Hello Park Voronezh / Personal data processing policy

This personal data privacy policy (hereinafter — the Privacy Policy) has been drawn up in accordance with Federal Law No. 152-FZ of 27.07.2006 “On Personal Data” (hereinafter — the Personal Data Law) and is intended to define the procedure for processing personal data and the measures taken to secure the personal data of individuals that Karusel Limited Liability Company () (hereinafter — the Operator) may receive.
Using the services of the Site means that the User unconditionally agrees to this Policy and to the conditions for processing their personal information set out in it; if the User does not agree with these conditions, they must refrain from using the services and/or visiting the Site.
By providing their personal data, the User confirms their consent to the processing of that data and to its transfer to the personal data operator (the Site administration).

KEY DEFINITIONS
Personal data — any information relating directly or indirectly to a specified or identifiable Personal data subject.
Site — the body of graphic and information materials, as well as computer programs and databases, that make them available on the internet at https://hello-park.com/voronezh/main and on all subdomains created on its basis.
Processing of personal data — any action (operation) or set of actions (operations) performed on personal data with or without the use of automation tools, including:

collection;
recording;
systematisation;
accumulation;
storage;
refinement (updating, modification);
retrieval;
use;
transfer (distribution, provision, access);
depersonalisation;
blocking;
deletion;
destruction of personal data.
Automated processing of personal data — the processing of personal data using computing equipment.
Distribution of personal data — actions aimed at disclosing personal data to an indefinite range of persons.
Provision of personal data — actions aimed at disclosing personal data to a specified person or a specified range of persons.
Blocking of personal data — the temporary suspension of the processing of personal data (except where the processing is necessary in order to refine the personal data).
Destruction of personal data — actions as a result of which it becomes impossible to restore the content of personal data in the personal data information system and/or as a result of which the physical media holding the personal data are destroyed.
Depersonalisation of personal data — actions as a result of which it becomes impossible, without the use of additional information, to attribute the personal data to a particular Personal data subject.
Personal data information system — the body of personal data contained in databases together with the information technologies and technical means that ensure its processing.
Cross-border transfer of personal data — the transfer of personal data to the territory of a foreign state, to a foreign public authority, a foreign individual or a foreign legal entity.
Personal data operator — Karusel Limited Liability Company (), which alone or jointly with others organises and/or carries out the processing of personal data and also determines the purposes of processing personal data, the composition of the personal data to be processed, and the actions (operations) performed on the personal data.
Personal data subject — an individual to whom the personal data in question relates; an individual to whom the personal data in question relates who views the content of the site and/or uses the functionality of the site.
Cookies — a small piece of data sent by a web service and stored on the computer of the Personal data subject, which the browser sends back to the web server in an HTTP request every time it attempts to open a page of the corresponding site.
IP address — the unique network address of a node in a computer network through which the Personal data subject accesses the Site.

GENERAL PROVISIONS
1.1. For the purposes of this Policy, the User’s personal information means:
1.1.1. Personal information that the User provides about themselves on their own initiative (surname, first name, patronymic, age, sex, telephone, email address, postal address and other information about the User) or in the course of using the Services, including the User’s personal data. Information that is mandatory in order to provide the Services is marked accordingly.
1.1.2. Data that is transmitted automatically to the services of the Site while they are in use by the software installed on the User’s device, including the IP address, cookie data, information about the User’s browser (or other program used to access the services), the technical characteristics of the hardware and software used by the User, the date and time of access to the services, the addresses of the requested pages and other similar information.
1.1.3. This Privacy Policy applies only to the Site https://hello-park.com/voronezh/main. The Site https://hello-park.com/voronezh/main does not control and is not responsible for third-party websites that the User may visit via links available on the Site https://hello-park.com/voronezh/main
1.1.4. The current version of the Privacy Policy is published on the Operator’s website at: https://hello-park.com/voronezh/main. All categories of Personal data subjects covered by the Privacy Policy are obliged to read the text of the Privacy Policy.
1.1.5. The Privacy Policy (including any part of it) may be amended by the Operator without any special notice and without any compensation being paid in connection with this. The new version of the Privacy Policy takes effect from the moment it is published on the Operator’s website.
1.1.6. By accepting the terms of the Privacy Policy, the Personal data subject gives their consent to the processing by the Operator of data about the Personal data subject for the purposes set out in the Privacy Policy.
1.1.7. Using the Site and its services with a web browser that accepts data from cookies means that the personal data subject agrees that the Operator may collect and process data from cookies in order to improve the Site, its content and its functionality. If the Personal data subject disables and/or blocks their web browser’s option to accept data from cookies, their use of the Site may be limited, in particular as regards some of its functions.
1.1.8. The Operator does not verify the accuracy of the personal information provided by the Personal data subject.
PURPOSES OF PROCESSING USERS’ PERSONAL INFORMATION
2.1. The Site collects and stores only the personal information that is necessary in order to provide the services or to perform agreements and contracts with the User, except where the law requires personal information to be kept for a period established by law.
If the Site receives notice from the User withdrawing consent to the processing of personal data, the Site stops processing the User’s personal data within no more than 10 working days from receipt of the notice.
Notice withdrawing consent to the processing of personal data shall be sent to the email address: [email protected], or in writing to the registered address: 396005, Voronezh Region, Ramonsky District, Solnechny settlement, Parkovaya St., 3, office 01.
2.2. The Operator collects and processes only such information about Users, including their personal data, as is relevant to achieving the following purposes:
2.2.1. sending advertising and information mailings;
2.2.2. making a call back;
2.2.3. administering and protecting the Site, including troubleshooting, data analysis, testing, system maintenance, support, reporting and data hosting;
2.2.4. giving the User access to personalised resources of the Site;
2.2.5. establishing feedback with the User, including sending notices and enquiries concerning the use of the Site and the provision of services, and handling the User’s enquiries and applications.
PROCESSING OF THE PERSONAL DATA
OF PERSONAL DATA SUBJECTS.
3.1. In most cases personal data is processed automatically, without the Operator accessing it. Should such access be required, it may be granted only to those persons who need it in order to perform their duties. To protect the data and keep it confidential, all such persons must observe the internal rules and procedures for processing personal data. They must also follow all the technical and organisational security measures in force for the protection of personal data.
3.2. The personal data of Russian Personal data subjects is stored in the Russian Federation. The Operator records, systematises, accumulates, stores, refines (updates, modifies) and retrieves the personal data of citizens of the Russian Federation using databases located in the territory of the Russian Federation.
3.3. The Operator has implemented sufficient technical and organisational measures to protect personal data against unauthorised, accidental or unlawful destruction, loss, alteration, misuse, disclosure or access, as well as other unlawful forms of processing. These security measures have been implemented taking into account the state of the art, the cost of implementation, the risks associated with the processing and the nature of the personal data, and include the following measures:
antivirus protection with regularly updated databases;
backup copying of information;
limiting the range of persons who have access to personal data.
3.4. The Operator will store personal data for as long as is necessary to achieve the purpose for which it was collected, or to comply with the requirements of laws and regulations.
3.5. The Personal data subject is hereby notified of, and agrees to, the Operator receiving depersonalised statistical data (not linked to the Personal data subject) about the actions of the Personal data subject when using the Site.
3.6. The Personal data subject has the right, upon request, to receive information from the Operator concerning the processing of their personal data.
3.7. Once the purposes of processing personal data have been achieved, and also if the User withdraws consent to its processing, the personal data is subject to destruction, unless:

otherwise provided by a contract to which the Personal data subject is a party, beneficiary or guarantor;
the Operator is entitled to carry out the processing without the consent of the Personal data subject on the grounds provided for by the Personal Data Law or other federal laws;
otherwise provided by another agreement between the Operator and the Personal data subject.

PROCEDURE FOR RESPONDING TO REQUESTS/ENQUIRIES FROM PERSONAL DATA SUBJECTS AND THEIR REPRESENTATIVES
4.1. A subject may send a request either in writing or electronically.
4.2. Written requests from Personal data subjects include any written enquiries from Personal data subjects addressed to the Operator, including enquiries sent through postal service offices.
4.3. Electronic requests from Personal data subjects include enquiries sent by email.
4.4. Procedure for handling requests and enquiries from Personal data subjects.
A written reply is sent to the Personal data subject by the Operator regardless of the form of the Personal data subject’s request (written or electronic) and of the outcome of the handling of the request or enquiry. Replies to the Personal data subject are prepared by the Operator.
4.5. Where necessary, the Operator requests additional information from the Personal data subject.
4.6. The reply is provided to the Personal data subject within no more than 30 (thirty) working days from receipt of the enquiry. The information provided to the Personal data subject in an accessible form does not contain personal data relating to other Personal data subjects.
LEGAL GROUNDS FOR PROCESSING PERSONAL DATA
5.1. The Privacy Policy has been drawn up in accordance with clause 2 of part 1 of article 18.1 of the Personal Data Law.
5.2. The Privacy Policy contains the information subject to disclosure in accordance with part 1 of article 14 of the Personal Data Law and is a publicly available document.
5.3. The Operator processes personal information, including personal data, only where:
5.3.1. the processing is necessary for the Operator to perform its contractual obligations towards Personal data subjects;
5.3.2. the processing is necessary in order to comply with obligations established by law;
5.3.3. where provided for by applicable law, the processing is necessary to serve the legitimate interests of the Operator, provided that such processing does not materially affect the interests, fundamental rights and freedoms of the Personal data subject. When processing personal information on this ground, the Operator will always seek to maintain a balance between its legitimate interests and the protection of the privacy of the Personal data subject.
FINAL PROVISIONS
6.1. The Privacy Policy, the relations between the Personal data subject and the Operator arising in connection with the application of the Privacy Policy, and also matters not covered by the Privacy Policy, are governed by the applicable law of the Russian Federation.
6.2. Personal data subjects have the right to send the Operator requests, proposals or questions concerning the Privacy Policy by email to [email protected]

Hello Park - Personal data processing policy