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1.1. This Personal Data Processing Policy (hereinafter referred to as the “Policy”) shall apply to all information that HIVE MIND ARTIFICIAL INTELLIGENCE Limited Liability Company (Hive Mind AI, LLC) (hereinafter referred to as the “Operator”) may obtain about the User during the use of website https://hivemindai.ru/, its facilities or domains and subdomains (hereinafter referred to as the “Operator’s Website”) as well as services rendered by the Operator. In this Policy, the “User” shall be understood as an individual who has access to the Operator’s Website.
1.2. This Policy shall disclose the basic principles and rules observed by the Operator in the processing of personal data, including defining the purposes, legal grounds, terms and conditions, methods and procedure of processing of personal data by the Operator, establish the Operator’s obligations on non-disclosure and protection of confidentiality of personal data that the User provides when transferring his/her personal data to the Operator on the Operator’s Website to receive services and use the facilities of the Operator’s Website.
1.3. The fact that the User uses the Operator’s Website shall mean that the User agrees with this Policy and the terms and conditions of processing of the User’s personal data.
In the event of disagreement with the terms and conditions of this Policy, the User shall stop using the Operator’s Website.
1.4. This Policy applies only to the Operator’s Website. The Operator shall not control and not be responsible for third party websites to which the User can go via links available on the Operator’s Website.
The Operator’s Website contains information about the Operator, Operator’s objectives and tasks, history, projects, services, products, activities of the Operator.
You can get from the Website information on how to obtain the Operator’s service.
The Operator’s Website contains forms to be filled in which the User fills in of his/her own free will. In this event, the Operator shall process only the data provided by the User and only for the purposes for which they have been provided.
2.1. The personal data of the User may be used by the Operator for the following purposes:
2.1.1. Carrying out activities of the Operator;
2.1.2. Informing the User about the services, products and activities of the Operator by sending e-mails, messages in messengers;
2.1.3. Providing the personal data subject with access to the personalised resources of the Operator’s Website and its facilities;
2.1.4. Providing feedback for the personal data subject, including calls, notifications, enquiries related to the use of the Website, handling enquiries and requests from the personal data subject;
2.1.5. Arranging and providing the service purchased from the Operator;
2.1.6. Ensuring the performance and security of the Website;
2.1.7. The anonymised data of the Users collected by means of Internet statistics services shall serve to collect information about actions of the User on the Website, improve the quality of the Website and its content;
2.1.8. Providing the User, with his/her consent, with newsletters and other information on behalf of the Operator and/or on behalf of the Operator’s partners.
2.1.9. Sending advertising information with the User’s consent.
2.1.10. Conclusion and fulfilment of contracts, offers and refunds.
2.1.11. Keeping books and records;
2.1.12. Implementation of civil relations;
2.1.13. For other purposes only with the User’s consent.
3.1. The Operator shall carry out activities in the field of the personal data processing on the basis of and in accordance with the requirements of the current legislation of the Russian Federation and other legal instruments, including, but not limited to:
3.2. The legal grounds for processing of personal data shall be a set of legal instruments in implementation of which and in accordance with which the Operator processes personal data, including:
3.3. The Operator shall process the User’s personal data only if they are provided and/or sent by the User himself /herself via special forms located on the Operator’s Website.
3.4. The Operator shall process anonymised data about the User if this is allowed in the User’s browser settings (cookie saving and use of JavaScript technology is enabled).
4.1. The content and scope of personal data of the categories of personal data subjects processed by the Operator shall be determined in accordance with the purposes of the personal data processing. The Operator shall not process personal data that are redundant with respect to the purposes of processing specified in this Policy or incompatible with such purposes.
4.2. The personal data means any data that can directly or indirectly identify the User, such as name, e-mail address, telephone number, IP address of the User. In accordance with the consent given by the User, the Operator may collect the following personal data of the User:
4.2.1. Reliable, accurate, up-to-date and complete registration data, including the User’s name, surname, position, company, e-mail of the User, User’s telephone number when the User transmits his/her data via a special form on the Operator’s Website.
4.2.2. To make purchase orders for the Operator’s services, products or other Operator’s facilities placed on the Operator’s Website, the User shall be required to provide his/her name, surname, position, company, contact information, e-mail address, telephone number. The scope of personal data to be collected shall depend on the request and/or the specific facility.
4.3. The list of personal data processed by the Operator and third parties engaged by it:
4.3.1. For the purpose of conclusion, fulfilment, amendment and termination of the contract to which the Operator is a party:
4.3.1.1. Category of the personal data subject: counterparty (individual); customer (individual).
4.3.1.2. List of personal data: full name; passport details or details of any other identity document; contact telephone number; e-mail address; bank details; date and place of birth; registration address; TIN.
4.3.1.3. Terms of processing: during the validity period of the contract and for 5 years after the expiry of the contract or until the activities of the Operator have been terminated.
4.3.1.4. Type of the personal data processing: mixed.
4.3.1.5. Grounds for the personal data processing: fulfilment of the contract to which the data subject is a party/beneficiary / conclusion, at the data subject’s initiative, of a contract under which the data subject will be a beneficiary (subparagraph 5 of paragraph 1 of Article 6 of the Law).
4.3.2. To provide an opportunity to receive services from the Operator:
4.3.2.1. Category of the personal data subject: customer (individual).
4.3.2.2. List of personal data: full name; e-mail address; contact telephone number; IP address; cookies data (necessary); information on visiting the Website provided by the statistical services.
4.3.2.3. Terms of processing: during the validity period of the contract and for 5 years after the expiry of the contract; or until the activities of the Operator have been terminated; or until the consent to the processing of personal data has been withdrawn.
4.3.2.4. Type of the personal data processing: mixed.
4.3.2.5. Grounds for the personal data processing: fulfilment of the contract to which the data subject is a party/beneficiary / conclusion, at the data subject’s initiative, of a contract under which the data subject will be a beneficiary (subparagraph 5 of paragraph 1 of Article 6 of the Law).
4.3.3. For purposes of technical support and consultations:
4.3.3.1. Category of the personal data subject: customer (individual).
4.3.3.2. List of personal data: full name; contact telephone number; e-mail address; IP address.
4.3.3.3. Terms of processing: during the validity period of the contract.
4.3.3.4. Type of the personal data processing: automated.
4.3.3.5. Grounds for the personal data processing: fulfilment of the contract to which the data subject is a party/beneficiary / conclusion, at the data subject’s initiative, of a contract under which the data subject will be a beneficiary (subparagraph 5 of paragraph 1 of Article 6 of the Law).
4.3.4. To fulfil the duties imposed on the Operator in connection with the need to carry out checks of counterparties:
4.3.4.1. Category of the personal data subject: counterparty (individual).
4.3.4.2. List of personal data: full name; passport details or details of any other identity document; contact telephone number; e-mail address; bank details.
4.3.4.3. Terms of processing: until activities of the Operator have been terminated.
4.3.4.4. Type of the personal data processing: automated.
4.3.4.5. Grounds for the personal data processing: fulfilment of functions, powers and duties assigned to the Operator by the Law (subparagraph 2 of paragraph 1 of Article 6 of the Law); legitimate interest of the Operator (subparagraph 7 of paragraph 1 of Article 6 of the Law).
4.3.5. To analyse the user experience in order to improve the product offered:
4.3.5.1. Category of the personal data subject: customer (individual), user of websites as well as domains and subdomains.
4.3.5.2. List of personal data: information on visiting the Website provided by the statistics services; browser information; access time; previous page address; IP address; cookie data.
4.3.5.3. Terms of processing: 14, 24 months (depending on the type of analytics).
4.3.5.4. Type of the personal data processing: automated.
4.3.5.5. Grounds for the personal data processing: legitimate interest of the Operator (subparagraph 7 of paragraph 1 of Article 6 of the Law); data subject’s consent to the processing of personal data (subparagraph 1 of paragraph 1 of Article 6 of the Law); processing for statistical and other research purposes (subparagraph 9 of paragraph 1 of Article 6 of the Law).
4.3.6. To send newsletters and advertising mailings:
4.3.6.1. Category of the personal data subject: counterparty/customer (individual), user of websites as well as domains and subdomains.
4.3.6.2. List of personal data: information on visiting the Website, domains and subdomains; IP address; cookie data; full name; telephone number; e-mail address.
4.3.6.3. Terms of processing: until withdrawal of consent to data processing.
4.3.6.4. Type of the personal data processing: automated.
4.3.6.5. Grounds for the personal data processing: data subject’s consent to the processing of personal data (subparagraph 1 of paragraph 1 of Article 6 of the Law).
4.3.7. To place information about persons engaged in fulfilling contracts and rendering services on the Website, domains and subdomains, channels in Telegram and other messengers of the Operator, printed handouts, increase customer loyalty and form a positive attitude of users to the products:
4.3.7.1. Category of the personal data subject: counterparty (individual), customer (individual).
4.3.7.2. List of personal data: full name; photo and video image; work experience; place of work; education; qualifications; achievements; feedback on services rendered, social media account.
4.3.7.3. Terms of processing: until withdrawal of consent to data processing.
4.3.7.4. Type of the personal data processing: automated.
4.3.7.5. Grounds for the personal data processing: consent of the personal data subject to processing of personal data authorised by the personal data subject for dissemination (Article 10.1 of the Law).
4.3.8. To place feedback from the customers of the Operator on the Operator’s Website, in the Telegram channel in order to increase customer loyalty and form a positive attitude of users to the products:
4.3.8.1. Category of the personal data subject: counterparties/customers (individuals).
4.3.8.2. List of personal data: full name; photo and video image; work experience; achievements, social media account.
4.3.8.3. Terms of processing: until withdrawal of consent to data processing.
4.3.8.4. Type of the personal data processing: automated.
4.3.8.5. Grounds for the personal data processing: consent of the personal data subject to processing of personal data authorised by the personal data subject for dissemination (Article 10.1 of the Law).
4.4. The sources of obtaining personal data processed by the Operator shall be:
4.4.1. Personal data subjects themselves (visitors, counterparties, individuals who have provided information to the Operator on the basis of personal data legislation as well as Users of the Operator’s Website);
4.5. Processing of personal data using cookies:
4.5.1. Cookies sent by the User’s/Operator’s equipment and to the User’s/Operator’s equipment may be used by the Operator to provide personalised information to the User, target the advertisements shown to the User, for statistical and research purposes as well as to improve the operation of the Operator’s Website.
4.5.2. The User shall acknowledge that the equipment and software used by the User may have the function of prohibiting operations with cookies and deleting cookies received previously. Information on how to disable and delete cookies can be found in the help sections of the Internet browser used by the User.
4.5.3. The Operator shall have the right to establish that the provision of a certain service is only possible if the acceptance and receipt of cookies is authorised by the User.
4.6. The consent to the processing of personal data may be signed by the User by means of an electronic signature in accordance with the provisions of Federal Law No. 63-FZ dated 06/04/2011 On Electronic Signature.
4.8. In the absence of the need to obtain the User’s consent in writing as established by the Federal Law On Personal Data, the User’s consent may be given by the User in any form allowing to confirm the fact of obtaining consent, including an electronic form (by ticking the appropriate checkbox).
5.1. The Operator shall ensure in its activities compliance with the principles of the personal data processing specified in Article 5 of Federal Law of the Russian Federation No. 152-FZ dated 27/07/2006 On Personal Data, including:
5.2. The Operator shall ensure in its activities compliance with the principles of the personal data processing established in Article 5 of Regulation (EU) 2016/679 of the European Parliament and of the Council dated April 27, 2016, On the Protection of Natural Persons with regard to the Processing of Personal Data and on the Free Movement of Such Data, and Repealing Directive 95/46/EC (General Data Protection Regulation), including:
5.2.1. The User shall have the right to request from the Operator to delete without undue delay the personal data relating to the personal data subject by referring to the provisions of Article 17. Right to Erasure (Right to be Forgotten) of the EU General Data Protection Regulation 2016/679 of April 27, 2016.
5.3. Processing of the User’s personal data shall be carried out in any lawful manner, including in personal data information systems with or without the use of means of automation with the transmission of information via Internet information and telecommunication network.
5.4. Processing of personal data shall be carried out subject to the User’s consent.
5.5. The User shall agree that the Operator has the right to transfer personal data to third parties involved in processing of personal data solely for the purpose of processing of the User’s personal data transferred to the Operator’s Website. The Operator shall ensure that the above-mentioned third parties observe confidentiality of the User’s personal data, and that they take necessary organisational, legal and technical protection measures.
The Website shall use Yandex Metrika web analytics service provided by YANDEX LLC (16 L. Tolstoy Street, Moscow, 119021) through which anonymised visitor data (including cookies) are collected and processed. Information collected through the cookie service cannot identify the data subject, but may help to improve the performance of the Operator’s Website. Information about the use of this Website by the data subject collected using cookies shall be transmitted to Yandex and stored on Yandex’s server in the Russian Federation.
5.6. The Operator shall provide recording, systematisation, accumulation, storage, clarification (update, change), extraction of personal data of the citizens of the Russian Federation using databases located on the territory of the Russian Federation.
5.7. Personal data of the User may be transferred to the inquiry and investigation bodies, authorised state authorities on the grounds and in accordance with the procedure established by the current legislation.
5.8. In the event of loss or disclosure of personal data, the Operator shall inform the User about the loss or disclosure of personal data.
5.9. The Operator shall take necessary organisational and technical measures to protect the User’s personal data from unlawful or accidental access, destruction, modification, blocking, copying, distribution as well as from other unlawful actions of third parties.
5.10. The Operator shall take all necessary measures to prevent losses or other negative consequences caused by the loss or disclosure of the User’s personal data.
5.11. The terms of the personal data processing shall be determined in accordance with the terms specified in the consent of the personal data subject.
6.1. If it is confirmed that the personal data are inaccurate or unlawful, the personal data shall be updated by the Operator and their processing shall be terminated accordingly.
6.2. The Operator shall not verify the existence of a special regime for processing of personal data of the personal data subject. If the personal data subject is a citizen of the European Union or a citizen of other states, temporarily or permanently residing in the territory of the EU countries and accesses the Website from the European countries, the Operator shall take all reasonable measures to ensure compliance with such requirements of the legislation on personal data protection. For this purpose, the personal data subject shall notify the Operator about the existence of a special protection regime for his/her personal data by e-mail to the Operator’s e-mail address info@hivemindai.ru.
6.3. The Operator shall not intentionally process personal data of minors. The Contractor shall recommend the use of the Website to persons who are 18 years of age or older. Responsibility for the actions of minors, including their purchase of services on the Website, shall lie with the legal representatives of minors. All visitors under the age of 18 shall obtain the permission of their legal representatives before providing any personal information about themselves. If the Operator becomes aware that it has received personal information about a minor without the consent of the legal representatives, such information shall be deleted as soon as possible.
6.4. When the purposes of the personal data processing have been achieved as well as in the event that the User withdraws his/her consent to their processing, the personal data shall be destroyed.
6.5. The Operator shall be obliged to inform the User or his/her representative about processing of personal data of such User at the latter’s request.
6.6. Requests/appeals from the User and his/her representative, authorised bodies regarding inaccuracy of personal data, unlawfulness of their processing, withdrawal of consent and access of the User to his/her data shall be processed by the Operator within 10 (Ten) business days, unless a shorter period is established by the legislation of the Russian Federation.
6.7. The Operator shall have the right to make changes to this Policy without the User’s consent.
6.8. When changes are made to the current edition, the date of the last update shall be indicated. The new edition of the Policy shall come into force from the moment it is placed on the Organiser’s Website, unless otherwise provided for by the new edition of the Policy.
6.9. The current Policy is available online at: https://hivemindai.ru/.
7.1. All suggestions, questions, enquiries or appeals in regard to this Policy may be sent by the User to the Operator at the e-mail address: info@hivemindai.ru.
7.2. The form of the request/appeal shall be arbitrary. The request should allow identifying the person making the request and may also contain contact details for sending a response.
7.3. Withdrawal of consent to the processing of personal data by the User shall be sent to the address specified in clause 8 of this Policy in the form set out in clause 7.2 hereof and shall be considered within the term specified in clause 6.6 hereof.
Hive Mind AI, LLC
Place of location: 41 Dubininskaya Street, building 1, room 12/1, Zamoskvorechye municipality intracity territory of the federal city, Moscow, 115054, Russian Federation
OGRN 1257700084696
INN 9705239073
