1. General Provisions
This personal data processing policy has been drawn up in accordance with the requirements of the Federal Law as of July 27, 2006. No. 152-FZ “On Personal Data” (hereinafter referred to as the Law on Personal Data) and determines the procedure for processing personal data and measures to ensure the security of personal data taken by “Mindmice” LLC (hereinafter referred to as the Operator).
1.1. The operator sets the observance of the rights and freedoms of human and citizen when processing his/her personal data, including the protection of the privacy rights as well as personal and family secrets as its 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://honest-view.com.

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 is a temporary cessation of processing of personal data (except for cases where processing is necessary to clarify personal data).
2.3. Website is a collection of graphic and information materials, as well as computer programs and databases that ensure their availability on the Internet at the network address https://honest-view.com.
2.4. Personal data information system is a set of personal data contained in databases and information technologies and technical means that ensure their processing.
2.5. Depersonalization of personal data - actions as a result of which it is impossible to determine without the use of additional information the belonging of personal data to a specific User or other subject of personal data.
2.6. Processing of personal data - any action (operation) or set of actions (operations) with personal data performed using automation tools or without the use of such tools, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, termination 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 the processing of personal data, as well as determining the purposes of processing personal data, 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://honest-view.com.
2.9. Personal data authorized by the subject of personal data for distribution - personal data, access to which is granted to an unlimited number of persons and was authorized by the subject of personal data by giving consent to the processing of personal data authorized by the subject of personal data for distribution in the manner prescribed by the Law on Personal Data (hereinafter referred to as personal data authorized for distribution).
2.10. User - any visitor to the website https://honest-view.com.
2.11. Providing of personal data - actions aimed at disclosing personal data to a certain person or a certain circle of persons.
2.12. Distribution of personal data - any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or familiarization with personal data of an unlimited number of persons, including the publication of personal data in the media, posting data in information and telecommunication networks or providing access to personal data in any other way.
2.13. Cross-border transfer of personal data is the transfer of personal data to the territory of a foreign state, to an authority of a foreign state, a foreign individual or a foreign legal entity.
2.14. Termination of personal data - any actions as a result of which personal data is irretrievably terminated with the impossibility of further restoration of the content of personal data in the personal data information system and/or termination of material media containing personal data.

3. Basic rights and obligations of the Operator
3.1. The operator has the right to:
— receive from the subject of personal data reliable information and/or documents containing personal data;
— in the event that the subject of personal data withdraws consent to the processing of personal data, as well as sends a request to stop processing personal data, the Operator has the right to continue processing personal data without the consent of the subject of personal data if there are grounds for that which are specified in the Law on Personal Data;
— independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of the obligations provided for by the Law on Personal Data and regulations adopted in accordance with it, unless otherwise provided by the Law on Personal Data or other federal laws.
3.2. The operator is obliged to:
— provide the subject of personal data, at his request, with information regarding the processing of his personal data;
— organize the processing of personal data in the manner established by the current legislation of the Russian Federation;
— respond to requests and inquiries from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
— report to the body authorized for the protection of the rights of personal data subjects, at the request of such body, the necessary information within 10 days from the date of receipt of such a request;
— publish or otherwise provide unrestricted 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, termination, modification, blocking, copying, provision, distribution of personal data, as well as from other unlawful actions in relation to personal data;
— stop the transfer (distribution, provision, access) of personal data, stop processing and terminate personal data in the manner and cases provided for by the Law on Personal Data;
— fulfill other duties provided for by the Personal Data Law.


4. Basic rights and obligations of personal data subjects
4.1. Subjects of personal data have the right:
— receive information regarding the processing of his/her personal data, except for cases provided for by federal laws. The information is provided to the subject of personal data by the Operator in an accessible form, and it should not contain personal data relating to other subjects of personal data, except in cases where there are legal grounds for the disclosure of such personal data. The list of information and the procedure for obtaining it is established by the Law on Personal Data;
— require the operator to clarify his personal data, block it or destroy it if the personal data is incomplete, outdated, inaccurate, illegally obtained or not required for the stated purpose of processing, as well as take measures provided by law to protect their rights;
— put forward the condition of prior consent when processing personal data in order to promote goods, works and services on the market;
— to withdraw consent to the processing of personal data, as well as to send a request to stop processing personal data;
— appeal to the body authorized for the protection of the rights of personal data subjects or in court on the matter of unlawful actions or inaction of the Operator when processing his/her personal data;
— to exercise other rights provided for by the legislation of the Russian Federation.
4.2. Subjects of personal data are obliged to:
— provide the Operator with reliable information about themselves;
— inform the Operator about clarification (updating, changing) of their personal data.
4.3. Persons who provided the Operator with false information about themselves or information about another subject of personal data without the latter’s consent are to be held liable in accordance with the legislation of the Russian Federation.

5. Principles for processing personal data
5.1. The processing of personal data is carried out on a legal and fair basis.
5.2. The processing of personal data is limited to the achievement of specific, pre-defined and legitimate purposes. Processing of personal data that is incompatible with the purposes of collecting personal data is not permitted.
5.3. It is not allowed to combine databases containing personal data, the processing of which is carried out for purposes that are incompatible with each other.
5.4. Only personal data that meets the purposes of its processing is subject to processing.
5.5. The content and volume of personal data processed shall correspond to the stated purposes of processing. Redundancy of the processed personal data in relation to the stated purposes of their processing is not allowed.
5.6. When processing personal data, the accuracy of personal data, their sufficiency, and, where necessary, relevance in relation to the purposes of processing personal data are ensured. The operator takes the necessary measures and/or ensures that they are taken to delete or clarify incomplete or inaccurate data.
5.7. The storage of personal data is carried out in a form that makes it possible to identify the subject of personal data, no longer than required by the purposes of processing personal data, unless the period for storing personal data is established by federal law, an agreement to which the subject of personal data is a party, beneficiary or guarantor. The processed personal data is terminated or depersonalized upon achievement of the purposes of processing or in the event of loss of the need to achieve such purposes, unless otherwise provided by federal law.

6. Purposes of processing personal data
  - Purpose of processing:
- Informing the User through sending e-mails
Personal data:

• last name, first name, patronymic (if applicable)
• e-mail address
• country

 - Legal grounds: Federal Law “On Information, Information Technologies and Information Protection” dated as of July 27, 2006 N 149-FZ
 - Types of processing of personal data: Collection, recording, systematization, accumulation, storage, termination and depersonalization of personal data
 - Sending information letters to an e-mail address

7. Conditions for processing personal data
7.1. The processing of personal data is carried out with the consent of the subject of personal data to the processing of his personal data.
7.2. The processing of personal data is necessary to achieve the goals provided for by an international treaty of the Russian Federation or law, to implement the functions, powers and responsibilities assigned by the legislation of the Russian Federation to the operator.
7.3. The processing of personal data is necessary for the administration of justice, the execution of a judicial act, an act of another body or official, subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. The processing of personal data is necessary for the execution of an agreement to which the subject of personal data is a party or beneficiary or guarantor, as well as for concluding an agreement on the initiative of the subject of personal data or an agreement under which the subject of personal data 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 subject of personal data are not violated.
7.6. The processing of personal data is carried out, access to such data shall be provided to an unlimited number of persons by the subject of personal data or at his request (hereinafter referred to as publicly available personal data).
7.7. Personal data being processed being a subject to publication or mandatory disclosure in accordance with federal law.

8. The procedure for collecting, storing, transferring and other types of processing of personal data
The security of personal data processed by the Operator is ensured through implementing legal, organizational and technical measures necessary to fully comply with the requirements of 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 implementation of current legislation or in the event when the subject of personal data gives consent to the Operator to transfer data to a third party to fulfill obligations under a civil law contract.
8.3. If inaccuracies in personal data are identified, the User can update them independently by sending a notification to the Operator to the Operator's email address: harlamov@malibu-group.ru with the note “Updating personal data.”
8.4. The period for processing personal data is determined by the achievement of the purposes for which the personal data is collected, unless a different period is provided for by the contract 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: harlamov@malibu-group.ru with the note “Withdrawal of consent to the processing of personal data.”
8.5. All information that is collected by third-party services, including payment systems, communications and other service providers, is stored and processed by these entities (Operators) in accordance with their User Agreement and Privacy Policy. Subject of personal data and/or with specified documents. The operator is not responsible for the actions of third parties, including the service providers specified in this paragraph.
8.6. Prohibitions established by the subject of personal data on the transfer (except for providing access), as well as on processing or conditions for processing (except for gaining access) of personal data permitted for distribution, do not apply in cases of processing personal data in state, public and other public interests determined by the laws 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 identifying the subject of personal data for no longer than required by the purposes of processing personal data if the storage period for personal data is not established by federal law, an agreement to which the subject of personal data is a party, beneficiary or guarantor.
8.9. The condition for terminating the processing of personal data may be the achievement of the purposes of processing personal data, the expiration of the consent of the subject of personal data, the withdrawal of consent by the subject of personal data or a requirement to cease the processing of personal data, as well as the identification of unlawful processing of personal data.

9. List of actions performed by the Operator with personal data received
9.1. The operator collects, records, systematizes, accumulates, stores, refines (updates, changes), extracts, uses, transfers (distribute, provide, access), depersonalizes, blocks, deletes and terminates personal data.
9.2. The operator carries out automated processing of personal data with or without receiving and/or transmitting the received information via information and telecommunication networks.

10. Cross-border transfer of personal data
10.1. Before starting activities of the cross-border transfer of personal data, the operator is obliged to notify the body authorized for the protection of the rights of personal data subjects of its intention to carry out cross-border transfer of personal data (such notification is sent separately from the notification of the intention to process personal data).
10.2. Before submitting the above mentioned notification, the operator is obliged to obtain relevant information from the authorities of a foreign state, foreign individuals, foreign legal entities to whom the cross-border transfer of personal data is planned.

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

12. Final provisions
12.1. The User can receive any clarification on issues of interest regarding the processing of his personal data by contacting the Operator via email: harlamov@malibu-group.ru.
12.2. This document will reflect any changes to the Operator’s personal data processing policy. The policy is valid indefinitely until it is replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet at https://honest-view.com.