Personal Data Processing Policy

General Provisions
This personal data processing policy (hereinafter referred to as the “Policy”) is prepared in accordance with the requirements of the Personal Data Law and defines the procedure for processing personal data and measures to ensure the security of personal data, implemented by TreeAxis LLC (hereinafter referred to as the “Operator”).
1.1. The Operator’s most important goal and condition for carrying out its activities is the observance of human and civil rights and freedoms in the processing of their personal data, including the protection of privacy, personal and family secrets.
1.2. This Policy applies to all information that the Operator may receive about visitors to the website https://glebova.jp.

Basic Concepts Used in the Policy
2.1. Automated processing of personal data — the processing of personal data using computer technology.
2.2. Blocking of personal data — temporary suspension of the processing of personal data (except in cases where processing is necessary to clarify personal data).
2.3. Website — a collection of graphical and information materials, as well as software and databases, ensuring their availability on the Internet at the network address https://glebova.jp.
2.4. Information system of personal data — a set of personal data contained in databases and ensuring their processing through information technologies and technical means.
2.5. Anonymization of personal data — actions that make it impossible to determine, without the use of additional information, the identity of personal data belonging to a specific User or other subject of personal data.
2.6. Processing of personal data — any action (operation) or set of actions (operations) performed with or without the use of automated tools on personal data, including the collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, usage, transfer (distribution, provision, access), anonymization, blocking, deletion, destruction of personal data.
2.7. Operator — a state or municipal body, legal or individual entity that organizes and/or performs the processing of personal data, as well as determines the purpose of processing personal data, the scope of personal data subject to processing, and the actions (operations) performed on personal data.
2.8. Personal data — any information directly or indirectly related to a specific or identifiable User of the website https://glebova.jp.
2.9. Personal data allowed by the subject of personal data for distribution — personal data to which the subject of personal data grants unlimited access by giving consent to the processing of personal data allowed for distribution, as provided for by the Personal Data Law.
2.10. User — any visitor to the website https://glebova.jp.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Distribution of personal data — any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or to making personal data available to an unlimited number of persons, including disclosure of personal data in the media, posting on information and telecommunications networks, or providing access to personal data by any other means.

Basic Rights and Obligations of the Operator
3.1. The Operator has the right to:
— receive from the subject of personal data reliable information and/or documents containing personal data;
— continue processing personal data without the consent of the subject of personal data if there are grounds specified in the Personal Data Law, even after the subject of personal data withdraws consent;
— independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of the obligations provided for by the Personal Data Law and regulatory legal acts adopted in accordance with it.

3.2. The Operator is obliged to:
— provide the subject of personal data with information about the processing of their personal data at their request;
— organize the processing of personal data in accordance with the laws of Japan;
— respond to inquiries and requests from subjects of personal data and their legal representatives;
— publish or otherwise ensure unrestricted access to this Policy;
— take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision, distribution, as well as from other unlawful actions;
— stop the transfer or processing of personal data and destroy data in the manner and cases provided for by the Law.

Basic Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects have the right to:
— request information regarding the processing of their personal data, except in cases provided for by the laws of Japan;
— demand that the operator update, block, or destroy their personal data if the data is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing;
— stipulate conditions for prior consent to the processing of personal data for the promotion of goods and services on the market;
— withdraw consent to the processing of their data;
— challenge the operator's unlawful actions in processing personal data.

4.2. Personal data subjects are obliged to:
— provide the Operator with reliable data about themselves;
— inform the Operator about the updating of their data.

Personal Data the Operator May Process
5.1. Last name, first name, patronymic (if applicable).
5.2. Email address.
5.3. Phone numbers.
5.4. The website also collects and processes anonymized data about visitors using cookies.

Principles of Personal Data Processing
6.1. Processing of personal data is carried out on a lawful and fair basis.
6.2. Processing of personal data is limited to achieving specific, pre-determined objectives.
6.3. The combination of databases containing personal data, the processing of which is carried out for incompatible purposes, is not allowed.
6.4. Only personal data that meets the purposes of processing may be processed.
6.5. The content and scope of personal data processed must correspond to the stated purposes of their processing.
6.6. The accuracy, sufficiency, and, where necessary, relevance of personal data must be ensured during processing.
6.7. Personal data shall be stored in a form that allows for the identification of the personal data subject no longer than necessary for the purposes of processing.

Purposes of Personal Data Processing
7.1. The Operator processes personal data for the following purposes:
— informing the User via email;
— conclusion, performance, and termination of civil contracts;
— providing the User with access to materials on the website https://glebova.jp.

7.2. The Operator may send the User notifications about new products, services, and special offers. The User may unsubscribe from these notifications at any time by sending a request to 16gov23@gmail.com with the subject “Unsubscribe from notifications.”

7.3. Anonymized data collected through internet statistics services is used to improve the quality of the website.

Legal Basis for Personal Data Processing
8.1. The legal basis for processing personal data by the Operator includes:
— Relevant laws of Japan and international regulations governing this area;
— The Operator’s charter and internal regulations;
— Contracts concluded between the Operator and the subject of personal data;
— Consent of Users to the processing of their personal data.

8.2. The Operator processes the User’s data only if provided voluntarily via forms on the website https://glebova.jp or sent via email to the Operator.

8.3. The Operator processes anonymized data only if it is allowed in the User's browser settings.

Conditions for Personal Data Processing
9.1. Personal data is processed with the consent of the personal data subject.
9.2. Processing may be performed without consent when required to fulfill contractual obligations.
9.3. Processing of personal data is allowed when necessary for legal enforcement or court rulings.

Procedure for Collecting, Storing, and Transmitting Personal Data
10.1. The Operator takes all necessary measures to protect data from unauthorized access.
10.2. Personal data will never be transferred to third parties unless required by law or with the User’s consent.
10.3. In case of inaccuracies, the User may update their personal data by sending a request to 16gov23@gmail.com.
10.4. Personal data is stored until the purposes of its processing are achieved. The User can withdraw their consent to processing at any time by sending a request to 16gov23@gmail.com.
10.5. All information collected by external service providers (payment systems, communication services, etc.) is stored according to their privacy policies. The Operator is not responsible for their actions.

Actions Performed by the Operator with Personal Data
The Operator performs the collection, recording, systematization, accumulation, storage, updating, use, transfer, anonymization, blocking, deletion, and destruction of personal data.

Cross-border Transfer of Personal Data
The Operator must ensure that the country to which personal data is being transferred provides adequate protection for the personal data of the subjects before transferring data abroad.

Confidentiality of Personal Data
The Operator and other persons who have access to personal data must not disclose it to third parties or distribute it without the consent of the subject.

Final Provisions

14.1. The User can ask any questions about personal data processing by sending an email to 16gov23@gmail.com.
14.2. Any changes to this Policy will be posted on the website https://glebova.jp.
14.3. The current version of this Policy is available at https://glebova.jp/privacy.