1.Introduction1.1. Individual Entrepreneur Vladimir Vladimirovich Mostovoy (TIN 910204258827, OGRNIP 324911200076104), acting in accordance with the legislation of the Russian Federation, registered at the address: 295053, Republic of Crimea, Simferopol, Maté Zalki St., 1/9 (hereinafter referred to as "Operator" or "We") takes the privacy and protection of personal data of all individuals using our personnel recruitment services (recruitment agency "HumanCode") seriously. "Personal data" refers to any information related to a directly or indirectly identified or identifiable individual (citizen), which we collect in the course of our activities.
1.2. We value your privacy and are committed to protecting your personal data in accordance with the Constitution of the Russian Federation, the Labor Code of the Russian Federation, Federal Law No. 152-FZ "On Personal Data" dated July 27, 2006, Federal Law No. 149-FZ "On Information, Information Technologies and Information Protection" dated July 27, 2006, and other regulations of the Russian Federation that govern the relationships in the field of personal data and information technology (hereinafter referred to as "Applicable Law").
1.3. This Privacy Policy (hereinafter referred to as the "Policy") describes how we collect, use, and process your personal data on our website, as well as during the provision of personnel recruitment services. It also explains your rights as a personal data subject and how the law protects you.
1.4. This Policy is developed in compliance with the requirements of paragraph 2 of part 1 of Article 18.1 of Law No. 152-FZ and applies to all personal data that the Operator may receive from a personal data subject when visiting the Site, filling out feedback forms, submitting resumes, and during the provision of services.
2.Terms and Definitions2.1. Personal Data — any information relating to a directly or indirectly identified or identifiable individual (citizen) — the personal data subject.
2.2. Personal Data Subject (You) — an individual who uses the Site, fills out forms, submits resumes, requests personnel recruitment services, and whose candidacy is being considered for employment for open positions at the Operator’s clients (potential employers) or the Operator itself.
2.3. Operator (We) — Individual Entrepreneur Vladimir Vladimirovich Mostovoy (Trade Name: "HumanCode"), registered in accordance with the legislation of the Russian Federation, located at: 295053, Republic of Crimea, Simferopol, Maté Zalki St., 1/9, TIN 910204258827, OGRNIP 324911200076104, who independently organizes and performs the processing of personal data, as well as determines the purposes of processing, the composition of personal data to be processed, and the actions (operations) performed with personal data.
2.4. Site — a set of programs for electronic computing machines and other information contained in the information system, which is accessible via the information and telecommunications network "Internet" at the web address: https://humancode.agency/ (or any other domain used by the Operator).
2.5. Processing of Personal Data — any action (operation) or set of actions (operations) performed with or without automation tools using personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, usage, transfer (dissemination, provision, access), anonymization, blocking, deletion, destruction.
2.6. Counterparties / Partner Organizations / Potential Employers — legal entities and individuals (clients of personnel recruitment services) with whom the Operator collaborates to assist candidates in finding employment.
2.7. Authorized Persons — individuals engaged by the Operator on a contractual basis to assist with personnel recruitment, provide technical support for the Site, manage accounting, and perform other tasks that ensure the Operator’s operations, and who undertake to ensure the confidentiality and security of personal data when processing it.
3. Information about the Operator3.1. Individual Entrepreneur Vladimir Vladimirovich Mostovoy
3.2. TIN: 910204258827
3.3. OGRNIP: 324911200076104
3.4. Registered Address: 295053, Republic of Crimea, Simferopol, Maté Zalki St., 1/9
3.5. Email Address: privacy@humancode.ru
3.6. Date of personal data processing initiation: 13.08.2024
3.7. Information on the presence of a database in the Russian Federation: The Operator’s personal data information system is located within the Russian Federation.
4.Purposes and Legal Grounds for Personal Data Processing4.1. We process your personal data solely for the following purposes, which correspond to the nature of our activities as a recruitment agency:
4.1.1. Consideration of Employment Opportunities: evaluating the candidate’s compliance with the requirements of vacancies at the Operator's clients (potential employers) or the Operator itself and making a decision about the candidate’s suitability for the vacancy.
4.1.2. Personnel Reserve Management: creating and maintaining a database of candidates for the purpose of offering vacancies matching the candidate's profile.
4.1.3. Communication with the Candidate: contacting the candidate (via phone, email, or messaging apps) for clarifying information, inviting for interviews, informing about the results of consideration, and making job offers.
4.1.4. Conducting Interviews and Evaluations: organizing and conducting interviews, testing, verifying candidate competencies (including audio and video recording of interviews, if specifically agreed), and analyzing provided materials.
4.1.5. Interaction with Employers: transmitting candidates' personal data to the Operator’s clients (potential employers) for their consideration and decision-making regarding staffing.
4.1.6. Verifying Information: analyzing information from publicly available sources (professional social networks, open registers) to confirm qualifications and data provided by the candidate.
4.1.7. Ensuring Website Functionality: processing technical information (cookies, IP addresses) to analyze site traffic, improve site functionality, and customize the user experience.
4.1.8. Compliance with Legal Requirements: fulfilling the Operator’s obligations under the Russian Tax Code, Labor Code, the "Personal Data" Law, and other regulations (for example, when concluding an employment contract or civil law contract with a candidate).
4.1.9. Protection of Rights and Legal Interests: in cases provided by the legislation of the Russian Federation, to protect the rights and legal interests of the Operator or third parties.
4.2. Legal grounds for processing personal data include:
- Consent of the personal data subject to process their personal data (offer and acceptance when filling out forms on the Site);
- Contracts between the Operator and the personal data subject or between the Operator and its clients (employers);
- Requirements of federal laws and other regulations of the Russian Federation;
- Necessity for the legitimate interests of the Operator or third parties.
5.Categories of Personal Data Processed5.1. In the course of providing services, the Operator may process the following categories of personal data:
5.1.1. Identification Data: surname, first name, patronymic (if applicable), date and place of birth, citizenship.
5.1.2. Contact Information: phone numbers (home, mobile), email addresses, social network and messenger profile links (e.g., Telegram, WhatsApp).
5.1.3. Professional Activity Data: education information (names of educational institutions, graduation years, specialties, qualifications), work experience data (previous employers, positions, job duties, achievements, reasons for termination), information about professional development, certifications, foreign language proficiency, academic degrees and titles.
5.1.4. Identification Document Details: may be processed if necessary for employment purposes and the establishment of labor relations (e.g., for issuing a pass or concluding an agreement with a potential employer), with the candidate's separate consent.
5.1.5. Resume and Cover Letter Information: any information voluntarily provided by the candidate in their resume, questionnaire, cover letter, or otherwise.
5.1.6. Interview Materials: results of tests, assignments performed, recruiter notes, protocols and recordings (including audio/video) of interviews.
5.1.7. Desired Work Conditions: desired salary, willingness to relocate, travel readiness, preferred work schedule.
5.1.8. Photograph: may be processed if provided by the candidate in their resume or profile.
5.1.9. Technical Data: IP address, device type, operating system, browser type, geographic location, cookie data, visit history, actions on the Site.
5.2. The Operator does not process special categories of personal data related to race, nationality, political views, religious or philosophical beliefs, health status, intimate life, except as required by Russian Federation legislation (for example, if such data is voluntarily provided by the candidate and necessary for assessing the ability to perform a job function).
6.Procedure and Conditions for Processing Personal Data6.1. Personal data processing is carried out using automated tools and manually (on paper), ensuring compliance with confidentiality and security requirements set by Applicable Law.
6.2. We store your personal data no longer than required by the purposes of processing, unless a different storage period is set by law or contract.
6.2.1. For candidates under active consideration (for specific vacancies), the processing period is determined until the recruitment process for this vacancy is complete.
6.2.2. For inclusion in the personnel reserve (candidate database) – for 2 (two) years from the last interaction with the candidate unless a longer period is agreed separately. After this period, data will be deleted or anonymized unless the candidate expresses a desire to continue cooperation.
6.2.3. In the case of employment with the Operator or its client, data may be processed according to labor and tax legislation requirements (e.g., 50 or 75 years).
6.3. The Operator takes necessary legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, alteration, blocking, copying, provision, dissemination, and other unlawful actions. These measures include:
- Appointing a responsible person for personal data processing (in the case of an individual entrepreneur, it may be the entrepreneur themselves or an authorized employee);
- Issuing internal regulations on personal data processing;
- Implementing legal, organizational, and technical security measures for personal data;
- Performing internal control to ensure compliance with the law during personal data processing;
- Assessing potential harm to data subjects and correlating it with security measures.
6.4. The Operator may delegate the processing of personal data to authorized persons (third parties such as cloud service providers, ATS system operators, accounting or legal firms) with the consent of the personal data subject, unless otherwise provided by federal law. These persons are required to comply with confidentiality and security requirements during personal data processing.
6.5. If inaccuracies are found in personal data, the subject may update them independently by sending a request to the Operator.
7.Categories of Individuals to Whom Personal Data May Be Transferred7.1. To achieve the purposes of processing, the Operator may transfer personal data of the candidate to the following categories of individuals:
7.1.1. Operator Clients (Potential Employers): legal entities and individuals who have ordered personnel recruitment services, exclusively for the purpose of considering the candidate’s application for an open vacancy. Transfer is made on the condition that the client guarantees confidentiality and the use of the data only for candidate evaluation and staffing decisions.
7.1.2. Authorized Persons (Partners and Contractors):
Organizations providing technical support for the Site and information systems of the Operator (e.g., hosting providers, software developers, ATS system operators like Huntflow, Talantix, etc.), based on agreements containing confidentiality and security terms.
Persons involved in candidate evaluations (e.g., professional testers, assessors, experts) provided they maintain confidentiality.
7.1.3. Government Authorities: in cases directly provided by the legislation of the Russian Federation (e.g., upon request from a court or law enforcement agencies in accordance with established procedures).
7.2. Transfer of personal data to other individuals is only permitted with the written consent of the personal data subject, except in cases established by federal law.
8.Cross-border Transfer of Personal Data8.1. Since the Operator’s activities may involve personnel recruitment for foreign companies or collaboration with foreign partners, cross-border transfer of personal data to foreign states may occur, including to countries that do not provide adequate protection for personal data subjects.
8.2. Before commencing cross-border transfer, the Operator must ensure that the foreign state to which the data is transferred ensures reliable protection of personal data subjects' rights.
9.Use of Cookies and Tracking Programs9.1. The Operator’s Site uses cookies and similar technologies (pixel tags, web beacons, scripts) to recognize users, analyze their behavior, collect traffic statistics, and customize content display.
9.2. Cookies are not used to identify a subject and contain anonymized information. By continuing to use the Site, you consent to the use of cookies according to your browser settings.
9.3. We also use third-party tracking programs (e.g., Yandex.Metrica, Google Analytics), which may collect technical data about the Site visit. This data is processed in an anonymized form.
9.4. You may block cookies at any time by changing your browser settings. However, this may limit the functionality of some sections of the Site.
10.Rights of Personal Data Subjects10.1. You as a personal data subject have the right to:
10.1.1. Obtain information regarding the processing of your personal data, including:
- Confirmation of the fact of personal data processing by the Operator;
- Legal grounds and purposes of processing;
- Methods of processing;
- Name and location of the Operator;
- Information about individuals who have access to personal data or to whom personal data may be disclosed based on an agreement with the Operator or federal law;
- List of personal data processed and the source of its collection;
- Processing terms, including data storage period;
- Information about potential legal consequences of personal data processing.
10.1.2. Request clarification (updating, changing) of your personal data if they are incomplete, outdated, or inaccurate.
10.1.3. Request the blocking or deletion of your personal data if they were unlawfully obtained or are unnecessary for the stated processing purpose, or if you have withdrawn your consent to processing.
10.1.4. Withdraw your consent to the processing of personal data at any time. Withdrawal of consent does not affect the legality of processing carried out before its withdrawal.
10.1.5. Appeal against the actions or omissions of the Operator to the authorized body for personal data protection (Roskomnadzor) or judicially.
10.2. To exercise your rights, you may send a request to the Operator in accordance with Article 14 of Law No. 152-FZ. The request must contain:
- A copy of the main identification document of the personal data subject or their representative;
- Information about the date of issuance of the document and the issuing authority;
- Information confirming your relationship with the Operator (or information otherwise confirming that personal data is being processed by the Operator);
- Signature (for written requests) or a qualified electronic signature (for electronic requests).
10.3. The request should be sent to the email address: privacy@humancode.ru (as an electronic document signed with a simple electronic signature or a qualified electronic signature).
11.Final Provisions11.1. This Policy is a public document and must be published on the Operator’s Site.
11.2. The Operator reserves the right to make changes to this Policy unilaterally. The new version of the Policy enters into force from the moment it is posted on the Site, unless otherwise provided by the new version of the Policy. The current version of the Policy is available on the Site at: https://humancode.agency/privacy-policy.
11.3. The compliance with the requirements of this Policy is monitored by the Operator (personally or through an authorized person).
11.4. Responsibility for violating the requirements of the legislation of the Russian Federation and this Policy is determined in accordance with the legislation of the Russian Federation.
11.5. All disputes arising between the personal data subject and the Operator are resolved through negotiations. If no agreement is reached, the dispute is considered in court at the location of the Operator (Individual Entrepreneur) in accordance with the legislation of the Russian Federation.
Effective Date: March 18, 2026Last Updated: March 18, 2026