Terms and their definitions

1. The Policy is the procedure for processing personal data and cookies, posted on the Internet at: https://homejoyre.com/privacy.
2. We, Us, Our, etc., as well as Operator – OOO «M2B-GROUP», INN: 7702832838, OGRN: 1147746150826, address: 123100, Moscow, Shmitovsky proezd, house No. 3, building 3, office 16, e-mail: info@hnjproperty.com.
3. You, Yours, Yours, etc., as well as The subject of personal data is our counterparty under the User Agreement, which may be an individual who uses the Site, in accordance with the procedure and conditions established by the Agreement.
4. User Agreement – an offer regulating the use of the Site by Users, and posted on the link: https://homejoyre.com/user-agreement.
5. Personal data is any information that relates to an identified or identifiable individual. An identifiable person is a person who can be identified directly or indirectly, in particular by reference to identifiers such as name, identification number, location data, network identifier, or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual faces.
6. Personal data processing is any action (operation) or a set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), Depersonalization, blocking, deletion, destruction of personal data. The processing of personal data is carried out by the method of mixed (including automated) processing.
7. Automated processing of personal data is the processing of personal data using computer technology.
8. Confidentiality of personal data is a mandatory requirement for Us or other persons who have access to Personal Data to prevent their dissemination without the consent of the Personal Data Subject or other legitimate reason.
9. Depersonalization of personal data is an action that makes it impossible to determine the identity of personal data to a specific personal data subject without using additional information.
10. Website – Our website https://homejoyre.com.  
11. Cookies are small text files placed by a Website on your computer or device when, for example, you visit certain sections of the Website and/or when you use certain functions of the Website.
12. Federal Law No. 152-FL is the Federal Law of the Russian Federation dated 07/27/2006 No. 152-FL «On Personal Data».
13. GDPR or Regulation is the EU General Data Protection Regulation 2016/679, of the European Parliament and of the European Council of 27 April 2016 on the protection of individuals with regard to the processing of their Personal Data and on the free movement of such data, repealing Directive 95/46/EC as amended, amended and supplemented, applied periodically and incorporated into national legislation. the legislation of the participating countries.
14. The California Law on the Protection of Personal Data on the Internet or CalOPPA is the California Law on the protection of personal data on the Internet.
15. The California Consumer Privacy Act or CCPA is the first comprehensive privacy law in the United States, adopted at the end of June 2018 and representing the various privacy rights of California consumers.
16. The US Privacy Act 1974 or UPA is a Privacy Protection Act that regulates the processing of personal information of US citizens or persons with permanent residence in the United States.
17. PECR – Privacy and Electronic Communications Regulations (EU Directive) 2003.
18. UAE Data Protection and Privacy Laws – all and any laws and regulations governing the processing of Personal Data, including, but not limited to: (1) the Dubai Emirate Data Protection and Privacy Act, (2) the Federal Data Protection Act (Law No. 45 of 2021), which entered into force effective January 2, 2022, (3) The Constitution of the United Arab Emirates (UAE), (Federal Law No. 1 of 1971), (4) The Law on Crimes and Punishments (Federal Law No. 31 of 2021, repealing Federal Law No. 3 of 1987), (5) The Law on Cybercrime (Federal Law No. 5 of 2012 «On Combating Crimes in the field of Information Technology») (as amended by Federal Law No. 12 of 2016 and Federal Decree-Law No. 2 of 2018), (6) The Law on the Regulation of Communications (Federal Law on in accordance with Decree 3 of 2003, as amended), including regulations/policies adopted by the State Regulatory Authority for Telecommunications and Digital Technologies (TDRA) regarding the protection of telecommunications consumer data in the UAE.

The subject and grounds for Processing Personal Data

1. The Subject of The Policy. The provisions of this Policy apply to the relationship between Us and You related to the Processing of personal data within the framework of the relationship arising between Us on the use of the Site, resulting from your acceptance of the terms of the User Agreement.
2. The bases of processing. The basis for Processing your personal data is always your consent. Without agreeing to the terms of this Policy, we will not be able to fully ensure the fulfillment of obligations under the contracts concluded with you (including, but not limited to, the User Agreement).

Acceptance of the terms of the Policy

1. In this section, you can learn about the actions that mean your consent to the Processing of your personal data (hereinafter referred to as «Consent to the processing of PD»).
2. The content of the Consent to the processing of PD. By providing Consent to the processing of personal data, you confirm that you have fully read and agree with the User Agreement, the Policy for Processing Personal Data and Cookies, and provide a specific, substantive, informed, conscious and unambiguous Consent to the processing of your personal data.
3. Please note that Consent to the processing of PD means that you, among other things, express your consent to the Automated, as well as without the use of Automation tools, Processing of your Personal Data, on the terms specified in the Policy, as well as in Consent to the processing of PD.
4. Order a callback. If you order a callback by using the appropriate functionality of the Site, then you are considered to have given Consent to the processing of PD at the time of clicking on the «Order a call» button (or equivalent).
5. Making an outgoing call. By making a call to the Operator and continuing the conversation with an employee of the Operator, you provide Consent to the processing of PD.
6. Messaging via messenger. If you send a message to Us via messenger, including using the appropriate functionality of the Site, then your Consent to the processing of PD is considered provided at the time of sending the first message to Our address.
7. Familiarization with the content of the Site. If you are just browsing the Site, you are considered to be giving Us Consent to the processing of PD, to the extent specified in this Policy (technical data, Cookies (unless a different consent procedure regarding the processing of Cookies is implemented on the Site).
8. Storing consent information. Please note that We may store data about your actions (by means of a logging system of your actions, or an analog) confirming your Consent to the PD, as specified in this section of the Policy, for 3 (three) years after your expression of consent to the Policy, unless otherwise provided by law.

The term of the policy and processing of Personal Data

1. The validity period of the Policy. After accepting the terms of the Policy, the Policy is valid indefinitely. However, this does not affect the period of Processing of your personal data - it is established by this Policy.
2. The period of processing of personal data. As a general rule, We process your Personal Data until we contact you upon your request, as well as for 3 (three) years after the specified event, unless the period of storage of personal data is established by applicable law, User Agreement, or other agreement related in one way or another to the use of the Site or the Processing of your Personal Data, which you are a party to. In all other cases, we will stop processing your Personal Data if you object to such processing or if you have withdrawn your previously given consent to processing, in accordance with the terms of this Policy and the provisions of the law. However, We may not be able to fulfill our obligations under contracts with you.
3. Change. The Policy may be changed by Us at any time. In particular, this may be due to changes in Our business processes, the influence of external factors and other reasons. After making changes, we will immediately publish the amended Policy on the Website so that you have the opportunity to study it in the new version. In the event that you continue to use the Site after making changes to the Policy, we certainly believe that you agree to the terms of the new version of the Policy.

The basis of the development, goals, principles of the Policy

1. The basis of the development. The policy was developed in compliance with the requirements of: a) GDPR; b) CalOPPA; c) CCPA; d) PECR; e) Federal Law No. 152-FL; f) GDPR; g) UAE laws on Data Protection and confidentiality; h) as well as other laws and regulations defining the cases and features of personal data processing the data of the Personal data Subject.
2. Purposes. The Policy pursues the following objectives: (1) ensuring the requirements for the protection of human and civil rights and freedoms in the processing of personal data, including the protection of the rights to privacy, personal and family secrets, (2) the exclusion of unauthorized actions (unlawful or accidental access) by any third parties to your Personal Data, as well as the destruction, modification, blocking, copying and dissemination of personal data, (3) ensuring the legal and regulatory regime of confidentiality and control of your Personal Data, (4) protection of the constitutional rights of citizens to personal privacy, confidentiality of information constituting Personal Data, and prevention of a possible threat to your security.
   
   Thus, the main purpose of the Policy is to provide you with a complete and transparent understanding of: the legal basis for the collection and processing of your Personal Data; the categories of Personal Data that we may collect about you; what happens to the Personal Data that we collect; where we process your Personal Data; how much we store your Personal Data; to whom we may share your Personal Data; and explain your rights as a Personal Data subject.
3. Principles. We pursue the following principles of Personal data Processing: (1) personal Data processing must be carried out on a lawful and fair basis, (2) personal data processing must be limited to achieving specific, predetermined and legitimate goals; personal Data processing incompatible with the purposes of personal data collection is not allowed, (3) the content and volume of personal data processed the data must meet the stated processing objectives; the processed Personal Data should not be redundant in relation to the stated purposes of their processing, (4) when Processing personal data, the accuracy of Personal Data, their sufficiency and relevance in relation to the purposes of personal data Processing should be ensured, (5) Personal Data storage should be carried out no longer than the purposes of personal data Processing require, unless a different period of storage of personal data (or the procedure for determining it) is provided for by the Policy.

The composition of the Personal Data collected

1. Order a callback. You have the opportunity to order a callback from Us. To do this, you need to leave the following data by entering information in a special form on our Website: (1) Mobile phone subscriber number, (2) Name. Please note that by providing data to third parties, you agree to comply with the guarantees specified in this Policy. We also ask you to take into account that you can give any Name by entering the relevant information in the form, including one that does not correspond to your own name. However, in this case, please keep in mind that the Name you enter must meet the requirements of ethics and morality.
2. Information about messengers. On our Website, it is possible to write to Us in the messenger What's App, Telegram, or other messenger (if available). During the transition, you will have the opportunity to send us a message to the selected messenger. When sending such a message, We will receive information about your account address in the corresponding messenger, and such other data that you specified in such an account and made publicly available.
3. Technical data. While using the Site, We automatically collect some of your Personal Data. Such data includes, for example, technical information, including the Internet Protocol (IP) address used to connect your computer to the Internet, login information, browser type and version, time zone settings, browser plug–in types and versions, operating system and platform, information about your visit websites, etc.
4. Other data. In exceptional cases, We may ask you to provide additional Personal Data. We will definitely notify you about this in advance and ask you to provide additional consent for the Processing of additional Personal Data.
5. Personal data of third parties. Please keep in mind that if you provide us with Personal Data of third parties, you guarantee that you have received from such persons all necessary consents (including consent to the transfer of personal data), other documents necessary for the implementation of the provisions of this Policy in full, drawn up by them in the form and in accordance with their personal applicable law (Consent of third parties), and if you act as the operator of personal data of such persons – you also guarantee that you ensure the transfer and protection of their personal data to an extent not less than provided for in this Policy. In this case, the consent of third parties must be issued by them in writing, the original of which must be provided by you within 7 (seven) calendar days from the date of sending the corresponding request from the Operator. Providing Personal Data to third parties without complying with this warranty is unacceptable, and you fully accept all responsibility for violating this warranty.

Rights of the Personal Data Subject

1. Getting information. You have the right to receive information about Us, about Our location, about the availability of your Personal Data, as well as to familiarize yourself with such Personal Data.
2. Correction. You have the right to require Us to clarify your Personal Data, block or destroy it if the Personal Data is incomplete, outdated, unreliable, illegally obtained or is not necessary for the stated purpose of processing, as well as to take legal measures to protect your rights.
3. The form of provision. Information about the availability of Personal Data will be provided to you in an accessible form, and they will not contain Personal Data related to other Personal Data Subjects.
4. The order of access. You (or your legal representative) can access your Personal Data in person or by sending a written request. In this case, the request must contain the number of the main document certifying your identity or your legal representative, information about the date of issue of the specified document and the issuing authority and a handwritten signature. The request can be sent in electronic form. We are obliged to respond to your request within 30 (thirty) days from the date of its receipt, which, taking into account the complexity and number of requests, can be extended to 60 (sixty) days.
5. The content of the response. In a request for access to Personal Data, You have the right to request information from Us regarding the Processing of Your Personal Data, including: (1) confirmation of the fact of processing Personal Data, as well as the purpose of such processing, (2) methods of processing Personal Data, (3) the name and location of the Operator, information about persons who have access to Personal Data or who may be granted such access, (4) the list of Personal Data being processed and the source of their receipt, (5) the terms of processing of Personal Data, (6) information on what legal consequences the Processing of Personal Data may entail for the Subject of Personal Data.
6. Withdrawal of consent. You have the right to revoke consent to the processing of Personal Data, restrict the methods and forms of processing Personal Data, and prohibit the dissemination of Personal Data without your consent.
7. The right to appeal. You have the right to appeal Our actions or omissions to the authorized body for the protection of the rights of personal data Subjects or in court.
8. The right to protection. You have the right to defend your rights and legitimate interests, including damages and compensation for moral damage in court.

Rights of the Personal Data Subject (GDPR)

If you are a citizen of a member State of the European Economic Area or the United Kingdom (or legally provide us with the Personal Data of such a person), you are also granted the following rights. You can use them by sending an appropriate e-mail to Our Contact Information.

1. The right to be informed (Articles 12-14 of the Regulations). You have the right to receive information about the collection and use of your Personal Data, in particular about the purposes of processing this Personal Data, the duration of storage and to whom it will be transferred. This information must be provided at the time we collect your Personal Data. If we receive Personal Data from other sources, we will inform you about it within a reasonable time after receiving the data and no later than one month, unless you already have such information and if it does not require disproportionate efforts to provide it. Information should be concise, transparent, understandable, easily accessible, and expressed in clear and understandable language, which is why we try to explain our data processing policy in detail. We will inform you about any new use of your Personal Data before processing it.
2. The right of access (Article 15 of the Regulations). You have the right to receive confirmation from the Operator whether Personal Data concerning you is being processed and, if necessary, access to personal data and the following information: purposes of processing; categories of relevant Personal Data; recipients or categories of recipients to whom Personal Data has been or will be disclosed, in particular recipients from third countries or international organizations; if possible, the stipulated period during which Personal Data will be stored, or, if this is not possible, the criteria used to determine such a period; the right to require the Operator to correct or delete Personal Data or restrict the processing of Personal Data in relation to the data subject or object to such processing; the right to file a complaint with the supervisory authority; the availability of an automated decision-making process, including the profiling referred to in articles 22 (1) and (4) of the Regulations, and, at least in these cases, meaningful information about the underlying algorithm, as well as the significance and intended consequences of such processing for the data subject. If Personal Data is transferred to a third country or an international organization, you have the right to receive information about the available guarantees related to such transfer. Upon request, the Operator also provides a copy of the Personal Data being processed. For all additional copies requested by the Personal Data subject, the Operator may charge a reasonable fee based on administrative costs. If you make a request by electronic means, and unless otherwise required, the information must be provided in a generally accepted electronic form.
3. The right to correction (Article 16 of the Regulations). You have the right to correct incorrect or inaccurate information regarding Personal Data upon a request for correction made orally or in writing. The Operator has one calendar month to respond to the request of the Personal Data subject.
4. The right to be deleted (the «right to be forgotten») (Article 17 of the Regulations) The Regulations grant individuals the right to delete personal data. You can make a deletion request by contacting our Personal Data Protection Officer, who has one month to respond to your request. Please note that this right is not absolute and applies only in certain circumstances provided for in article 17 of the Rules.
5. The right to restrict processing (Article 18 of the Regulations). You have the right to request the restriction or termination of the processing of your Personal Data. If processing has been restricted, such Personal Data, with the exception of storage, is processed only with the consent of the data subject or to justify, execute or defend legal claims, or to protect the rights of another natural or legal person, or to protect the public interest of the union or a member State. Please note that this right is not absolute and applies only in certain circumstances provided for in article 18 of the Rules.
6. The right to data portability (Article 20 of the Regulations). The right to data portability allows you to receive and reuse your Personal Data for your own purposes within the framework of various services. It allows you to easily move, copy or transfer Personal Data from one IT environment to another in a safe and reliable way without affecting the usability of Personal Data. Please note that you have the right to transfer Personal Data directly from one Operator to another, in cases where it is technically possible.
7. The right to object (Article 21 of the Rules). You have the right to object at any time to the processing of your personal data on grounds relevant to your specific situation. We will not further process your Personal Data, except in cases where we have sufficient legitimate grounds for processing that are more significant than the interests, rights and freedoms of the data subject or to establish, implement or protect legitimate claims. If your Personal Data is processed for direct marketing purposes, you have the right to object to the processing of Personal Data related to you for the purposes of said marketing, including the formation of a profile to the extent it is related to direct marketing.
8. Rights related to automated decision-making, including profiling (Article 22 of the Regulations). You have the right not to be subject to a decision based solely on automatic processing, including the formation of a profile that generates legal consequences for him or her or significantly affects him or her. Please note that this right is not absolute and applies only in certain circumstances provided for in article 22 of the Rules. You can revoke your consent to the processing of Personal Data at any time. Please remember that withdrawal of consent applies only to the future. Any processing-related actions performed prior to such a recall are not affected by it.

Transfer of Personal Data

1. Transfer of Personal Data. In order to achieve the purposes of Processing personal data, we may need to provide your Personal Data to our contractors. Your Personal Data may also be transferred to government agencies, in particular, executive authorities, on the basis of their request.
2. Mandatory and optional transfer. The transmission of information may be mandatory, for example, in terms of information about user equipment: IP address, OS, geographical data, ID/type of equipment, channel used: browser/application, payment authorization, identification/verification, or optional, for example, in terms of information about address match indicators, information about account, etc.

Storage of Personal Data

1. Localization of Personal Data. If you are a citizen of the Russian Federation, then We store your data on servers located on the territory of the Russian Federation. If you are a citizen of one of the member States of the European Economic Area, the United Kingdom, or another country whose personal data legislation requires that Personal Data be Processed on the territory of such a country, then your Personal Data is collected and Processed on the territory of the European Economic Area or such a country, respectively.

Principles and measures of Personal Data protection

1. Principles of protection. We apply legal, organizational, administrative, technical and physical data protection measures to ensure the protection of your Personal Data.
2. Security measures. Measures to ensure the security of Personal Data during their processing are planned and implemented in order to ensure compliance with the requirements of legislation in the field of Personal data and regulatory legal acts adopted in accordance with it. We ensure the security of your Personal Data, including in the following ways: (1) limitation and indication of the number of employees of the Operator who have access to Personal Data, (2) appointment of a person responsible for organizing the processing of Personal Data, (3) development and implementation of local acts on personal data processing, (4) identification of threats to the security of Personal Data during their processing in Personal data information systems, (5) the application of organizational and technical measures to ensure the security of Personal Data, (6) the use of information security tools that have passed the compliance assessment procedure in accordance with the established procedure, (7) taking into account electronic media, (8) establishing rules for access to Personal data, (9) restricting access to premises where technical means for processing Personal Data are located, as well as information media are stored, (10) by detecting the facts of unauthorized access to Personal Data and taking measures to prevent such access, (11) by entering Personal Data (which are not publicly available, to the list of confidential information of the Operator, (12) obtaining an obligation not to disclose confidential information, including Personal Data, from all employees of the Operator directly involved in the processing of Personal Data, (13) restoring Personal Data modified or destroyed due to unauthorized access to them, (14) familiarizing employees Operators who directly process Personal Data, in accordance with the provisions of the legislation on personal data, including requirements for the protection of Personal Data, local acts on the processing of Personal Data, (15) control over the measures taken to ensure the security of Personal Data.

Cookies files

1. The Use of Cookies. The Site uses cookies. When visiting the Site, your Internet browser transmits certain information to Our server: (1) date and time of the visit, (2) browser type, (3) language settings, (4) operating system. This information is stored in connection logs for a limited time (from a session to a year) to ensure the security and proper operation of the Site, as well as to collect statistical information.
2. The functions of Cookies. There are various groups of Cookies that are used on the Site.The first group is functional and technical Cookies. The main function of such files is to allow the Site server to receive information about your session, the language used, the browser, etc., as well as to ensure the full operation of the Site. These files are needed in order to recognize you when you visit the Site again. This allows us to personalize the content of the Site to your needs, to remember your preferences. The second group is analytical Cookies, which allow us to evaluate and count the number of visitors, as well as understand how they move around the Site when working with it. This helps us to make improvements to the Site, for example, by optimizing the search for the right sections, making it simple and effective. You have the right to refuse the use of analytical Cookies by making the appropriate settings in your web browser.
3. The storage time of Cookies. According to the storage time on users' devices, Cookies are divided into Permanent and Session Cookies: «Session Cookies» are files that are stored on your device until you close the browser. «Persistent Cookies» are stored on your device until they expire or until you delete them.
4. Disabling Cookies. You have the option to accept or reject all Cookies on all sites that you visit by changing the settings in your web browser. For example, when you use Internet Explorer version 11.0, you should do the following: (1) select «Settings», then «Internet Options», (2) go to the «Privacy» tab, (3) use the mouse to select your preferred settings. Each browser must use its own settings to change and delete Cookies. Please note that certain functionality of the Site may not be available when cookies are disabled. To learn more about how to adjust or change your browser settings, refer to the browser instructions or at www.aboutcookies.org either www.allaboutcookies.org. If you use different devices to access the Site (e.g. smartphone, tablet, computer, etc.), you should make sure that each browser on each device is configured according to your preferences regarding Cookies.

Addresses for exchanging legally significant messages

1. Details of the Parties. In the course of fulfilling obligations under this Policy and (or) other obligations, as an Operator of Personal Data, there may be (and in some cases must be) an exchange of legally significant messages between Us. Such an exchange takes place through official contacts of the Parties, both in writing and in electronic form (equivalent). At the same time, the conclusion of a separate agreement on the use of electronic document management is not required. Our data is indicated in the Official Notification (at the bottom of the document), and your data is indicated by you at the time of leaving a request for a callback, by sending us a message via messenger or other communication channels. Please remember that you bear all risks associated with the fact that your data for the exchange of legally significant messages is no longer relevant.
2. Exchange of correspondence. The exchange of correspondence is possible only using the data of the Parties, determined in accordance with the rules of this Policy.

Final provisions

1. The divisibility clause. In the event that one or more provisions of the Policy are declared invalid/irreconcilable, etc., then such provisions are considered to be replaced by valid provisions as close as possible in their meaning. At the same time, the Policy cannot be invalidated in full under any circumstances.

Official notification

OOO «M2B-GROUP»
Taxpayer Identification Number (INN): 7702832838, Primary State Registration Number (OGRN): 1147746150826
Email address: info@hnjproperty.com
E-mail (questions about Personal data): info@hnjproperty.com

THESE CONTACTS ARE THE ONLY OFFICIAL SOURCES OF COMMUNICATION WITH US. PLEASE BE CAREFUL!

Link to the document: https://homejoyre.com/privacy

The Policy is published in free access on the Internet information and telecommunications network on the Operator's Website