Consent to the Processing of Personal Data
An individual, by submitting a request on the website www.tesstea.co.uk through this form, acting freely, of their own will and in their own interest, and confirming their legal capacity, provides their consent to the processing of personal data (hereinafter – the "Consent") to **ORIMI Limited Liability Company** (INN 4703044256, registered address: 188682, Leningrad Region, Vsevolozhsky District, Sverdlova Settlement, 1st Microdistrict, Building 15/4, hereinafter – "ORIMI LLC") for the purposes of informational interaction and communications related to providing information about ORIMI LLC products.
This Consent is provided for mixed processing (processing with and without the use of automation tools) of the following personal data, which do not belong to special categories of personal data or biometric personal data: Full Name, email address.
The following actions may be performed with the personal data during processing: collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (provision, access), blocking, deletion, destruction.
Third parties to whom ORIMI LLC transfers data to achieve the specified purpose:
* **Astra Obfako Limited Liability Company** (INN 7707301630, OGRN 1027739119286, registered address: 123100, Moscow, Krasnopresnenskaya Naberezhnaya, 8);
* **Diskonto Limited Liability Company** (INN 7734348475, OGRN 1157746156655, registered address: 115054, Moscow, Danilovsky District, Dubininskaya Street, 57, Structure 2, Premises 11).
Personal data is processed from the moment Consent for processing is received until the refusal of informational interaction and communications related to providing information about ORIMI LLC products. This Consent is effective from the moment it is provided until the termination condition specified in this paragraph of the Consent occurs, or until the Consent is withdrawn, whichever occurs first. Personal data is destroyed within 30 days after the conditions specified in this paragraph are met, provided there are no other legal grounds for continuing the processing as per clauses 2-11, part 1, article 6 of Federal Law No. 152-FZ "On Personal Data" dated July 27, 2006.
Consent may be withdrawn by sending a written application to the registered address of ORIMI LLC specified in this Consent, or an electronic application, signed in accordance with the legislation of the Russian Federation in the field of electronic signature, to the email address: opd@orimitrade.ru.
In case of withdrawal of Consent, as well as after the expiration of this Consent, ORIMI LLC has the right to continue processing personal data without it if there are grounds specified in clauses 2-11, part 1, article 6 of Federal Law No. 152-FZ "On Personal Data" dated July 27, 2006.
### Personal Data Processing Policy
**ORIMI Limited Liability Company** (INN 4703044256, registered address: 188682, Leningrad Region, Vsevolozhsky District, Sverdlova Settlement, 1st Microdistrict, Building 15/4, hereinafter – "ORIMI LLC")
This Personal Data Processing Policy (hereinafter – the "Policy") is intended to inform users (visitors) of the website www.tesstea.co.uk, including its subdomains and pages (hereinafter – the "Website"), about the procedure and conditions for processing personal data necessary for achieving the stated processing purposes.
#### Terms Used in the Policy
* **Personal Data** – any information relating to a directly or indirectly identified or identifiable individual (data subject);
* **Personal Data Operator (Operator)** – a state body, municipal body, legal entity or individual that independently or jointly with other persons organizes and/or processes personal data, and also determines the purposes of personal data processing, the composition of personal data to be processed, and the actions (operations) performed with personal data (in this Policy – ORIMI LLC);
* **Personal Data Subject** – an individual whose personal data is being processed (in this Policy – the user (visitor) of the Website);
* **Processing of Personal Data** – any action (operation) or a set of actions (operations) performed with personal data, with or without the use of automation tools. Processing of personal data may include, but is not limited to: collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction;
* **Destruction of Personal Data** – actions as a result of which it becomes impossible to restore the content of personal data in the personal data information system and/or which result in the destruction of tangible media containing personal data;
* **Personal Data Information System** – a set of personal data contained in databases and information technologies and technical means that ensure their processing.
#### Principles of Personal Data Processing
The processing of personal data by ORIMI LLC is carried out in accordance with the following principles:
* Processing of personal data is carried out on a lawful and fair basis;
* Processing of personal data is limited to achieving specific, predetermined, and lawful purposes;
* Processing of personal data that is incompatible with the purposes of personal data collection is not permitted;
* Merging databases containing personal data processed for incompatible purposes is not permitted;
* Only personal data that meets the purposes of their processing is subject to processing;
* The content and volume of processed personal data correspond to the stated processing purposes; the processed personal data is not excessive in relation to the stated purposes of their processing;
* During processing, the accuracy, sufficiency, and relevance of personal data in relation to the purposes of processing are ensured;
* Personal data is stored in a form that allows identification of the data subject for no longer than required by the purposes of personal data processing;
* Processed personal data is subject to destruction or depersonalization upon achieving the processing purposes or in case the necessity to achieve these purposes is lost, unless otherwise provided by federal law.
#### Purposes of Personal Information Processing
The Website processes personal data for the following purposes:
**1. Personalization of Services and Improving Usability of the Website.**
This purpose involves the processing of cookies; information about user actions on the website, information about the devices used for this; date and time of the session, including using metric programs.
Cookies are small files stored on a device (computer, tablet, smartphone, etc.) that contain information about user activity on the Internet.
Data collected via cookies does not belong to special categories of personal data or biometric personal data under Articles 10-11 of Federal Law No. 152-FZ "On Personal Data" dated July 27, 2006, and is processed automatically.
Actions performed with personal data: collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (provision, access), blocking, deletion, destruction.
ORIMI LLC, using cookies, does not aim to identify a specific user of the Website.
The legal basis for processing personal data for this purpose is the consent to the processing of personal data provided by the website visitor through conclusive actions – continued use of the website. The website user is notified of the possibility to prohibit the processing of cookie files by adjusting the respective browser settings.
To achieve this processing purpose, ORIMI LLC uses web analytics services (metric programs) and transfers personal data to third-party service providers:
* YANDEX LLC (INN 7736207543, registered address: 119021, Moscow, Lev Tolstoy Street, 16);
* ADRIVER LLC (INN 7813378916, registered address: 197374, Saint Petersburg, Savushkina Street, 83, Building 3, Liter A).
**2. Informational Interaction and Communications related to providing information about ORIMI LLC products.**
This purpose involves the processing by ORIMI LLC of personal data provided by the Website user by filling out the relevant form and subsequently submitting a request.
To achieve this purpose, the following personal data is processed: Full Name, email address.
Actions performed with personal data: collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (provision, access), blocking, deletion, destruction.
Personal data processed for this purpose does not belong to special categories of personal data or biometric personal data under Articles 10-11 of Federal Law No. 152-FZ "On Personal Data" dated July 27, 2006, and is processed in a mixed manner (using automation tools and without their use).
The legal basis for processing personal data for this purpose is the consent to the processing of personal data.
Personal data is processed from the moment consent for processing is received until the user refuses informational interaction and communications related to providing information about ORIMI LLC products, or until the consent for personal data processing is withdrawn, whichever occurs first. Personal data is destroyed within 30 days after the conditions specified in this paragraph are met, provided there are no other legal grounds for continuing the processing as per clauses 2-11, part 1, article 6 of Federal Law No. 152-FZ "On Personal Data" dated July 27, 2006.
Third parties to whom ORIMI LLC transfers data to achieve this purpose:
* Astra Obfako Limited Liability Company (INN 7707301630, OGRN 1027739119286, registered address: 123100, Moscow, Krasnopresnenskaya Naberezhnaya, 8);
* Diskonto Limited Liability Company (INN 7734348475, OGRN 1157746156655, registered address: 115054, Moscow, Danilovsky District, Dubininskaya Street, 57, Structure 2, Premises 11).
#### Rights of the Personal Data Subject
In accordance with Federal Law No. 152-FZ "On Personal Data" dated July 27, 2006, the website user whose data is processed by ORIMI LLC has the right to:
* Access their personal data;
* Rectify their personal data;
* Block or delete their personal data;
* Appeal against actions or omissions of ORIMI LLC;
* Withdraw consent to the processing of personal data.
ORIMI LLC does not make decisions based solely on automated processing of personal data that give rise to legal consequences for the data subject or otherwise affect their rights and legitimate interests.
The exercise of the aforementioned rights is possible by sending a request to the registered address of ORIMI LLC, indicating details of an identity document (type, series, number, issuing authority, date of issue), Full Name, information about the relationship with ORIMI LLC confirming the fact of personal data processing, and a signature. The request can also be sent to the email address opd@orimitrade.ru in the form of an electronic document signed in accordance with the legislation of the Russian Federation on electronic signatures.
Actions (or omissions) of ORIMI LLC as a personal data operator can be appealed by contacting the territorial body of Roskomnadzor and the court in accordance with the procedure established by the legislation of the Russian Federation.
#### Information on Measures Implemented to Ensure Personal Data Security
When processing personal data, ORIMI LLC takes necessary legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, distribution, as well as from other unlawful actions.
Personal data processed by ORIMI LLC is considered confidential information and is protected from loss, alteration, or unauthorized access in accordance with the requirements of the legislation of the Russian Federation in the field of personal data.
Data security is ensured, in particular, by:
* Identifying threats to personal data security during their processing in personal data information systems;
* Applying organizational and technical measures to ensure the security of personal data during their processing in personal data information systems, necessary to fulfill the personal data protection requirements, the implementation of which ensures the levels of personal data protection established by the Government of the Russian Federation;
* Applying information security tools that have passed the conformity assessment procedure in accordance with the established procedure, when the use of such tools is necessary to neutralize actual threats;
* Assessing the effectiveness of measures taken to ensure personal data security before commissioning the personal data information system;
* Detecting facts of unauthorized access to personal data and taking measures;
* Restoring personal data modified or destroyed due to unauthorized access;
* Establishing rules for access to personal data processed in the personal data information system, as well as ensuring the recording and accounting of all actions performed with personal data in the personal data information system;
* Monitoring the measures taken to ensure the protection of personal data and the security level of personal data information systems.
#### Policy Changes
ORIMI LLC reserves the right to periodically update this Policy without separate notice. The current update date is indicated on the first page of the Policy (under the title). Website users are recommended to review Policy updates to track possible changes.
The Policy shall be revised and updated in case of changes in the legislation of the Russian Federation in the field of personal data, based on the analysis of the relevance, sufficiency, and effectiveness of measures applied to ensure the security of personal data at ORIMI LLC.
#### Additional Information
The effect of this Policy applies only to the ORIMI LLC Website and cannot be extended to other websites of service providers, links to which may be placed on the ORIMI LLC Website.
The ORIMI LLC Website is not intended for processing personal data of minors. If there is reason to believe that a minor has provided their personal data through the website, please send a notification to the email address opd@orimitrade.ru.
#### Contact Details
The contacts specified in this section are used for interaction on issues of personal data processing and protection:
Email address: opd@orimitrade.ru
This Consent is provided for mixed processing (processing with and without the use of automation tools) of the following personal data, which do not belong to special categories of personal data or biometric personal data: Full Name, email address.
The following actions may be performed with the personal data during processing: collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (provision, access), blocking, deletion, destruction.
Third parties to whom ORIMI LLC transfers data to achieve the specified purpose:
* **Astra Obfako Limited Liability Company** (INN 7707301630, OGRN 1027739119286, registered address: 123100, Moscow, Krasnopresnenskaya Naberezhnaya, 8);
* **Diskonto Limited Liability Company** (INN 7734348475, OGRN 1157746156655, registered address: 115054, Moscow, Danilovsky District, Dubininskaya Street, 57, Structure 2, Premises 11).
Personal data is processed from the moment Consent for processing is received until the refusal of informational interaction and communications related to providing information about ORIMI LLC products. This Consent is effective from the moment it is provided until the termination condition specified in this paragraph of the Consent occurs, or until the Consent is withdrawn, whichever occurs first. Personal data is destroyed within 30 days after the conditions specified in this paragraph are met, provided there are no other legal grounds for continuing the processing as per clauses 2-11, part 1, article 6 of Federal Law No. 152-FZ "On Personal Data" dated July 27, 2006.
Consent may be withdrawn by sending a written application to the registered address of ORIMI LLC specified in this Consent, or an electronic application, signed in accordance with the legislation of the Russian Federation in the field of electronic signature, to the email address: opd@orimitrade.ru.
In case of withdrawal of Consent, as well as after the expiration of this Consent, ORIMI LLC has the right to continue processing personal data without it if there are grounds specified in clauses 2-11, part 1, article 6 of Federal Law No. 152-FZ "On Personal Data" dated July 27, 2006.
### Personal Data Processing Policy
**ORIMI Limited Liability Company** (INN 4703044256, registered address: 188682, Leningrad Region, Vsevolozhsky District, Sverdlova Settlement, 1st Microdistrict, Building 15/4, hereinafter – "ORIMI LLC")
This Personal Data Processing Policy (hereinafter – the "Policy") is intended to inform users (visitors) of the website www.tesstea.co.uk, including its subdomains and pages (hereinafter – the "Website"), about the procedure and conditions for processing personal data necessary for achieving the stated processing purposes.
#### Terms Used in the Policy
* **Personal Data** – any information relating to a directly or indirectly identified or identifiable individual (data subject);
* **Personal Data Operator (Operator)** – a state body, municipal body, legal entity or individual that independently or jointly with other persons organizes and/or processes personal data, and also determines the purposes of personal data processing, the composition of personal data to be processed, and the actions (operations) performed with personal data (in this Policy – ORIMI LLC);
* **Personal Data Subject** – an individual whose personal data is being processed (in this Policy – the user (visitor) of the Website);
* **Processing of Personal Data** – any action (operation) or a set of actions (operations) performed with personal data, with or without the use of automation tools. Processing of personal data may include, but is not limited to: collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction;
* **Destruction of Personal Data** – actions as a result of which it becomes impossible to restore the content of personal data in the personal data information system and/or which result in the destruction of tangible media containing personal data;
* **Personal Data Information System** – a set of personal data contained in databases and information technologies and technical means that ensure their processing.
#### Principles of Personal Data Processing
The processing of personal data by ORIMI LLC is carried out in accordance with the following principles:
* Processing of personal data is carried out on a lawful and fair basis;
* Processing of personal data is limited to achieving specific, predetermined, and lawful purposes;
* Processing of personal data that is incompatible with the purposes of personal data collection is not permitted;
* Merging databases containing personal data processed for incompatible purposes is not permitted;
* Only personal data that meets the purposes of their processing is subject to processing;
* The content and volume of processed personal data correspond to the stated processing purposes; the processed personal data is not excessive in relation to the stated purposes of their processing;
* During processing, the accuracy, sufficiency, and relevance of personal data in relation to the purposes of processing are ensured;
* Personal data is stored in a form that allows identification of the data subject for no longer than required by the purposes of personal data processing;
* Processed personal data is subject to destruction or depersonalization upon achieving the processing purposes or in case the necessity to achieve these purposes is lost, unless otherwise provided by federal law.
#### Purposes of Personal Information Processing
The Website processes personal data for the following purposes:
**1. Personalization of Services and Improving Usability of the Website.**
This purpose involves the processing of cookies; information about user actions on the website, information about the devices used for this; date and time of the session, including using metric programs.
Cookies are small files stored on a device (computer, tablet, smartphone, etc.) that contain information about user activity on the Internet.
Data collected via cookies does not belong to special categories of personal data or biometric personal data under Articles 10-11 of Federal Law No. 152-FZ "On Personal Data" dated July 27, 2006, and is processed automatically.
Actions performed with personal data: collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (provision, access), blocking, deletion, destruction.
ORIMI LLC, using cookies, does not aim to identify a specific user of the Website.
The legal basis for processing personal data for this purpose is the consent to the processing of personal data provided by the website visitor through conclusive actions – continued use of the website. The website user is notified of the possibility to prohibit the processing of cookie files by adjusting the respective browser settings.
To achieve this processing purpose, ORIMI LLC uses web analytics services (metric programs) and transfers personal data to third-party service providers:
* YANDEX LLC (INN 7736207543, registered address: 119021, Moscow, Lev Tolstoy Street, 16);
* ADRIVER LLC (INN 7813378916, registered address: 197374, Saint Petersburg, Savushkina Street, 83, Building 3, Liter A).
**2. Informational Interaction and Communications related to providing information about ORIMI LLC products.**
This purpose involves the processing by ORIMI LLC of personal data provided by the Website user by filling out the relevant form and subsequently submitting a request.
To achieve this purpose, the following personal data is processed: Full Name, email address.
Actions performed with personal data: collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (provision, access), blocking, deletion, destruction.
Personal data processed for this purpose does not belong to special categories of personal data or biometric personal data under Articles 10-11 of Federal Law No. 152-FZ "On Personal Data" dated July 27, 2006, and is processed in a mixed manner (using automation tools and without their use).
The legal basis for processing personal data for this purpose is the consent to the processing of personal data.
Personal data is processed from the moment consent for processing is received until the user refuses informational interaction and communications related to providing information about ORIMI LLC products, or until the consent for personal data processing is withdrawn, whichever occurs first. Personal data is destroyed within 30 days after the conditions specified in this paragraph are met, provided there are no other legal grounds for continuing the processing as per clauses 2-11, part 1, article 6 of Federal Law No. 152-FZ "On Personal Data" dated July 27, 2006.
Third parties to whom ORIMI LLC transfers data to achieve this purpose:
* Astra Obfako Limited Liability Company (INN 7707301630, OGRN 1027739119286, registered address: 123100, Moscow, Krasnopresnenskaya Naberezhnaya, 8);
* Diskonto Limited Liability Company (INN 7734348475, OGRN 1157746156655, registered address: 115054, Moscow, Danilovsky District, Dubininskaya Street, 57, Structure 2, Premises 11).
#### Rights of the Personal Data Subject
In accordance with Federal Law No. 152-FZ "On Personal Data" dated July 27, 2006, the website user whose data is processed by ORIMI LLC has the right to:
* Access their personal data;
* Rectify their personal data;
* Block or delete their personal data;
* Appeal against actions or omissions of ORIMI LLC;
* Withdraw consent to the processing of personal data.
ORIMI LLC does not make decisions based solely on automated processing of personal data that give rise to legal consequences for the data subject or otherwise affect their rights and legitimate interests.
The exercise of the aforementioned rights is possible by sending a request to the registered address of ORIMI LLC, indicating details of an identity document (type, series, number, issuing authority, date of issue), Full Name, information about the relationship with ORIMI LLC confirming the fact of personal data processing, and a signature. The request can also be sent to the email address opd@orimitrade.ru in the form of an electronic document signed in accordance with the legislation of the Russian Federation on electronic signatures.
Actions (or omissions) of ORIMI LLC as a personal data operator can be appealed by contacting the territorial body of Roskomnadzor and the court in accordance with the procedure established by the legislation of the Russian Federation.
#### Information on Measures Implemented to Ensure Personal Data Security
When processing personal data, ORIMI LLC takes necessary legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, distribution, as well as from other unlawful actions.
Personal data processed by ORIMI LLC is considered confidential information and is protected from loss, alteration, or unauthorized access in accordance with the requirements of the legislation of the Russian Federation in the field of personal data.
Data security is ensured, in particular, by:
* Identifying threats to personal data security during their processing in personal data information systems;
* Applying organizational and technical measures to ensure the security of personal data during their processing in personal data information systems, necessary to fulfill the personal data protection requirements, the implementation of which ensures the levels of personal data protection established by the Government of the Russian Federation;
* Applying information security tools that have passed the conformity assessment procedure in accordance with the established procedure, when the use of such tools is necessary to neutralize actual threats;
* Assessing the effectiveness of measures taken to ensure personal data security before commissioning the personal data information system;
* Detecting facts of unauthorized access to personal data and taking measures;
* Restoring personal data modified or destroyed due to unauthorized access;
* Establishing rules for access to personal data processed in the personal data information system, as well as ensuring the recording and accounting of all actions performed with personal data in the personal data information system;
* Monitoring the measures taken to ensure the protection of personal data and the security level of personal data information systems.
#### Policy Changes
ORIMI LLC reserves the right to periodically update this Policy without separate notice. The current update date is indicated on the first page of the Policy (under the title). Website users are recommended to review Policy updates to track possible changes.
The Policy shall be revised and updated in case of changes in the legislation of the Russian Federation in the field of personal data, based on the analysis of the relevance, sufficiency, and effectiveness of measures applied to ensure the security of personal data at ORIMI LLC.
#### Additional Information
The effect of this Policy applies only to the ORIMI LLC Website and cannot be extended to other websites of service providers, links to which may be placed on the ORIMI LLC Website.
The ORIMI LLC Website is not intended for processing personal data of minors. If there is reason to believe that a minor has provided their personal data through the website, please send a notification to the email address opd@orimitrade.ru.
#### Contact Details
The contacts specified in this section are used for interaction on issues of personal data processing and protection:
Email address: opd@orimitrade.ru