Personal Data Processing Policy
Version of March 5, 2026
Vladivostok
This Personal Data Processing Policy (hereinafter – the Policy) is developed in accordance with the requirements of the Federal Law of July 27, 2006 No. 152-FZ “On Personal Data” (hereinafter – 152-FZ) and defines the procedure for processing personal data and measures to ensure the security of personal data undertaken by BERNK Co., Ltd. (hereinafter – the Operator).
The Operator sets as its most important goal and condition for its activities the observance of human and civil rights and freedoms when processing their personal data, including the protection of the rights to privacy, personal and family secrets.
This Policy applies to all information that the Operator may receive about visitors to the website https://bernk.ru (hereinafter – the Site).
1. Definition of Terms
1.1. The following terms are used in this Policy:
- Personal Data – any information relating directly or indirectly to a specific or identifiable individual (personal data subject).
- Processing of Personal Data – any action (operation) or set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
- User – any visitor to the website https://bernk.ru.
- Site Administration – authorized employees for managing the Site, acting on behalf of the Operator, who organize and (or) carry out the processing of personal data.
- Cookies — a small piece of data sent by a web server and stored on the User’s device.
2. General Provisions
2.1. The User’s use of the Site means familiarization and agreement with the terms of this Policy. Consent to the processing of personal data is provided by the User separately and consciously when filling out the relevant forms on the Site.
2.2. In case of disagreement with the terms of the Policy, the User must immediately stop using the Site.
2.3. This Policy applies only to the bernk.ru site. The Operator does not control and is not responsible for third-party sites to which the User can go via links available on the Site.
2.4. The site administration does not verify the accuracy of the personal data provided by the User, assuming that the User provides reliable and sufficient personal data.
3. Purposes, Legal Grounds, Categories, and Terms of Personal Data Processing
3.1. The Operator processes Users’ personal data for the following purposes:
| Purpose of Processing | Categories of Subjects | List of Processed Data | Legal Ground | Processing and Storage Term |
|---|---|---|---|---|
| User identification for placing an order, concluding and executing a contract | Clients (individuals), representatives of legal entities | Last name, first name, patronymic; contact phone number; email address; place of residence; delivery address | Consent to the processing of personal data; Contract with the data subject | Until the contract is executed, and for accounting data – 5 years |
| Establishing feedback with the User, processing requests and applications | Site visitors, clients | Last name, first name, patronymic; contact phone number; email address | Consent to the processing of personal data | Until the purpose of processing is achieved or the consent is withdrawn |
| Providing the User with newsletters and promotional materials with their consent | Newsletter subscribers | Email address | Consent to the processing of personal data | Until the consent to receive the newsletter is withdrawn |
| Ensuring the functioning of the site, collecting statistics | All site users | IP address; information from cookies; browser information; access time; referrer | Consent to the processing of cookies | In accordance with the storage periods established for specific cookies (see section 9) |
4. Procedure and Conditions for Processing Personal Data
4.1. The processing of the User’s personal data is carried out in any legal way, both with and without the use of automation tools.
4.2. The User agrees that the Site Administration has the right to transfer personal data to third parties (courier services, postal organizations) solely for the purpose of fulfilling the User’s order.
4.3. The User’s personal data may be transferred to the authorized state authorities of the Russian Federation only on the grounds and in the manner established by the legislation of the Russian Federation.
4.4. Upon detection of an unlawful or accidental transfer (leak) of personal data that resulted in a violation of the User’s rights, the Site Administration is obliged to notify the User of the data leak within 72 hours from the moment the incident is detected and take all necessary measures to minimize negative consequences.
5. Rights and Obligations of the Parties
5.1. The User has the right to: – Receive information from the Operator regarding the processing of their personal data. – Demand that the Operator clarify, block or destroy their personal data. – Withdraw their consent to the processing of personal data. – Appeal the actions or inaction of the Operator to the authorized body or in court. – Exercise other rights provided for by the legislation of the Russian Federation.
5.2. The Site Administration is obliged to: – Use the information received solely for the purposes specified in section 3 of this Policy. – Ensure the confidentiality of personal data and not disclose it without the User’s permission, except as provided by law. – Block or destroy personal data at the User’s request within the time limits established by the legislation of the Russian Federation.
6. Procedure for the Destruction of Personal Data
6.1. The destruction of personal data is carried out upon reaching the goals of their processing, at the expiration of the storage periods, upon withdrawal of consent by the subject, or upon detection of unlawful processing.
6.2. The destruction of data is carried out by erasing information from electronic media or physically destroying paper media. The fact of destruction is confirmed by an act.
7. Localization of Databases
7.1. The recording, systematization, accumulation, and storage of personal data of citizens of the Russian Federation is carried out using databases located on the territory of the Russian Federation.
8. Cross-Border Transfer of Personal Data
8.1. The Operator does not carry out cross-border transfer of Users’ personal data.
9. Use of Cookies
9.1. The Site uses the following types of cookies:
| Name | Provider | Storage Period | Purpose |
|---|---|---|---|
| _ym_uid | Yandex.Metrica | 1 year | Used for identifying site users |
| _ym_isad | Yandex.Metrica | 20 hours | Used to determine if a visitor has ad blockers |
| _ym_d | Yandex.Metrica | 1 year | Saves the date of the user’s first site session |
| _ym_visorc_* | Yandex.Metrica | 30 minutes | Allows Session Replay to function correctly |
| fazcookie-consent | bernk.ru | 1 year | Recording the user’s cookie consent preferences |
| PHPSESSID | bernk.ru | Session | Ensuring the functioning of the user session |
9.2. The User can independently manage cookies through their browser settings. Disabling cookies may result in the inability to access some sections of the Site.
9.3. Some cookies are necessary for the proper functioning of the website and cannot be disabled. They do not collect information for analytics or advertising purposes, but only ensure basic functions, such as remembering your privacy preferences or maintaining a session when filling out forms. These cookies do not require separate consent, but we are obliged to inform you about their use in accordance with the position of the Russian Federal Service for Supervision of Communications, Information Technology and Mass Media (Roskomnadzor).
10. Liability of the Parties
10.1. The Operator is responsible for the unlawful use of personal data in accordance with the legislation of the Russian Federation.
11. Dispute Resolution
11.1. Before going to court, it is mandatory to submit a written claim. The response time to the claim is 30 calendar days.
12. Additional Conditions
12.1. The Operator has the right to make changes to this Policy. The new version comes into force from the moment it is posted on the Site.
12.2. Questions on this Policy should be sent to the email address: .
Operator’s Details
BERNK Co., Ltd.
Legal address: 19a-3 Aleutskaya St, Vladivostok, 690091
OGRN: 1022502281240