Privacy
policy
1. Key Terms and Definitions
For the purposes of this Personal Data Processing Policy (hereinafter referred to as the "Policy"), the following terms, definitions, and abbreviations shall be used:
Automated processing of personal data – processing of personal data using computing technology.
Biometric personal data – information that describes an individual’s physiological and biological characteristics enabling their identification and used for verifying the identity of the personal data subject.
Blocking of personal data – temporary suspension of the processing of personal data (except in cases where processing is necessary to clarify personal data).
Personal data legislation – Federal Law No. 152-FZ dated July 27, 2006, “On Personal Data,” and other regulatory acts of the Russian Federation governing the conditions, procedures, and security measures for processing and ensuring the confidentiality of personal data.
Confidentiality of personal data – the obligation of the Company (its employees) and other persons with access to personal data to refrain from disclosing or disseminating personal data to third parties without the consent of the data subject, unless otherwise required by Russian law.
Tangible medium for personal data – any physical object used for storing or recording personal data in electronic or written form (including paper carriers and machine-readable media).
Non-automated processing of personal data – personal data processing performed without the use of automation tools (manual processing), provided such actions (e.g., use, updating, distribution, deletion) are performed manually for each subject.
Anonymization of personal data – actions that render it impossible to determine the identity of a data subject without the use of additional information.
Processing of personal data – any operation or set of operations performed on personal data, with or without the use of automated tools, including collection, recording, systematization, accumulation, storage, updating (modification), retrieval, use, transfer (dissemination, provision, access), anonymization, blocking, deletion, and destruction.
Company – Limited Liability Company “Specialized Developer ‘Springs’,” located at: 87 Vernadskogo Ave., Bldg. 2, Moscow, 119415, Russian Federation — the legal entity that independently or jointly with others organizes and (or) performs personal data processing, defines processing purposes, the scope of personal data to be processed, and the actions (operations) performed.
Personal data – any information processed by the Company, including any information submitted via the official Company website at https://springs.house and (or) collected through the use of the website, relating directly or indirectly to a specific or identifiable natural person (data subject).
The Company processes the following categories of personal data:
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data voluntarily submitted by the data subject via input forms on the website (e.g., full name, email address, phone number);
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data included in messages sent by the data subject to the Company;
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data necessary for the conclusion and performance of contracts with the Company’s counterparties, to fulfill the Company’s legal obligations, or to protect the Company’s lawful interests;
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statistical data (e.g., user settings and identifiers, cookies), including third-party tracking tools; the Company does not combine personally identifiable information with passively collected data.
Policy – this Personal Data Processing Policy of LLC “Specialized Developer ‘Springs’”.
Disclosure of personal data – intentional or accidental violation of confidentiality requirements by the Company’s employees or third parties with unauthorized access to data.
Dissemination of personal data – actions aimed at disclosing personal data to an indefinite number of persons.
Website – the official Company website at https://springs.house.
Data subject – a natural person whose personal data is processed by the Company, including:
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Company employees (current or prospective under contract),
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Clients or counterparties (under service agreements),
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Other individuals, including:
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legal representatives of physical or legal entities,
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beneficiaries of Company contracts,
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directors, shareholders, and representatives of counterparties,
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persons subject to statutory disclosure obligations,
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users accessing the website or requesting services from the Company.
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Cross-border transfer of personal data – transmission of data to foreign states or foreign individuals/legal entities.
Destruction of personal data – actions making it impossible to restore personal data content in the information system and (or) resulting in the destruction of physical carriers.
Cookies – a set of depersonalized data stored in a user's web browser and processed by the Company’s web resource during website usage.
Federal Law No. 152-FZ – Federal Law “On Personal Data” dated July 27, 2006.
2. General Provisions
This Policy sets forth the basic principles, objectives, conditions, and methods of personal data processing conducted by the Company.
The Policy is developed in accordance with applicable data protection legislation and internal Company regulations on information security and data protection.
The Policy applies to all personal data processed by the Company, regardless of the format or method of transmission, receipt, or storage. In resolving personal data processing matters, the Company prioritizes compliance with applicable laws over internal policies. In the event of any conflict between this Policy and applicable data protection laws, the Company adheres strictly to the requirements of the law until such internal documents are brought into compliance.
For all matters not explicitly covered by this Policy or internal Company acts, the Company refers to applicable Russian data protection laws, guidance issued by competent authorities, and international best practices.
This Policy is a publicly available internal regulation of the Company and is published online at https://springs.house.
The Company may update this Policy periodically. The new version becomes effective upon publication on the website unless stated otherwise. By continuing to use the website or interact with the Company, users confirm their acceptance of the revised Policy.
