PRIVACY POLICY
If you reside in the region of California, you may review the CCPA Notice (California)

Last updated: June 4, 2026

1. CONTROLLER INFORMATION

Individual Entrepreneur Kovaleva Daria Olegovna
Tax ID (INN): 550516410817
Legal address: Russia, Moscow Region, Krasnogorsk, Volnaya Street, Building 2
Email for legal matters: info@somanails.com
Customer support: support@somanails.com
Instagram: @soma.nailstore

2. PERSONAL DATA WE COLLECT

When you use our website, we collect the following information:

When you place an order:
- Full name
- Billing and shipping address
- Email address
- Phone number (if provided)
- Order details (products, quantity, price)

When you subscribe to our email newsletter:
- Email address
- Name (optional)
- Subscription date and IP address at subscription

When you browse our website (via Google Analytics):
- IP address (anonymized)
- Browser type and version
- Operating system
- Pages visited and time spent
- Referring website
- Approximate location (city/country level)

Payment information:
- We do NOT store your full credit/debit card details
- Payments are processed by Cloud Payments. Your card information goes directly to them, not to us
- We receive only: payment status, amount, and last 4 digits of the card

3. HOW WE COLLECT YOUR DATA

We collect data:
- Directly from you: when you fill forms, place orders, or subscribe to newsletter
- Automatically: via cookies and Google Analytics when you browse our site
- From payment processor: Cloud Payments sends us transaction confirmation

4. LEGAL BASIS FOR PROCESSING (for European Economic Area customers)

Under GDPR, we process your data based on:

| Purpose | Legal Basis |
|---------|-------------|
| Processing and delivering your order | Contract performance |
| Sending order confirmation and shipping updates | Contract performance |
| Customer support | Contract performance |
| Email newsletter (if you subscribed) | Your consent |
| Google Analytics (non-essential cookies) | Your consent |
| Fraud prevention and security | Legitimate interest |
| Tax and accounting records | Legal obligation |

You may withdraw consent for marketing and analytics at any time.

5. HOW WE USE YOUR DATA

We use your personal data for:

Order Processing:
- Confirm your order via email
- Process payment through Cloud Payments
- Pack and ship your order to your address
- Provide tracking information
- Handle returns and refunds

Email Marketing (only if you subscribed):
- Send promotional offers and new product announcements
- Send educational content about file manicure
- You can unsubscribe anytime by clicking "unsubscribe" link in any email

Website Improvement:
- Analyze how visitors use somanails.com via Google Analytics
- No personal identification – aggregate data only

Legal Compliance:
- Maintain records as required by Russian tax law (5 years)
- Respond to legal requests from authorities

6. COOKIES AND TRACKING TECHNOLOGIES

We use the following cookies:

Essential Cookies (no consent required – necessary for site function):
- session_id – keeps you logged in during your visit
- cart – remembers items in your shopping cart
- csrf_token – security against cross-site request forgery

Analytics Cookies (require your consent):
- _ga – Google Analytics, expires after 2 years
- _gid – Google Analytics, expires after 24 hours
- _gat – Google Analytics, limits request rate

We do NOT use:
- Facebook Pixel
- TikTok Pixel
- Any advertising or remarketing pixels
- Third-party advertising cookies

Cookie Banner:
When you first visit somanails.com, a cookie banner will appear asking for your consent to analytics cookies. You can change your preference anytime via the "Cookie Settings" link in our footer.

7. GOOGLE ANALYTICS – DETAILED INFORMATION

We use Google Analytics to understand website traffic and user behavior. Google Analytics sets cookies that store:

- Time of visit
- Pages viewed
- Time spent on each page
- How you arrived at our site (search engine, direct, referral)
- Device type and browser
- Approximate geographic location (country/city level – not your exact address)

Google Analytics does NOT collect:
- Your name
- Your email address
- Your phone number
- Your exact street address

Google processes this data according to its own privacy policy: https://policies.google.com/privacy

You can completely opt out of Google Analytics across all websites by installing this browser add-on: https://tools.google.com/dlpage/gaoptout

8. INTERNATIONAL DATA TRANSFER

Your personal data is transferred to and stored on servers located in Russia.

Please be aware:
- Russian data protection laws may not be considered "adequate" by the European Commission
- This means your data may not have the same legal protections as in your country (EU, USA, Brazil, etc.)

By using our website and providing your data, you acknowledge and consent to this transfer.

We do not sell, rent, or trade your personal data to any third parties. We only share data with essential service providers (see Section 9).

9. WHO WE SHARE YOUR DATA WITH

We share your data only with:

Cloud Payments (payment processor):
- Receives: payment card details, billing address, order total
- Purpose: to charge your card
- Their privacy policy: [insert Cloud Payments privacy policy URL if available]

Shipping Carriers (DHL, EMS, Russian Post, etc.):
- Receives: your name, shipping address, phone number
- Purpose: to deliver your order

Google LLC (Google Analytics):
- Receives: anonymized browsing data (no name, email, or address)
- Purpose: website analytics
- Their privacy policy: https://policies.google.com/privacy

Email Marketing Platform (if you subscribe):
- Receives: your email address and name (if provided)
- Purpose: to send you newsletters
- [Platform name and privacy policy – add when you choose one]

We do NOT share your data with:
- Advertising networks
- Data brokers
- Any other third parties for marketing purposes

10. DATA RETENTION PERIOD

We keep your personal data for the following periods:

| Data Type | Retention Period |
|-----------|------------------|
| Order information (name, address, order details) | 5 years (required by Russian tax law) |
| Email newsletter subscription | Until you unsubscribe |
| Google Analytics data | 26 months (Google's default) |
| Customer support correspondence | 2 years after last contact |

After the retention period expires, we delete or anonymize your data.

11. YOUR RIGHTS – BY REGION

11.1. For European Union Customers (GDPR)

You have the right to:
- ACCESS: Request a copy of all data we hold about you
- RECTIFICATION: Correct inaccurate or incomplete data
- ERASURE ("right to be forgotten"): Request deletion of your data
- RESTRICT PROCESSING: Limit how we use your data
- DATA PORTABILITY: Receive your data in a machine-readable format
- OBJECT: Object to processing based on legitimate interests
- WITHDRAW CONSENT: Withdraw marketing or analytics consent anytime

To exercise these rights: email support@somanails.com with "GDPR Request" in the subject line.

We will respond within 30 days.

If you are not satisfied with our response, you have the right to lodge a complaint with your local Data Protection Authority (DPA). Find your DPA at: https://edpb.europa.eu/about-edpb/about-edpb/members_en

11.2. For California Residents (CCPA)

You have the right to:
- KNOW: Request disclosure of what personal information we collect, use, and share
- DELETE: Request deletion of your personal information (subject to legal exceptions)
- OPT OUT: Direct us not to "sell" your personal information – WE DO NOT SELL YOUR DATA
- NON-DISCRIMINATION: Exercise your rights without receiving poorer service or prices

To exercise these rights: email support@somanails.com with "CCPA Request" in the subject line.

We will verify your identity before responding. We may ask for your order number or email address used on our site.

We respond within 45 days.

11.3. For Brazilian Customers (LGPD – Lei Geral de Proteção de Dados)

You have the right to:
- CONFIRMATION: Confirm whether we process your data
- ACCESS: Request access to your data
- CORRECTION: Correct incomplete, inaccurate, or outdated data
- ANONYMIZATION: Request anonymization, blocking, or deletion of unnecessary data
- PORTABILITY: Request data portability
- DELETION: Request deletion of data processed with your consent
- INFORMATION: Know which entities we share your data with
- WITHDRAW CONSENT: Withdraw consent at any time

To exercise these rights: email support@somanails.com with "LGPD Request" in the subject line.

We respond within 15 days.

12. EMAIL MARKETING – SUBSCRIPTION AND UNSUBSCRIBE

We use an email marketing platform (to be selected) to send newsletters to subscribers.

Subscription:
- You subscribe by checking a box on our website (opt-in)
- We do NOT add you automatically
- We keep proof of your consent (date, time, IP address)

What we send:
- New product announcements
- Promotional offers and discounts
- Educational content about file manicure and pedicure

Frequency: maximum 4 emails per month

Unsubscribe:
- Every email contains an "unsubscribe" link at the bottom
- Clicking it will remove you from our list immediately
- You will receive no further marketing emails from us

Transactional emails (order confirmation, shipping updates) are NOT affected by unsubscribe – you will always receive these as part of your purchase.

13. CHILDREN'S PRIVACY

Our website and products are not intended for children under 16 years old. We do not knowingly collect personal information from anyone under 16.

If you believe we have collected data from a child under 16, please contact us at support@somanails.com and we will delete it immediately.

14. SECURITY MEASURES

We implement reasonable security measures to protect your data:
- SSL/TLS encryption (HTTPS) for all data transmission
- Regular software updates
- Limited employee access to order data
- Video-recorded packaging (as noted on your package)

However, no internet transmission is 100% secure. You use our website at your own risk.

15. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time. Changes become effective on the "Last updated" date at the top of this page.

If we make material changes, we will notify you:
- By email (if you have an account or recent order)
- Or via a banner on our website

We encourage you to review this page periodically.

16. CONTACT INFORMATION

For any privacy-related questions or to exercise your rights:

Email: support@somanails.com
Legal matters: info@somanails.com
Instagram: @soma.nailstore

For data protection inquiries specifically, please include "Privacy Request" in your email subject line.

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Last reviewed: June 4, 2026