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Personal Data Processing Policy

This Personal Data Processing Policy sets out how the personal data of users of / is processed and protected. The Policy has been drawn up in accordance with Federal Law No. 152-FZ of 27 July 2006 “On Personal Data” and applies to all personal data the Operator receives from the User through the Site.

1. Data operator

The personal data operator is:

Whitewill Limited Liability Company (OOO “VAYTVILL”)
TIN: 5032309922
PSRN: 1195081051846
Address: bldg. 100, unit 13, Usovo, Odintsovo, Moscow Region, 143084, Russia
E-mail: info@whitewill.ru
E-mail for personal data enquiries: privacy@whitewill.ru

2. Data processed

The Operator may process the following categories of personal data:

  • name;
  • phone number;
  • e-mail address, where provided by the User;
  • messenger account details, where the User opens WhatsApp, Telegram or another messenger;
  • details the User provides in a quiz, request form or message, including the type of property of interest, budget, area, purpose of purchase, preferences and any other information supplied voluntarily;
  • technical data: IP address, device type, browser, operating system, language settings, date and time of the visit, referral source, records of interaction with the Site, cookies and similar identifiers.

The Operator does not request special categories of personal data, including data on health, political views, religious beliefs, intimate life or biometric data. The User must not enter such information in forms or messages.

3. Purposes of processing

Personal data is processed for the following purposes:

  • handling the User’s request;
  • contacting the User by phone, e-mail or messenger;
  • selecting properties matching the criteria specified by the User;
  • advising on properties, purchase terms, investment opportunities and related services;
  • sending information about the Company’s offers, projects and services, where the User has given the relevant consent;
  • improving the Site and analysing traffic and user behaviour;
  • keeping the Site secure and preventing abuse;
  • complying with the requirements of the legislation of the Russian Federation.

4. Legal grounds for processing

The Operator processes personal data on the basis of the User’s consent, given when filling in a form, taking a quiz, requesting a call back, sending a message to a messenger, accepting cookies or taking any other active step on the Site.

The User is free not to provide personal data. In that case the Operator may be unable to handle the request, contact the User or provide advice.

5. Operations with personal data

The Operator may carry out the following operations with personal data: collection, recording, systematisation, accumulation, storage, verification, updating, alteration, retrieval, use, transfer, disclosure, anonymisation, blocking, deletion and destruction.

Processing may be carried out with or without the use of automation.

6. Transfer of personal data to third parties

The Operator may transfer personal data to third parties only to the extent necessary to achieve the purposes of processing, including:

  • employees and representatives of the Company;
  • CRM systems, telephony services, messengers, analytics services, hosting providers and other technical contractors;
  • partners and counterparties involved in handling the request or selecting properties;
  • state authorities — in the cases provided for by law.

The Operator takes steps to ensure that third parties maintain the confidentiality and security of personal data.

7. Retention period

Personal data is processed until the purposes of processing are achieved, the User withdraws consent, or the retention period established by law or by the Operator’s internal documents expires.

As a general rule, data obtained through the Site may be stored for 3 years after the last interaction with the User, unless a different period is required by law or by contract.

8. Protection of personal data

The Operator takes the legal, organisational and technical measures necessary to protect personal data against unlawful or accidental access, destruction, alteration, blocking, copying, disclosure, distribution and other unlawful acts.

Such measures include restricting access to data, using technical protection tools, monitoring operations with data, appointing responsible officers and applying internal information security procedures.

9. Rights of the User

The User has the right to:

  • obtain information about the processing of their personal data;
  • request that personal data be verified, blocked or destroyed if it is incomplete, out of date, inaccurate, unlawfully obtained or not necessary for the stated purpose of processing;
  • withdraw consent to the processing of personal data;
  • require processing to cease in the cases provided for by law;
  • appeal against the Operator’s acts or omissions to the competent authority or to a court.

To exercise these rights, the User may send a request to privacy@whitewill.ru.

10. Withdrawal of consent

The User may withdraw consent to the processing of personal data by sending a request to privacy@whitewill.ru.

On receiving a withdrawal, the Operator ceases processing the personal data unless further processing is required by law or to protect the rights and legitimate interests of the Operator.

11. Changes to the Policy

The Operator may amend this Policy. A new version takes effect from the moment it is published on the Site, unless a different date is specified in that version.

Users are advised to check the current version of the Policy from time to time.