Privacy Policy
Privacy Policy
1. General Provisions This Personal Data Processing Policy has been drafted in accordance with the requirements of Federal Law No. 152-FZ dated July 27, 2006, "On Personal Data" (hereinafter referred to as the "Personal Data Law") and defines the procedure for processing personal data and measures to ensure the security of personal data undertaken by LLC "Supplement" (hereinafter referred to as the "Operator").
1.1. The Operator sets as its most important goal and condition for the implementation of its activities the observance of human and civil rights and freedoms in the processing of 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 may receive about visitors to the website https://supplementopt.tilda.ws/.
2. Key Terms Used in the Policy
2.1. Automated processing of personal data — processing of personal data using computer technology.
2.2. Blocking of personal data — temporary cessation of personal data processing (unless processing is necessary to clarify personal data).
2.3. Website — a collection of graphic and information materials, as well as computer programs and databases, ensuring their availability on the Internet at the network address https://supplementopt.tilda.ws/.
2.4. Personal data information system — a set of personal data contained in databases, along with the 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 — any action (operation) or set of actions (operations) performed with personal data, with or without the use of automation tools, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (dissemination, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
2.7. Operator — a state body, municipal body, legal entity, or individual that independently or jointly with others organizes and/or performs the processing of personal data, as well as determines the purposes of processing personal data, the scope of personal data to be processed, and the actions (operations) performed with personal data.
2.8. Personal data — any information relating directly or indirectly to a specific or identifiable User of the website https://supplementopt.tilda.ws/.
2.9. Personal data authorized by the subject for dissemination — personal data to which access by an unlimited number of persons is provided by the personal data subject by giving consent to the processing of personal data authorized by the subject for dissemination in the manner prescribed by the Personal Data Law (hereinafter referred to as personal data authorized for dissemination).
2.10. User — any visitor to the website https://supplementopt.tilda.ws/.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific circle of persons.
2.12. Dissemination of personal data — any actions aimed at disclosing personal data to an undefined circle of persons (transfer of personal data) or making personal data available to an unlimited circle of persons, including the publication of personal data in the media, placement in information and telecommunication networks, or providing access to personal data in any other way.
2.13. Cross-border transfer of personal data — the transfer of personal data to the territory of a foreign state to an authority of a foreign state, a foreign individual, or a foreign legal entity.
2.14. Destruction of personal data — any actions as a result of which personal data are irretrievably destroyed with the impossibility of further restoring the content of the personal data in the personal data information system and/or the physical media of the personal data are destroyed.
3. Basic Rights and Obligations of the Operator
3.1. The Operator has the right:
— to receive from the personal data subject reliable information and/or documents containing personal data;
— in the event that the personal data subject withdraws consent to the processing of personal data, or submits a request to terminate the processing of personal data, the Operator is entitled to continue processing personal data without the consent of the personal data subject if there are grounds specified in the Personal Data Law;
— to independently determine the scope and list of measures necessary and sufficient to ensure the fulfillment of obligations provided for by the Personal Data Law and the regulatory legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.
3.2. The Operator is obliged:
— to provide the personal data subject, upon their request, with information regarding the processing of their personal data;
— to organize the processing of personal data in the manner established by the current legislation of the Russian Federation;
— to respond to inquiries and requests from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
— to provide the authorized body for the protection of the rights of personal data subjects, upon its request, with the necessary information within 10 days from the date of receipt of such a request;
— to publish or otherwise provide unrestricted access to this Policy regarding the processing of personal data;
— to take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, dissemination, as well as from other unlawful actions in relation to personal data;
— to cease the transfer (dissemination, provision, access) of personal data, cease processing, and destroy personal data in the manner and cases provided for by the Personal Data Law;
— to perform other duties provided for by the Personal Data Law.
4. Basic Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects have the right:
— to receive information regarding the processing of their personal data, except in cases provided for by federal laws. The information shall be provided to the personal data subject by the Operator in an accessible form and must not contain personal data related to other personal data subjects, except in cases where there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
— to require the Operator to clarify their personal data, block, or destroy it if the personal data is incomplete, outdated, inaccurate, illegally obtained, or is not necessary for the stated purpose of processing, and to take measures provided by law to protect their rights;
— to set a condition of prior consent when processing personal data for the purpose of promoting goods, works, and services on the market;
— to withdraw consent to the processing of personal data, as well as to submit a demand to terminate the processing of personal data;
— to appeal to the authorized body for the protection of the rights of personal data subjects or in court against unlawful actions or omissions of the Operator during the processing of their personal data;
— to exercise other rights provided for by the legislation of the Russian Federation.
4.2. Personal data subjects are obliged:
— to provide the Operator with reliable data about themselves;
— to notify the Operator regarding the clarification (updating, changing) of their personal data.
4.3. Persons who have provided the Operator with unreliable information about themselves, or information about another personal data subject without the latter's consent, shall be held liable in accordance with the legislation of the Russian Federation.
5. Principles of Personal Data Processing
5.1. Personal data processing is carried out on a legal and fair basis.
5.2. Personal data processing is limited to the achievement of specific, predetermined, and legitimate goals. Processing of personal data incompatible with the purposes of personal data collection is not permitted.
5.3. It is not allowed to merge databases containing personal data that are processed for purposes incompatible with each other.
5.4. Only personal data that meet the purposes of their processing are subject to processing.
5.5. The content and scope of the processed personal data correspond to the stated purposes of processing. Redundancy of the processed personal data in relation to the stated purposes of their processing is not permitted.
5.6. When processing personal data, the accuracy of personal data, its sufficiency, and, where necessary, its relevance in relation to the purposes of personal data processing, are ensured. The Operator takes the necessary measures and/or ensures their adoption to delete or clarify incomplete or inaccurate data.
5.7. Storage of personal data is carried out in a form that allows for the identification of the personal data subject, for no longer than required by the purposes of personal data processing, unless the storage period for personal data is established by federal law, or by a contract to which the personal data subject is a party, beneficiary, or guarantor. Processed personal data are destroyed or depersonalized upon achievement of the processing goals or in case of loss of the need to achieve these goals, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing
6.1. The purpose of processing is to provide access to information, services, and products on the Website; processing user inquiries and requests; analyzing user behavior to improve Website performance; informing users by sending emails, messages via instant messengers, and making phone calls; as well as ensuring security and preventing fraudulent activities.
Personal Data:
6.2. In addition to the data mentioned above, the Operator processes information that is automatically transmitted by the Yandex Metrica service during the use of the Website:
7.1. Personal data processing is carried out with the consent of the personal data subject to the processing of their personal data.
7.2. Personal data processing is necessary to achieve the goals provided for by an international treaty of the Russian Federation or by law, for the implementation of functions, powers, and duties imposed on the operator by the legislation of the Russian Federation.
7.3. Personal data processing is necessary for the administration of justice, execution of a judicial act, or an act of another body or official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. Personal data processing is necessary for the execution of a contract to which the personal data subject is a party, beneficiary, or guarantor, as well as for the conclusion of a contract at the initiative of the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor.
7.5. Personal data processing is necessary for the exercise of the rights and legitimate interests of the operator or third parties, or to achieve socially significant goals, provided that the rights and freedoms of the personal data subject are not violated.
7.6. Processing of personal data is carried out where access to such data by an unlimited number of persons is provided by the personal data subject or at their request (hereinafter referred to as publicly available personal data).
7.7. Processing is carried out for personal data subject to publication or mandatory disclosure in accordance with federal law.
8. Procedure for Collection, Storage, Transfer, and Other Types of Personal Data Processing
The security of personal data processed by the Operator is ensured through the implementation of legal, organizational, and technical measures necessary to fully comply with the requirements of current legislation in the field of personal data protection.
8.1. The Operator ensures the safety of personal data and takes all possible measures to exclude access to personal data by unauthorized persons.
8.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to the implementation of current legislation or if the personal data subject has given consent to the Operator to transfer data to a third party to fulfill obligations under a civil law contract.
8.3. In case of detecting inaccuracies in personal data, the User may update them independently by sending a notification to the Operator's email address info@supplementopt.com marked "Updating of personal data."
8.4. The period for processing personal data is determined by the achievement of the purposes for which the personal data were collected, unless a different period is provided for by contract or current legislation.
The User may withdraw their consent to the processing of personal data at any time by sending a notification to the Operator via email to the Operator's email address info@supplementopt.com marked "Withdrawal of consent to the processing of personal data."
8.5. All information collected by third-party services, including payment systems, communication providers, and other service providers, is stored and processed by these entities (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject is obliged to independently familiarize themselves with the specified documents. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this clause.
8.6. Prohibitions established by the personal data subject on the transfer (other than granting access), as well as on the processing or conditions of processing (other than obtaining access) of personal data authorized for dissemination, do not apply in cases of personal data processing in state, public, and other public interests as defined by the legislation of the Russian Federation.
8.7. The Operator ensures the confidentiality of personal data during its processing.
8.8. The Operator stores personal data in a form that allows for the identification of the personal data subject for no longer than the purposes of personal data processing require, unless the storage period for personal data is established by federal law, or by a contract to which the personal data subject is a party, beneficiary, or guarantor.
8.9. The conditions for terminating personal data processing may include the achievement of the personal data processing purposes, the expiration of the consent period of the personal data subject, the withdrawal of consent by the personal data subject, or a request to terminate personal data processing, as well as the identification of unlawful processing of personal data.
9. List of Actions Performed by the Operator with Received Personal Data
9.1. The Operator carries out the collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (dissemination, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
9.2. The Operator carries out automated processing of personal data with the receipt and/or transmission of the received information via information and telecommunication networks or without such networks.
10. Cross-border Transfer of Personal Data
10.1. Before commencing activities related to the cross-border transfer of personal data, the Operator is obliged to notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out the cross-border transfer of personal data (such notification is sent separately from the notification of the intention to process personal data).
10.2. Before submitting the aforementioned notification, the Operator is obliged to obtain the relevant information from the authorities of the foreign state, foreign individuals, or foreign legal entities to whom the cross-border transfer of personal data is planned.
11. Confidentiality of Personal Data
The Operator and other persons who have gained access to personal data are obliged not to disclose to third parties and not to disseminate personal data without the consent of the personal data subject, unless otherwise provided by federal law.
12. Final Provisions
12.1. The User may obtain any clarifications on issues of interest regarding the processing of their personal data by contacting the Operator via email at info@supplementopt.com.
12.2. 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.
12.3. The current version of the Policy is freely available on the Internet at https://supplementopt.tilda.ws/privacy
1.1. The Operator sets as its most important goal and condition for the implementation of its activities the observance of human and civil rights and freedoms in the processing of 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 may receive about visitors to the website https://supplementopt.tilda.ws/.
2. Key Terms Used in the Policy
2.1. Automated processing of personal data — processing of personal data using computer technology.
2.2. Blocking of personal data — temporary cessation of personal data processing (unless processing is necessary to clarify personal data).
2.3. Website — a collection of graphic and information materials, as well as computer programs and databases, ensuring their availability on the Internet at the network address https://supplementopt.tilda.ws/.
2.4. Personal data information system — a set of personal data contained in databases, along with the 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 — any action (operation) or set of actions (operations) performed with personal data, with or without the use of automation tools, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (dissemination, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
2.7. Operator — a state body, municipal body, legal entity, or individual that independently or jointly with others organizes and/or performs the processing of personal data, as well as determines the purposes of processing personal data, the scope of personal data to be processed, and the actions (operations) performed with personal data.
2.8. Personal data — any information relating directly or indirectly to a specific or identifiable User of the website https://supplementopt.tilda.ws/.
2.9. Personal data authorized by the subject for dissemination — personal data to which access by an unlimited number of persons is provided by the personal data subject by giving consent to the processing of personal data authorized by the subject for dissemination in the manner prescribed by the Personal Data Law (hereinafter referred to as personal data authorized for dissemination).
2.10. User — any visitor to the website https://supplementopt.tilda.ws/.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific circle of persons.
2.12. Dissemination of personal data — any actions aimed at disclosing personal data to an undefined circle of persons (transfer of personal data) or making personal data available to an unlimited circle of persons, including the publication of personal data in the media, placement in information and telecommunication networks, or providing access to personal data in any other way.
2.13. Cross-border transfer of personal data — the transfer of personal data to the territory of a foreign state to an authority of a foreign state, a foreign individual, or a foreign legal entity.
2.14. Destruction of personal data — any actions as a result of which personal data are irretrievably destroyed with the impossibility of further restoring the content of the personal data in the personal data information system and/or the physical media of the personal data are destroyed.
3. Basic Rights and Obligations of the Operator
3.1. The Operator has the right:
— to receive from the personal data subject reliable information and/or documents containing personal data;
— in the event that the personal data subject withdraws consent to the processing of personal data, or submits a request to terminate the processing of personal data, the Operator is entitled to continue processing personal data without the consent of the personal data subject if there are grounds specified in the Personal Data Law;
— to independently determine the scope and list of measures necessary and sufficient to ensure the fulfillment of obligations provided for by the Personal Data Law and the regulatory legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.
3.2. The Operator is obliged:
— to provide the personal data subject, upon their request, with information regarding the processing of their personal data;
— to organize the processing of personal data in the manner established by the current legislation of the Russian Federation;
— to respond to inquiries and requests from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
— to provide the authorized body for the protection of the rights of personal data subjects, upon its request, with the necessary information within 10 days from the date of receipt of such a request;
— to publish or otherwise provide unrestricted access to this Policy regarding the processing of personal data;
— to take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, dissemination, as well as from other unlawful actions in relation to personal data;
— to cease the transfer (dissemination, provision, access) of personal data, cease processing, and destroy personal data in the manner and cases provided for by the Personal Data Law;
— to perform other duties provided for by the Personal Data Law.
4. Basic Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects have the right:
— to receive information regarding the processing of their personal data, except in cases provided for by federal laws. The information shall be provided to the personal data subject by the Operator in an accessible form and must not contain personal data related to other personal data subjects, except in cases where there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
— to require the Operator to clarify their personal data, block, or destroy it if the personal data is incomplete, outdated, inaccurate, illegally obtained, or is not necessary for the stated purpose of processing, and to take measures provided by law to protect their rights;
— to set a condition of prior consent when processing personal data for the purpose of promoting goods, works, and services on the market;
— to withdraw consent to the processing of personal data, as well as to submit a demand to terminate the processing of personal data;
— to appeal to the authorized body for the protection of the rights of personal data subjects or in court against unlawful actions or omissions of the Operator during the processing of their personal data;
— to exercise other rights provided for by the legislation of the Russian Federation.
4.2. Personal data subjects are obliged:
— to provide the Operator with reliable data about themselves;
— to notify the Operator regarding the clarification (updating, changing) of their personal data.
4.3. Persons who have provided the Operator with unreliable information about themselves, or information about another personal data subject without the latter's consent, shall be held liable in accordance with the legislation of the Russian Federation.
5. Principles of Personal Data Processing
5.1. Personal data processing is carried out on a legal and fair basis.
5.2. Personal data processing is limited to the achievement of specific, predetermined, and legitimate goals. Processing of personal data incompatible with the purposes of personal data collection is not permitted.
5.3. It is not allowed to merge databases containing personal data that are processed for purposes incompatible with each other.
5.4. Only personal data that meet the purposes of their processing are subject to processing.
5.5. The content and scope of the processed personal data correspond to the stated purposes of processing. Redundancy of the processed personal data in relation to the stated purposes of their processing is not permitted.
5.6. When processing personal data, the accuracy of personal data, its sufficiency, and, where necessary, its relevance in relation to the purposes of personal data processing, are ensured. The Operator takes the necessary measures and/or ensures their adoption to delete or clarify incomplete or inaccurate data.
5.7. Storage of personal data is carried out in a form that allows for the identification of the personal data subject, for no longer than required by the purposes of personal data processing, unless the storage period for personal data is established by federal law, or by a contract to which the personal data subject is a party, beneficiary, or guarantor. Processed personal data are destroyed or depersonalized upon achievement of the processing goals or in case of loss of the need to achieve these goals, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing
6.1. The purpose of processing is to provide access to information, services, and products on the Website; processing user inquiries and requests; analyzing user behavior to improve Website performance; informing users by sending emails, messages via instant messengers, and making phone calls; as well as ensuring security and preventing fraudulent activities.
Personal Data:
- Surname, first name, middle name (patronymic);
- Email address;
- Phone numbers;
- Telegram username.
- Statutory (founding) documents of the Operator;
- Contracts concluded between the Operator and the personal data subject.
- Collection, recording, systematization, accumulation, storage, destruction, and depersonalization of personal data.
- Sending service and transactional notifications to the email address: providing information regarding order status, registration confirmation, as well as responding to User inquiries on technical and organizational issues related to the Website's operation.
- Sending notifications to instant messengers: informing the User about the details of order placement, payment, and delivery, as well as providing responses to inquiries sent to the support service.
6.2. In addition to the data mentioned above, the Operator processes information that is automatically transmitted by the Yandex Metrica service during the use of the Website:
- IP address and user device type;
- Browser type and operating system;
- Date and time of access to the Website;
- Information about user actions on the Website (including the use of "Session Replay" / "Webvisor" technology: mouse movements, clicks, page scrolling);
- Sources of traffic to the Website (referral links, advertisements, direct visits);
- Location information (city, country) based on the IP address;
- Cookie identifiers (Client ID).
- Analyzing user activity and optimizing the Website interface;
- Evaluating the effectiveness of advertising campaigns and marketing activities;
- Ensuring the technical accessibility and correct operation of Website functions;
- Preventing fraudulent activities and ensuring the security of the Website.
7.1. Personal data processing is carried out with the consent of the personal data subject to the processing of their personal data.
7.2. Personal data processing is necessary to achieve the goals provided for by an international treaty of the Russian Federation or by law, for the implementation of functions, powers, and duties imposed on the operator by the legislation of the Russian Federation.
7.3. Personal data processing is necessary for the administration of justice, execution of a judicial act, or an act of another body or official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. Personal data processing is necessary for the execution of a contract to which the personal data subject is a party, beneficiary, or guarantor, as well as for the conclusion of a contract at the initiative of the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor.
7.5. Personal data processing is necessary for the exercise of the rights and legitimate interests of the operator or third parties, or to achieve socially significant goals, provided that the rights and freedoms of the personal data subject are not violated.
7.6. Processing of personal data is carried out where access to such data by an unlimited number of persons is provided by the personal data subject or at their request (hereinafter referred to as publicly available personal data).
7.7. Processing is carried out for personal data subject to publication or mandatory disclosure in accordance with federal law.
8. Procedure for Collection, Storage, Transfer, and Other Types of Personal Data Processing
The security of personal data processed by the Operator is ensured through the implementation of legal, organizational, and technical measures necessary to fully comply with the requirements of current legislation in the field of personal data protection.
8.1. The Operator ensures the safety of personal data and takes all possible measures to exclude access to personal data by unauthorized persons.
8.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to the implementation of current legislation or if the personal data subject has given consent to the Operator to transfer data to a third party to fulfill obligations under a civil law contract.
8.3. In case of detecting inaccuracies in personal data, the User may update them independently by sending a notification to the Operator's email address info@supplementopt.com marked "Updating of personal data."
8.4. The period for processing personal data is determined by the achievement of the purposes for which the personal data were collected, unless a different period is provided for by contract or current legislation.
The User may withdraw their consent to the processing of personal data at any time by sending a notification to the Operator via email to the Operator's email address info@supplementopt.com marked "Withdrawal of consent to the processing of personal data."
8.5. All information collected by third-party services, including payment systems, communication providers, and other service providers, is stored and processed by these entities (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject is obliged to independently familiarize themselves with the specified documents. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this clause.
8.6. Prohibitions established by the personal data subject on the transfer (other than granting access), as well as on the processing or conditions of processing (other than obtaining access) of personal data authorized for dissemination, do not apply in cases of personal data processing in state, public, and other public interests as defined by the legislation of the Russian Federation.
8.7. The Operator ensures the confidentiality of personal data during its processing.
8.8. The Operator stores personal data in a form that allows for the identification of the personal data subject for no longer than the purposes of personal data processing require, unless the storage period for personal data is established by federal law, or by a contract to which the personal data subject is a party, beneficiary, or guarantor.
8.9. The conditions for terminating personal data processing may include the achievement of the personal data processing purposes, the expiration of the consent period of the personal data subject, the withdrawal of consent by the personal data subject, or a request to terminate personal data processing, as well as the identification of unlawful processing of personal data.
9. List of Actions Performed by the Operator with Received Personal Data
9.1. The Operator carries out the collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (dissemination, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
9.2. The Operator carries out automated processing of personal data with the receipt and/or transmission of the received information via information and telecommunication networks or without such networks.
10. Cross-border Transfer of Personal Data
10.1. Before commencing activities related to the cross-border transfer of personal data, the Operator is obliged to notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out the cross-border transfer of personal data (such notification is sent separately from the notification of the intention to process personal data).
10.2. Before submitting the aforementioned notification, the Operator is obliged to obtain the relevant information from the authorities of the foreign state, foreign individuals, or foreign legal entities to whom the cross-border transfer of personal data is planned.
11. Confidentiality of Personal Data
The Operator and other persons who have gained access to personal data are obliged not to disclose to third parties and not to disseminate personal data without the consent of the personal data subject, unless otherwise provided by federal law.
12. Final Provisions
12.1. The User may obtain any clarifications on issues of interest regarding the processing of their personal data by contacting the Operator via email at info@supplementopt.com.
12.2. 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.
12.3. The current version of the Policy is freely available on the Internet at https://supplementopt.tilda.ws/privacy
