Personal Data Processing Policy
Approved by T.V. Stepanova, General Director of EF GEF LLC.
St. Petersburg 07/07/2026
This privacy and personal data processing policy has been compiled in accordance with the requirements of the Federal Law of July 27, 2006. No. 152-FZ “On Personal Data” (hereinafter referred to as the Law on Personal Data) and determines the procedure for processing personal data and measures to ensure the security of personal data taken by EF GI EF LLC INN: 7801737783 (hereinafter referred to as the Operator).
1. General
1.1. The operator sets as its most important goal and condition for carrying out its activities the observance of the rights and freedoms of man and citizen when processing his personal data, including the protection of the rights to privacy, personal and family secrets.
1.2. This Operator’s policy regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator can receive about visitors to the website https://fgfmed.ru
2. Basic concepts used in the Policy
2.1. Automated processing of personal data - processing of personal data using computer technology.
2.2. Blocking of personal data is a temporary cessation of processing of personal data (except for cases where processing is necessary to clarify personal data).
2.3. Website - a collection of graphic and information materials, as well as computer programs and databases that ensure their availability on the Internet at the network address https://fgfmed.ru
2.4. Personal data information system is a set of personal data contained in databases and information technologies and technical means that ensure their processing.
2.5. Depersonalization of personal data - actions as a result of which it is impossible to determine without the use of additional information the ownership of personal data to a specific User or other subject of personal data.
2.6. Processing of personal data is any action (operation) or set of actions (operations) performed using automation tools or without using such tools with personal data, including collection, booking, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
2.7. Operator - a state body, municipal body, legal or natural person, independently or jointly with other persons organizing and (or) carrying out the processing of personal data, as well as determining the purposes of processing personal data, the composition of personal data to be processed, actions (operations) performed with personal data.
2.8. Personal data - any information relating directly or indirectly to a specific or identified User of the website https://fgfmed.ru
2.9. Personal data authorized by the subject of personal data for distribution - personal data, access to an unlimited number of persons to which is provided by the subject of personal data by giving consent to the processing of personal data authorized by the subject of personal data for distribution in the manner prescribed by the Law on Personal Data (hereinafter referred to as personal data permitted for distribution).
2.10. User - any visitor to the website https://fgfmed.ru
2.11. Providing personal data - actions aimed at disclosing personal data to a certain person or a certain circle of persons.
2.12. Dissemination of personal data - any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or to familiarize with personal data to an unlimited number of persons, including the publication of personal data in the media, posting in information and telecommunication networks or providing access to personal data in any other way.
2.13. Destruction of personal data - any actions as a result of which personal data are destroyed irrevocably with the impossibility of further restoration of the content of personal data in the personal data information system and (or) the material media of personal data are destroyed.
3. Basic rights and obligations of the Operator
3.1. The operator has the right:
3.1.1. receive from the subject of personal data reliable information and/or documents containing personal data;
3.1.2. if the subject of personal data withdraws consent to the processing of personal data, the Operator has the right to continue processing personal data without the consent of the subject of personal data if there are grounds specified in the Law on Personal Data;
3.1.3. independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of the obligations provided for by the Law on Personal Data and regulations adopted in accordance with it, unless otherwise provided by the Law on Personal Data or other federal laws.
3.2. The operator is obliged:
3.2.1. Comply with the principles of PD processing: legality, specific purposes, minimization of data composition, relevance and accuracy, limitation of storage periods, termination of processing and destruction/depersonalization when the goals are achieved or in the absence of grounds for further processing.
3.2.2. Ensure transparency and accessibility of information: place this Policy and other mandatory documents in public access, provide subjects with information about the processing and procedure for exercising their rights.
3.2.3. Obtain and record consent when processing is based on consent: ensure informed and specific consent, separate consents for purposes (including separately for online mailings; separately for photos/videos and “before/after” publication, if applicable), keep records of the fact of obtaining consents.
3.2.4. Process special categories of data (including health information) with increased requirements: do not collect excessive medical information through the site, limit processing to the necessary minimum for booking/feedback, ensure increased access and confidentiality.
3.2.5. Ensure the implementation of the rights of subjects: accept and consider requests (access, clarification, restriction, deletion, withdrawal of consent), respond within the time limits established by law, keep records of requests and measures taken.
3.2.6. Ensure the security of personal data: apply organizational and technical protection measures, differentiate access by role, ensure accounting of actions/accesses, backup, updating of security measures; conduct employee training.
3.2.7. Comply with localization requirements and exclude cross-border transfer if it is not actually carried out (and reflect this in documents); when using analytics and cookie services, provide notice and a separate Cookie Policy.
3.2.8. provide the subject of personal data, at his request, with information regarding the processing of his personal data;
3.2.9. organize the processing of personal data in the manner established by the current legislation of the Russian Federation;
3.2.10. respond to requests and inquiries from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
3.2.11. report to the authorized body for the protection of the rights of personal data subjects, at the request of this body, the necessary information within 30 days from the date of receipt of such a request;
3.2.12. publish or otherwise provide unrestricted access to this Policy regarding the processing of personal data;
3.2.13. take legal, organizational and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other unlawful actions in relation to personal data;
3.2.14. stop transfer (distribution, provision, access) of personal data, stop processing and destroy personal data in the manner and cases provided for by the Law on Personal Data;
3.2.15. perform other duties provided for by the Personal Data Law.
4. Basic rights and obligations of personal data subjects.
4.1. Subjects of personal data have the right:
4.1.1. receive information regarding the processing of his personal data, except for cases provided for by federal laws. The information is provided to the subject of personal data by the Operator in an accessible form, and it should not contain personal data relating to other subjects of personal data, except in cases where there are legal grounds for the disclosure of such personal data. The list of information and the procedure for obtaining it is established by the Law on Personal Data;
4.1.2. require the operator to clarify his personal data, block it or destroy it if the personal data is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing, as well as take measures provided by law to protect their rights;
4.1.3. put forward a condition of prior consent when processing personal data in order to promote goods, works and services on the market;
4.1.4. to withdraw consent to the processing of personal data;
4.1.5. appeal to the authorized body for the protection of the rights of personal data subjects or in court the unlawful actions or inaction of the Operator when processing his personal data;
4.1.6. to exercise other rights provided for by the legislation of the Russian Federation.
4.2. Subjects of personal data are obliged to:
4.2.1. Provide reliable and up-to-date personal data necessary for making an appointment, feedback and provision of services, as well as promptly report changes in such data.
4.2.2. Do not provide excessive personal data through forms on the Site (including do not indicate in free fields information that is not required for booking/feedback), unless this is due to the purpose of the request.
4.2.3. When applying in the interests of a third party (including a minor), confirm the existence of legal grounds to act on behalf of such person (as a legal representative/authorized person) and provide personal data only to the extent necessary for the purpose of the application.
4.2.4. Read this Policy and other posted documents regulating the processing of personal data and the use of cookies before sending data to the Operator through the Site.
4.2.5. When using the capabilities of the Site and communication channels, comply with the requirements of the law and not send information the distribution of which is prohibited, and also not take actions aimed at disrupting the operation of the Site.
4.2.6. If you identify errors in your personal data transferred to the Operator, contact the Operator with a request for clarification/updating, and, if necessary, with a request to withdraw consent or limit processing. Provide the Operator with reliable information about yourself;
4.2.7. Notify the Operator about clarification (updating, changing) of your personal data.
4.3. Persons who provided the Operator with false information about themselves or information about another subject of personal data without the latter’s consent are liable in accordance with the legislation of the Russian Federation.
5. The Operator may process the following personal data of the User.
5.1. Depending on the purposes of contacting, making an appointment, providing services and operating the Site, the Operator may process the following personal data of the User:
5.1.1. Identification and contact information: Last name, first name, patronymic (if available), date of birth (if necessary), telephone number, email address, residential/stay address (if necessary for the contract/documents).
5.1.2. Contact data and records: content of the request/application, selected service/specialist, desired date and time, history of requests and communications, results of processing the application (confirmation, transfer, cancellation).
5.1.3. Data of contracts and settlements (if applicable): details for drawing up contracts/acts/invoices, information about payment (fact of payment, amount, date, method). The operator does not process or store complete bank card data; payment processing is carried out by payment services (if used).
5.1.4. Technical data when visiting the Site (including cookies): P-address, information about the browser and device, date and time of access, addresses of pages visited, referral source, cookies, identifiers and other anonymized data necessary to ensure the operation of the Site, analytics and improve the quality of service (in accordance with the Cookie Policy). The conditions for using cookies, their categories, storage periods and methods of refusal/setting are defined in the “Cookie Policy”.
5.2. The Operator does not purposefully collect special categories of personal data (including health information) through the Site. At the same time, the User is recommended not to indicate information about health status and other special categories of personal data in forms on the Site. If such information is provided by the User on his own initiative, it is processed solely to consider the request and feedback.
5.3. Data on consents: the fact of provision and content of consent (for the processing of personal data, cookies, online newsletter - if any), the date and method of obtaining it, as well as information about the withdrawal of consent.
5.4. Data about the representative (if the User acts as a representative): full name of the representative, contact details, information and documents confirming authority (to the extent necessary for confirmation).
5.5. The Site also collects and processes anonymized data about visitors (including cookies, IP addresses, device and browser information, data about actions on pages) using the Yandex.Metrica Internet statistics service.
5.6. Processing of personal data permitted for distribution from among the special categories of personal data specified in Part 1 of Art. 10 of the Law on Personal Data is permitted if the prohibitions and conditions provided for in Art. 10.1 of the Personal Data Law.
5.7. The User’s consent to the processing of personal data permitted for distribution is issued separately from other consents to the processing of his personal data. In this case, the conditions provided for, in particular, Art. 10.1 of the Personal Data Law. Requirements for the content of such consent are established by the authorized body for the protection of the rights of personal data subjects.
5.8. The User provides consent to the processing of personal data permitted for distribution to the Operator directly.
5.9. The Operator is obliged, no later than three working days from the date of receipt of the specified consent of the User, to publish information about the conditions of processing, the existence of prohibitions and conditions for the processing of personal data permitted for distribution by an unlimited number of persons.
5.10. The transfer (distribution, provision, access) of personal data authorized by the subject of personal data for distribution must be stopped at any time at the request of the subject of personal data. This requirement must include the last name, first name, patronymic (if any), contact information (telephone number, email address or postal address) of the subject of personal data, as well as a list of personal data whose processing is subject to termination. The personal data specified in this requirement can only be processed by the Operator to whom it is sent.
5.11. Consent to the processing of personal data permitted for distribution terminates from the moment the Operator receives the request of the Personal Data Subject.
6. Principles for processing personal data.
6.1. The processing of personal data by the Operator is carried out on the basis of the following principles:
6.1.1. The legality and fairness of the processing of personal data in accordance with clause 1, part 1, art. 5 Federal Law 152;
6.1.2. Limitation of processing to specific, predetermined and legitimate purposes, inadmissibility of processing personal data incompatible with the purposes of collecting personal data.
6.1.3. Preventing the merging of databases containing personal data, the processing of which is carried out for purposes that are incompatible with each other.
6.1.4. Compliance of the content and volume of processed personal data with the stated purposes of processing; preventing the processing of personal data that is excessive in relation to the stated purposes of their processing.
6.1.5. Sufficiency and relevance of personal data in relation to the purposes of processing; taking the necessary measures (or ensuring their adoption) to delete or clarify incomplete or inaccurate data in accordance with clause 5, part 1, art. 5 FZ-152.
6.1.6. Limitation of periods for storing personal data: storage in a form that allows you to identify the subject of personal data, no longer than required by the purposes of processing, unless the storage period for personal data is established by federal law or an agreement; destruction or depersonalization of personal data upon achievement of the processing goals or in the event of loss of the need to achieve these goals, unless otherwise provided by federal law. In accordance with clause 6, part 1, art. 5 Federal Law-152; Part 4 Art. 21 FZ152.
6.1.7. Confidentiality of personal data: prevention of disclosure to third parties and dissemination of personal data without the consent of the subject of personal data, unless otherwise provided by federal law.
6.1.8. Ensuring the security of personal data: taking the necessary legal, organizational and technical measures (or ensuring their adoption) to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other unlawful actions in relation to personal data.
6.1.9. Compliance with the rights of personal data subjects and ensuring the possibility of exercising such rights, including providing information about processing, as well as fulfilling the legal requirements of personal data subjects.
6.2. In cases where the processing of personal data is carried out on the basis of the consent of the subject of personal data, the Operator ensures that the consent is specific, informed and conscious, and also ensures the possibility of its withdrawal by the subject of personal data.
6.3. The operator ensures the implementation of these principles by establishing internal procedures for processing personal data, determining the composition and timing of processing, limiting access to personal data, applying protection measures and monitoring compliance with the requirements of Federal Law-152.
6.4. If the purposes of processing, the composition of the processed personal data or the technologies used change, the Operator updates this Policy and other documents regulating the processing of personal data in the manner established by the Operator.
6.5. The storage of personal data is carried out in a form that makes it possible to identify the subject of personal data, no longer than required by the purposes of processing personal data, unless the period for storing personal data is established by federal law, an agreement to which the subject of personal data is a party, beneficiary or guarantor. The processed personal data is destroyed or anonymized upon achievement of the processing goals or in the event of the loss of the need to achieve these goals, unless otherwise provided by federal law.
7. Purposes of processing personal data.
7.1. The Operator processes the personal data of Users/Patients for the purposes necessary for the legal and high-quality provision of cosmetology (medical) services, ensuring the operation of the Site and fulfilling the obligations provided for by the legislation of the Russian Federation.
7.2. Processing of personal data is carried out for:
7.2.1. receiving and processing requests (applications) through the Website, telephone, instant messengers and other communication channels;
7.2.2. making appointments for consultations/procedures, confirming, rescheduling and canceling appointments;
7.2.3. feedback from the User/Patient on registration and treatment issues.
7.2.4. identifying the Patient and making an appointment;
7.2.5. registration and maintenance of medical/cosmetology documentation (including questionnaires, cards, informed consents, examination results and prescriptions);
7.2.6. conducting consultations, procedures, monitoring results, monitoring the quality and safety of services provided;
7.2.7. interaction with the Patient regarding treatment/procedures (reminders about visits, information about preparation, recommendations after the procedure - to the extent necessary for the provision of the service).
7.3. Processing of personal data for the conclusion and execution of contracts, settlements and accounting is carried out:
7.3.1. preparation, conclusion and execution of contracts for the provision of services;
7.3.2. registration of accounts, acts, cash documents and other primary documents;
7.3.3. carrying out calculations, accounting for payments, returns, reconciliations;
7.3.4. fulfillment of tax, accounting and other mandatory accounting requirements.
7.4. Processing of personal data to ensure the functioning and security of the Site, improving the quality of service is carried out for:
7.4.1. ensuring the correct operation of the Site, its security and prevention of abuse;
7.4.2. maintaining traffic statistics, analyzing user behavior, improving the interface and quality of service;
7.4.3. ensuring the operation of forms, booking services, widgets and other technical components of the Site.
7.5. Compliance with legal requirements and interaction with authorized bodies. Processing of personal data is carried out for:
7.5.1. compliance with the requirements of the legislation of the Russian Federation in the field of healthcare, consumer protection, accounting and tax accounting, archival storage;
7.5.2. consideration of appeals, claims and requests;
7.5.3. providing information upon legitimate requests from authorized bodies if there are legal grounds.
7.6. The processing of personal data for information and mailings is carried out with separate consent and is carried out for:
7.6.1. sending information messages about the work of the clinic (schedule changes, appointment confirmation, organizational notifications);
7.6.2. sending advertising/marketing messages about special offers, promotions and clinic news - only with separate consent to online mailing, with the possibility of refusal at any time.
7.7. Processing of personal data regarding the use of photo and video materials, portfolio “before/after” is carried out with separate consent and is carried out for:
7.7.1. carrying out photo/video recording of the results of procedures;
7.7.2. formation of a medical/cosmetology portfolio and quality control;
7.7.3. publication of materials (including “before/after”) on the Site/social networks - only with separate consent indicating the purposes, terms and methods of use.
8. Legal grounds for processing personal data.
8.1. The legal grounds for the processing of personal data by the Operator are:
8.1.1. Federal Law of July 27, 2006 No. 152-FZ “On Personal Data”;
8.1.2. Federal Law of July 27, 2006 No. 149-FZ “On information, information technologies and information protection”;
8.1.3. Federal Law No. 323-FZ of November 21, 2011 “On the fundamentals of protecting the health of citizens in the Russian Federation.”
8.1.4. Federal Law No. 99-FZ of May 4, 2011 “On licensing of certain types of activities.”
8.1.5. Law of the Russian Federation No. 2300-1 of 02/07/1992 “On the protection of consumer rights.”
8.1.6. other regulatory legal acts of the Russian Federation regulating the activities of the Operator;
8.1.7. constituent documents of the Operator;
8.1.8. agreements concluded between the Operator and the subject of personal data;
8.1.9. consent of personal data subjects to the processing of personal data and (if necessary) to receive newsletters.
8.1.10. consent of Users to the processing of their personal data, to the processing of personal data permitted for distribution.
8.2. The Operator processes the User’s personal data only if it is filled out and/or sent by the User independently through special forms located on the website https://fgfmed.ru or sent to the Operator via email. By filling out the appropriate forms and/or sending his personal data to the Operator, the User expresses his consent to this Policy.
8.3. The Operator processes anonymized data about the User if this is allowed in the User's browser settings (saving cookies and using JavaScript technology are enabled).
8.4. The subject of personal data independently decides to provide his personal data and gives consent freely, of his own free will and in his own interest.
9. Conditions for processing personal data.
9.1. The processing of personal data is carried out with the consent of the subject of personal data to the processing of his personal data.
9.2. The operator processes personal data in the presence of one or more legal grounds, including:
9.2.1. with the consent of the personal data subject - in cases where processing is based on consent;
9.2.2. for concluding and executing an agreement (including for carrying out pre-contractual actions on an application/record) - when the subject is a party to the agreement or a beneficiary/guarantor;
9.2.3. to fulfill the obligations imposed by law on the Operator;
9.2.4. to exercise the rights and legitimate interests of the Operator or third parties, provided that the rights and freedoms of the subject are not violated;
9.2.5. The processing of personal data is necessary for the execution of an agreement to which the subject of personal data is a party or beneficiary or guarantor, as well as for concluding an agreement on the initiative of the subject of personal data or an agreement under which the subject of personal data will be a beneficiary or guarantor.
10. The procedure for collecting, storing, transferring and other types of processing of personal data.
10.1. The security of personal data processed by the Operator is ensured by implementing legal, organizational and technical measures necessary to fully comply with the requirements of current legislation in the field of personal data protection.
10.2. The operator ensures the safety of personal data and takes all possible measures to prevent access to personal data by unauthorized persons.
10.3. The User's personal data is not disclosed to third parties, except in the following cases:
10.3.1. compliance with the requirements of the legislation of the Russian Federation;
10.3.2. if the subject of personal data has given consent to provide data;
10.3.3. provision of data to persons carrying out processing on behalf of the Operator (for example, hosting provider, web analytics service Yandex.Metrica and other contractors), subject to the conclusion of contracts and compliance with the requirements of Federal Law-152.
11. List of actions performed by the Operator with received personal data.
11.1. The operator carries out:
- collection;
- record;
- systematization;
- accumulation;
- storage;
- clarification (update, change);
- extract;
- use;
- transmission (distribution, provision, access);
- depersonalization;
- blocking;
- removal and destruction of personal data.
12. The operator carries out automated processing of personal data with or without receiving and/or transmitting the received information via information and telecommunication networks.
13. The operator and other persons who have access to personal data are obliged not to disclose to third parties or distribute personal data without the consent of the subject of personal data, unless otherwise provided by federal law.
14. Terms of processing and storage of personal data.
14.1. The period for processing personal data is determined by the achievement of the purposes for which the data was collected, unless a different period is provided for by the contract or current legislation. For inquiries and requests through the Site, personal data is usually stored for no more than 1 (one) year from the date of the last interaction, unless a longer period is required to fulfill the contract or comply with legal requirements.
14.2. The user has the right to withdraw his consent at any time by sending a notification via email to the email address hello@fgfmed.ru with the note “Withdrawal of consent to the processing of personal data.”
14.3. Upon withdrawal of consent, the Operator stops processing and ensures the destruction of personal data within up to 30 (thirty) days, unless there are other legal grounds for their processing.
15. Final Provisions.
15.1. The User can receive any clarification on issues of interest regarding the processing of his personal data by contacting the Operator via email hello@fgfmed.ru
15.2. If inaccuracies in personal data are identified, the User can update them independently by sending a notification to the Operator to the Operator's email address hello@fgfmed.ru with the note “Updating personal data.”
15.3. All information that is collected by third-party services, including payment systems, communications and other service providers, is stored and processed by these persons (Operators) in accordance with their User Agreement and Privacy Policy.
15.4. The subject of personal data and/or the User is obliged to independently familiarize himself with the specified documents in a timely manner. The operator is not responsible for the actions of third parties, including the service providers specified in this paragraph.
15.5. The Operator does not carry out cross-border transfer of personal data.
15.6. The prohibitions established by the subject of personal data on the transfer (except for providing access), as well as on the processing or conditions for processing (except for gaining access) of personal data permitted for distribution, do not apply in cases of processing personal data in state, public and other public interests determined by the legislation of the Russian Federation.
15.7. When processing personal data, the operator ensures the confidentiality of personal data.
15.8. The operator stores personal data in a form that makes it possible to identify the subject of personal data for no longer than required by the purposes of processing personal data, unless the period for storing personal data is established by federal law, an agreement to which the subject of personal data is a party, beneficiary or guarantor.
15.9. The condition for cessation of processing of personal data is the achievement of the purposes of processing, expiration of the storage period, withdrawal of consent by the subject of personal data, or identification of unlawful processing. Unless otherwise provided by law, personal data is subject to destruction or depersonalization within the time limits provided for by Federal Law No. 152.
10/15. This document will reflect any changes to the Operator’s personal data processing policy. The policy is valid indefinitely until it is replaced by a new version.
16. Operator details.
LIMITED LIABILITY COMPANY "FFGFF" (FFGFF LLC)
Legal address: 199406, St. Petersburg, Maly Prospekt V.O. street, building 64 building 1 building 1 room 100-N
Postal address: 199406, St. Petersburg, Maly Prospekt V.O. street, building 64 building 1 building 1 room 100-N
Actual address: 199406, St. Petersburg, Maly Prospekt V.O. street, building 64 building 1 building 1 room 100-N
INN: 7801737783 OGRN: 1247800113120 CHECKPOINT: 780101001
Phone: 8(812)5096333 E-mail: hello@fgfmed.ru
The Site also contains:
- “Consent to the processing of personal data”
- "Cookie Policy"
- "Consent to online newsletter"
- These documents apply where appropriate and supplement this Policy.