In this document, Limited Liability Company “ECH A ES” (also referred to as “we,” “us,” “our” in this text) describes the procedure for processing personal data of visitors to the websites: https://hrs.ru, https://ru.hrsacademy.com, and the social network group VKontakte.

If you have any questions regarding the processing of personal data, you may send a letter to:
• our legal address: 109028, Moscow, Tagansky District, Serebryanicheskaya Embankment, 29, room I, or
• our official email: info@hrs.ru.

We attach great importance to protecting your privacy and the security of your personal data. We ask you to carefully read the Personal Data Processing Policy (hereinafter – the Policy) to understand the purposes for which we process your personal data and how you can exercise your rights concerning your personal data.

A bit about personal data and your rights regarding its processing
Personal data means any information that directly or indirectly relates to you or allows you to be identified.

A personal data operator is a legal or natural person who processes personal data. When you visit our website, we become the operator of your personal data.

Personal data processing means performing any actions with personal data.
According to the Federal Law “On Personal Data,” you have the right to:
• access your personal data;
• correct your personal data;
• block and delete personal data;
• appeal against our actions or inactions;
• appeal decisions made solely on the basis of automated processing of your personal data;
• withdraw consent to personal data processing.

How can you exercise your rights?
• You can submit an official request to our address (109028, Moscow, Tagansky District, Serebryanicheskaya Embankment, 29, room I), indicating information about the identity document (type, series and number, issuing authority and date), your full name or your representative’s full name, information confirming your relationship with the data subject that proves the fact of personal data processing, and your signature or that of your representative.
Such a request may be sent to our email as an electronic document signed in accordance with the laws of the Russian Federation on electronic signatures;
• You can also use our email address for inquiries: info@hrs.ru.

You may appeal against our actions as a personal data operator to the territorial office of Roskomnadzor in your region.

Why do we process your personal data?
This section explains the purposes and terms of personal data processing, as well as to whom we may transfer your personal data.
For the stated purposes, we may collect, record, systematize, accumulate, store, update (renew, modify), extract, use, transfer (provide, grant access), block, delete, or destroy your personal data.
Personal data processing on the site https://hrs.ru

Processing requests submitted via website feedback forms
You may send inquiries via email or by sending a letter to the postal address. When processing requests, we may process the following personal data:
• full name;
• contact phone numbers;
• email;
• company name;
• other information specified in the message.

The personal data processed for this purpose are not special categories or biometric data according to Articles 10–11 of Federal Law 152-FZ and are processed by automated and non-automated methods.

The legal basis for processing these personal data is Consent to the processing of personal data in accordance with paragraph 1, part 1, article 6 of Federal Law 152-FZ.

Personal data are processed up to 30 days from the completion date of processing the request received via feedback forms on the website.
After this period, the user’s personal data is destroyed by deleting it from the information systems using built-in tools, and from paper media, if any, by burning or shredding.

Processing inquiries received through contact channels specified on the website
If you have questions about our products or company activities, you can contact us using the contacts provided on the website.
For this purpose, we may access the following personal data:
• full name;
• contact phone numbers;
• email;
• company name;
• other information specified in the message.

The legal basis for processing these personal data is the exercise of your lawful rights and interests.

Personal data is processed until the inquiry is resolved.

After this period, the user’s personal data is destroyed by deleting it from information systems using built-in tools.

Candidate selection for vacant positions
If you want to join our team, you may contact us via the communication channels listed on the website. For this purpose, we will need to process the following information about you:
• full name;
• date of birth;
• citizenship;
• city of residence;
• contact phone numbers;
• email address;
• education information;
• work experience;
• professional skills;
• information contained in your resume and cover letter.

The personal data processed for this purpose are not special categories or biometric data according to Articles 10–11 of Federal Law 152-FZ and are processed by automated and non-automated methods.

The legal basis for processing these personal data is Consent to the processing of personal data in accordance with paragraph 1, part 1, article 6 of Federal Law 152-FZ.

Personal data obtained for this purpose are processed for up to 3 months from the date of the employment decision or refusal. We may continue processing personal data beyond this period only if there are grounds provided by part 1 of article 6 of Federal Law 152-FZ.

After this period, the user’s personal data is destroyed by deleting it from information systems using built-in tools, and from paper media, if any, by burning or shredding.

Personal data processing in the VKontakte social network group
Publication of personal data
To increase awareness of our company’s activities, we publish personal data of partners and clients, including:
• full name;
• job title;
• workplace information;
• photo.

The personal data processed for this purpose are not special categories or biometric data according to Articles 10–11 of Federal Law 152-FZ and are processed by automated and non-automated methods.

The legal basis for processing these personal data is Consent for processing personal data permitted by the data subject for dissemination.

Published data is processed until the page containing the data is deleted.

User personal data is destroyed by deleting it from information systems using built-in tools.

Processing of Personal Data on the website https://ru.hrsacademy.com
Registration on the website
For registration on the website we may obtain access to the following personal data from you:
• last name, first name;
• email;
• city;
• country;
• company;
• department;
• login;
• password.

The personal data processed within this purpose do not belong to special categories or biometric data according to Articles 10–11 of Federal Law 152-FZ and are processed by automated and non-automated methods.

The legal basis for processing this personal data is Consent to the processing of personal data.

Personal data is processed until the user deletes their account.

After the specified processing period, the User’s personal data is destroyed by deleting it from information systems using the built-in tools of the information system.

Processing inquiries received via communication channels specified on the website
If you have questions about the products offered or about our company’s activities, you can contact us through the contacts highlighted on the website.

Within this purpose we may obtain access to the following personal data from you:
• last name, first name, patronymic;
• email;
• other data specified in the message.

The personal data processed within this purpose do not belong to special categories or biometric data according to Articles 10–11 of Federal Law 152-FZ and are processed by automated and non-automated methods.

The legal basis for processing this personal data is the exercise of your lawful rights and interests.

Personal data is processed until the inquiry is completed.

After the specified processing period, the User’s personal data is destroyed by deleting it from information systems using the built-in tools of the information system.

Sending informational and advertising newsletters
If you want to stay informed about our special offers, you can subscribe to our newsletter. Within this purpose we may obtain access to the following personal data from you:
• last name, first name;
• email.

The personal data processed within this purpose do not belong to special categories or biometric data according to Articles 10–11 of Federal Law 152-FZ and are processed by automated methods.

The legal basis for processing this personal data is Consent to the processing of personal data in accordance with paragraph 1, part 1, article 6 of Federal Law 152-FZ, provided by you during registration on the website.

The data processed by us within the sending of newsletters is processed until the marketing campaign ends or consent is withdrawn (whichever occurs first), and destroyed within 30 days according to parts 4-5 of article 21 of Federal Law 152-FZ.

After the specified processing period, the User’s personal data is destroyed by deleting it from information systems using the built-in tools of the information system.

Website visit analytics
What are cookies? Cookies are small files, usually consisting of letters and numbers, downloaded to your device when you visit certain websites. Cookies allow websites to recognize your device.
We want you to be comfortable using all the functions of our sites, so for its correct operation we process cookies: they allow recognizing you when you visit our sites or use our services, remember your preferences, and provide you with a personalized experience.

Cookies are categorized as:
• Necessary cookies, which help make the website usable by enabling basic functions such as page navigation and access to secure areas of the website. The website cannot function properly without these cookies;
• Statistical cookies, which help website owners understand how visitors interact with websites by collecting and reporting information anonymously;
• Marketing cookies, which are used to track visitors across websites. They are intended to display ads that are relevant and attractive to an individual user and thus more valuable to website owners and third-party advertisers.

All three types of cookies are used on our websites.
You can refuse cookie processing via the corresponding settings in your browser.

When you use our services, the following information about you becomes available to us: device technical specifications; IP address; information about the browser and language used; date and time of access to the site; addresses of requested pages.

These technologies are used to track your behavior on the site and collect statistical information about our client base as a whole to improve the services we provide.
Like most other organizational information resources, our web servers and security systems store some temporary technical data in their log files.

Our websites use cookies and retargeting pixels of analytics services. Cookies of such third-party services are used by us for statistical, analytical, and marketing purposes. For more information about which services we use, see the section “Third-Party Transfers.”

Personal data collected by web analytics services is processed after prior notification of users via an informational message placed in the footer of the website’s main page.

The personal data processed within this purpose do not belong to special categories or biometric data according to Articles 10–11 of Federal Law 152-FZ and are processed by automated methods.

Cookies collected on our site:
Strictly necessary, i.e., those without which our site will not function correctly:

Operational cookies provide us with information about which pages are popular, monitor incoming traffic, and provide aggregated anonymous analytical data:

Targeted cookies: these cookies record the pages you visited and links you clicked during your visit to our site, and are used to connect with social networks or to show ads tailored to your interests:

Our site uses functional cookies to remember the information you selected about language, country, or other search engine settings and provide personalized or enhanced features you chose:

Data transfer to third parties
For the purpose of providing services and improving their quality, we transfer information about you to the following third parties:

Collection of Personal Data from Minors
Our website is not intended for the processing of personal data from minors. If you have reason to believe that a child has provided us with their personal data, please notify us by emailing info@hrs.ru.

Information about the conditions of processing and the presence of prohibitions and conditions on the processing of personal data by an unlimited number of persons, permitted by the data subject for distribution
Regarding personal data published on the Operator’s website, the following rules and restrictions apply:

transfer of personal data to an unlimited number of persons is not prohibited;

processing of personal data by an unlimited number of persons is not prohibited;

personal data received by the Operator may be transmitted using information and telecommunication networks.

Data Security
The personal data we collect and store is considered confidential information. It is protected against loss, alteration, or unauthorized access in accordance with the legislation of the Russian Federation on personal data. To this end, we apply technical means and organizational measures. We continuously improve our data protection systems.

Policy Changes
We reserve the right to make changes to our Policy at any time. We ask you to regularly review all updates to our Policy. We will send notifications about Policy changes if such changes are significant and accessible by the means available to us.