Privacy
Privacy Policy

1. General Provisions

This personal data processing policy is drawn up in accordance with the requirements of Federal Law No. 152-FZ of July 27, 2006 “On Personal Data” (hereinafter referred to as the Personal Data Law) and determines the procedure for processing personal data and the measures to ensure the security of personal data undertaken by Denis Olegovich Khakhalkin (hereinafter referred to as the Operator).

1.1. The Operator considers compliance with the rights and freedoms of an individual and citizen in the processing of his personal data, including the protection of the right to privacy, personal and family secrets, as the most important goal and condition for carrying out its activities.

1.2. This Operator’s policy regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator may receive about visitors to the website https://holystaff.com/en.

2. Basic Concepts Used in the Policy

2.1. Automated processing of personal data means the processing of personal data using computer technology.

2.2. Blocking of personal data means the 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 computer programs and databases, ensuring their availability on the internet at the network address https://holystaff.com/en.

2.4. Information system of personal data 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 that make it impossible to determine the ownership of personal data by a specific User or other subject of personal data without using additional information.

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

2.7. Operator means a state body, municipal body, legal or natural person who, independently or jointly with other persons, organizes and/or carries out the processing of personal data, and determines the purposes of processing personal data, the composition of personal data to be processed, and actions (operations) performed with personal data.

2.8. Personal data means any information related directly or indirectly to a specific or identifiable User of the website https://holystaff.com/en.

2.9. Personal data permitted by the personal data subject for distribution means personal data to which an unlimited number of persons have access, granted by the personal data subject by giving consent to the processing of personal data permitted by the personal data subject for distribution in accordance with the procedure provided for in the Personal Data Law (hereinafter referred to as personal data permitted for distribution).

2.10. User means any visitor to the website https://holystaff.com/en.

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

2.12. Distribution of personal data means any actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or making personal data available to the general public, including publication of personal data in the media, posting in information and telecommunication networks, or providing access to personal data in any other way.

2.13. Cross-border transfer of personal data means the transfer of personal data to the territory of a foreign state, to an authority of a foreign state, to a foreign natural or foreign legal person.

2.14. Destruction of personal data means any actions resulting in the irrevocable destruction of personal data with no possibility of further restoration of personal data content in the personal data information system and/or destruction of tangible 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 reliable information and/or documents containing personal data;
  • in the event of withdrawal by the personal data subject of consent to the processing of personal data, as well as in the event of an appeal requiring the cessation of personal data processing, continue processing personal data without the personal data subject’s consent if there are grounds specified in the Personal Data Law;
  • independently determine the composition and list of measures necessary and sufficient to ensure compliance with the obligations provided for by the Personal Data Law and the regulatory legal acts adopted in accordance with it, unless otherwise provided for by the Personal Data Law or other federal laws.

3.2. The Operator is obliged to:

  • provide the personal data subject, upon his request, with information regarding the processing of his personal data;
  • organize the processing of personal data in accordance with the procedure established by the current legislation of the Russian Federation;
  • respond to requests and inquiries of personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
  • provide the authorized body for the protection of the rights of personal data subjects, at its request, with the necessary information within 10 days from the date of receipt of such a request;
  • publish or otherwise ensure unlimited access to this Policy regarding the processing of personal data;
  • take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, alteration, blocking, copying, provision, distribution of personal data, as well as from other unlawful actions regarding personal data;
  • cease the transfer (distribution, provision, access) of personal data, cease processing, and destroy personal data in accordance with the procedure and in the cases provided for by the Personal Data Law;
  • 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:

  • receive information concerning the processing of their personal data, except in cases provided for by federal laws. The information is provided to the personal data subject by the Operator in an accessible form and must not contain personal data relating to other personal data subjects, unless there are legitimate grounds for disclosing such personal data. The list of information and the procedure for obtaining it is established by the Personal Data Law;
  • demand that the Operator clarify their personal data, block or destroy them if the personal data are incomplete, outdated, inaccurate, illegally obtained, or not necessary for the stated purpose of processing, as well as take measures provided by law to protect their rights;
  • require prior consent when processing personal data for the purpose of promoting goods, works, and services on the market;
  • withdraw consent to the processing of personal data, as well as submit a demand to cease the processing of personal data;
  • appeal to the authorized body for the protection of the rights of personal data subjects or to a court against unlawful acts or omissions of the Operator in processing their personal data;
  • 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;
  • inform the Operator about any clarification (updating, changing) of their personal data.

4.3. Persons who have provided the Operator with false information about themselves or information about another personal data subject without that subject’s consent bear liability in accordance with the legislation of the Russian Federation.

5. Principles of Personal Data Processing

5.1. The processing of personal data is carried out on a lawful and fair basis.

5.2. The processing of personal data is limited to achieving specific, predetermined, and lawful purposes. Processing of personal data that is incompatible with the purposes of collecting personal data is not allowed.

5.3. It is not permitted to combine databases containing personal data which are processed for purposes that are incompatible with each other.

5.4. Only personal data that meets the purposes of their processing is subject to processing.

5.5. The content and scope of the personal data being processed correspond to the stated purposes of processing. The processed personal data must not be excessive in relation to the stated purposes of its processing.

5.6. When processing personal data, the accuracy of personal data, its sufficiency, and, where necessary, relevance to the purposes of personal data processing are ensured. The Operator takes the necessary measures and/or ensures their adoption to remove or clarify incomplete or inaccurate data.

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

6. Purpose of Personal Data Processing

Purpose of processing
providing the User with access to the services, information, and/or materials contained on the website 		Personal data
last name, first name, patronymic
email address
phone numbers
year, month, date, and place of birth
photographs
information about marital status and family composition 		Legal grounds
the Operator’s charter (founding) documents
agreements concluded between the Operator and the personal data subject
the Constitution of the Russian Federation, the Civil Code of the Russian Federation, the Labor Code of the Russian Federation, the Tax Code of the Russian Federation, Federal Law “On Personal Data” No. 152-FZ, Federal Law “On Accounting,” Federal Law “On Mandatory Pension Insurance in the Russian Federation” 		Types of personal data processing
collection, recording, systematization, accumulation, storage, destruction, and depersonalization of personal data
sending informational emails to the email address
Purpose of processing
informing the User by sending emails		 Personal data
last name, first name, patronymic
email address
phone numbers
year, month, date, and place of birth
photographs 		Legal grounds
the Operator’s charter (founding) documents
agreements concluded between the Operator and the personal data subject
the Constitution of the Russian Federation, the Civil Code of the Russian Federation, the Labor Code of the Russian Federation, the Tax Code of the Russian Federation, Federal Law “On Personal Data” No. 152-FZ, Federal Law “On Accounting,” Federal Law “On Mandatory Pension Insurance in the Russian Federation” 		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 Personal Data Processing

7.1. The processing of personal data is carried out with the consent of the personal data subject to the processing of his personal data.

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

7.3. The processing of personal data is necessary for the administration of justice, the execution of a court decision, or a decision of another authority or official to be executed in accordance with the legislation of the Russian Federation on enforcement proceedings.

7.4. The processing of personal data 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.

7.5. The processing of personal data is necessary to exercise the rights and legitimate interests of the Operator or third parties, or to achieve socially significant goals, provided that the rights and freedoms of the personal data subject are not violated.

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

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

8. Procedure for Collecting, Storing, Transferring and Other Types of Personal Data Processing

The security of personal data processed by the Operator is ensured by implementing legal, organizational, and technical measures necessary to fully comply with the requirements of the current legislation in the field of personal data protection.

8.1. The Operator ensures the safety of personal data and takes all possible measures to prevent access to personal data by unauthorized persons.

8.2. The User’s personal data will never, under any circumstances, be transferred to third parties, except in cases related to the fulfillment of current legislation or if the personal data subject has given the Operator consent to transfer data to a third party for the execution of obligations under a civil contract.

8.3. In the event of inaccuracies in personal data, the User can update them independently by sending the Operator a notification to the Operator’s email address info@holystaff.com with the subject “Updating of personal data.”

8.4. The period of personal data processing is determined by the achievement of the purposes for which the personal data were collected, unless a different period is stipulated by an agreement or current legislation. The User may at any time withdraw his consent to the processing of personal data by sending the Operator a notification via email to the Operator’s email address info@holystaff.com with the subject “Withdrawal of consent to the processing of personal data.”

8.5. All information that is collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by these persons (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject must independently familiarize himself with these documents. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this clause.

8.6. The bans established by the personal data subject on the transfer (except for granting access), as well as on the processing or conditions of processing (except for gaining access) of personal data permitted for distribution, do not apply in cases of processing personal data in the interests of the state, society, and other public interests as defined by the legislation of the Russian Federation.

8.7. When processing personal data, the Operator ensures the confidentiality of personal data.

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

8.9. The condition for terminating the processing of personal data may be the achievement of the goals of personal data processing, the expiration of the personal data subject’s consent, the withdrawal of consent by the personal data subject, or a request to cease personal data processing, as well as the detection of unlawful personal data processing.

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

9.1. The Operator carries out the collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.

9.2. The Operator performs automated processing of personal data with the receipt and/or transfer of the obtained information via information and telecommunication networks or without such means.

10. Cross-Border Transfer of Personal Data

10.1. Before starting the cross-border transfer of personal data, the Operator must notify the authorized body for the protection of the rights of personal data subjects of its intention to perform such transfer (this notification is sent separately from the notification of its intention to process personal data).

10.2. Before submitting the above notification, the Operator must obtain the appropriate information from the foreign state authorities, foreign individuals, or foreign legal entities to whom the cross-border transfer of personal data is intended.

11. Confidentiality of Personal Data

The Operator and other persons who have gained access to personal data are obliged not to disclose the personal data to third parties or distribute the 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 clarifications on questions of interest regarding the processing of his personal data by contacting the Operator via email at info@holystaff.com.

12.2. Any changes to the Operator’s personal data processing policy will be reflected in this document. The Policy is valid indefinitely until replaced by a new version.

12.3. The current version of the Policy is freely available on the internet at the address https://holystaff.com/en/privacy.