Privacy Policy

Website https: www .hsr.ru HSR LLC

GENERAL PROVISIONS:

1.1 Definition and purpose of the Personal Data Processing Policy

The privacy policy of the website www.hsr.ru (hereinafter referred to as the Website) determines the procedure for receiving, recording, processing, accumulation and storage of information related to the personal data of the Website users.

The policy is intended to inform users about who, how, for what purpose and to what extent collects and processes data of users of the Site.

1.2 Scope of the Policy

This Privacy Policy applies to the processing of personal data of the Site users. The User Agreement regulating the procedure for using the Site, its software and design is located at the link www . hsr . ru .

Terms and definitions

Term	Definition
User of the Site, User	Individuals viewing information posted on the Site and using the Site for personal purposes.
Personal data (PD)	Any information relating to a directly or indirectly identified or identifiable individual (subject of personal data), for example, the user’s name and email address in aggregate or other data that is directly or indirectly related to an individual who can be identified or determined from the mass of other users of the Site.
Personal data operator, Operator	A legal entity that, independently or jointly with other persons, organizes and/or carries out the processing of personal data, as well as determines the purposes of processing personal data, the composition of personal data subject to processing, and the actions (operations) performed with personal data. On the Website www.hsr.ru the Operator of personal data is LLC “HSR”, INN 5047212828, OGRN 1185029014059, address 141401, Moscow region, Khimki, Transportny proezd, vl. 4, e – mail : info@hsr.ru
Subject of personal data	Directly or indirectly, a defined or determinable natural person. For example, a User of the Site.
Cookies	This is a small piece of data that the Site requests from the User’s mobile device. Cookie technology allows the Site to “remember” the User’s actions or preferences. Cookies are stored locally on the User’s mobile device. Users can delete saved cookies at their discretion through their browser settings.
Processing of personal data	This is any action (operation) or set of actions (operations) performed with the use of automation tools or without the use of such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
Confidentiality of personal data	The Operator is required to comply with the requirement not to allow their disclosure and distribution without a legal basis.

Grounds and principles of processing personal data by the Operator

1.4.1 The Operator is a Russian legal entity and carries out its activities on the territory of the Russian Federation. The Operator’s activities are aimed at Russian users, citizens of the Russian Federation or persons residing on the territory of the Russian Federation, and are not aimed at making a profit or carrying out other activities outside the territory of the Russian Federation, therefore the Operator is guided by:

– The Constitution of the Russian Federation

– Federal Law No. 152-FZ “On Personal Data” (hereinafter referred to as 152-FZ).

– Civil Code of the Russian Federation

– other laws and by-laws governing the processing of personal data in the Russian Federation

1.4.2 The Operator’s activities are based on the following principles:

– Legality.

– Justice.

– Data minimization.

– Targeted data processing.

– Urgency of data processing.

– Data privacy.

– Localization of data processing.

– The operator does not carry out cross-border transfer of personal data.

PURPOSES OF USER DATA PROCESSING, TYPES AND VOLUME OF PROCESSED DATA

2.1 Purposes, types and volume of processed personal data

Processing purpose No. 1	Authorization of Site Users
Description of the process	To apply for a commercial offer, the user must provide their contact information
List of data	Phone number Email address Surname Name Patronymic Company name Job title
Actions performed with personal data	Collection, recording, systematization, accumulation, storage, clarification, extraction, use, transfer, blocking, deletion, destruction.
Legal basis	p. 5 part 1 art. 6 152-FZ of 27.07.2006 No. 152-FZ p. 1 part 1 art. 6 152-FZ of 27.07.2006 No. 152-FZ
Third parties involved in the processing process	No
Processing period and conditions for termination of processing	from the moment the form is submitted until the moment of withdrawal
Processing purpose No. 2	Tracking User activity, analyzing User behavior, ensuring normal functioning of the Site
Description of the process	For the specified purposes, the Site collects and processes cookies and other User data.
List of data	Geolocation IP address, connection point data Data about the mobile device, including data on statistics of visits and use of sections of the Site (including clicks, scrolls ) Cookies (essential cookies , session cookies , statistical cookies , persistent cookies , trackers cookies )
Actions performed with personal data	Collection, recording, systematization, accumulation, storage, clarification, extraction, use, transfer, blocking, deletion, destruction.
Legal basis	p. 1 part 1 art. 6 152-FZ
Processing period and conditions for termination of processing	from the moment the form is submitted until the moment of withdrawal

3. OPERATOR’S RESPONSIBILITIES

3.1. The operator is obliged to:

3.1.1. Use personal data solely for the purposes specified in this Policy.

3.1.2. Ensure that personal data is kept secret, not disclosed without the prior written permission of the User, and not sold, exchanged, published or disclosed in any other possible way the transferred personal data of the User, except as provided for in this Policy and legislation.

3.1.3. To ensure the protection of the User’s personal data during their processing, take legal, organizational and technical measures against unauthorized, illegal or accidental access to personal data, destruction, modification, blocking, copying, provision, distribution of personal data, as well as other illegal actions in relation to personal data, namely:

3.1.3.1 Appoint a person responsible for organizing the processing of personal data, issue documents defining the operator’s policy regarding the processing of personal data, local acts on issues of processing personal data, defining for each purpose of processing personal data the categories and list of personal data to be processed, the categories of subjects whose personal data are processed, the methods and terms of their processing and storage, the procedure for the destruction of personal data upon achieving the purposes of their processing or upon the occurrence of other legal grounds, as well as local acts establishing procedures aimed at preventing and identifying violations of the legislation of the Russian Federation, eliminating the consequences of such violations.

3.1.3.2 Apply legal, organizational and technical measures to ensure the security of personal data in accordance with Federal Law No. 152 (Article 19).

3.1.3.3. Carry out internal control and (or) audit of compliance of personal data processing with Federal Law No. 152 and regulatory legal acts adopted in accordance with it, requirements for the protection of personal data, the operator’s policy regarding the processing of personal data, and the operator’s local acts;

3.1.3.4 Conduct an assessment of the harm in accordance with the requirements established by the authorized body for the protection of the rights of personal data subjects, which may be caused to personal data subjects in the event of a violation of this Federal Law, the ratio of the said harm and the measures taken by the operator aimed at ensuring the fulfillment of the obligations stipulated by this Federal Law;

3.1.3.5 Familiarize the operator’s employees directly involved in the processing of personal data with the provisions of the legislation of the Russian Federation on personal data, including requirements for the protection of personal data, documents defining the operator’s policy regarding the processing of personal data, local acts on issues of processing personal data, and (or) train the said employees.

3.1.4. Block personal data related to the relevant User from the moment of the User’s request or appeal or their legal representative or authorized body for the protection of the rights of personal data subjects for the period of verification in the event of detection of inaccurate personal data or illegal actions.

3.1.5 Stop processing personal data when the subject revokes consent to the processing of personal data, the purpose of processing personal data is achieved or the need to achieve such purpose is lost, the data processing period has expired, upon receipt of a request from an authorized government agency to destroy inaccurate or illegally obtained personal data, upon detection of illegal processing of personal data within the timeframes stipulated by law, and destroy personal data in the manner and cases stipulated by law and the Operator’s internal acts.

4. INTERACTION WITH THE OPERATOR

4.1 The User or other subject of personal data has the right to send the Operator requests provided for by Federal Law 152.

sent to the e-mail address info@hsr.ru or in writing to the address 141401, Moscow region, Khimki, Transportny proezd, vl. 4.

5. LIABILITY OF THE PARTIES

5.1. The Operator who has failed to fulfill its obligations shall be liable for losses incurred by the User in connection with the unlawful use of personal data, in accordance with the legislation of the Russian Federation.

6. ADDITIONAL TERMS

6.1. The Operator has the right to make changes to this Privacy Policy without the consent of the User.

6.2. The Operator has no way to verify the relevance and accuracy of the information provided by Users. The Operator assumes that Users provide reliable and sufficient personal data.

6.3. The new Privacy Policy comes into effect from the moment it is posted.

6.4. By using the Site, the User accepts the terms of this Policy. In case of disagreement with the terms of this Policy, the User has the right not to use the Site.

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