Personal Data Processing Policy

1. General Provisions
This Personal Data Processing Policy (hereinafter — the Policy) has been prepared in accordance with the requirements of Federal Law No. 152-FZ of July 27, 2006, On Personal Data (hereinafter — the Personal Data Law) and defines the procedure for processing personal data and measures to ensure the security of personal data undertaken by Nikita Bokov pr Mem-Box (hereinafter — the Operator).
1.1.The Operator considers the observance of human and civil rights and freedoms during the processing of personal data as its most important goal and condition for conducting activities, including the protection of the right to privacy, personal and family secrecy.
1.2.This Policy applies to all information that the Operator may obtain about visitors to the website https://memoracapsule.com.

2. Key Terms Used in This Policy
2.1. Automated processing of personal data — processing using computer technology.
2.2. Blocking of personal data — temporary suspension of processing (except where processing is necessary to clarify data).
2.3. Website — the set of graphic and informational materials as well as software and databases accessible on the Internet at https://memoracapsule.com.
2.4. Personal data information system — databases containing personal data along with the technologies and means used to process them.
2.5. Depersonalization of personal data — actions making it impossible to determine the ownership of personal data without additional information.
2.6. Processing of personal data — any action (operation) or set of actions performed with or without automation tools, including collection, recording, systematization, accumulation, storage, updating, extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
2.7. Operator — a public authority, municipal authority, legal or natural person that organizes and/or performs personal data processing, and determines its purposes, scope, and actions.
2.8. Personal data — any information relating directly or indirectly to an identified or identifiable user of the website https://memoracapsule.com.
2.9. Personal data permitted for distribution — data to which the subject has granted access to an unlimited number of persons by giving consent in accordance with the Personal Data Law.
2.10. User — any visitor to the website.
2.11. Provision of personal data — actions aimed at disclosing data to a specific person or group of persons.
2.12. Distribution of personal data — any actions aimed at disclosing data to an indefinite number of persons or providing access in any form.
2.13. Cross-border transfer of personal data — transfer of data to a foreign country, authority, individual, or organization.
2.14. Destruction of personal data — any actions leading to the irreversible deletion of data, making its restoration impossible.

3. Operator’s Main Rights and Obligations
3.1. The Operator has the right to:

• Receive accurate information and/or documents containing personal data from the data subject.
• Continue processing personal data without consent in cases provided by the Personal Data Law.
• Determine independently the scope of measures sufficient to fulfill obligations prescribed by law.

3.2. The Operator must:

• Provide information to the data subject upon request regarding the processing of their data.
• Organize data processing in accordance with Serbian legislation.
• Respond to inquiries from data subjects and competent authorities.
• Ensure publication or free access to this Policy.
• Take legal, organizational, and technical measures to protect data from unlawful access, alteration, dissemination, or destruction.
• Cease processing and destroy data when required by law.

4. Rights and Obligations of Personal Data Subjects
4.1. The data subject has the right to:

• Obtain information about the processing of their data, except in cases provided by law.
• Request clarification, blocking, or destruction of incomplete or inaccurate data.
• Require prior consent for processing aimed at marketing.
• Withdraw consent and demand cessation of processing.
• Lodge complaints with the authorized data protection body or court.
• Exercise other rights established by law.

4.2. The data subject must:

• Provide accurate information about themselves.
• Notify the Operator of changes or updates.

4.3. Persons providing false or third-party data without consent bear responsibility as per Serbian law.

5. Principles of Personal Data Processing

• Lawfulness and fairness.
• Processing only for specific, lawful, and predefined purposes.
• No combining of incompatible databases.
• Data must correspond to the purposes of processing.
• Data must be accurate, sufficient, and kept up to date.
• Storage duration is limited to the period necessary to achieve processing purposes.
• Data is destroyed or depersonalized once the purpose is achieved.

7. Conditions for Processing
Processing is performed:

• With the consent of the data subject;
• As required by law or contract;
• For the execution of judicial or governmental decisions;
• To protect legitimate interests without infringing the rights of the subject;
• For public purposes or when data is made publicly available by the subject.

8. Procedure for Collection, Storage, and Transfer

• The Operator ensures personal data security through legal, organizational, and technical measures.
• Data will never be transferred to third parties unless required by law or authorized by consent.
• Users may update their data by emailing info@memoracapsule.com (subject: “Personal Data Update”).
• Data is processed until the objectives are achieved or consent is withdrawn.
• Consent withdrawal may be sent to info@memoracapsule.com (subject: “Withdrawal of Consent for Personal Data Processing”).
• Third-party services (payment systems, communication tools, etc.) process data under their own privacy policies. The Operator is not responsible for their actions.
• The Operator ensures confidentiality and limits storage to what is necessary.

9. Actions Performed with Personal Data

• The Operator carries out collection, recording, storage, updating, extraction, transfer, depersonalization, blocking, deletion, and destruction of personal data, including automated processing.

10. Cross-Border Data Transfer

• Before initiating cross-border transfers, the Operator shall notify the authorized data protection authority and obtain information about foreign recipients.

11. Confidentiality

• The Operator and all persons with access to personal data must not disclose or distribute it without the subject’s consent, except as required by law.

12. Final Provisions

• Users may obtain clarifications regarding data processing by contacting info@memoracapsule.com.
• Any updates to this Policy will be reflected in this document.
• The Policy remains in force indefinitely until replaced by a new version.
• The current version is publicly available at https://memoracapsule.com/privacy/.