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Personal Data Processing Policy
1. General provisions
This Personal Data Processing Policy is drafted in accordance with Federal Law No. 152‑FZ “On Personal Data” dated July 27, 2006, and defines the procedure for processing personal data and the measures taken to ensure the security of personal data by
Individual Entrepreneur XXX
(hereinafter referred to as the “Operator”).
Individual Entrepreneur XXX
(hereinafter referred to as the “Operator”).
1.1. The Operator considers compliance with human and civil rights and freedoms in the processing of personal data, including the protection of privacy and personal and family secrets, to be one of the most important conditions for carrying out its activities.
1.2. This Policy regarding the processing of personal data applies to all information that the Operator may obtain about visitors to the website https://eng.homkahomes.com/.
1.2. This Policy regarding the processing of personal data applies to all information that the Operator may obtain about visitors to the website https://eng.homkahomes.com/.
2. Basic terms used in the Policy
2.1. Automated processing of personal data means processing of personal data using computer technology.
2.2. Blocking of personal data means temporary cessation of personal data processing, except where processing is necessary to clarify personal data.
2.3. Website means a set of graphic and informational materials, as well as software and databases, ensuring their availability on the Internet at https://eng.homkahomes.com/.
2.4. Personal data information system means a set of personal data contained in databases and information technologies and technical means ensuring their processing.
2.5. Depersonalization of personal data means actions making it impossible, without additional information, to determine whether personal data belongs to a particular User or another personal data subject.
2.6. Processing of personal data means any action or set of actions performed with or without automation tools in relation to personal data, including collection, recording, systematization, accumulation, storage, clarification, updating, modification, retrieval, use, transfer, dissemination, provision, access, depersonalization, blocking, deletion, and destruction of personal data.
2.7. Operator means a state body, municipal body, legal entity, or individual that independently or jointly with others organizes and/or performs personal data processing and determines the purposes, scope, and actions performed with personal data.
2.8. Personal data means any information relating directly or indirectly to an identified or identifiable User of the website https://eng.homkahomes.com/.
2.9. Personal data authorized by the personal data subject for dissemination means personal data to which an unlimited number of persons is granted access by the subject through consent in accordance with the Personal Data Law.
2.10. User means any visitor to the website https://eng.homkahomes.com/.
2.11. Provision of personal data means actions aimed at disclosing personal data to a certain person or group of persons.
2.12. Dissemination of personal data means any actions aimed at disclosing personal data to an indefinite number of persons, including publication in mass media, posting in information and telecommunication networks, or providing access in any other way.
2.13. Cross-border transfer of personal data means transfer of personal data to the territory of a foreign state, to a foreign government authority, foreign individual, or foreign legal entity.
2.14. Destruction of personal data means any actions resulting in irreversible destruction of personal data with no possibility of restoring the content of the personal data in an information system and/or destruction of physical media containing personal data.
2.2. Blocking of personal data means temporary cessation of personal data processing, except where processing is necessary to clarify personal data.
2.3. Website means a set of graphic and informational materials, as well as software and databases, ensuring their availability on the Internet at https://eng.homkahomes.com/.
2.4. Personal data information system means a set of personal data contained in databases and information technologies and technical means ensuring their processing.
2.5. Depersonalization of personal data means actions making it impossible, without additional information, to determine whether personal data belongs to a particular User or another personal data subject.
2.6. Processing of personal data means any action or set of actions performed with or without automation tools in relation to personal data, including collection, recording, systematization, accumulation, storage, clarification, updating, modification, retrieval, use, transfer, dissemination, provision, access, depersonalization, blocking, deletion, and destruction of personal data.
2.7. Operator means a state body, municipal body, legal entity, or individual that independently or jointly with others organizes and/or performs personal data processing and determines the purposes, scope, and actions performed with personal data.
2.8. Personal data means any information relating directly or indirectly to an identified or identifiable User of the website https://eng.homkahomes.com/.
2.9. Personal data authorized by the personal data subject for dissemination means personal data to which an unlimited number of persons is granted access by the subject through consent in accordance with the Personal Data Law.
2.10. User means any visitor to the website https://eng.homkahomes.com/.
2.11. Provision of personal data means actions aimed at disclosing personal data to a certain person or group of persons.
2.12. Dissemination of personal data means any actions aimed at disclosing personal data to an indefinite number of persons, including publication in mass media, posting in information and telecommunication networks, or providing access in any other way.
2.13. Cross-border transfer of personal data means transfer of personal data to the territory of a foreign state, to a foreign government authority, foreign individual, or foreign legal entity.
2.14. Destruction of personal data means any actions resulting in irreversible destruction of personal data with no possibility of restoring the content of the personal data in an information system and/or destruction of physical media containing personal data.
3. Main rights and obligations of the Operator
3.1. The Operator has the right to:
— receive accurate information and/or documents containing personal data from the personal data subject;
— continue processing personal data without consent if there are legal grounds under the Personal Data Law, including where consent has been withdrawn;
— independently determine the composition and list of measures necessary and sufficient to comply with the Personal Data Law and related regulations, unless otherwise provided by law.
3.2. The Operator is obliged to:
— provide the personal data subject, upon request, with information relating to the processing of their personal data;
— organize personal data processing in accordance with the legislation of the Russian Federation;
— respond to requests from personal data subjects and their representatives in accordance with the Personal Data Law;
— provide the authorized body for protection of personal data subjects’ rights with the necessary information within 10 days of receiving a request;
— publish or otherwise ensure unrestricted access to this Policy;
— take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, dissemination, and other unlawful actions;
— stop transfer, provision, access, processing, and destroy personal data in cases provided by applicable law;
— fulfill other obligations established by the Personal Data Law.
— receive accurate information and/or documents containing personal data from the personal data subject;
— continue processing personal data without consent if there are legal grounds under the Personal Data Law, including where consent has been withdrawn;
— independently determine the composition and list of measures necessary and sufficient to comply with the Personal Data Law and related regulations, unless otherwise provided by law.
3.2. The Operator is obliged to:
— provide the personal data subject, upon request, with information relating to the processing of their personal data;
— organize personal data processing in accordance with the legislation of the Russian Federation;
— respond to requests from personal data subjects and their representatives in accordance with the Personal Data Law;
— provide the authorized body for protection of personal data subjects’ rights with the necessary information within 10 days of receiving a request;
— publish or otherwise ensure unrestricted access to this Policy;
— take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, dissemination, and other unlawful actions;
— stop transfer, provision, access, processing, and destroy personal data in cases provided by applicable law;
— fulfill other obligations established by the Personal Data Law.
4.1. Personal data subjects have the right to:
— receive information regarding the processing of their personal data, except in cases provided by law;
— require clarification, blocking, or destruction of their personal data if such data are incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the declared purpose of processing;
— require prior consent for processing personal data for the purpose of promoting goods, works, and services on the market;
— withdraw consent to personal data processing and demand termination of processing;
— appeal unlawful actions or inaction of the Operator to the authorized authority or in court;
— exercise other rights provided by Russian law.
4.2. Personal data subjects are obliged to:
— provide the Operator with accurate information about themselves;
— notify the Operator of any clarification, updating, or changes to their personal data.
4.3. Persons who provide the Operator with inaccurate information about themselves, or about another person without that person’s consent, bear liability in accordance with the legislation of the Russian Federation.
— require clarification, blocking, or destruction of their personal data if such data are incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the declared purpose of processing;
— require prior consent for processing personal data for the purpose of promoting goods, works, and services on the market;
— withdraw consent to personal data processing and demand termination of processing;
— appeal unlawful actions or inaction of the Operator to the authorized authority or in court;
— exercise other rights provided by Russian law.
4.2. Personal data subjects are obliged to:
— provide the Operator with accurate information about themselves;
— notify the Operator of any clarification, updating, or changes to their personal data.
4.3. Persons who provide the Operator with inaccurate information about themselves, or about another person without that person’s consent, bear liability in accordance with the legislation of the Russian Federation.
5. Principles of personal data processing
5.1. Personal data shall be processed lawfully and fairly.
5.2. Processing of personal data shall be limited to the achievement of specific, predetermined, and lawful purposes.
5.3. It is not allowed to merge databases containing personal data processed for incompatible purposes.
5.4. Only personal data that meet the purposes of processing shall be processed.
5.5. The content and scope of processed personal data shall correspond to the stated purposes and shall not be excessive.
5.6. The Operator shall ensure the accuracy, sufficiency, and relevance of personal data and take necessary measures to delete or clarify incomplete or inaccurate data.
5.7. Personal data shall be stored in a form allowing identification of the subject for no longer than required by the purposes of processing, unless a longer period is established by federal law or contract.
5.2. Processing of personal data shall be limited to the achievement of specific, predetermined, and lawful purposes.
5.3. It is not allowed to merge databases containing personal data processed for incompatible purposes.
5.4. Only personal data that meet the purposes of processing shall be processed.
5.5. The content and scope of processed personal data shall correspond to the stated purposes and shall not be excessive.
5.6. The Operator shall ensure the accuracy, sufficiency, and relevance of personal data and take necessary measures to delete or clarify incomplete or inaccurate data.
5.7. Personal data shall be stored in a form allowing identification of the subject for no longer than required by the purposes of processing, unless a longer period is established by federal law or contract.
6. Purposes of personal data processing
Purpose of processing:
Informing the User by sending email messages.
Personal data:
- Full name.
- Email address.
- Phone numbers.
Legal grounds:
- Charter and constituent documents of the Operator.
- Agreements concluded between the Operator and the personal data subject.
Types of processing:
- Collection, recording, systematization, accumulation, storage, destruction, and depersonalization of personal data.
- Sending informational emails to the email address.
7. Conditions for personal data processing
7.1. Personal data are processed with the consent of the personal data subject to the processing of his or her personal data.
7.2. Personal data are processed when this is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, and to perform the functions, powers, and duties imposed on the Operator by the legislation of the Russian Federation.
7.3. Personal data are processed when this is necessary for the administration of justice, or for the execution of a court judgment or an act of another body or official that is subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. Personal data are processed when this is necessary for the performance of a contract to which the personal data subject is a party, beneficiary, or guarantor, as well as for entering into 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 are processed when this is necessary to exercise the rights and legitimate interests of the Operator or third parties, or to achieve socially significant purposes, provided that the rights and freedoms of the personal data subject are not thereby violated.
7.6. Personal data are processed where access to them is provided by the personal data subject to an unlimited number of persons or at the subject’s request (hereinafter “personal data made publicly available by the personal data subject”).
7.7. Personal data are processed where they are subject to publication or mandatory disclosure in accordance with a federal law.
7.2. Personal data are processed when this is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, and to perform the functions, powers, and duties imposed on the Operator by the legislation of the Russian Federation.
7.3. Personal data are processed when this is necessary for the administration of justice, or for the execution of a court judgment or an act of another body or official that is subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. Personal data are processed when this is necessary for the performance of a contract to which the personal data subject is a party, beneficiary, or guarantor, as well as for entering into 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 are processed when this is necessary to exercise the rights and legitimate interests of the Operator or third parties, or to achieve socially significant purposes, provided that the rights and freedoms of the personal data subject are not thereby violated.
7.6. Personal data are processed where access to them is provided by the personal data subject to an unlimited number of persons or at the subject’s request (hereinafter “personal data made publicly available by the personal data subject”).
7.7. Personal data are processed where they are subject to publication or mandatory disclosure in accordance with a federal law.
8. Procedure for collection, storage, transfer, and other processing of personal data
The security of personal data processed by the Operator is ensured through legal, organizational, and technical measures necessary to fully comply with current legislation on personal data protection.
8.1. The Operator ensures the safety of personal data and takes all possible measures to prevent unauthorized access.
8.2. The User’s personal data shall never be transferred to third parties except as required by law or where the User has consented to such transfer for the performance of obligations under a civil law contract.
8.3. If inaccuracies in personal data are identified, the User may update them by sending a notification to the Operator’s email address with the subject line “Update of personal data.”
8.4. The period of personal data processing is determined by the purposes for which the personal data were collected, unless otherwise provided by contract or law. The User may withdraw consent at any time by sending an email to the Operator with the subject line “Withdrawal of consent to the processing of personal data.”
8.5. Any information collected by third-party services, including payment systems and communication providers, is stored and processed by such parties in accordance with their own user agreements and privacy policies. The Operator is not liable for the actions of such third parties.
8.6. Restrictions established by the personal data subject regarding transfer or processing of personal data authorized for dissemination do not apply where such processing is carried out in state, public, or other public interests defined by the legislation of the Russian Federation.
8.7. The Operator ensures confidentiality of personal data during processing.
8.8. The Operator stores personal data in a form that allows identification of the personal data subject for no longer than required by the purposes of processing, unless a different storage period is established by law or contract.
8.9. Grounds for termination of personal data processing may include achievement of the processing purposes, expiration of the consent period, withdrawal of consent, demand for termination of processing, or detection of unlawful processing.
8.2. The User’s personal data shall never be transferred to third parties except as required by law or where the User has consented to such transfer for the performance of obligations under a civil law contract.
8.3. If inaccuracies in personal data are identified, the User may update them by sending a notification to the Operator’s email address with the subject line “Update of personal data.”
8.4. The period of personal data processing is determined by the purposes for which the personal data were collected, unless otherwise provided by contract or law. The User may withdraw consent at any time by sending an email to the Operator with the subject line “Withdrawal of consent to the processing of personal data.”
8.5. Any information collected by third-party services, including payment systems and communication providers, is stored and processed by such parties in accordance with their own user agreements and privacy policies. The Operator is not liable for the actions of such third parties.
8.6. Restrictions established by the personal data subject regarding transfer or processing of personal data authorized for dissemination do not apply where such processing is carried out in state, public, or other public interests defined by the legislation of the Russian Federation.
8.7. The Operator ensures confidentiality of personal data during processing.
8.8. The Operator stores personal data in a form that allows identification of the personal data subject for no longer than required by the purposes of processing, unless a different storage period is established by law or contract.
8.9. Grounds for termination of personal data processing may include achievement of the processing purposes, expiration of the consent period, withdrawal of consent, demand for termination of processing, or detection of unlawful processing.
9. List of actions performed by the Operator with personal data
9.1. The Operator collects, records, systematizes, accumulates, stores, updates, retrieves, uses, transfers, depersonalizes, blocks, deletes, and destroys personal data.
9.2. The Operator performs automated processing of personal data with and/or without transmission of information through information and telecommunication networks.
9.2. The Operator performs automated processing of personal data with and/or without transmission of information through information and telecommunication networks.
10. Cross-border transfer of personal data
10.1. Before commencing cross-border transfer of personal data, the Operator shall notify the authorized authority for the protection of personal data subjects’ rights of its intention to carry out such transfer.
10.2. Before submitting such notification, the Operator shall obtain relevant information from foreign state authorities, foreign individuals, or foreign legal entities to whom the transfer is planned.
10.2. Before submitting such notification, the Operator shall obtain relevant information from foreign state authorities, foreign individuals, or foreign legal entities to whom the transfer is planned.
11. Confidentiality of personal data
The Operator and other persons who have access to personal data are obliged not to disclose or disseminate personal data to third parties 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 regarding the processing of personal data by contacting the Operator by email.
12.2. Any changes to the personal data processing policy will be reflected in this document. The Policy remains valid indefinitely until replaced by a new version.
12.3. The current version of the Policy is publicly available on the Internet at: https://eng.homkahomes.com/policy.
12.2. Any changes to the personal data processing policy will be reflected in this document. The Policy remains valid indefinitely until replaced by a new version.
12.3. The current version of the Policy is publicly available on the Internet at: https://eng.homkahomes.com/policy.