This Privacy Policy (hereinafter referred to as the «Policy») has been developed in accordance with the requirements of Directive 2002/58/EC of the European Parliament and of the Council of 12 July 2002 concerning the processing of personal data and the protection of privacy in the electronic communications sector, and Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 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 (hereinafter referred to as the «Law»).
This Policy establishes the procedures by which HAGUARDS LLC (hereinafter referred to as the «Company») processes personal data provided by clients who use the website and its specific services to receive or provide services (hereinafter referred to as «Users» and the «Website,» respectively). The Policy defines the types of personal data collected, the purposes for which such data are used, the Company’s interactions with third parties, security measures for the protection of personal data, conditions for accessing personal data, and contact information for Users regarding how to access, modify, block, or delete their personal data, as well as how to address any questions that may arise concerning personal data protection practices. The Company treats the confidential (personal) information of all individuals—without exception—who visit the website http://haguards.com or use the services provided by the website with the utmost respect. Accordingly, the Company is committed to protecting the confidentiality of personal data (information or a set of information regarding an individual who is identified or can be specifically identified), thereby ensuring the most comfortable experience possible for every user when utilizing the website’s services.
The text of this Policy is available to Users online at https://haguards.com/privacy-policy. If a User does not agree with the terms of this Policy, they must immediately cease any use of the website.
1. Terminology and Abbreviations
- The terminology used in this Policy shall have the following meanings:1.1. Personal Data — Any information relating, directly or indirectly, to a specific or identifiable natural person (data subject).
1.2. Processing of Personal Data — Any operation or set of operations performed upon personal data, whether or not by automated means, including collection, recording, systematization, accumulation, storage, refinement (updating, modification), retrieval, use, transfer (dissemination, provision, granting access), depersonalization, and blocking.
1.3. Automated Processing of Personal Data — The processing of personal data using computing equipment. However, automated processing of personal data does not include automated processing systems—including profiling—that produce legal effects concerning the User or otherwise significantly affect the User.
1.4. Dissemination of Personal Data — Actions aimed at disclosing personal data to an indefinite circle of persons.
1.5. Provision of Personal Data — Actions aimed at disclosing personal data to a specific person or a specific circle of persons.
1.6. Blocking of Personal Data — The temporary suspension of the processing of personal data (except in cases where such processing is necessary for the purpose of refining the personal data).
1.7. Use of Personal Data — Actions (operations) involving personal data, performed by the Company for the purpose of making decisions or taking other actions that result in legal consequences for the data subject or other persons, or that otherwise affect the rights and freedoms of the data subject or other persons.
1.8. Depersonalization of Personal Data — Actions that render it impossible to determine which specific data subject the personal data belongs to, without the use of additional information.
1.9. Destruction of Personal Data — Actions that render it impossible to restore the content of personal data within a personal data information system, and/or actions that result in the destruction of the physical media on which the personal data is stored.
1.10. Website — A collection of information, text, graphic elements, design, images, photos, videos, and other results of intellectual activity, as well as computer software, contained within an information system that makes such information accessible on the Internet at the network address https://haguards.com.
1.11. Cookies — Data automatically transmitted to the Company during the use of the Website via software installed on the User’s device. This includes IP addresses, geographic location, information regarding the browser and the operating system of the User’s device, technical specifications of the hardware and software used by the User, the specific Website accessed, and the time of access. Cookies can be permanent (known as persistent cookies) and remain on the computer until the user deletes them, or temporary (known as session cookies), meaning they are stored only until the browser is closed. Furthermore, cookies are categorized into first-party cookies (set directly by the website being visited) and third-party cookies (set by other websites).
1.12. An IP address is a numerical identifier used by computers on a network to identify a specific computer each time it connects to the Internet.
2. User’s Consent to the Processing of Personal Data by the Company
2.1. The User accepts the terms of the Policy and provides the Company with informed and conscious consent to the processing of their personal data under the conditions stipulated by the Policy and the Law:
2.1.1. Upon completing a feedback form — regarding personal data provided by the User to the Company when filling out a feedback form online on the Website or via electronic services (Google, etc.). The User is deemed to have provided consent to the processing of the personal data entered into the feedback form fields at the moment they click the button confirming the submission of the request (such buttons may be labeled «Send,» «Submit Request,» or similar).
2.1.2. During any use of the Website — regarding personal data automatically transmitted to the Company while the Website is being used, via software installed on the User’s device. The User is deemed to have provided consent to the processing of their personal data at the moment they begin using the Website.
2.2. The User’s consent to the processing of their personal data by the Company remains in effect from the date such consent is provided (Clause 2.1 of the Policy) and continues for the duration necessary to achieve the purposes for which the personal data is processed (Section 5 of the Policy).
2.3. The User has the right to withdraw their consent to the processing of personal data in the form and manner specified in Section 9 of the Policy.
3. Conditions for the Provision of Personal Data by the User
The Company proceeds on the understanding that, upon providing personal data on the Site, the User:
3.1. Confirms that they possess all necessary rights to acquire civil rights and exercise them independently, as well as the capacity to assume civil obligations through their own actions, fulfill them independently, and bear responsibility in the event of non-fulfillment.
3.2. Provides accurate information about themselves to the extent necessary for using the Site and keeps the provided personal data up to date.
3.3. Acknowledges that any telephone conversations with a Company employee are automatically recorded for the purposes of monitoring the quality of service provided to Users, as well as for resolving any disputes or conflicts that may arise during such conversations. In doing so, the User consents to such automatic recording of telephone conversations and the storage of these recordings in accordance with the terms of this Policy.
3.4. Has reviewed this Policy and expresses their informed and conscious consent to it.
4. Personal Data Processed by the Company
4.1. The User’s personal data processed by the Company includes:
surname, first name, and patronymic;
mobile phone number;
email address;
data from accounts on social networks and electronic services (links to the User’s profiles on VKontakte, Facebook, LinkedIn, Skype, Google, Twitter, etc.);
IP address;
cookies;
internet browser parameters and settings (User-agent);
4.2. The Company protects data that is automatically transmitted during the viewing of ad units and visits to pages where a system statistical script (“pixel”) is installed:
IP address;
information from cookies;
information about the browser (or other program used to access the displayed advertisement);
access time;
the address of the page where the ad unit is located;
referrer (the address of the previous page);
4.3. All system logins are recorded when the Site is visited. No other information regarding user traffic is processed or stored.
4.4. The Company does not collect any information subject to specific legal requirements regarding its processing—such as information concerning racial or ethnic origin; political, religious, or philosophical beliefs; membership in political parties or trade unions; or data regarding criminal convictions.
4.5. The Company collects data regarding statistics on visits to the Site. This information may include details about the connection, traffic, the user’s browser, as well as the date, time, duration of internet usage, and time spent on the Site.
4.6. Any other personal information not specified above (browsing history, browsers and operating systems used, etc.) shall be securely stored and not disclosed.
5. Use of cookies
5.1. The Company cares about its users and strives to make their experience on the Site as comfortable as possible. To achieve this, the Company uses cookies to analyze user behavior, preferences, and interests. Such analysis helps the Company improve the user experience on the Site and determine the most user-friendly interface and navigation for the Service.
5.2. In accordance with the classification established by the International Chamber of Commerce, the Company uses the following categories of cookies:
Strictly necessary cookies — these are required for users to navigate the webpage and use specific services, such as accessing secure pages, registering, logging in, or performing searches on the Site. They also remember a user’s previous actions when navigating back to a prior page within the same session.
Performance cookies — these aggregate information regarding how the Site is used. This data is stored on the user’s device between browser sessions. Examples of such data include metrics such as time spent on the Site, the most frequently visited pages, insights into which specific sections and services were of most interest to the user, and the effectiveness of various advertising and/or marketing campaigns.
All information collected via performance cookies is used for statistical and analytical purposes. Certain cookie data may be shared with authorized third parties, strictly for the purposes mentioned above. Functional cookies — These are used to store settings or configurations that remain on the user’s device between browser sessions. Examples of such data include: username, profile photo, information regarding comments left, site language, location, records of whether information has previously been presented to the user or if specific preferences have been selected, as well as other site customization settings.
These cookies also enable users to watch videos, participate in interactive features (such as polls or voting), and interact with social networks.
To enhance the user experience, these cookies remember information provided by the user, thereby improving the efficiency of their interaction with the Site.
Certain data from these cookies may be shared with third parties authorized by the web resource, strictly for the purposes mentioned above.
Targeting cookies — These are used to deliver content that may be of interest to the user. This data is stored on the user’s device between browser sessions. Examples include: tracking recommended text, visual, audio, or video content to prevent repetitive display; managing targeted advertising; evaluating the effectiveness of advertising campaigns; tracking the user’s visits to other resources via external links; and other site customization settings. The Site may share this information with third parties—including media clients, advertisers, agencies, and partners in related businesses—to enable the delivery of high-quality, targeted advertising.
Cookies from third-party services and analytics providers:
To ensure efficient delivery, improved display, and detailed analysis of content on the Site, the Company utilizes services owned by third-party entities, such as Facebook, Twitter, Instagram, Alphabet Inc., Gemius, and others.
These companies may place cookies on the user’s device while the user interacts with the Site.
Please note that the Site has no control over the operation of cookies used by these services. Detailed information regarding their use can be found by visiting the respective service’s website.
Google Analytics Terms of Service — http://www.google.com/analytics/terms/ua.html
Managing cookies:
Major web browsers (listed below) are configured to accept cookies automatically. To disable them, please refer to the help function within your browser. You can access the help section via the menu or by pressing the F1 key.
Microsoft Edge — https://privacy.microsoft.com/ru-ru/privacystatement
Mozilla Firefox — https://www.mozilla.org/uk/privacy/websites/#cookies
Google Chrome — https://support.google.com/chrome/answer/95647?hl=ua
Opera — http://help.opera.com/Windows/11.50/ua/cookies.html
Safari for macOS — https://support.apple.com/kb/PH21411?locale=en_US
Important:
Cookie settings may vary across different mobile web browsers;
Please note that full functionality of the Site is available only when cookies are enabled;
Disabling cookies may restrict access to content and impair the proper functioning of the Site’s services.
To contact the Company regarding the use of cookies, please send an email to support@haguards.com. If a user does not enable cookies or intentionally deletes all cookies from their web browser, they will be prompted to enable and use cookies again upon their next visit to the Site.
User information collected via cookies is neither sold nor made publicly available; it remains the property of the company that owns the resource.
6. Purposes of Personal Data Processing
The Company processes Users’ personal data exclusively for the following purposes:
6.1. Establishing and maintaining communication between the User and the Company, providing consultations regarding the provision of services, and offering customer and technical support in the event of issues related to the use of the Site.
6.2. Fulfillment of the Company’s obligations to a User who has ordered a service via the Site.
6.3. Sending promotional messages to the User’s email address and targeting advertising materials.
6.4. Improving the quality of service provided to Users and enhancing the Site by processing requests and inquiries submitted by the User.
6.5. Conducting statistical and other research based on anonymized information provided by the User.
Users retain the right to opt out of receiving communications. In such a case, their name and email address will be automatically removed from the database. To do this, simply click the relevant option provided in any email received.
7. Processing of Personal Data
7.1. The processing and storage of personal data take place in data centers housing the equipment that enables the operation of the Site’s services. Provided personal data are processed and may be stored within a Personal Data Database or in a separate table within the Site’s database. As the Company’s servers are located in various regions worldwide, a specific User’s information may be processed in a country other than their country of residence. The level of data protection and the applicable legal standards in this area may vary from country to country. Regardless of where a User’s data is processed, the Company applies the same security measures as described in this Policy. The Company also complies with various legal requirements regarding data transfer, including the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework.
7.2. Personal data are processed using automated systems, except in cases where non-automated processing is required to comply with legal obligations.
7.3. The processing of a User’s personal data by the Company encompasses the following actions: collection, recording, systematization, accumulation, storage, refinement (updating, modification), retrieval, use, transfer (dissemination, provision, granting access), depersonalization, blocking, deletion, and destruction.
7.4. The collection of a User’s personal data occurs in the circumstances specified in Section 2.1 of this Policy.
7.5. Personal data shall be stored until such time as it is destroyed by the Company, following the receipt from the User of a withdrawal of consent for the processing of personal data or a request for the destruction of personal data;
7.6. The Company may disseminate personal data exclusively in the context of publishing reviews of the services provided by the Company—submitted by Users—across various information sources.
7.7. The Company has the right to transfer personal data to third parties (the Company’s Processors), subject to the following conditions:
the third party ensures the confidentiality of personal data during its processing and use; it undertakes not to disclose personal data of Users to other parties, nor to disseminate such data without the Users’ consent;
the third party guarantees the implementation of the following measures to ensure the security of personal data during processing: the use of information protection tools; the detection and recording of instances of unauthorized access to personal data, along with the implementation of measures to restore such data; the restriction of access to personal data; the logging and tracking of actions performed involving personal data; and the monitoring and evaluation of the effectiveness of the measures taken to ensure the security of personal data;
7.8. The Company shall destroy personal data in the following cases:
upon receipt of a request from a User to destroy their personal data;
upon the expiration of the consent (Section 2.2 of the Policy).
The Company does not transfer personal data to third parties, except where such transfer is required by law, requested by the data subject, or otherwise provided for in this Policy. The Company recognizes that personal information is a valuable asset and an integral component of an individual’s personal non-property rights; therefore, it takes all possible measures to protect the personal information that Users voluntarily and knowingly provide to the Company.
7.9. Cross-border Transfer of Personal Data
The Company is required to ensure that the foreign state to which personal data is to be transferred provides adequate protection for the rights of the data subjects before such a transfer takes place.
Cross-border transfer of personal data to foreign states that do not provide adequate protection for the rights of data subjects may occur in the following cases:
the data subject has provided written consent for the cross-border transfer of their personal data;
the transfer is necessary for the performance of a contract to which the data subject is a party.
8. Protection of Personal Data
The Company implements necessary and sufficient legal, organizational, and technical measures to protect information provided by Users against unauthorized or accidental access, destruction, alteration, blocking, copying, or dissemination, as well as against other unlawful actions by third parties. However, despite all efforts, the Company cannot guarantee absolute protection against any threats arising outside the Company’s control.
The Company employs standard operational practices—such as encrypted communication, secured premises, network security systems, and password protection—to ensure the confidentiality of personal data.
The Company grants access to information and personal data only to authorized employees who have agreed to maintain the confidentiality of such information and data in accordance with the Company’s requirements.
The website may contain links to other websites (provided for informational purposes only). Please note that this Policy does not apply to such external websites. Therefore, the Company recommends reviewing the privacy and personal data policies of each website before providing any personal data that could be used to identify you. Read more here.
9. Users’ Rights
The User has the right to:
9.1. Provide personal data to the Company, at their own discretion, for processing under the terms set forth in the Policy. Please note that certain personal data provided are necessary for the conclusion of the Agreement; failure to provide such data makes the conclusion of the Agreement impossible;
9.2. Request that the Company clarify, block, or destroy their personal data if such data are incomplete, outdated, inaccurate, obtained unlawfully, or are not necessary for the stated purpose of processing; the User may also take measures provided by law to protect their rights;
9.3. Receive a response—no later than thirty calendar days from the date the request is received (except in cases provided for by law)—confirming whether their personal data are being processed, and to obtain the content of such personal data;
9.4. Seek legal remedies in the event of a violation of legislation regarding the protection of personal data, including filing a complaint with a supervisory authority;
9.5. Contact the Company to update, access, modify, block, or delete their personal data, or to withdraw the consent for personal data processing previously granted to the Company under this Policy. You may also contact the Company regarding any comments, requests, or complaints concerning your personal data processed by the Company;
9.6. Submit requests and demands to the Company, including those regarding the use of their personal data or the withdrawal of consent for the processing of such personal data. The request must be sent via email (the document must be sent from the User’s email address specified in the agreement as the authorized email address) to the email address support@haguards.com. The Company reviews User requests, provides responses, and/or takes necessary actions within 30 calendar days from the date of receipt of the request.
9.7. In addition to the rights listed in this Policy, the User may exercise any right provided for by law.
10. Changes to the Policy
10.1. The Company reserves the right to make changes and additions periodically, without prior notice to the User, including in response to changes in legal requirements.
It is the User’s responsibility to review the text of the Policy each time they use the Site.
10.2. A new version of the Policy enters into force upon its publication in the relevant section of the Company’s website. Continued use of the Site or its services following the publication of a new version of the Policy constitutes the User’s acceptance of the Policy and its terms. If the User does not agree with the terms of the Policy, they must immediately cease using the Site and its services.
10.3. Please review the Policy from time to time to stay informed of any changes or additions.