1. General Provisions1.1. 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 Processing2.1. 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 Processing3.1. 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 Subjects4.1. 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).