Legal information
Personal Data Processing Policy
The Operator’s policy on the processing of personal data on the Babysmile Group website
This is an English translation provided for convenience. In the event of any discrepancy, the Russian version prevails.
Published: 28 July 2026
1. General provisions
This Personal Data Processing Policy (the “Policy”) has been drawn up in accordance with the personal data legislation of the Russian Federation and is published in fulfilment of the obligation of Limited Liability Company “Bismile” (TIN (INN) 7805735106, KPP 780501001, OGRN 1187847307119, address: Office 304, Letter A, 15A Uryupin Lane, St Petersburg, 198095, Russia) (the “Operator”) to publish a document setting out the Operator’s policy on personal data processing and information on the personal data protection requirements it implements.
The Policy sets out the Operator’s procedure for processing personal data, the purposes of processing, the categories of data subjects, the scope of the data processed, the legal grounds and periods of processing, and the measures taken by the Operator to ensure the security of personal data and to protect the rights of data subjects.
The Policy is publicly available without restriction at https://babysmile.group and may be viewed by any internet user.
The Policy applies to personal data obtained by the Operator through the website https://babysmile.group, including via enquiry forms, when handling requests from data subjects, and through the use of cookies and web analytics services.
The name “Babysmile Group” is used as an umbrella brand for a group of projects and organisations. The operator of the website and of the personal data obtained through it is Bismile LLC.
2. Terms used in the Policy
Personal data — any information relating to a directly or indirectly identified or identifiable individual.
Data subject — an individual who is directly or indirectly identified or identifiable by means of personal data.
Operator — Bismile LLC, which processes personal data and determines the purposes of processing, the scope of personal data and the actions performed with it.
Website — the set of graphic and information materials, computer programs and databases that make them available on the internet at https://babysmile.group.
Personal data processing — any action or set of actions performed with personal data, with or without automation, including collection, recording, systematisation, accumulation, storage, clarification, retrieval, use, transfer, depersonalisation, blocking, deletion and destruction.
Cookies — small pieces of data that a website may store on a user’s device and use to ensure the website works, analyse traffic and improve the user experience.
Confidentiality of personal data — a mandatory requirement for the Operator or any other person who has gained access to personal data not to disclose it to third parties or distribute it without the data subject’s consent or another legal basis.
3. Main rights and obligations of the Operator
The Operator has the right to:
- process personal data in accordance with the stated purposes and legal grounds;
- require the data subject to provide accurate data necessary to achieve the purposes of processing;
- entrust the processing of personal data to another person in the cases and manner provided for by the legislation of the Russian Federation;
- provide personal data to third parties where required by law or necessary to achieve the purposes of processing, subject to the requirements of the law;
- exercise other rights provided for by the legislation of the Russian Federation.
The Operator is obliged to:
- use personal data solely for the purposes specified in this Policy;
- provide the data subject, upon request, with information concerning the processing of their personal data;
- take the necessary legal, organisational and technical measures to protect personal data;
- ensure the confidentiality of personal data;
- when collecting personal data of citizens of the Russian Federation, ensure that such data is recorded, systematised, accumulated, stored, clarified and retrieved using databases located in the territory of the Russian Federation;
- stop processing, destroy or depersonalise personal data in the cases and manner provided for by the legislation of the Russian Federation.
4. Main rights of the data subject
The data subject has the right to:
- receive information concerning the processing of their personal data;
- demand that their personal data be clarified, blocked or destroyed if it is incomplete, outdated, inaccurate, unlawfully obtained or not necessary for the stated purpose of processing;
- withdraw consent to the processing of personal data where processing is based on consent;
- demand that the processing of personal data be stopped in the cases provided for by law;
- appeal against the Operator’s actions or omissions to the authorised body for the protection of the rights of personal data subjects or to a court;
- take other measures provided for by law to protect their rights.
5. Purposes of processing, scope and categories of personal data
The Operator does not process special categories of personal data or biometric personal data through the Website.
| Purpose of processing | Categories of data subjects | Data processed | Legal basis | Processing period |
|---|---|---|---|---|
| Handling an enquiry submitted via the form on the Website and related correspondence | Website users who have submitted an enquiry | Name, phone number, email address, content of the enquiry, organisation and position — if provided voluntarily by the data subject | Consent of the data subject | Until the purpose of processing is achieved or consent is withdrawn, but no longer than 3 years from the date of the enquiry |
| Ensuring the Website works, analysing traffic and improving the user experience | Website users | Cookies, IP address, browser and device information, referral source and UTM tags, data on actions on the Website | Consent of the data subject; the Operator’s legitimate interest in ensuring the Website works | For the lifetime of the relevant cookies, but no longer than 1 year |
| Sending replies, information and business messages on the substance of the enquiry | Website users who have submitted an enquiry | Name, email address, phone number | Consent of the data subject | Until consent is withdrawn |
6. Legal grounds for processing
The legal grounds for processing personal data are: the Constitution of the Russian Federation; Federal Law No. 152-FZ of 27 July 2006 “On Personal Data”; Federal Law No. 149-FZ of 27 July 2006 “On Information, Information Technologies and Information Protection”; the Operator’s constituent documents; agreements concluded between the Operator and data subjects; and the consent of data subjects to the processing of their personal data.
7. Procedure for collection, storage, transfer and other processing
The security of personal data is ensured through the legal, organisational and technical measures necessary to meet the requirements of the legislation of the Russian Federation on personal data protection.
The Operator ensures the safety of personal data and takes measures to prevent access to it by unauthorised persons. The data subject’s personal data is not transferred to third parties, except in cases expressly provided for by the legislation of the Russian Federation and where the Operator engages providers of hosting and technical support services for the Website under an agreement that requires them to maintain confidentiality.
The Operator does not carry out cross-border transfers of personal data.
If inaccuracies are found in personal data, the data subject may update it by sending a notice to the Operator at info@bsmile.ru marked “Personal data update”.
The period of personal data processing is determined by the achievement of the purposes for which the data was collected, unless another period is provided for by an agreement or by law. The data subject may withdraw consent at any time by sending a notice to the Operator at info@bsmile.ru marked “Withdrawal of consent to personal data processing”.
8. Cookies and web analytics
The Website uses cookies necessary for its operation and may also use web analytics services. How they are used and how to opt out is described in a separate document — the “Cookie Notice”.
9. Final provisions
The data subject may obtain any clarification on matters concerning the processing of their personal data by contacting the Operator at info@bsmile.ru.
Any changes to the Operator’s personal data processing policy are reflected in this document. The Policy is valid indefinitely until replaced by a new version.
10. Operator details
Limited Liability Company “Bismile”
TIN (INN) 7805735106 · KPP 780501001 · OGRN 1187847307119
Address: Office 304, Letter A, 15A Uryupin Lane, St Petersburg, 198095, Russia
Email: info@bsmile.ru
Phone: +7 800 775-63-71