Personal data processing policy

Current version. Last updated: 21 October 2026

1. General provisions

1.1. This policy is drawn up in accordance with Federal Law of the Russian Federation No. 152-FZ of 27 July 2006 “On Personal Data” and sets out how personal data is processed and protected by sole proprietor Evgeniy Vladimirovich Kolesnikov (hereinafter — the Operator).

1.2. The Operator regards respect for human rights and freedoms during the processing of personal data, including the right to privacy and to personal and family confidentiality, as a condition of carrying on its activity.

1.3. This policy applies to all information the Operator may receive about visitors of the website kangen.johnnykole.com, including its English version, and about people who submit the request form on that website.

2. Terms used in this policy

2.1. Personal data — any information relating directly or indirectly to an identified or identifiable individual (the data subject).

2.2. Processing of personal data — any action or set of actions performed with personal data with or without automation tools, including collection, recording, systematisation, accumulation, storage, amendment, retrieval, use, transfer, depersonalisation, blocking, erasure and destruction.

2.3. Operator — sole proprietor Evgeniy Vladimirovich Kolesnikov, who organises and carries out the processing of personal data and determines its purposes and scope.

2.4. Website — the set of materials, programs and databases available on the internet at kangen.johnnykole.com.

2.5. User — any visitor of the website.

2.6. Blocking — temporary suspension of processing; destruction — actions after which personal data cannot be restored.

3. Rights and obligations of the Operator

3.1. The Operator has the right to receive accurate information and documents from the data subject, to continue processing without consent in the cases provided by law, and to determine the scope of measures required to protect the data.

3.2. The Operator is obliged to provide the data subject with information about the processing on request, to process data lawfully, to reply to enquiries from the data subject and from the supervisory authority, to publish this policy, and to take legal, organisational and technical measures protecting the data from unlawful access, destruction, alteration, copying or distribution.

4. Rights and obligations of the data subject

4.1. The data subject has the right to receive information about the processing of their personal data, to demand that inaccurate data be corrected, that unlawfully processed data be blocked or destroyed, to withdraw consent at any time, to object to the processing, and to complain to the supervisory authority or to a court.

4.2. The data subject is obliged to provide accurate data about themselves and to inform the Operator when that data changes.

4.3. Anyone who submits personal data of a third party to the Operator is responsible for having that person’s consent.

5. Principles of processing

5.1. Processing is lawful and fair.

5.2. Processing is limited to the achievement of specific, predetermined and legitimate purposes; processing incompatible with those purposes is not allowed.

5.3. Databases containing personal data processed for incompatible purposes are not combined.

5.4. Only the data that is necessary for the stated purposes is processed.

5.5. The Operator keeps the data accurate and up to date, and takes measures to erase or correct incomplete or inaccurate data.

5.6. Personal data is kept in a form that allows the data subject to be identified for no longer than the purposes of processing require, unless a different period is set by law or by contract.

6. Purposes of processing

6.1. The Operator processes personal data in order to:

  • reply to enquiries and consultation requests sent through the website;
  • prepare and complete orders for Enagic equipment, including delivery and the documents that go with it;
  • support people who decide to become Enagic distributors, where they ask for such support;
  • fulfil the obligations that Russian law places on the Operator, including tax and accounting obligations.

6.2. The Operator does not take decisions producing legal effects for the data subject on the basis of automated processing alone.

7. Data processed and legal basis

7.1. Through the request form the Operator may receive: full name; telephone number; email address; country, city, postcode and delivery address; the chosen product and payment method; free-text comments; and, where the person applies as a distributor, the registration number, tax number, tax regime and a company details file attached voluntarily.

7.2. The Operator does not collect special categories of personal data (race, nationality, political views, religious or philosophical beliefs, health, intimate life) or biometric personal data.

7.3. Personal data is processed on the basis of the consent given by ticking the consent box in the form, and also where processing is necessary to perform a contract to which the data subject is a party, or to comply with a legal obligation of the Operator.

7.4. Providing data is voluntary. Without a name and a means of contact the Operator cannot reply to an enquiry or complete an order.

8. Collection, storage and transfer

8.1. Data submitted through the website form is transmitted over an encrypted connection and stored in the Operator’s information system at platform.johnnykole.com, hosted on servers located in the Russian Federation.

8.2. The Operator ensures the security of personal data with organisational and technical measures, including restricted access, encrypted connections, regular backups and monitoring.

8.3. Personal data may be disclosed to third parties only with the consent of the data subject, or where the law requires it, or where it is necessary to complete an order — for example to a delivery service or to Enagic when an order is placed.

8.4. Personal data is kept for as long as the purposes of processing require, and for the period set by tax and accounting rules where those apply.

8.5. In the event of inaccurate data being found, the Operator blocks it from the moment the request is received and corrects it within seven working days.

8.6. Where unlawful processing is established, the Operator stops it and destroys the data within thirty days of the request, and informs the data subject.

8.7. Consent may be withdrawn at any time by writing to privacy@johnnykole.com. The Operator then stops processing and destroys the data, unless the law requires it to be kept.

9. Actions performed with personal data

9.1. The Operator carries out collection, recording, systematisation, accumulation, storage, amendment, retrieval, use, transfer, depersonalisation, blocking, erasure and destruction of personal data.

9.2. Processing is carried out both with and without automation tools.

10. Cross-border transfer

10.1. The Operator does not transfer personal data to foreign states as a matter of routine. Where an order requires equipment to be shipped from abroad, the data needed for delivery is transferred to Enagic and to the carrier, within the limits set by Russian law on cross-border transfer.

11. Confidentiality

11.1. The Operator and anyone who gains access to personal data are obliged not to disclose it to third parties and not to distribute it without the consent of the data subject, unless the law provides otherwise.

12. Cookies

12.1. A cookie is a small piece of data that a website stores in the visitor’s browser. The Operator uses cookies only for the website to work and does not pass them to third parties.

12.2. The website does not use advertising cookies and does not build advertising profiles of its visitors.

12.3. A visitor may delete stored cookies or forbid them in the browser settings at any time. Some parts of the website may stop working if cookies are disabled.

13. Final provisions

13.1. The data subject may obtain any clarification about the processing of their personal data by writing to privacy@johnnykole.com.

13.2. This document reflects any change in the Operator’s policy on personal data. It is valid indefinitely until replaced by a new version.

13.3. The current version is freely available on the internet at this address.

13.4. This text is an English translation provided for convenience. The processing of personal data is governed by the law of the Russian Federation, and the Russian original of this policy has legal force. In the event of any discrepancy, the Russian text prevails.