded by Stargift with the personal data Subject (including via placing an order through the website cart or signing an invoice-contract at the gallery);
    • consent of the personal data Subject to the processing of personal data, expressed by filling in forms on the Stargift website, registering a personal account or sending an enquiry through any of the communication channels.

    By filling in the cart, callback, Premium/VIP consultation, "For Business", "For Interior", "Gift Selection" or "Ask a Question" forms, and by initiating correspondence with Stargift via WhatsApp, Telegram, e-mail info@stargift.ru or phone, the User of the Website expresses, by way of implied actions, their consent to the processing of personal data in accordance with this Policy.

    3.3. The Subject's consent to the processing of personal data is recorded by the Operator at the moment the form is submitted on the Website, with the date and time of consent, the Subject's IP address and browser identifier (User-Agent). This data is stored in the system consent log table together with the personal data record and serves as confirmation of consent in accordance with part 4 of Article 9 of the Personal Data Law. For enquiries received via WhatsApp (Wazzup24) and the Telegram bot @stargiftgallerybot, the fact of the Subject initiating the dialogue and subsequently providing personal data in the correspondence is recognised as confirmation of consent.

    4. Purposes and Conditions of Personal Data Processing

    4.1. Personal data processing is limited to the achievement of specific, predetermined and lawful purposes related to the sale of VIP gifts, artworks, certificates and Stargift services. Personal data processing incompatible with the purposes of collection is not permitted.

    4.2. The content and volume of personal data processed must correspond to the stated processing purposes. The Operator does not request information from Subjects that is not necessary for order fulfilment, certificate issuance, event organisation or CRM communication.

    4.3. In accordance with this Policy, the Operator processes personal data belonging to the following categories of personal data Subjects:

    • retail clients of Stargift;
    • representatives of corporate clients of Stargift;
    • counterparties of the Operator (artists, autograph authentication experts, restorers, suppliers, courier services);
    • recipients of gifts and services, including participants of events at the "Vremena Goda", "Gimeney" and Dream House galleries;
    • subjects filling in feedback forms on the Stargift website (callback, "Ask a Question", Premium/VIP, "For Business", "For Interior", "Gift Selection");
    • subjects seeking consultation via WhatsApp (Wazzup24), the Telegram bot @stargiftgallerybot, e-mail info@stargift.ru, phone +7 495 233-51-11 or in person at the galleries;
    • subjects submitting requests, complaints, queries and claims to the Operator, including those concerning autograph authenticity certificates and artworks.

    4.3.4. Stargift Retail Clients and Representatives of Corporate Clients

    4.3.4.1. The Operator processes personal data for the purpose of preparing, concluding and performing retail purchase and supply contracts for VIP gifts, artworks, original art objects, gift certificates and sets, as well as related services (delivery, packaging, issuance of autograph authenticity certificates, organisation of events at Stargift galleries).

    4.3.4.2. Processing of personal data is necessary for performance of a contract to which the personal data subject is a party (part 2 of Article 6 of the Personal Data Law). The client's personal data reaches the Operator in one of the following ways: placing an order via the website cart (`/cart/`), registering a client personal account, contacting via website forms, correspondence on WhatsApp/Telegram, a phone call, or a personal visit to the "Vremena Goda" gallery (Kutuzovsky Avenue), "Gimeney" gallery (Pokrovka Street) or Dream House gallery (Dream House Shopping Mall).

    Separate consents are obtained from clients in the following cases:

    • publication of customer reviews bearing the client's name in Stargift's public materials and social media;
    • sending of advertising and information messages about new arrivals at Stargift, gallery events, personalised offers and gift certificates.

    4.3.4.3. For the purposes of concluding and performing the contract, the Operator processes the following categories of personal data:

    • surname, first name, patronymic of the client and the payer; the name of the gift recipient if the order is placed for a third party;
    • contact telephone number, including the recipient's telephone for delivery coordination;
    • e-mail address, delivery address (street, building, flat, postcode, city), delivery comments;
    • messenger identifiers and messages (WhatsApp via Wazzup24, Telegram @stargiftgallerybot), client portal credentials (e-mail and password hash), `sg_client_token` authorization token (30-day lifetime), order history, message history with Stargift managers.

    4.3.4.4. The Operator does not process biometric personal data of clients. Certificates of authenticity issued by the Operator with the Goods describe the characteristics of the Goods themselves (artwork, autograph, author's piece) and do not contain photographs, images or other identifying information about the Buyer.

    4.3.4.5. The Operator does not process special categories of personal data.

    4.3.4.6–4.3.4.10. Clients' personal data are processed for the duration of contractual obligations and retained for the periods established by law (see clause 5.3.1). The Operator performs automated processing via Stargift CRM, non-automated processing (paper records in galleries) and mixed processing. Disclosure of personal data to third parties without the client's consent is not permitted, except for transfers to the contractors listed in clause 4.5 of this Policy and cases provided for by law. No cross-border transfer of personal data is carried out.

    4.3.5. Counterparties of the Operator (artists, experts, restorers, suppliers, courier partners)

    4.3.5.1. The Operator processes counterparties' personal data for the purpose of fulfilling obligations under contractual or other civil-law relationships: purchase of artworks and art objects from artists, engagement of experts for the authentication of celebrity autographs, restoration of collection items, organisation of deliveries to Stargift clients, holding of events at the galleries.

    4.3.5.3. The Operator processes the following categories of counterparties' personal data:

    • surname, first name, patronymic (for self-employed persons and sole proprietors — also INN and banking details);
    • contact telephone number;
    • e-mail address, address for receipt/shipment of goods;
    • name/identifier in messengers and social networks, correspondence with Stargift managers.

    4.3.5.4–4.3.5.10. Biometric and special categories of data are not processed. Storage for the term of the contract and 5 (five) years after its termination in accordance with Article 29 of Federal Law No. 402-FZ. Disclosure to third parties without consent is not permitted. Cross-border transfer is not carried out.

    4.3.6. Recipients of Stargift Services (Including Participants of Gallery Events)

    4.3.6.1. The Operator processes personal data for the purpose of providing related services — organisation and holding of events at Stargift galleries located at: "Vremena Goda" gallery (Kutuzovsky Avenue, Moscow), "Gimeney" gallery (Pokrovka Street, Moscow), Dream House gallery (Dream House Shopping Mall, Moscow) — including presentations of new arrivals, meetings with artists, private viewings, corporate events, as well as collecting feedback from gift recipients and event participants to improve the quality of service.

    4.3.6.2. Processing of personal data of service recipients and event participants is carried out subject to obtaining the Subject's prior consent (upon registration for an event or upon the customer's provision of recipient data when sending a gift — in the latter case, responsibility for obtaining the third party's consent rests with the customer, in accordance with clause 5.2 of this Policy).

    4.3.6.3. Categories processed: surname, first name, patronymic, contact telephone, e-mail address, delivery address (for gift recipients), the fact of attending an event at a specific Stargift gallery, preferences regarding event topics (optional).

    4.3.6.4–4.3.6.10. Biometric and special categories of data are not processed. Storage for the period necessary to perform obligations to the service recipient and thereafter for the periods established by legislation. Disclosure to third parties without consent is not permitted. Cross-border transfer is not carried out.

    4.3.7. Subjects Filling in Feedback Forms on the Stargift Website

    4.3.7.1. Purpose of processing: establishing and maintaining communication between the Subject and the Operator, sending messages, notifications, queries and replies in respect of enquiries received via the following website forms: the callback form (FloatingContact / callback), the "Ask a Question" form in the website footer, the Premium/VIP consultation form (`/vip/`), the "For Business" form (`/for-business/` — corporate enquiries and gift sets), the "For Interior" form (`/for-interior/` — space decoration), the "Gift Selection" form (`/podarok/...` — individual selection), as well as dialogues initiated by the Subject via WhatsApp (Wazzup24), the Telegram bot @stargiftgallerybot, e-mail info@stargift.ru and phone +7 495 233-51-11.

    4.3.7.2. Processing is carried out subject to obtaining prior consent, expressed by submitting the relevant form or initiating a dialogue. Consent is recorded in accordance with clause 3.3 of this Policy.

    4.3.7.3. Categories processed: surname, first name, patronymic (if provided), contact telephone, e-mail address, identifier in messengers and social networks, text of the enquiry, context of the enquiry (form type, website page, budget/parameters of the request in the "For Business", "For Interior" and "Gift Selection" forms).

    4.3.7.3.1. When subscribing to Stargift push notifications, the Operator processes the browser's push subscription identifier (endpoint), required for delivering notifications about new arrivals and gallery events. The subscription may be revoked by the Subject in the browser settings at any time.

    4.3.7.4–4.3.7.10. Biometric and special categories of data are not processed. Storage for the period specified in clause 5.3.1. Disclosure to third parties without consent is not permitted. Cross-border transfer is not carried out.

    4.3.8. Subjects Submitting Requests, Complaints, Queries and Claims to Stargift

    4.3.8.1. Purpose of processing: consideration and execution of requests, complaints, queries and claims, including those relating to the quality of artworks, authenticity of autographs, issuance of authenticity certificates, fulfilment of orders and the work of Stargift galleries.

    4.3.8.3. Categories processed: surname, first name, patronymic, contact telephone, e-mail address, identity document data (only when necessary for considering the enquiry — for example, to confirm the fact of purchase), identifier in messengers and social networks, text of the enquiry, attached materials (photos, copies of receipts, certificates).

    4.3.8.4–4.3.8.10. Biometric and special categories of data are not processed. Enquiries and related correspondence are stored for 3 (three) years from the date of completion of the enquiry consideration for the purposes of confirming the Operator's compliance with consumer protection legislation. Disclosure to third parties without consent is not permitted. Cross-border transfer is not carried out.

    4.4. Cookies and Their Use

    4.4.1. The Operator uses cookies for:

    • analysing visits to the Stargift website and user behaviour in the catalogue;
    • developing the website's content strategy and forming personalised gift selections;
    • optimising and developing the website functionality, including the cart, personal account and CRM employee interface;
    • ensuring the security of users' personal data and secure authorisation.

    De-identified technical cookies collect statistical information about website visits; users remain anonymous.

    4.4.2. The Stargift website uses, in particular, the following cookies: `sg_client_token` — client authorisation token in the personal account (30-day lifetime, httpOnly), `PHPSESSID` — Stargift employees' CRM session cookie (lifetime — browser session, extended up to 30 days during active CRM work), technical localisation cookies (website language choice: Russian, English, Chinese, Arabic), and web analytics counter cookies.

    4.4.3. Upon the first visit to the website, the user is informed about the use of cookies. The user is entitled to give consent or to refuse by disabling cookies in browser settings. Disabling cookies may make personal account authorisation and order placement impossible.

    Cookies are small text files saved on the user's device by the website; they are NOT malicious.

    4.4.4. The Stargift website has a Yandex.Metrica web analytics counter installed (ID 107719775) to collect de-identified visit statistics. The data is processed by Yandex LLC in accordance with Yandex's Privacy Policy and stored on the territory of the Russian Federation. Other foreign web analytics systems (Google Analytics, Facebook Pixel, etc.) are not used by the Operator.

    4.5. Recipients of Personal Data

    4.5. To achieve the purposes specified in this Policy, the Operator entrusts the processing of personal data to the following parties, which are residents of the Russian Federation:

    • Beget LLC (hosting provider — hosting of the stargift.ru website, MySQL databases and web infrastructure on servers in the Russian Federation);
    • YooMoney NBCO LLC / YooKassa LLC (acceptance of payments for Stargift orders and fiscalisation of receipts in accordance with Federal Law No. 54-FZ);
    • Wasap24 LLC (Wazzup24 — integration of the Stargift CRM with the WhatsApp and Telegram messengers for processing client enquiries);
    • Yandex LLC (Yandex.Metrica — de-identified web analytics; Yandex.OAuth — authorisation of Stargift employees in the CRM; Yandex.Calendar — synchronisation of manager reminders via CalDAV).

    Cross-border transfer of personal data is not carried out by the Operator. All Stargift databases containing personal data of citizens of the Russian Federation are hosted on Beget LLC servers located on the territory of the Russian Federation. Foreign cloud providers (Supabase, Firebase, AWS, Vercel, Cloudflare for personal data storage, etc.) are not used by the Operator.

    4.6. Employees of the Operator performing processing

    4.6.1. In addition to delegating processing to the external contractors listed in clause 4.5, processing of personal data is also performed by employees of the Operator within their employment duties. Employees are not independent personal data operators; they act as persons performing processing on behalf of the Operator in accordance with Part 3 of Article 6 of the Personal Data Law, and separate registration of each such employee in the Roskomnadzor registry of operators is not required by law.

    4.6.2. Internal persons performing processing on behalf of the Operator include:

    • Stargift managers handling client communications via CRM, telephone, e-mail and messengers (WhatsApp, Telegram);
    • directors of the «Vremena Goda», «Gimenei» and Dream House galleries, providing client reception and on-site service;
    • couriers and delivery staff who receive the recipient's name, delivery address and contact phone number to the extent strictly necessary to fulfil the Order;
    • Operator's personnel processing primary accounting documentation for transactions in connection with accounting and tax obligations.

    4.6.3. All employees of the Operator with access to personal data sign a non-disclosure undertaking covering personal data, complete training on personal data handling rules, and bear responsibility for violations in accordance with Russian Federation law and the Operator's internal acts. Employee access to the Stargift CRM is granted on a role-based model (owner / admin / director / manager / staff), technically limiting each employee's access to the data scope necessary for their job duties.

    5. Procedure for Collecting and Storing Personal Data

    5.1. When collecting personal data, the Operator ensures the recording, systematisation, accumulation, storage, clarification and extraction of personal data of citizens of the Russian Federation using MySQL databases located on Beget LLC servers in the Russian Federation (the `stargift_catalog` database).

    5.2. Persons who have transferred to the Operator information about another Subject without that Subject's consent (including customers specifying the data of a gift recipient) bear liability in accordance with the legislation of the Russian Federation and are obliged to independently obtain the third party's consent to transfer their personal data to the Operator.

    5.3. The Operator stores personal data in a form allowing the Subject to be identified no longer than required by the purposes of processing and the mandatory retention periods established by legislation.

    5.3.1. Specific personal data retention periods at Stargift:

    • data received via the Stargift website feedback forms (callback, "Ask a Question", Premium/VIP, "For Business", "For Interior", "Gift Selection"), WhatsApp/Telegram correspondence and e-mail enquiries — until withdrawal of consent by the Subject, but no longer than 3 (three) years from the moment of receipt;
    • client data within the performance of retail sale and supply contracts — for the duration of the contract and 5 (five) years after its termination in accordance with Article 29 of Federal Law No. 402-FZ «On Accounting» (with respect to primary accounting documents related to the transaction);
    • data whose processing is required for compliance with tax legislation — for the periods established by the Tax Code of the Russian Federation;
    • the record of consent (date, IP, User-Agent, source — the specific Stargift form or communication channel) — for the period of storage of the relevant personal data.

    5.4. Processed personal data is subject to destruction in case of:

    • expiry of the personal data processing period set out in clause 5.3.1;
    • achievement of the personal data processing purposes;
    • loss of the need to achieve the processing purposes;
    • receipt of withdrawal of consent to personal data processing (subject to clause 7.5);
    • exclusion of the Operator (Individual Entrepreneur V. A. Martirosyan) from the Unified State Register of Individual Entrepreneurs.

    6. Protection of Personal Data

    6.1. The Operator takes the necessary legal, organisational and technical measures to protect Stargift personal data against unlawful or accidental access, destruction, alteration, blocking, distribution and other unauthorised actions, including:

    • identifying threats to personal data security when processed in the Stargift CRM and on the stargift.ru website;
    • adopting local regulatory acts and other documents governing relations in the field of personal data processing and protection;
    • appointing persons responsible for ensuring personal data security and applying role-based access control for gallery staff and CRM managers (owner, admin, director, manager, staff);
    • storing personal data under conditions ensuring their safety and excluding unlawful access: secure HTTPS connection, httpOnly authorisation cookies, action logging in the `crm_activity_log`, regular database backups.

    7. Update, Correction, Deletion and Destruction of Personal Data

    7.1. Confirmation of the fact of personal data processing is provided to the Subject upon application or receipt of a request. The request is sent to the Operator at the e-mail address vashik@stargift.ru and must contain:

    • the number of the main identity document of the Subject, information about the date of issue and the issuing authority;
    • information confirming the Subject's relationship with the Operator (Stargift order number, date of purchase in a gallery, e-mail or phone used in the inquiry);
    • signature of the personal data Subject or their representative.

    7.2. In case of detection of inaccurate personal data, the Operator blocks the data for the verification period and clarifies it within seven working days.

    7.3. In case of detection of unlawful processing, the Operator blocks the unlawfully processed personal data.

    7.4. Upon achievement of the processing purposes or revocation of consent, personal data are subject to destruction, unless otherwise required by contract or law (in particular, 402-FZ regarding primary accounting documentation).

    7.5. Consent to processing of personal data may be revoked by sending a written request to vashik@stargift.ru, indicating the Subject's full name, contact details (phone / e-mail / Stargift order number) used for processing, and the demand to revoke consent. Within 30 (thirty) calendar days from receipt of the request, the Operator ceases processing and destroys the corresponding personal data, **except for data whose processing is required to fulfill the Operator's obligations under the Tax Code of the Russian Federation, Federal Law No. 402-FZ of 06.12.2011 «On Accounting», Part 5 of Article 21 of the Personal Data Law (protection of the rights and legitimate interests of the Operator and third parties), and to perform contractual obligations**. The list of retained personal data, the legal basis for retention and the maximum retention period are recorded by the Operator in the Subject requests registry and are provided to the Subject upon a reasoned request. The fact of the revocation request, the date of the request and the substance of the demands are retained by the Operator for 3 (three) years from the date of receipt to demonstrate the Operator's compliance with personal data legislation.

    8. Final Provisions

    8.1. The Operator is entitled to send the Subject advertising and information messages about new arrivals at Stargift, events at the "Vremena Goda", "Gimeney" and Dream House galleries and personalised offers only subject to prior consent. The Subject is entitled at any time to opt out of receiving such messages by contacting the e-mail address vashik@stargift.ru

    8.2. The Operator informs personal data subjects of changes to this Policy by publishing a new edition at https://stargift.ru/privacy/ with the edition date indicated in the document header.

    8.3. The place of expression of consent and the place of performance of the Policy is always the Operator's location (city of Moscow, Russian Federation), and the applicable law is the law of the Russian Federation, regardless of the location of the personal data Subject. All disputes and disagreements are resolved at the Operator's location, unless otherwise provided by law.