1.1. The Operator's highest priority and a condition for its operations is the observance of human and civil rights and freedoms when processing their personal data, including the protection of the rights to privacy, personal and family secrets.
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 obtain about visitors to the website https://en.hot-walls.ru/.

2.1. Automated processing of personal data — processing of personal data by means of computer technology.
2.2. Blocking of personal data — temporary cessation of processing of personal data (except in cases where processing is necessary to clarify personal data).
2.3. Website — an aggregate of graphic and informational materials, as well as computer programs and databases that ensure their availability on the Internet at the network address https://en.hot-walls.ru/.
2.4. Personal data information system — an aggregate of personal data contained in databases and the information technologies and technical means ensuring 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) 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, destruction of personal data.
2.7. Operator — a state body, municipal body, legal entity, or individual that independently or jointly with others organizes and/or performs the processing of personal data, as well as 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 relating directly or indirectly to a specific or identifiable User of the website https://en.hot-walls.ru/.
2.9. Personal data permitted by the subject of personal data for dissemination — personal data, access to which by an unlimited number of persons has been provided by the subject of personal data by giving consent to the processing of personal data permitted by the subject of personal data for dissemination in the manner prescribed by the Personal Data Law (hereinafter referred to as "personal data permitted for dissemination").
2.10. User — any visitor to the website https://en.hot-walls.ru/.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific circle of persons.
2.12. Dissemination of personal data — any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or at making personal data available to an unlimited number of persons, including the publication of personal data in mass media, placement in information and telecommunication networks, or providing access to personal data in any other way.
2.13. Cross-border transfer of personal data — 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. Destruction of personal data — any actions as a result of which personal data are destroyed irreversibly with the impossibility of further restoring the content of personal data in the personal data information system and/or as a result of which the material media of personal data are destroyed.

3.1. The Operator has the right:
— To receive from the subject of personal data reliable information and/or documents containing personal data;
— In case the subject of personal data withdraws consent to the processing of personal data, as well as submits a request to cease 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 specified in the Personal Data Law;
— To independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations provided for by the Personal Data Law and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.
3.2. The Operator is obliged:
— To provide the subject of personal data, 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 current legislation of the Russian Federation;
— To respond to appeals and requests from subjects of personal data and their legal representatives in accordance with the requirements of the Personal Data Law;
— To report to the authorized body for the protection of the rights of subjects of personal data, upon request of this body, the necessary information within 10 days from the date of receipt of such request;
— To publish or otherwise provide unrestricted access to this Policy regarding the processing of personal data;
— To take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision, dissemination of personal data, as well as from other unlawful actions regarding personal data;
— To cease the transfer (distribution, provision, access) of personal data, cease processing, and destroy personal data in the manner and cases provided for by the Personal Data Law;
— To perform other duties provided for by the Personal Data Law.

4.1. Subjects of personal data 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 subject of personal data by the Operator in an accessible form and should not contain personal data relating to other subjects of personal data, except in cases where there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
— To demand from the Operator clarification of their personal data, its blocking, or destruction if the personal data is incomplete, outdated, inaccurate, unlawfully obtained, or is not necessary for the stated purpose of processing, and to take legal measures to protect their rights;
— To stipulate prior consent when processing personal data for the purpose of promoting goods, works, and services on the market;
— To withdraw consent to the processing of personal data, as well as to submit a request to cease processing personal data;
— To appeal to the authorized body for the protection of the rights of subjects of personal data or in court 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. Subjects of personal data are obliged:
— To provide the Operator with reliable data about themselves;
— To inform the Operator about the clarification (updating, modification) of their personal data.
4.3. Persons who have provided the Operator with false information about themselves or information about another subject of personal data without the latter's consent shall bear responsibility in accordance with the legislation of the Russian Federation.

5.1. Processing of personal data is carried out on a lawful and fair basis.
5.2. Processing of personal data is limited to achieving specific, predetermined, and lawful purposes. Processing of personal data incompatible with the purposes of collecting personal data is not allowed.
5.3. Merging of databases containing personal data, the processing of which is carried out for incompatible purposes, is not allowed.
5.4. Only personal data that meets the purposes of its processing is subject to processing.
5.5. The content and volume of processed personal data correspond to the stated purposes of processing. Redundancy of processed personal data relative to the stated purposes of their processing is not allowed.
5.6. When processing personal data, accuracy, sufficiency, and, where necessary, relevance of personal data in relation to the purposes of processing are ensured. The Operator takes necessary measures and/or ensures their adoption to delete or clarify incomplete or inaccurate data.
5.7. Storage of personal data is carried out in a form that allows identification of the subject of personal data for no longer than required by the purposes of processing personal data, unless the storage period for personal data is established by federal law, an agreement to which the subject of personal data is a party, beneficiary, or guarantor. Processed personal data is destroyed or depersonalized upon achieving the processing purposes or in case of loss of necessity to achieve these purposes, unless otherwise provided by federal law.

6. Processing Purposes.
The purposes of processing the User's personal data are to provide information about the Operator's products/services, promotions, special offers, and other events potentially of interest to the User.

6.1. Personal data:

• Last name, first name, patronymic
• Email address
• Phone numbers
• Address
• Date of birth
• Link to personal website and/or social media profile
• Photograph
• Internet session data (behavioral statistics)

6.2. Legal grounds:

• The Operator's charter (constituent) documents

6.3. Types of personal data processing:

• Collection, recording, systematization, accumulation, storage, destruction, and depersonalization of personal data.
• Email Campaigns: Sending promotional emails with promotions, news, special offers, as well as personalized offers based on analysis of User preferences and interests.
• Push Notifications: Sending notifications via mobile applications and/or browser (Web Push) with information about events, news, and updates.
• SMS Campaigns: Sending promotional messages to the phone number specified by the User.
• Messenger Communications: Sending promotional messages via the User's used messengers, including but not limited to WhatsApp, Telegram, Viber, and other similar platforms.
• Social Media: Sending private messages on social networks, targeting advertisements, and interacting via comments under the User's publications (in case of interaction).
• Manager Phone Calls: Making outbound calls to the User with offers of promotions, special terms, new products/services, and other promotional information.
• Chatbots and Auto-messaging: Sending automated promotional messages via chatbots in messengers.
• Retargeting and Personalized Advertising: Displaying targeted advertising on social networks, search engines, and partner websites based on analysis of past visits to the Operator's Website/Application and interaction history with the Operator's content.
• Advertising via Affiliate Programs: Providing recommendations and personal offers through the Operator's partner companies based on analysis of User interests and preferences.
• Personal Offers in the Personal Account: Sending notifications about discounts, promotions, special offers in the User's Personal Account (if available).

6.4. Depersonalized User data collected via internet statistics services is used to collect information about Users' actions on the site, improve the quality of the site and its content.

6.5. The User may at any time withdraw their consent to the processing of personal data by sending a notification to the Operator via email to the Operator's email address info@hot-walls.ru with the subject "Withdrawal of consent to the processing of personal data."

7.1. Processing of personal data is carried out with the consent of the subject of personal data to the processing of their personal data.
7.2. Processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, to perform the functions, powers, and duties imposed on the operator by the legislation of the Russian Federation.
7.3. Processing of personal data is necessary for the administration of justice, execution of a judicial act, act of another body or official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. Processing of personal data is necessary for the performance of a contract to which the subject of personal data is a party, beneficiary, or guarantor, as well as for concluding a contract on the initiative of the subject of personal data or a contract under which the subject of personal data will be a beneficiary or guarantor.
7.5. Processing of personal data is necessary for the exercise of 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 subject of personal data are not violated.
7.6. Processing of personal data, access to which is provided by the subject of personal data or at their request to an unlimited number of persons (hereinafter referred to as "publicly available personal data"), is carried out.
7.7. Processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.

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 execution of current legislation or if the subject of personal data has given consent to the Operator to transfer data to a third party to fulfill obligations under a civil law contract.
8.3. In case of inaccuracies in personal data, the User may update them independently by sending a notification to the Operator's email address info@hot-walls.ru with the subject "Updating personal data."
8.4. The period of processing personal data is determined by the achievement of the purposes for which the personal data was collected, unless another period is provided for by the contract or current legislation.
The User may at any time withdraw their consent to the processing of personal data by sending a notification to the Operator via email to the Operator's email address info@hot-walls.ru with the subject "Withdrawal of consent to the processing of personal data."
8.5. All information collected by third-party services, including payment systems, communication means, and other service providers, is stored and processed by the said persons (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data and/or with the specified documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.
8.6. Prohibitions established by the subject of personal data on the transfer (except for providing access), as well as on the processing or conditions of processing (except for obtaining access) of personal data permitted for dissemination, do not apply in cases of processing personal data in state, public, and other public interests defined by the legislation of the Russian Federation.
8.7. The Operator ensures the confidentiality of personal data during their processing.
8.8. The Operator stores personal data in a form that allows identification of the subject of personal data for no longer than required by the purposes of processing personal data, unless the storage period for personal data is established by federal law, an agreement to which the subject of personal data is a party, beneficiary, or guarantor.
8.9. Conditions for terminating the processing of personal data may include achieving the purposes of processing personal data, expiration of the consent of the subject of personal data, withdrawal of consent by the subject of personal data, or a demand to cease processing personal data, as well as the detection of unlawful processing of personal data.

9.1. The Operator performs collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, 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 transmission of the received information via information and telecommunication networks or without it.

10.1. Before commencing activities related to the cross-border transfer of personal data, the Operator is obliged to notify the authorized body for the protection of the rights of subjects of personal data 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 aforementioned notification, the Operator is obliged to obtain relevant information from the authorities of the foreign state, foreign individuals, foreign legal entities to whom the cross-border transfer of personal data is planned.

12.1. The Operator, for the purposes of processing personal data established by this Policy, may collect electronic user data on its websites automatically, without requiring user participation or any actions to send data.
12.2. The Operator does not verify the accuracy of electronic data collected in this manner; information is processed "as is" in the form it is received from the client device.
12.3. Users may be shown pop-up notifications about the collection and processing of cookies data with a link to this Policy and buttons to accept the processing conditions or close the pop-up notification.
12.4. Such notifications mean that when visiting and using the Website, information (e.g., cookies data) may be saved in the browser on the user's device, allowing further identification of the user or device, remembering the work session, or saving some user settings and preferences specific to these particular sites. Such information, after being saved in the browser and until the expiration of the set validity period or deletion from the device, will be sent with each subsequent request to the site on whose behalf they were saved, for processing by the Operator.
12.5. Processing of cookies data is necessary for the Operator for the correct operation of the sites, in particular, their functions related to access for registered users to the Operator's software products, services, works, and resources; user personalization; improving the efficiency and convenience of working with the sites, as well as for other purposes provided for in this Policy.
12.6. In addition to processing cookies set by the Operator's sites themselves, users and visitors may have cookies set that relate to third-party websites, for example, when third-party components and software are used on the Operator's sites. The processing of such cookies is governed by the policies of the respective sites to which they belong and may change without notice to users of the Operator's sites. Such cases may include placement on sites:
12.6.1. Visitor counters, analytical and statistical services such as Yandex.Metrica or Google Analytics for collecting statistics on the traffic of publicly available site pages.
12.6.2. Widgets of auxiliary services for collecting feedback, organizing chats, and other types of communication with users.
12.6.3. Contextual advertising systems, banner and other marketing networks.
12.6.4. Authorization buttons on sites using social media accounts.
12.6.5. Other third-party components used by the Operator on its sites.
12.7. The User's acceptance of the cookies processing conditions or closing the pop-up notification in accordance with this Policy is regarded as consent to the processing of cookies data on the Website.
12.8. If the user does not agree with the processing of cookies, they must accept the risk that in such a case, the site's functions and capabilities may not be available in full, and then follow one of the following options:
12.8.1. Configure their browser independently in accordance with its documentation or help so that it permanently does not allow accepting or sending cookies data for any sites or for the specific site of the Operator or the site of a third-party component.
12.8.2. Switch to the browser's special "incognito" mode to allow the site to use cookies until the browser window is closed or until switching back to normal mode.
12.8.3. Leave the site to avoid further processing of cookies.
12.9. The User can independently manage saved cookies data through the built-in browser tools for working with cookies, including deleting or viewing information about cookies set by sites, such as:
12.9.1. Website addresses and paths to which cookies will be sent.
12.9.2. Names and values of parameters stored in cookies.
12.9.3. Expiration dates of cookies.

13.1. The User can obtain any clarifications on questions of interest regarding the processing of their personal data by contacting the Operator via email at info@hot-walls.ru.
13.2. This document will reflect any changes to the Operator's personal data processing policy. The Policy is valid indefinitely until replaced by a new version.
13.3. The current version of the Policy is freely available on the Internet at https://en.hot-walls.ru/privacy.