Personal Data Processing Policy

1. General ProvisionsThis Personal Data Processing Policy has been prepared in accordance with the requirements of Federal Law No. 152-FZ dated July 27, 2006 “On Personal Data” (hereinafter referred to as the Personal Data Law) and defines the procedure for processing personal data and the measures taken by RED LLC (hereinafter referred to as the Operator) to ensure the security of personal data.

1.1. The Operator considers compliance with the rights and freedoms of individuals and citizens when processing their personal data, including the protection of the rights to privacy, personal and family secrets, to be one of its most important objectives and conditions of its activities.

1.2. This Personal Data Processing Policy of the Operator (hereinafter referred to as the Policy) applies to all information that the Operator may obtain about visitors to the website https://redhr.tech.

2. Basic Terms 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 suspension of the processing of personal data (except 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 availability on the Internet at https://redhr.tech.

2.4. Personal data information system — a set of personal data contained in databases and the information technologies and technical means used to process such data.

2.5. Depersonalization of personal data — actions resulting in the inability to determine, without the use of additional information, whether personal data belongs to a particular User or other personal data subject.

2.6. Processing of personal data — any action (operation) or set of actions (operations) performed with personal data, with or without the use of automation tools, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.

2.7. Operator — a government authority, municipal authority, legal entity, or individual that independently or jointly with other persons organizes and/or carries out the processing of personal data and determines the purposes of personal data processing, the composition of personal data to be processed, and the actions (operations) performed with personal data.

2.8. Personal data — any information directly or indirectly relating to an identified or identifiable User of the website https://redhr.tech.

2.9. Personal data permitted by the personal data subject for distribution — personal data to which access by an unlimited number of persons has been granted by the personal data subject by providing consent to the processing of personal data permitted by the personal data subject for distribution in accordance with the procedure established by the Personal Data Law (hereinafter referred to as personal data permitted for distribution).

2.10. User — any visitor to the website https://redhr.tech.

2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific group of persons.

2.12. Distribution of personal data — any actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or making personal data available to an unlimited number of persons, including publication of personal data in the mass media, placement in information and telecommunications networks, or providing access to personal data by any other means.

2.13. Cross-border transfer of personal data — 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 — any actions resulting in the irreversible destruction of personal data so that the content of such personal data cannot subsequently be restored in a personal data information system and/or resulting in the destruction of physical media containing personal data.

3. Basic Rights and Obligations of the Operator

3.1. The Operator has the right:— to receive from the personal data subject accurate information and/or documents containing personal data;— if the personal data subject withdraws consent to the processing of personal data or submits a request to terminate the processing of personal data, the Operator may continue processing personal data without the consent of the personal data subject where grounds specified in the Personal Data Law exist;— to independently determine the composition and list of measures necessary and sufficient to ensure compliance with the obligations established by the Personal Data Law and regulatory legal acts adopted pursuant thereto, unless otherwise provided by the Personal Data Law or other federal laws.

3.2. The Operator is obliged:— to provide the personal data subject, upon request, with information concerning the processing of their personal data;— to organize the processing of personal data in accordance with the procedure established by the applicable legislation of the Russian Federation;— to respond to requests and inquiries from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;— to provide the authorized body for the protection of the rights of personal data subjects, upon request of such body, with the necessary information within 10 days from the date of receipt of such request;— to publish or otherwise provide unrestricted access to this Personal Data Processing Policy;— to take legal, organizational, and technical measures to protect personal data against unlawful or accidental access, destruction, modification, blocking, copying, provision, distribution, and other unlawful actions involving personal data;— to terminate the transfer (distribution, provision, access) of personal data, terminate processing, and destroy personal data in the procedure and cases provided for by the Personal Data Law;— to perform other obligations stipulated by the Personal Data Law.

4. Basic Rights and Obligations of Personal Data Subjects

4.1. Personal data subjects have the right:— to obtain information concerning the processing of their personal data, except in cases provided for by federal laws. Such information shall be provided to the personal data subject by the Operator in an accessible form and shall not contain personal data relating to other personal data subjects, except where there are lawful grounds for disclosure of such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;— to require the Operator to clarify, block, or destroy their personal data if the personal data is incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the stated purpose of processing, and to take measures provided by law to protect their rights;— to require prior consent when personal data is processed for the purposes of promoting goods, works, and services in the market;— to withdraw consent to the processing of personal data and to submit a request to terminate the processing of personal data;— to appeal to the authorized body for the protection of the rights of personal data subjects or through the courts against unlawful actions or inaction of the Operator in 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 accurate information about themselves;— to inform the Operator of any clarification (update or modification) of their personal data.

4.3. Persons who provide the Operator with inaccurate information about themselves or information about another personal data subject without the latter’s consent shall be liable 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. The processing of personal data shall be limited to achieving specific, predetermined, and lawful purposes. Processing of personal data that is incompatible with the purposes for which the personal data was collected shall not be permitted.

5.3. Databases containing personal data processed for mutually incompatible purposes shall not be combined.

5.4. Only personal data that corresponds to the purposes of its processing shall be processed.

5.5. The content and volume of personal data processed shall correspond to the stated purposes of processing. Excessive processing of personal data in relation to the stated purposes of its processing shall not be permitted.

5.6. When processing personal data, the accuracy and sufficiency of personal data and, where necessary, its relevance to the purposes of personal data processing shall be ensured. The Operator shall take the necessary measures and/or ensure that such measures are taken to delete or clarify incomplete or inaccurate data.

5.7. Personal data shall be stored in a form that allows the personal data subject to be identified for no longer than required by the purposes of personal data processing, unless the storage period is established by federal law or an agreement to which the personal data subject is a party, beneficiary, or guarantor. Personal data being processed shall be destroyed or depersonalized upon achievement of the processing purposes or where the need to achieve such purposes ceases to exist, unless otherwise provided by federal law.

6. Purposes of Personal Data Processing

Purpose of processing: informing the User by sending emails

Personal data:

• last name, first name, patronymic
• email address
• telephone numbers
• Telegram account

Legal grounds: agreements concluded between the Operator and the personal data subject.

Types of personal data processing: 

• Collection, recording, systematization, accumulation, storage, destruction, and depersonalization of personal data
• Sending informational emails to the email address

7. Conditions for Processing Personal Data

7.1. Personal data shall be processed with the consent of the personal data subject to the processing of their personal data.

7.2. Personal data processing is necessary to achieve the purposes stipulated by an international treaty of the Russian Federation or by law, and to exercise the functions, powers, and obligations imposed on the Operator by the legislation of the Russian Federation.

7.3. Personal data processing is necessary for the administration of justice and execution of a judicial act or an act of another authority or official that is subject to enforcement in accordance with the legislation of the Russian Federation on enforcement proceedings.

7.4. Personal data processing is necessary for the performance of an agreement to which the personal data subject is a party, beneficiary, or guarantor, as well as for entering into an agreement at the initiative of the personal data subject or an agreement under which the personal data subject will be a beneficiary or guarantor.

7.5. Personal data processing is necessary for exercising the rights and legitimate interests of the Operator or third parties or for achieving socially significant purposes, provided that the rights and freedoms of the personal data subject are not violated.

7.6. Personal data to which access by an unlimited number of persons has been granted by the personal data subject or at their request shall be processed (hereinafter referred to as publicly available personal data).

7.7. Personal data subject to publication or mandatory disclosure in accordance with federal law shall be processed.

8. Procedure for Collection, Storage, Transfer, and Other Types of Personal Data Processing

The security of personal data processed by the Operator shall be ensured through the implementation of legal, organizational, and technical measures necessary to fully comply with the requirements of applicable legislation governing personal data protection.

8.1. The Operator shall ensure the security of personal data and take all possible measures to prevent unauthorized persons from gaining access to personal data.

8.2. The User’s personal data shall never, under any circumstances, be transferred to third parties, except in cases related to compliance with applicable legislation or where the personal data subject has given the Operator consent to transfer the data to a third party for the performance of obligations under a civil-law agreement.

8.3. If inaccuracies in personal data are identified, the User may update such data independently by sending a notification to the Operator’s email address tech@redhr.ru with the subject line “Personal Data Update”.

8.4. The period of personal data processing shall be determined by achievement of the purposes for which the personal data was collected, unless another period is provided for by an agreement or applicable legislation.The User may withdraw their consent to the processing of personal data at any time by sending the Operator a notification by email to tech@redhr.ru with the subject line “Withdrawal of Consent to Personal Data Processing”.

8.5. All information collected by third-party services, including payment systems, communication services, and other service providers, shall be stored and processed by such persons (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject and/or with the specified documents. The Operator shall not be responsible for the actions of third parties, including the service providers specified in this clause.

8.6. Restrictions imposed by the personal data subject on the transfer (except for granting access), as well as on the processing or conditions of processing (except for obtaining access) of personal data permitted for distribution, shall not apply in cases where personal data is processed in state, public, or other public interests defined by the legislation of the Russian Federation.

8.7. When processing personal data, the Operator shall ensure the confidentiality of personal data.

8.8. The Operator shall store personal data in a form that allows the personal data subject to be identified for no longer than required by the purposes of personal data processing, unless the storage period is established by federal law or an agreement to which the personal data subject is a party, beneficiary, or guarantor.

8.9. Personal data processing may be terminated upon achievement of the purposes of personal data processing, expiration of the personal data subject’s consent, withdrawal of consent by the personal data subject, submission of a request to terminate personal data processing, or identification of unlawful processing of personal data.

9. List of Actions Performed by the Operator with the Personal Data Obtained

9.1. The Operator shall collect, record, systematize, accumulate, store, clarify (update, modify), retrieve, use, transfer (distribute, provide, grant access), depersonalize, block, delete, and destroy personal data.

9.2. The Operator shall carry out automated processing of personal data with or without receiving and/or transferring the information obtained through information and telecommunications networks.

10. Cross-Border Transfer of Personal Data

10.1. Before commencing activities involving the cross-border transfer of personal data, the Operator shall notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out cross-border transfers of personal data (such notification shall be submitted separately from the notification of the intention to process personal data).

10.2. Before submitting the above-mentioned notification, the Operator shall obtain the relevant information from the authorities of the foreign state, foreign individuals, and foreign legal entities to whom personal data is intended to be transferred across borders.

11. Confidentiality of Personal Data

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

12. Final Provisions

12.1. The User may obtain any clarification regarding matters related to the processing of their personal data by contacting the Operator by email at tech@redhr.ru.

12.2. Any changes to the Operator’s Personal Data Processing Policy shall be reflected in this document. The Policy shall remain in effect indefinitely until replaced by a new version.

12.3. The current version of the Policy is publicly available on the Internet at https://redhr.tech/policy