Personal Data Processing Policy

1. General Provisions

This personal data processing policy is compiled in accordance with the requirements of Federal Law No. 152-FZ dated July 27, 2006 "On Personal Data" (hereinafter - the Personal Data Law) and defines the procedure for processing personal data and measures to ensure the security of personal data taken by Hive Home Real Estate Agency (hereinafter - the Operator).
1.1. The Operator sets as its most important goal and condition for carrying out its activities the observance of human and civil rights and freedoms when processing personal data, including protection of rights to privacy, personal and family secrets.
1.2. This Operator's policy regarding personal data processing (hereinafter - the Policy) applies to all information that the Operator may obtain about visitors to the website https://hivehomeestate.com/en.

2. Basic Concepts Used in the Policy

2.1. Automated processing of personal data - processing of personal data using computer technology.
2.2. Blocking of personal data - temporary cessation of personal data processing (except in cases where processing is necessary to clarify personal data).
2.3. Website - a collection of graphic and informational materials, as well as computer programs and databases ensuring their accessibility on the Internet at the network address https://hivehomeestate.com/en.
2.4. Personal data information system - a collection of personal data contained in databases and information technologies and technical means ensuring their processing.
2.5. Depersonalization of personal data - actions as a result of which it is impossible to determine without using additional information the belonging of personal data to a specific User or other personal data subject.
2.6. Personal data processing - any action (operation) or set of actions (operations) performed using automation tools or without using 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.
2.7. Operator - a state body, municipal body, legal or natural person, independently or jointly with other persons organizing and (or) carrying out personal data processing, as well as determining the purposes of personal data processing, the composition of personal data to be processed, actions (operations) performed with personal data.
2.8. Personal data - any information relating directly or indirectly to a specific or identifiable User of the website https://hivehomeestate.com/en.
2.9. Personal data permitted by the personal data subject for distribution - personal data to which access by an unlimited number of persons is provided by the personal data subject by giving consent to the processing of personal data permitted by the personal data subject for distribution in the manner provided for by the Personal Data Law (hereinafter - personal data permitted for distribution).
2.10. User - any visitor to the website https://hivehomeestate.com/en.
2.11. Provision of personal data - actions aimed at disclosing personal data to a specific person or a specific circle of persons.
2.12. Distribution of personal data - any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or familiarizing with personal data an unlimited circle of persons, including publication of personal data in mass media, placement in information and telecommunication networks or providing access to personal data in any other way.
2.13. Cross-border transfer of personal data - transfer of personal data to the territory of a foreign state to a foreign state authority, foreign natural or foreign legal person.
2.14. Destruction of personal data - any actions as a result of which personal data is irretrievably destroyed with the impossibility of further restoration of personal data content in the personal data information system and (or) material carriers of personal data are destroyed.

3. Basic Rights and Obligations of the Operator

3.1. The Operator has the right:
– to receive reliable information and/or documents containing personal data from the personal data subject;
– in case of withdrawal by the personal data subject of consent to personal data processing, the Operator has the right to continue processing personal data without the consent of the personal data subject if there are grounds specified in the Personal Data Law;
– to independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations provided for by the Personal Data Law and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.
3.2. The Operator is obliged:
– to provide the personal data subject, at their request, with information regarding the processing of their personal data;
– to organize personal data processing in the manner established by the current legislation of the Russian Federation;
– to respond to appeals and requests from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
– to report to the authorized body for the protection of personal data subjects' rights, upon request of this body, the necessary information within 30 days from the date of receipt of such request;
– to publish or otherwise ensure unlimited access to this Policy regarding personal data processing;
– to take legal, organizational and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other unlawful actions regarding personal data;
– to cease transfer (distribution, provision, access) of personal data, cease processing and destroy personal data in the manner and cases provided for by the Personal Data Law;
– to fulfill other obligations provided for by the Personal Data Law.

4. Basic Rights and Obligations of Personal Data Subjects

4.1. Personal data subjects have the right:
– to receive information regarding the processing of their personal data, except in cases provided for by federal laws. Information is provided to the personal data subject by the Operator in an accessible form, and it should not contain personal data relating to other personal data subjects, except in cases where there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it is established by the Personal Data Law;
– to demand from the operator clarification of their personal data, their blocking or destruction if the personal data is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing, as well as to take measures provided by law to protect their rights;
– to put forward the condition of prior consent when processing personal data for the purpose of promoting goods, works and services on the market;
– to withdraw consent to personal data processing;
– to appeal to the authorized body for the protection of personal data subjects' rights or in court the unlawful actions or inaction of the Operator when processing their personal data;
– to exercise other rights provided for by the legislation of the Russian Federation.
4.2. Personal data subjects are obliged:
– to provide the Operator with reliable data about themselves;
– to inform the Operator about clarification (updating, modification) of their personal data.
4.3. Persons who provided the Operator with false information about themselves or information about another personal data subject without the latter's consent are liable in accordance with the legislation of the Russian Federation.

5. The Operator may process the following personal data of the User

5.1. Last name, first name, patronymic.
5.2. Email address.
5.3. Phone numbers.
5.4. Year, month, date, and place of birth.
5.5 Photographs
5.6. The site also collects and processes depersonalized data about visitors (including cookies) using Internet statistics services (Yandex Metrica and Google Analytics and others).
5.7. The above data hereinafter in the text of the Policy are united by the general concept of Personal Data.
5.8. Processing of special categories of personal data relating to race, nationality, political views, religious or philosophical beliefs, intimate life is not carried out by the Operator.
5.9. Processing of personal data permitted for distribution from among the special categories of personal data specified in part 1 of article 10 of the Personal Data Law is allowed if the prohibitions and conditions provided for in article 10.1 of the Personal Data Law are observed.
5.10. User consent to the processing of personal data permitted for distribution is issued separately from other consents to personal data processing. In this case, the conditions provided for, in particular, by article 10.1 of the Personal Data Law are observed. The requirements for the content of such consent are established by the authorized body for the protection of personal data subjects' rights.
5.10.1. The User provides consent to the processing of personal data permitted for distribution directly to the Operator.
5.10.2. The Operator is obliged no later than three working days from the moment of receiving the specified User consent to publish information about processing conditions, about the existence of prohibitions and conditions for processing by an unlimited circle of persons personal data permitted for distribution.
5.10.3. Transfer (distribution, provision, access) of personal data permitted by the personal data subject for distribution must be stopped at any time upon request of the personal data subject. This request must include the last name, first name, patronymic (if any), contact information (phone number, email address or postal address) of the personal data subject, as well as a list of personal data whose processing is to be terminated. The personal data specified in this request may be processed only by the Operator to whom it is addressed.
5.10.4. Consent to the processing of personal data permitted for distribution ceases to be effective from the moment the Operator receives the request specified in clause 5.10.3 of this Policy regarding the processing of personal data.

6. Principles of personal data processing

6.1. Personal data processing is carried out on a legal and fair basis.
6.2. Personal data processing is limited to achieving specific, predetermined and legitimate purposes. Processing of personal data incompatible with the purposes of personal data collection is not allowed.
6.3. It is not allowed to combine databases containing personal data, the processing of which is carried out for purposes incompatible with each other.
6.4. Only personal data that meets the purposes of their processing are subject to processing.
6.5. The content and volume of processed personal data correspond to the stated purposes of processing. Redundancy of processed personal data in relation to the stated purposes of their processing is not allowed.
6.6. When processing personal data, the accuracy of personal data, their sufficiency, and where necessary, relevance in relation to the purposes of personal data processing is ensured. The operator takes the necessary measures and/or ensures their taking to delete or clarify incomplete or inaccurate data.
6.7. Personal data storage is carried out in a form that allows determining the personal data subject no longer than required by the purposes of personal data processing, unless the period of personal data storage is established by federal law, an agreement to which the personal data subject is a party, beneficiary or guarantor. Processed personal data is destroyed or depersonalized upon achievement of processing purposes or in case of loss of necessity to achieve these purposes, unless otherwise provided by federal law.

7. Purposes of personal data processing

7.1. The purpose of processing the User's personal data:
– informing the User by sending electronic letters;
– conclusion, execution and termination of civil law contracts;
– providing the User with access to services, information and/or materials contained on the website https://hivehomeestate.com/en.
7.2. The Operator also has the right to send the User notifications about new products and services, special offers and various events. The User can always refuse to receive informational messages by sending the Operator a letter to the email address info@hivehomeestate.com with the note "Refusal of notifications about new products and services and special offers".
7.3. Depersonalized User data collected using Internet statistics services is used to collect information about User actions on the site, improve the quality of the site and its content.

8. Legal grounds for personal data processing

8.1. The legal grounds for personal data processing by the Operator are:
Federal Law "On Information, Information Technologies and Information Protection" dated July 27, 2006 No. 149-FZ;
– federal laws, other regulatory legal acts in the field of personal data protection;
– consent of Users to the processing of their personal data, to the processing of personal data permitted for distribution.
8.2. The Operator processes the User's personal data only if they are filled in and/or sent by the User independently through special forms located on the website https://hivehomeestate.com/en or sent to the Operator via email. By filling in the corresponding forms and/or sending their personal data to the Operator, the User expresses their consent to this Policy.
8.3. The Operator processes depersonalized data about the User if this is allowed in the User's browser settings (saving cookies and using JavaScript technology is enabled).
8.4. The personal data subject independently decides on providing their personal data and gives consent freely, by their own will and in their interest.

9. Conditions of personal data processing

9.1. Personal data processing is carried out with the consent of the personal data subject to the processing of their personal data.
9.2. Personal data processing is necessary to achieve the goals provided for by international agreement of the Russian Federation or law, to implement the functions, powers and duties imposed by the legislation of the Russian Federation on the operator.
9.3. Personal data processing is necessary for the administration of justice, execution of a court sentence, act of another body or official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
9.4. Personal data processing is necessary for the performance of an agreement to which the personal data subject is a party or beneficiary or guarantor, as well as for concluding an agreement on the initiative of the personal data subject or an agreement under which the personal data subject will be a beneficiary or guarantor.
9.5. Personal data processing is necessary for exercising the rights and legitimate interests of the operator or third parties or for achieving socially significant goals, provided that the rights and freedoms of the personal data subject are not violated.
9.6. Processing of personal data is carried out, access to which by an unlimited number of persons is provided by the personal data subject or at their request (hereinafter - publicly available personal data).
9.7. Processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.

10. Procedure for collection, storage, transfer and other types of personal data processing

The security of personal data processed by the Operator is ensured through the implementation of legal, organizational and technical measures necessary for full compliance with the requirements of current legislation in the field of personal data protection.
10.1. The Operator ensures the preservation of personal data and takes all possible measures to exclude access to personal data by unauthorized persons.
10.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to the implementation of current legislation or in case the personal data subject has given consent to the Operator to transfer data to a third party for the performance of obligations under a civil law contract.
10.3. In case of detection of inaccuracies in personal data, the User can update them independently by sending a notification to the Operator's email address info@hivehomeestate.com with the note "Personal data update".
10.4. The term of personal data processing is determined by achieving the purposes for which personal data was collected, unless another term is provided by contract or current legislation. The User can at any time withdraw their consent to personal data processing by sending a notification to the Operator via email to the Operator's email address info@hivehomeestate.com with the note "Withdrawal of consent to personal data processing".
10.5. All information collected by third-party services, including payment systems, means of communication and other service providers, is stored and processed by the specified persons (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject and/or User is obliged to independently and timely familiarize themselves with the specified documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this paragraph.
10.6. Prohibitions established by the personal data subject on transfer (except for providing access), as well as on processing or conditions of processing (except for obtaining access) of personal data permitted for distribution, do not apply in cases of personal data processing in state, public and other public interests defined by the legislation of the Russian Federation.
10.7. The Operator ensures confidentiality of personal data when processing personal data.
10.8. The Operator stores personal data in a form that allows determining the personal data subject no longer than required by the purposes of personal data processing, unless the period of personal data storage is established by federal law, an agreement to which the personal data subject is a party, beneficiary or guarantor.
10.9. The condition for terminating personal data processing may be achieving the purposes of personal data processing, expiration of the personal data subject's consent or withdrawal of consent by the personal data subject, as well as identification of unlawful personal data processing.

11. List of actions performed by the Operator with the received personal data

11.1. The Operator carries out collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion and destruction of personal data.
11.2. The Operator carries out automated processing of personal data with receiving and/or transmitting the received information via information and telecommunication networks or without such.

12. Cross-border transfer of personal data

12.1. Before starting cross-border transfer of personal data, the Operator must ensure that the foreign state to whose territory the transfer of personal data is supposed to be carried out provides reliable protection of personal data subjects' rights.
12.2. Cross-border transfer of personal data to the territories of foreign states that do not meet the above requirements can be carried out only if there is written consent of the personal data subject to cross-border transfer of their personal data and/or performance of an agreement to which the personal data subject is a party.

13. Confidentiality of personal data

The Operator and other persons who have gained access to personal data are obliged not to disclose to third parties and not to distribute personal data without the consent of the personal data subject, unless otherwise provided by federal law.

14. Final provisions

14.1. The User can obtain any clarifications on issues of interest regarding the processing of their personal data by contacting the Operator via email info@hivehomeestate.com.
14.2. This document will reflect any changes in the Operator's personal data processing policy. The Policy is valid indefinitely until replaced by a new version.
14.3. The current version of the Policy is freely available on the Internet at https://hivehomeestate.com/en/policy/.