Privacy Policy Regarding the Processing of Personal Data

1. General Provisions
This Personal Data Processing Policy has been prepared in accordance with the requirements of Federal Law No. 152-FZ dated July 27, 2006, "On Personal Data" (hereinafter referred to as the Personal Data Law) and defines the procedure for processing personal data and the measures taken by NOOR LLC (hereinafter referred to as the Operator) to ensure the security of personal data.
1.1. The Operator considers the observance of human and civil rights and freedoms in the processing of personal data, including the protection of the rights to privacy, personal, and family confidentiality, to be its most important goal and a prerequisite for carrying out its activities.
1.2. This Operator’s Personal Data Processing Policy (hereinafter referred to as the Policy) applies to all information that the Operator may obtain about visitors to the website: https://hp-wild.ru.

2. Key Terms Used in the Policy
2.1. Automated processing of personal data — processing of personal data using computer technology.
2.2. Blocking of personal data — temporary suspension of the processing of personal data, except where processing is required for the clarification of personal data.
2.3. Website — a collection of graphic and informational materials, as well as computer programs and databases, ensuring their availability on the Internet at the following address: https://hp-wild.ru.
2.4. Personal Data Information System — a set of personal data contained in databases, along with information technologies and technical means that ensure their processing.
2.5. Anonymization of personal data — actions resulting in the impossibility of determining, without the use of additional information, whether personal data belongs to a specific User or another personal data subject.
2.6. Processing of personal data — any action (operation) or set of actions (operations) performed with personal data, whether using automation tools or without such tools, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
2.7. Operator — a state authority, municipal authority, legal entity, or individual who independently or jointly with others organizes and/or carries out the processing of personal data, and 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 an identified or identifiable User of the website https://hp-wild.ru.
2.9. Personal data permitted by the personal data subject for dissemination — personal data to which an unlimited number of persons have been granted access by the personal data subject through consent to the processing of personal data permitted for dissemination in accordance with the Personal Data Law (hereinafter referred to as personal data permitted for dissemination).
2.10. User — any visitor to the website https://hp-wild.ru.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Dissemination of personal data — any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or making personal data available to an unlimited number of persons, including publication in mass media, placement in information and telecommunication networks, or providing access to personal data by any other means.
2.13. Cross-border transfer of personal data — transfer of personal data to the territory of a foreign state, to a foreign government authority, foreign individual, or foreign legal entity.
2.14. Destruction of personal data — any actions resulting in the irreversible destruction of personal data, making it impossible to restore the content of personal data in a personal data information system and/or resulting in the destruction of physical media containing personal data.

3. Main Rights and Responsibilities of the Operator
3.1. The Operator has the right to:

• Receive accurate information and/or documents containing personal data from the personal data subject.
• In the event that the personal data subject withdraws consent to the processing of personal data or submits a request to cease processing, continue processing personal data without the subject’s consent where grounds specified by the Personal Data Law exist.
• Independently determine the composition and list of measures necessary and sufficient to ensure compliance with the obligations established by the Personal Data Law and the regulations adopted pursuant thereto, unless otherwise provided by the Personal Data Law or other federal laws.

3.2. The Operator is obliged to:

• Provide the personal data subject, upon request, with information regarding the processing of their personal data.
• Organize the processing of personal data in accordance with the procedure established by the current legislation of the Russian Federation.
• Respond to appeals and requests from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law.
• Provide the authorized body for the protection of the rights of personal data subjects, upon its request, with the necessary information within 10 days from the date of receipt of such request.
• Publish or otherwise ensure unrestricted access to this Personal Data Processing Policy.
• Take legal, organizational, and technical measures to protect personal data against unauthorized or accidental access, destruction, modification, blocking, copying, provision, dissemination, and other unlawful actions involving personal data.
• Cease the transfer (dissemination, provision, access) of personal data, stop processing, and destroy personal data in the manner and cases prescribed by the Personal Data Law.
• Fulfill other obligations provided for by the Personal Data Law.

4. Main Rights and Responsibilities of Personal Data Subjects
4.1. Personal Data Subjects Have the Right To:

• Obtain information regarding the processing of their personal data, except in cases provided for by federal laws. Such information shall be provided by the Operator in an accessible form and must not contain personal data relating to other personal data subjects, except 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.
• Require the Operator to clarify, block, or destroy their personal data if the personal data is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, and to take measures provided by law to protect their rights.
• Require prior consent for the processing of personal data for the purpose of promoting goods, works, and services on the market.
• Withdraw consent to the processing of personal data and submit a request to cease the processing of personal data.
• Appeal unlawful actions or omissions of the Operator in the processing of their personal data to the authorized personal data protection authority or in court.
• Exercise other rights provided for by the legislation of the Russian Federation.

4.2. Personal Data Subjects Are Obliged To:

• Provide the Operator with accurate information about themselves.
• Notify the Operator of any clarification, update, or modification of their personal data.

4.3. Persons who provide the Operator with inaccurate information about themselves, or information about another personal data subject without that person's consent, shall bear liability in accordance with the legislation of the Russian Federation.

5. Principles of Personal Data Processing
5.1. Personal data shall be processed on a lawful and fair basis.
5.2. The processing of personal data shall be limited to the achievement of specific, predetermined, and lawful purposes. Processing of personal data that is incompatible with the purposes for which the personal data was collected shall not be permitted.
5.3. The consolidation of databases containing personal data, where such data is processed for purposes incompatible with one another, shall not be permitted.
5.4. Only personal data that is relevant to the purposes of its processing shall be subject to processing.
5.5. The content and scope of the personal data being processed shall correspond to the stated purposes of processing. Excessive processing of personal data in relation to the stated purposes shall not be permitted.
5.6. When processing personal data, the accuracy, sufficiency, and, where necessary, relevance of personal data in relation to the purposes of processing shall be ensured. The Operator shall take the necessary measures and/or ensure the implementation of such measures to delete or rectify incomplete or inaccurate data.
5.7. Personal data shall be stored in a form that permits identification of the personal data subject for no longer than is necessary for the purposes of processing, unless a longer retention period is established by federal law or by a contract to which the personal data subject is a party, beneficiary, or guarantor. Processed personal data shall be destroyed or anonymized upon achievement of the purposes of processing or when the need to achieve those purposes no longer exists, unless otherwise provided by federal law.

6. Purposes of Personal Data Processing

7. Conditions for Processing Personal Data
7.1. Personal data shall be processed with the consent of the personal data subject.
7.2. Processing of personal data is necessary to achieve the purposes established by an international treaty of the Russian Federation or by law, and to perform the functions, powers, and obligations assigned to the Operator by the legislation of the Russian Federation.
7.3. Processing of personal data is necessary for the administration of justice, the execution of a court judgment, or an act of another authority or official that is subject to enforcement 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 personal data subject is a party, beneficiary, or guarantor, as well as for entering into a contract at the initiative of the personal data subject or a contract under which the personal data subject 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 objectives, provided that such processing does not violate the rights and freedoms of the personal data subject.
7.6. Personal data that has been made available to an unlimited number of persons by the personal data subject or at their request (hereinafter referred to as publicly available personal data) may be processed.
7.7. Personal data subject to publication or mandatory disclosure in accordance with federal law may be processed.

8. Procedure for the Collection, Storage, Transfer, and Other Types of Personal Data Processing
The security of personal data processed by the Operator is ensured through the implementation of legal, organizational, and technical measures necessary to fully comply with the applicable legislation on personal data protection.
8.1. The Operator ensures the security of personal data and takes all possible measures to prevent unauthorized persons from accessing personal data.
8.2. The User’s personal data shall never, under any circumstances, be transferred to third parties, except in cases required by applicable law or where the personal data subject has given consent to the Operator to transfer such data to a third party for the performance of obligations under a civil law contract.
8.3. In the event of inaccuracies in personal data, the User may update such data independently by sending a notification to the Operator’s email address hookahplace.wild@gmail.com with the subject line “Personal Data Update.”
8.4. The period of personal data processing is determined by the achievement of the purposes for which the personal data was collected, unless another period is established by a contract or applicable law.
The User may withdraw consent to the processing of personal data at any time by sending a notification to the Operator via email to hookahplace.wild@gmail.com with the subject line “Withdrawal of Consent to Personal Data Processing.”
8.5. All information collected by third-party services, including payment systems, communication services, and other service providers, is stored and processed by such entities (Operators) in accordance with their respective User Agreements and Privacy Policies. The personal data subject is responsible for reviewing such documents. The Operator shall not be liable for the actions of third parties, including the service providers referred to in this clause.
8.6. Restrictions established by the personal data subject regarding the transfer (except for granting access), processing, or conditions of processing (except for obtaining access) of personal data permitted for dissemination shall not apply where personal data is processed in state, public, or other public interests as defined by the legislation of the Russian Federation.
8.7. The Operator shall ensure the confidentiality of personal data during its processing.
8.8. The Operator shall store personal data in a form that allows identification of the personal data subject for no longer than is necessary to achieve the purposes of processing, unless a longer retention period is required by federal law or by a contract to which the personal data subject is a party, beneficiary, or guarantor.
8.9. Grounds for termination of personal data processing may include the achievement of the processing purposes, expiration of the consent period, withdrawal of consent by the personal data subject, a request to cease processing, or the identification of unlawful processing of personal data.

9. List of Actions Performed by the Operator with Received Personal Data
9.1. The Operator carries out the collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (dissemination, provision, access), anonymization, blocking, deletion, and destruction of personal data.
9.2. The Operator performs automated processing of personal data with the receipt and/or transmission of information through information and telecommunication networks, as well as without such transmission.

10. Cross-Border Transfer of Personal Data
10.1. Prior to commencing activities involving the cross-border transfer of personal data, the Operator shall notify the authorized authority responsible for protecting the rights of personal data subjects of its intention to carry out such cross-border transfer of personal data (such notification shall be submitted separately from the notification of intent to process personal data).
10.2. Before submitting the above-mentioned notification, the Operator shall obtain the necessary information from the authorities of the foreign state, foreign individuals, or foreign legal entities to whom the cross-border transfer of personal data is planned.

11. Confidentiality of Personal Data
The Operator and any other persons who have gained access to personal data shall be obligated not to disclose or distribute personal data to third parties without the consent of the personal data subject, unless otherwise provided by federal law.

12. Final Provisions
12.1. The User may obtain clarification regarding any matters related to the processing of their personal data by contacting the Operator via email at hookahplace.wild@gmail.com.
12.2. Any changes to the Operator’s Personal Data Processing Policy shall be reflected in this document. This Policy shall remain in effect indefinitely until replaced by a new version.
12.3. The current version of the Policy is publicly available on the Internet at: https://hp-wild.ru/privacy.