GENERAL PRIVACY NOTICE
1. Introduction
This privacy notice describes how HMS Group collects and uses personal information. This privacy notice is not intended to override any other privacy notice we provide you in specific circumstances.
If you have any questions about this privacy notice or how we treat your personal information, please contact us using one of the following methods:
7, Chayanova str., Moscow 125047, Russia
HMS Group
E-mail: info@hms.ru
The feedback form available on our website.
2. What personal information do we collect about you?
In addition to the personal information you provide directly to us, we also collect the following personal information about you:
Board Members and Officers
- Your name, professional title, contact details, details regarding shared owned, passport details, address, residence, telephone number, email address, correspondence data, etc.;
Investors
- Your name, professional title, contact details, address, telephone number, email address, correspondence data, etc.;
HMS Customer Representatives
- Your name, professional title and contact details from the organization you represent.
Website Visitors
- When you navigate to our website, we may collect personal information about you and how you interact with our site. You can find out more about this in our website privacy notice available.
3. How do we use your personal information?
Board Members and Officers
- As necessary to register you as a member of our board or company officer so you are able to adopt your position.
- As necessary for the performance of your contract of service with us.
- As necessary to protect our legitimate interests in ensuring that you are suitable for your (proposed) role with us.
- As necessary for our legitimate interests in protecting us against fraud, other unlawful acts or misconduct by monitoring your activities on our IT systems.
Investors
- As necessary to enable your investment to be processed and managed by us and to inform you about our performance as a company.
- As necessary to ensure compliance with our legal obligations, for example anti-money laundering and terrorist financing due diligence.
- To further our legitimate interest in providing you with information about future opportunities to invest with HMS.
HMS Customer Representatives
- As necessary to communicate with you in your capacity as a customer representative in order to manage and perform our business relationships and promote our legitimate interests in growing our business interests with the company you represent.
4. How do we share your personal information?
As a general rule, we do not share your personal information with third parties outside of the HMS Group other than to the extent it is necessary for our business operations. Accordingly, your personal information may be shared with our service providers including IT hosting companies, payroll providers, and legal and other business advisors, as necessary from time to time.
We may also disclose your personal information to third parties such as law enforcement agencies if we believe disclosure is necessary or appropriate in our legitimate interests to prevent harm or loss, or in connection with an investigation of suspected or actual illegal activity, or when we are required to do so by applicable law.
5. Transfers to Outside the European Economic Area
Our IT systems are located and maintained in the Russian Federation. Accordingly, we will transfer your personal information there for storage and processing in connection with our company business. Russian data protection laws may be less protective of personal data than those in the European Economic Area. Nevertheless, we take robust steps to safeguard your personal information. All transfers from HMS Group to its Russian affiliates are made on the basis of intra-group data transfer agreements incorporating the Model Clauses approved by the European Commission.
Where we transfer your personal information to third party service providers outside of the European Economic Area, we also put in place service agreements incorporating the Model Clauses. These service providers are located in the Russian Federation.
If you wish to receive a copy of these agreements, please contact us using one of the following methods:
7, Chayanova str., Moscow 125047, Russia
HMS Group
E-mail: info@hms.ru
The feedback form available on our website.
6. How long do we keep your personal information?
We will only retain your personal information for as long as necessary to fulfill the purposes for which we collected it, including meeting any legal, accounting, or reporting requirements. In most cases, this will mean that we keep personal information associated with you as indicated below:
Board Members and Officers
- For 5 years after termination of your appointment.
Investors
- For 5 years after your investment terminates.
Customer Representatives
- For 5 years after our business relationship with the company you work for terminates.
7. Rights of Individuals in the European Economic Area
Individuals based in the European Economic Area have certain rights in relation to the personal information we hold about them. Depending on the circumstances, these may include the right to:
- request access to your personal information and obtain a copy of the information we hold about you;
- correct your personal information that we hold where it is incomplete or inaccurate;
- have your personal information erased where there is no good reason for us continuing to use or retain it;
- request that your personal information is used only for restricted purposes;
- object to your personal information being processed if the lawful basis for processing your personal information is either our or a third party’s legitimate interests;
- require certain of your personal information to be transferred to you or a third party; and
- lodge a complaint with the relevant data protection authority in your jurisdiction.
If you wish to exercise any of these rights, please contact us using one of the following methods:
7, Chayanova str., Moscow 125047, Russia
HMS Group
E-mail: info@hms.ru