Privacy Policy

  1. General Conditions
    1. The policy regarding the processing of personal data (hereinafter referred to as the Policy) is aimed at protecting the rights and freedoms of individuals, whose personal data are processed by the Harwal Enterprises LLC.
    2. The policy is developed in accordance with paragraph 2 of Part 1 of Art. 18.1 of the Federal Law (FZ) of July 27, 2006 No. 152-ФЗ “About Personal Data” (hereinafter - the Federal Law (FZ) “About Personal Data”).
    3. The policy contains information to be disclosed in accordance with Part 1 of Art. 14 of the Federal Law (FZ) "About Personal Data", and it is a public document
  2. Information about the operator
    1. The operator conducts his activities at the address Russian Federation, Moscow, Sharikopodshipnikovskaya, 1, «Business Plaza»
  3. Information on the processing of personal data
    1. The Operator processes personal data on a lawful and fair basis in order to fulfill the functions, rights and duties entrusted by law, exercise the rights and legitimate interests of the Operator, Operator’s employees and third parties.
    2. The operator receives personal data directly from the subjects of personal data (hereinafter – PD).
    3. The operator processes personal data in automated and non-automated ways, using computer technology and without the use of such tools.
    4. Actions for the processing of personal data include the collection, recording, systematization, accumulation, storage, refinement (update, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion and destruction
  4. Processing customer personal data
    1. The Operator processes the personal data of customers in the framework of legal relations with the Operator, settled by part two of the Civil Law of the Russian Federation from January 26, 1996 No.14-FZ, (hereinafter referred to as customers).
    2. The operator processes the personal data of customers in order to comply with the norms of the legislation of the Russian Federation, as well as in order to:
      • receive requests and applications from the subject of PD;
      • inform about new products, special promotions and offers;
      • to conclude and execute the contract.
    3. The operator processes the personal data of customers with their consent, provided by customers and|or their legal representatives by making specific actions on this Internet site, including, but not limited to, placing an order, registering in a personal account, subscribing to a newsletter, in accordance with this Policy.
    4. The operator processes the personal data of customers no longer than the purpose of processing personal data requires, unless otherwise provided by the requirements of the laws of the Russian Federation.
    5. The operator can process the following personal customer data:
      • First and last name;
      • Address;
      • Phone number;
      • E-mail address.
    6. The processing of special categories of personal data such as race, nationality, political or philosophical views, religious beliefs, health or private life is not carried out
  5. Information about the security of personal data
    1. The operator in the processing of personal datatakes the necessary legal, organizational and technical measures or ensures their adoption to protect personal data from illegal or accidental access to them, destruction, modification, blocking, copying, provision, dissemination of personal data, as well as from other illegal actions in relation to personal data .
    2. Measures to ensure the security of personal data during their processing, applied by the Operator, are planned and implemented in order to ensure compliance with the requirements set forth in Article 19 of the Federal Law (FZ) FZ-152 “About Personal Data”.
    3. In accordance with Article 18.1 FZ-152, the Operator independently determines the composition and list of measures necessary and sufficient to ensure compliance with the requirements of the law. The operator in particular took the following measures:
      • appointed personnel responsible for the organization of PD processing;
      • local acts on the treatment of PDs were developed and introduced, -as well as local acts that establish procedures aimed at preventing and detecting violations of established procedures for treating PD and eliminating the consequences of such violations;
      • legal, organizational and technical measures are applied measures to ensure the safety of personal data in accordance with Article 19 of the Federal Law (FZ)-152;
      • internal control is functioning
      • the compliance of PD processing with the FZ-152 and the regulatory legal acts adopted in accordance with it, the requirements for the protection of PD, the policy of the Operator regarding the processing of PD, the local acts of the Operator;
      • an assessment of the harm that may be caused to the personal data subjects in the event of a violation of the FZ-152 is maid, the ratio of the said harm and the measures taken by the operator to ensure the fulfillment of the duties stipulated by the FZ-152;
      • Operator’s employees who directly process PDs are familiar with the provisions of Russian law on PD, including PD protection requirements, documents defining Operator’s policy regarding PD processing, local acts on PD processing;
      • in addition to the requirements of 152-Federal Law (FZ) “About Personal Data”, the Operator takes a set of measures aimed at protecting information about customers, employees and counterparties.
  6. Rights of personal data subjects
    1. The personal data subject has the right to:
      • to obtain personal data relating to the subject, and information relating to its processing;
      • to clarify, block or destroy his personal data if they it is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing;
      • revocation of their consent to the processing of personal data;
      • to protect their rights and legitimate interests, including damages and moral suffering in court;
      • to appeal the actions or omissions of the Operator to the authorized body for the protection of the rights of personal data subjects or in court.
    2. In order to exercise their rights and legitimate interests, the personal data subjects have the right to contact the Operator or send a request in person or with the help of a representative. The request must contain the information specified in Part 3 of Art. 14 of the Federal Law (FZ) "About Personal Data”.