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Personal Data Processing Policy of the Publishing House HORS LLC
1. General Provisions
1.1. This document sets outthe Policy of the Publishing House HORS LLC regarding the processing of personal data (hereinafter "Policy").
1.2. This Policy uses the terms and definitions specified in Table 1. Other terms used in this Policy shall have the meanings assigned by the legislation of the Russian Federation, other regulatory legal acts, and national standards in the field of personal data processing and protection.
Table 1 – List of Terms and Definitions

Term

Definition

Source

Automated Processing of Personal Data

Processing of personal data by means of computer technology

Federal Law No. 152-FZ of July 27, 2006 "On Personal Data"

Blocking of Personal Data

Temporary suspension of personal data processing (except where processing is necessary to rectify personal data)

Federal Law No. 152-FZ of July 27, 2006 "On Personal Data"

Personal Data Information System

A set of personal data contained in databases and information technologies and technical means ensuring their processing

Federal Law No. 152-FZ of July 27, 2006 "On Personal Data"

Personal Data Anonymisation

Actions that make it impossible without the use of additional information to determine the ownership of personal data to a specific data subject

Federal Law No. 152-FZ of July 27, 2006 "On Personal Data"

Personal Data Processing

Any action (operation) or set of actions (operations) performed with personal data, with or without the use of automation means, including collection, recording, systematization, accumulation, storage, rectification (updating, alteration), retrieval, use, transfer (distribution, provision, access), anonymisation, blocking, deletion, destruction of personal data

Federal Law No. 152-FZ of July 27, 2006 "On Personal Data"

Operator (data controller)

A state body, municipal body, legal entity or individual, that, independently or jointly with others, organizes and/or processes personal data, as well as determines the purposes of personal data processing, the composition of personal data to be processed, and actions (operations) performed with such data

Federal Law No. 152-FZ of July 27, 2006 "On Personal Data"

Personal Data

Any information relating directly or indirectly to an identified or identifiable individual (data subject)

Federal Law No. 152-FZ of July 27, 2006 "On Personal Data"

Personal Data Provision

Actions aimed at disclosing personal data to a specific individual or a specific group of individuals

Federal Law No. 152-FZ of July 27, 2006 "On Personal Data"

Personal Data Dissemination

Actions aimed at disclosing personal data to an indefinite group of individuals

Federal Law No. 152-FZ of July 27, 2006 "On Personal Data"

Computer Technology Means

A set of software and technical elements of data processing systems capable of functioning independently or as part of other systems

GOST R 50739-95

Personal Data Destruction

Actions that result in the irretrievable loss of personal data within the personal data information system and/or the destruction of the physical media containing such data

Federal Law No. 152-FZ of July 27, 2006 "On Personal Data"

Personal Data Processing Carried out without the Use of Automation Means

Actions involving personal data, such as use, rectification, dissemination, and destruction of personal data, performed in relation to each data subject, which are carried out with the direct human involvement

Decree of the Government of the Russian Federation No. 687 of September 15, 2008 "On Approval of the Regulation on the Specifics of Personal Data Processing Carried Out Without the Use of Automation Means"


1.3. This Policy is based on the following regulatory legal acts:
- Federal Law No. 152-FZ of July 27, 2006 "On Personal Data";
- Decree of the Government of the Russian Federation No. 1119 of November 1, 2012 "On Approval of Requirements for the Protection of Personal Data During Their Processing in Personal Data Information Systems";
- Decree of the Government of the Russian Federation No. 687 of September 15, 2008 "On Approval of the Regulation on the Specifics of Personal Data Processing Carried Out Without the Use of Automation Means".
1.4. This Policy, as well as all additions and amendments thereto, shall be approved by an order of the Publishing House HORS LLC.
1.5. The Policy shall be published on the official website of the Publishing House HORS LLC.
1.6. The provisions of the Policy shall apply to all relations related to the processing of personal data carried out in the Publishing House HORS LLC, with or without the use of automation means.
1.7. The Policy shall apply to all employees of the Publishing House HORS LLC.
2. Purposes of Personal Data Processing
2.1. The purposes of personal data processing in the Publishing House HORS LLC are:
- journalistic activities and/or lawful activities of a mass media outlet;
- exercising the functions, powers and duties assigned to the operator relating to employment relations and other directly related relations;
- preparation, conclusion and execution of a civil law contract;
3. Legal Basis for Personal Data Processing
3.1. The grounds for personal data processing in the Publishing House HORS LLC are the following regulatory acts and documents:
- The data subject's consent to the processing of their personal data;
- The data subject's consent to the processing of their personal data permitted by the data subject for dissemination;
- Processing of personal data is necessary for the purposes set out in an international treaty of the Russian Federation or law, to perform functions, powers and duties assigned by the legislation of the Russian Federation to the operator;
- Processing of personal data is necessary for journalistic activities and/or lawful activities of a mass media outlet, or scientific, literary or other creative activities, provided that the rights and legitimate interests of the data subject are not violated;
- The Constitution of the Russian Federation;
- The Labor Code of the Russian Federation;
- The Tax Code of the Russian Federation;
- The Civil Code of the Russian Federation;
- Federal Law No. 326-FZ of November 29, 2010 "On Compulsory Medical Insurance in the Russian Federation";
- Federal Law No. 165-FZ of July 16, 1999 "On the Basics of Compulsory Social Insurance";
- Federal Law No. 167-FZ of December 15, 2001 "On Compulsory Pension Insurance in the Russian Federation";
- Federal Law No. 255-FZ of December 29, 2006 "On Compulsory Social Insurance in Case of Temporary Disability and in Connection with Maternity";
- Federal Law No. 400-FZ of December 28, 2013 "On Insurance Pensions";
- Federal Law No. 166-FZ of December 15, 2001 "On State Pension Provision in the Russian Federation";
- Federal Law No. 53-FZ of March 28, 1998 "On Military Duty and Military Service";
- Federal Law No. 402-FZ of December 6, 2011 "On Accounting";
- Employment contract;
- Personal data processing is necessary for the performance of a contract to which the data subject is a party, beneficiary or surety, as well as for concluding a contract at the initiative of the data subject or a contract under which the data subject will be a beneficiary or surety. A contract concluded with a data subject shall not contain provisions restricting the rights and freedoms of the data subject, establishing cases of processing personal data of minors, unless otherwise provided by the legislation of the Russian Federation, as well as provisions making the failure of the data subject to act a condition for entering into a contract;
4. Scope and Categories of Personal Data Processed; Categories of Data Subjects
4.1. In accordance with the purposes of personal data processing specified in Clause 2 of this Policy, the Publishing House HORS LLC processes personal data of the following categories of subjects:
- Chief Editors;
- Employees;
- Reviewers;
- Website visitors (readers);
- Contractual Counterparties;
- Representatives of counterparties;
- Authors;
- Dismissed employees;
- Relatives of employees;
4.2. For each purpose of processing personal data processed in the Publishing House HORS LLC, the scope, categories and lists of personal data processed, categories of data subjects processed in personal data information systems, methods, terms of their processing and storage, and the procedure for destruction of personal data upon achievement of processing purposes or upon the occurrence of legal grounds shall be approved by orders of the Publishing House HORS LLC.
4.3. On the website https://dom-hors.ru/ for the purpose of journalistic activities and/or lawful activities of a mass media outlet – "website https://dom-hors.ru/" – the Publishing House HORS LLC uses one or more third-party metric programs: Yandex Metrica.
The composition and conditions for collecting anonymized data using third-party software (Yandex Metrica) are determined directly by their copyright holders and may include: operating system data (type, version, screen resolution), request data (time, referral source, IP address), browser data (type, version, cookies), device data and its location.
The Operator shall not be liable for the manner in which anonymized data is used by third parties (Yandex Metrica).

5. Principles and Conditions for Personal Data Processing
5.1. When processing personal data, the Publishing House HORS LLC observes the following principles:
- Personal data processing is carried out on a lawful and fair basis;
- Personal data processing is limited to achieving specific, predetermined and lawful purposes;
- Processing of personal data incompatible with the purposes of collecting personal data is not permitted;
- Combining databases containing personal data processed for mutually incompatible purposes is not permitted;
- Only personal data that meet the purposes of their processing shall be processed;
- The content and scope of processed personal data correspond to the stated purposes of processing;
- Processed personal data are adequate, relevant and not excessive in relation to the stated purposes of their processing;
- When processing personal data, the accuracy of personal data, their sufficiency, and, where necessary, relevance to the purposes of personal data processing are ensured;
- Necessary measures are taken to delete or rectify incomplete or inaccurate personal data;
- Personal data are stored in a form that allows identifying the data subject no longer than required by the purposes of personal data processing, unless the storage period for personal data is established by federal law or a contract to which the data subject is a party, beneficiary or surety; processed personal data shall be destroyed or anonymised upon achievement of processing purposes or in case of loss of necessity to achieve these purposes, unless otherwise provided by the legislation of the Russian Federation.
5.2. The Publishing House HORS LLC carries out both automated processing of personal data and processing without the use of automation means. Processing operations in the Publishing House HORS LLC include: collection, recording, systematization, accumulation, storage, rectification (updating, alteration), retrieval, use, transfer (provision, access), blocking, deletion, destruction, anonymisation, dissemination.
5.3. When collecting personal data, the Publishing House HORS LLC ensures recording, systematization, accumulation, storage, rectification (updating, alteration), retrieval of personal data using databases located on the territory of the Russian Federation.
5.4. The Publishing House HORS LLC does not engage third parties to process personal data.
5.5. Termination of personal data processing is carried out upon termination of the activities of the Publishing House HORS LLC (liquidation or reorganization).
5.6. Cross-border transfer of personal data is carried out in accordance with the requirements of Article 12 of Federal Law No. 152-FZ of June 27, 2006 "On Personal Data" for the purpose of providing issues of the periodical to international scientific citation databases that provide access to scientific information. Prior to commencing cross-border transfer of personal data, the Operator has duly notified the authorized body for the protection of data subjects' rights of its intention to carry out cross-border transfer of personal data.
5.7. The Publishing House HORS LLC ensures the confidentiality of personal data. Employees of the Publishing House HORS LLC who have gained access to personal data shall not disclose personal data to third parties or disseminate the data without the consent of the data subject, unless otherwise provided by federal law.
5.8. Processing of other categories of personal data is carried out by the Publishing House HORS LLC in compliance with the following conditions:
– Personal data processing is necessary for journalistic activities and/or lawful activities of a mass media outlet, or scientific, literary or other creative activities, provided that the rights and legitimate interests of the data subject are not violated;
– Personal data processing is carried out with the data subject's consent to the processing of their personal data;
– Personal data processing is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or law, to carry out and perform functions, powers and duties assigned by the legislation of the Russian Federation to the operator;
– Personal data processing is necessary for the performance of a contract to which the data subject is a party, beneficiary or surety, as well as for concluding a contract at the initiative of the data subject or a contract under which the data subject will be a beneficiary or surety. A contract concluded with a data subject may not contain provisions restricting the rights and freedoms of the data subject, establishing cases of processing personal data of minors, unless otherwise provided by the legislation of the Russian Federation, as well as provisions making the failure of the data subject to act a condition for concluding a contract.
5.9. Processing of special categories of personal data is permitted by the Publishing House HORS LLC in cases specified in Article 10 of the Federal Law "On Personal Data".
6. Implementation of Measures to Ensure the Security of Personal Data Adopted by the Publishing House HORS LLC
6.1. The Publishing House HORS LLC implements and maintains necessary and sufficient legal, organizational and technical measures to protect personal data from unlawful or accidental access, destruction, alteration, blocking, copying, provision, dissemination of personal data, as well as from other unlawful actions in relation to personal data.
Such measures in the Publishing House HORS LLC include:
- Appointment of a person responsible for organizing personal data processing;
- Issuance of local acts on personal data processing issues, defining for each purpose of personal data processing the categories and list of personal data processed, categories of subjects whose personal data are processed, methods, terms of their processing and storage, procedure for destruction of personal data upon achievement of their processing purposes or upon the occurrence of other legal grounds, as well as local acts establishing procedures aimed at preventing and detecting violations of the legislation of the Russian Federation in the field of personal data processing and protection, and eliminating the consequences of such violations;
- Implementation of internal control over the compliance of personal data processing with the legislation of the Russian Federation on personal data, requirements for the protection of personal data, internal documents of the Publishing House HORS LLC in the field of personal data processing and protection;
- Assessment of harm that may be caused to data subjects in the event of violation of Federal Law "On Personal Data", and the assessment of disproportionality to the measures adopted by the Publishing House HORS LLC aimed at ensuring the fulfillment of obligations provided for by Federal Law "On Personal Data";
- Ensuring that the employees of the Publishing House HORS LLC are informed of the provisions of the legislation of the Russian Federation on personal data, internal documents of the Publishing House HORS LLC on personal data processing issues, and requirements for the protection of personal data;
- Application or ensuring the application of legal, organizational and technical measures to ensure the security of personal data in accordance with Article 19 of the Federal Law "On Personal Data", in particular:
- Identification of threats to personal data security during their processing in personal data information systems of the Publishing House HORS LLC;
- Implementation of technical and organizational measures to protect personal data processed in personal data information systems of the Publishing House HORS LLC based on the requirements approved by Decree of the Government of the Russian Federation No. 1119 of November 1, 2012 "On Approval of Requirements for the Protection of Personal Data During Their Processing in Personal Data Information Systems" and the requirements of Order of the FSTEC of Russia No. 21 of February 18, 2013 "On Approval of the Composition and Content of Organizational and Technical Measures to Ensure the Security of Personal Data During Their Processing in Personal Data Information Systems" developed based on the results of:
- Determination of categories of personal data processed in personal data information systems of the Publishing House HORS LLC;
- Determination of the level of personal data protection during their processing in personal data information systems based on analysis of current threats to personal data security and possible damage to data subjects in the event of realization of threats to personal data security;
- Organization of a regime ensuring the security of premises where personal data information systems are located, preventing the possibility of uncontrolled entry or presence in these premises of individuals without access rights to these premises;
- Ensuring accounting and safekeeping of machine-readable personal data carriers;
- Organization of access to personal data processed in personal data information systems;
- Use of information security means that have undergone conformity assessment procedures with the requirements of the legislation of the Russian Federation in the field of information security;
- Implementation of anti-virus monitoring and detection;
- Use of network security (filtering) firewalls;
- Timely installation of updates for software used in personal data information systems and information security means;
- Organization of protection of technical means of personal data information systems.

7. Personal Data Processing Carried out without the Use of Automation Means
7.1. Personal data, when processed without the use of automation means, shall be separated from other information, in particular by recording it on separate physical media for personal data (hereinafter "physical media"), in special sections or on the margins of forms.
7.2. When recording personal data on physical media, recording personal data with obviously incompatible processing purposes on the same physical medium is not permitted. For processing different categories of personal data without the use of automation means, a separate physical medium shall be used for each category of personal data.
7.3. Individuals processing personal data without the use of automation means (including employees of the Publishing House HORS LLC or persons carrying out such processing under a contract with the Publishing House HORS LLC) shall be informed that they process personal data on behalf of the Publishing House HORS LLC, the categories of personal data being processed, as well as the specifics and rules for carrying out such processing established by regulatory legal acts of the Russian Federation and local legal acts of the Publishing House HORS LLC.
7.4. When using standard document forms, where the nature of the information suggests or permits the inclusion of personal data (hereinafter "standard form"), the following conditions shall be observed:
- The standard form or related documents (instructions for its completion, cards, registers and logs) shall contain information about the purpose of personal data processing carried out without the use of automation means, the name and address of the Publishing House HORS LLC, the surname, first name, patronymic and address of the data subject, the source of obtaining personal data, the terms of personal data processing, the list of actions with personal data to be performed during their processing, a general description of the methods of personal data processing used by the Publishing House HORS LLC;
- The standard form shall provide a field in which the data subject may provide their consent to the processing of personal data carried out without the use of automation means, if written consent to the processing of personal data is required;
- The standard form shall be drawn up in such a way that each data subject whose personal data are contained in the document may have the opportunity to review their personal data contained in the document without violating the rights and legitimate interests of other data subjects;
- The standard form shall preclude the combination of fields intended for entering personal data whose processing purposes are manifestly incompatible.
7.5. If the purposes of processing personal data recorded on the same physical media are incompatible, and if the media does not allow processing personal data separately from other personal data recorded on the same media, measures shall be taken to ensure separate processing of personal data, in particular:
- If it is necessary to use or disseminate certain personal data separately from other personal data on the same physical media, the personal data to be disseminated or used shall be copied in a manner that precludes simultaneous copying of personal data not subject to dissemination and use, and the copy of personal data shall be used (disseminated);
- If it is necessary to destroy or block part of the personal data, the physical media shall be destroyed or blocked, with prior copying of information not subject to destruction or blocking in a manner that precludes simultaneous copying of data subject to destruction or blocking.
7.6. Destruction or anonymisation of part of the personal data, if permitted by the physical media, may be carried out in a manner that precludes further processing of such personal data while preserving the possibility of processing other data recorded on the physical media (deletion, redaction). The provisions set forth in this clause and clause 7.5 of this Policy shall also apply if it is necessary to ensure separate processing of personal data recorded on the same physical media and information not containing personal data.
7.7. Rectification of personal data during their processing without the use of automation means shall be carried out by updating or changing data on the physical media, or, if this is not permitted by the technical characteristics of the media, by recording information about the changes made on the same media, or by producing a new physical medium with the rectified personal data.
7.8. Measures to ensure the security of personal data during their processing carried out without the use of automation means:
- Processing of personal data carried out without the use of automation means shall be carried out in such a way that, for each category of personal data, the storage locations of personal data (physical media) can be determined and a list of individuals processing personal data or having access to them can be established;
- Separate storage of personal data (physical media) processed for different purposes shall be ensured;
- When storing physical media, conditions ensuring the safety of personal data and preventing unauthorized access to them shall be observed. The list of measures necessary to ensure such conditions, the procedure for their adoption, as well as the list of individuals responsible for the implementation of such measures, shall be established by the Publishing House HORS LLC.
8. Updating, Correction, Deletion and Destruction of Personal Data, Responses to Requests from Subjects for Access to Personal Data
8.1. Rights of data subjects:
8.1.1. The right of a data subject to access their personal data:
1) A data subject has the right to receive information (hereinafter referred to as "requested information") concerning the processing of their personal data, including containing:
- Confirmation of the fact of personal data processing by the Publishing House HORS LLC;
- Legal grounds and purposes of personal data processing;
- Purposes and methods of personal data processing used by the Publishing House HORS LLC;
- Name and registered address of the Publishing House HORS LLC, information about individuals (excluding employees of the Publishing House HORS LLC) who have access to personal data or to whom personal data may be disclosed on the basis of a contract with the Publishing House HORS LLC or on the basis of federal law;
- Processed personal data relating to the relevant data subject, the source of their receipt, unless a different procedure for providing such data is provided for by federal law;
- Terms of personal data processing, including storage periods;
- Procedure for exercising the rights provided for by Federal Law "On Personal Data" by the data subject;
- Information on completed or proposed cross-border data transfer;
- Full name and address of the individual processing personal data on behalf of the Publishing House HORS LLC, if processing is or will be entrusted to such person;
- Information on how the operator fulfills the obligations established by Article 18.1 of Federal Law "On Personal Data";
- Other information provided for by Federal Law "On Personal Data" or other federal laws.
2) A data subject has the right to receive the requested information, except in cases where the data subject's access to their personal data violates the rights and legitimate interests of third parties.
3) A data subject has the right to demand from the Publishing House HORS LLC the rectification of their personal data, their blocking or destruction if the personal data are incomplete, outdated, inaccurate, unlawfully obtained, or are not necessary for the stated purpose of processing, as well as to take measures provided for by law to protect their rights.
4) The requested information shall be provided to the data subject by the Publishing House HORS LLC in an accessible form, and shall not contain personal data relating to other data subjects, unless there are legal grounds for disclosing such personal data.
5) The requested information shall be provided to the data subject or their representative by the Publishing House HORS LLC within 10 business days from the date of the request or upon receipt of the request from the data subject or their representative. This period may be extended, but by no more than 5 business days, by sending a reasoned notice to the data subject indicating the reasons for extending the period for providing the requested information. The request must contain the number of the main identity document of the data subject or their representative, information on the date of issuance of said document and the issuing authority, information confirming the data subject's participation in relations with the Publishing House HORS LLC (contract number, date of conclusion of the contract, conventional verbal designation and/or other information), or information otherwise confirming the fact of personal data processing by the Publishing House HORS LLC, and the signature of the data subject or their representative (hereinafter "information required for the request"). The request may be sent in the form of an electronic document and signed with an electronic signature in accordance with the legislation of the Russian Federation. The Publishing House HORS LLC shall provide information to the data subject or their representative in the form in which the relevant application or request was submitted, unless otherwise specified in the application or request.
6) If the requested information, as well as the processed personal data, were provided for review to the data subject upon their request, the data subject has the right to re-apply to the Publishing House HORS LLC or send a repeat request for the purpose of obtaining the requested information and reviewing such personal data no earlier than 30 days after the initial application or submission of the initial request, unless a shorter period is established by federal law, a regulatory legal act adopted in accordance therewith, or a contract to which the data subject is a party, beneficiary or surety.
7) A data subject has the right to re-apply to the Publishing House HORS LLC or send a repeat request for the purpose of obtaining the requested information, as well as for the purpose of reviewing the processed personal data, before the expiration of the period specified in subclause 6 of clause 8.1.1 of this Policy, if such information and/or processed personal data were not provided to them for review in full based on the results of consideration of the initial request. The repeat request, along with the information required for the request, must contain a justification for submitting the repeat request.
8) The Publishing House HORS LLC has the right to refuse the data subject to fulfill a repeat request that does not meet the conditions for a repeat request. Such refusal shall be reasoned. The obligation to provide evidence justifying the refusal to fulfill a repeat request lies with the Publishing House HORS LLC.
8.1.2. Right to appeal actions or inaction of the Publishing House HORS LLC:
1) If a data subject believes that the Publishing House HORS LLC is processing their personal data in violation of the requirements of Federal Law "On Personal Data" or otherwise violating their rights and freedoms, the data subject has the right to appeal the actions or inaction of the Publishing House HORS LLC to the authorized body for the protection of data subjects' rights or in court.
2) A data subject has the right to protect their rights and legitimate interests, including compensation for losses and/or compensation for moral harm in court.
8.1.3.Processing of personal data for the purpose of promoting goods, works, and services on the market through direct contacts with potential consumers using communication means, as well as for the purpose of political campaigning, is not carried out by the Publishing House HORS LLC.
8.2. Obligations of the operator:
8.2.1. Obligations of the operator when collecting personal data:
1) When collecting personal data, the Publishing House HORS LLC shall provide the data subject, upon their request, with the requested information concerning the processing of their personal data in accordance with Part 7 of Article 14 of Federal Law "On Personal Data".
2) If the provision of personal data and/or obtaining consent from the Publishing House HORS LLC for the processing of personal data is mandatory in accordance with federal law, the Publishing House HORS LLC shall inform the data subject the legal consequences of refusing to provide their personal data and/or give consent to their processing.
3) If personal data is obtained not from the data subject, the Publishing House HORS LLC shall, prior to commencing processing of such personal data, provide the data subject with the following information (hereinafter as "information to be provided when personal data is obtained not from the data subject"):
- The name and address of the Publishing House Hors LLC;
- The purpose of personal data processing and its legal basis;
- The list of personal data;
- The intended users of the personal data;
- The rights of the data subject established by Federal Law "On Personal Data";
- The source of obtaining the personal data.
4) The Publishing House HORS LLC shall not provide the subject with information to be provided when personal data is obtained not from the data subject in cases where:
- The data subject has been notified of the processing of their personal data by the Publishing House HORS LLC;
- Personal data was obtained by the Publishing House HORS LLC on the basis of federal law or in connection with the performance of a contract to which the data subject is a party, beneficiary or surety;
- Processing of personal data permitted by the data subject for dissemination is carried out in compliance with the prohibitions and conditions provided for in Article 10.1 of Federal Law No. 152-FZ of June 27, 2006 "On Personal Data";
- The Publishing House HORS LLC processes personal data for statistical or other research purposes, for journalistic activities, or for scientific, literary or other creative activities, provided that the rights and legitimate interests of the data subject are not violated;
- Providing the data subject with information to be provided when personal data is obtained not from the data subject violates the rights and legitimate interests of third parties.
8.2.2. Obligations of the operator when a data subject applies to the operator or upon receipt of a request from a data subject or their representative, as well as from the authorized body for the protection of data subjects' rights:
1) The Publishing House HORS LLC shall, in accordance with the established procedure, inform the data subject or their representative of the existence of personal data relating to the relevant data subject, and also provide an opportunity to review such personal data upon application of the data subject or their representative, or within 10 business days from the date of receipt of the request from the data subject or their representative. This period may be extended, but by no more than 5 business days, by sending a reasoned notice to the data subject indicating the reasons for extending the period for providing the requested information.
2) In case of refusal to provide information on the existence of personal data regarding the relevant data subject or to provide personal data to the data subject or their representative upon their application or upon receipt of a request from the data subject or their representative, the Publishing House HORS LLC shall provide a reasoned response in writing within a period not exceeding 10 business days from the date of the application of the data subject or their representative, or from the date of receipt of the request from the data subject or their representative. This period may be extended, but by no more than 5 business days, by sending a reasoned notice to the data subject indicating the reasons for extending the period for providing the requested information.
3) The Publishing House HORS LLC shall provide the data subject or their representative with the opportunity to review the personal data relating to that data subject free of charge. Within a period not exceeding 7 business days from the date the data subject or their representative provides information confirming that the personal data is incomplete, inaccurate, or outdated, the Publishing House HORS LLC shall make the necessary changes to it. Within a period not exceeding 7 business days from the date the data subject or their representative provides information confirming that such personal data was unlawfully obtained or is not necessary for the stated purpose of processing, the Publishing House HORS LLC shall destroy such personal data. The Publishing House HORS LLC shall notify the data subject or their representative of the changes made and measures taken, and shall take reasonable measures to notify third parties to whom the personal data of that subject was transferred.
4) The Publishing House HORS LLC shall provide the authorized body for the protection of data subjects' rights with the necessary information upon request from that body within 10 business days from the date of receipt of such request. This period may be extended, but by no more than 5 business days, by sending a reasoned notice to the authorized body for the protection of data subjects' rights indicating the reasons for extending the period for providing the requested information.
8.2.3. Obligations of the operator to eliminate violations of the law committed during personal data processing, to rectify, block and destroy personal data:
1) In the event of detection of unlawful processing of personal data upon application of the data subject or their representative, or upon request of the data subject or their representative, or the authorized body for the protection of data subjects' rights, the Publishing House HORS LLC shall block the unlawfully processed personal data relating to that data subject, or ensure their blocking (if personal data processing is carried out by another person acting on behalf of the Publishing House HORS LLC) from the moment of such application or receipt of said request for the period of verification. In the event of detection of inaccurate personal data upon application of the data subject or their representative, or upon their request, or upon request of the authorized body for the protection of data subjects' rights, the Publishing House HORS LLC shall block the personal data relating to that data subject, or ensure their blocking (if personal data processing is carried out by another person acting on behalf of the Publishing House HORS LLC) from the moment of such application or receipt of said request for the period of verification, if blocking of personal data does not violate the rights and legitimate interests of the data subject or third parties.
2) In the event of confirmation of the inaccuracy of personal data, the Publishing House HORS LLC, on the basis of information provided by the data subject or their representative, or the authorized body for the protection of data subjects' rights, or other necessary documents, shall rectify the personal data or ensure their rectification (if personal data processing is carried out by another person acting on behalf of the Publishing House HORS LLC) within 7 business days from the date of provision of such information and shall lift the blocking of personal data.
3) In the event of detection of unlawful processing of personal data carried out by the Publishing House HORS LLC or a person acting on behalf of the Publishing House HORS LLC, the Publishing House HORS LLC shall, within a period not exceeding 3 business days from the date of such detection, cease the unlawful processing of personal data or ensure the cessation of unlawful processing of personal data by the person acting on behalf of the Publishing House HORS LLC. If it is impossible to ensure the lawfulness of personal data processing, the Publishing House HORS LLC shall, within a period not exceeding 10 business days from the date of detection of unlawful processing of personal data, destroy such personal data or ensure their destruction. The Publishing House HORS LLC shall notify the data subject or their representative of the elimination of the violations committed or of the destruction of personal data, and, if the application of the data subject or their representative or the request of the authorized body for the protection of data subjects' rights was sent by the authorized body for the protection of data subjects' rights, also notify said body.
4) In case of detection of unlawful or accidental transfer (provision, dissemination, access) of personal data resulting in a violation of the rights of data subjects, the Publishing House HORS LLC shall, upon becoming aware of the incident, the authorized body for the protection of data subjects' rights, or another interested party, notify the authorized body for the protection of data subjects' rights:
- within 24 hours of the incident that occurred, of the suspected causes that led to the violation of the rights of data subjects, and the suspected harm caused to the rights of data subjects, of the measures taken to eliminate the consequences of the relevant incident, and also provide information about the person authorized by the Publishing House HORS LLC to interact with the authorized body for the protection of data subjects' rights on issues related to the identified incident;
- within 72 hours of the results of the internal investigation of the identified incident, and also provide information about the persons whose actions caused the identified incident (if any).
5) Upon achieving the purpose of personal data processing, the Publishing House HORS LLC shall cease processing personal data or ensure its cessation (if personal data processing is carried out by another person acting on behalf of the Publishing House HORS LLC) and shall destroy personal data or ensure their destruction (if personal data processing is carried out by another person acting on behalf of the Publishing House HORS LLC) within a period not exceeding 30 days from the date of achieving the purpose of personal data processing, unless otherwise provided by a contract to which the data subject is a party, beneficiary or surety, or by another agreement between the Publishing House HORS LLC and the data subject, or unless the Publishing House HORS LLC is not entitled to process personal data without the data subject's consent on the grounds provided for by Federal Law "On Personal Data" or other federal laws.
6) In case of withdrawal of consent to the processing of their personal data by the data subject, the Publishing House HORS LLC shall cease processing such data or ensure the cessation of such processing (if personal data processing is carried out by another person acting on behalf of the Publishing House HORS LLC) and, if the retention of personal data is no longer required for the purposes of personal data processing, shall destroy the personal data or ensure their destruction (if personal data processing is carried out by another person acting on behalf of the Publishing House HORS LLC) within a period not exceeding 30 days from the date of receipt of said withdrawal, unless otherwise provided by a contract to which the data subject is a party, beneficiary or surety, or by another agreement between the Publishing House HORS LLC and the data subject, or unless the Publishing House HORS LLC is not entitled to process personal data without the data subject's consent on the grounds provided for by Federal Law "On Personal Data" or other federal laws.
7) In case of a request from a data subject to the Publishing House HORS LLC to cease processing personal data, the operator shall, within a period not exceeding 10 business days from the date of receipt by the operator of such request, cease processing such data or ensure the cessation of such processing (if such processing is carried out by a person processing personal data), except in cases provided for by Federal Law "On Personal Data". This period may be extended, but by no more than 5 business days, by sending a reasoned notice to the data subject indicating the reasons for extending the period for providing the requested information.
8) If it is impossible to destroy personal data within the specified period, the Publishing House HORS LLC shall block such personal data or ensure their blocking (if personal data processing is carried out by another person acting on behalf of the Publishing House HORS LLC) and shall ensure the destruction of personal data within a period not exceeding 6 months, unless another period is established by federal laws.
8.3. The rules for considering requests from data subjects or their representatives in the Publishing House HORS LLC, as well as the forms for considering relevant requests from data subjects or their representatives, shall be approved by an order of the Publishing House HORS LLC.
9. Liability
9.1. Individuals guilty of violating the requirements of Federal Law "On Personal Data" shall be liable as provided for by the legislation of the Russian Federation.
9.2. Moral harm caused to a data subject as a result of violation of their rights, violation of the rules for processing personal data established by Federal Law "On Personal Data", as well as requirements for the protection of personal data established in accordance with Federal Law "On Personal Data", shall be compensated in accordance with the legislation of the Russian Federation. Compensation for moral harm shall be made regardless of compensation for material harm and losses incurred by the data subject.