This Privacy Policy (the “Policy”) governs the processing of personal data of visitors to the website homzer.com (the “Website”) in accordance with Federal Law No. 152-FZ “On Personal Data” of July 27, 2006 (“Law 152-FZ”) and other laws and regulations of the Russian Federation.

By using the Website and submitting a request through its contact forms, you confirm that you have read this Policy and consent to the processing of your personal data on its terms. The terms for transferring data to partners (including cross-border transfer) and for receiving marketing communications are set out in a separate document, the Consent to Personal Data Processing.

1. Personal Data Operator

The operator of personal data is:

  • Individual Entrepreneur Anton Aleksandrovich Ivanov
  • Taxpayer ID (INN): 164492149360
  • Primary State Registration Number (OGRNIP): 316169000109745
  • Email for requests: [email protected]
  • Contact information: /contacts/

A notification of personal data processing under Part 1 of Article 22 of Law 152-FZ has been filed with Roskomnadzor (the Russian Federal Service for Supervision of Communications, Information Technology and Mass Media). The operator’s registration can be checked in the register of personal data operators by the Taxpayer ID given above.

2. Legal Grounds for Processing

  • Consent of the data subject (Clause 1, Part 1, Article 6 of Law 152-FZ), given when a form is submitted on the Website.
  • Performance of a contract to which the data subject is a party (Clause 5, Part 1, Article 6 of Law 152-FZ), once a service agreement has been concluded.
  • Compliance with the laws of the Russian Federation (Clause 2, Part 1, Article 6 of Law 152-FZ), such as tax and accounting laws.

3. Data We Collect

  • Contact details: name, phone number, email, message text — provided voluntarily when you submit a contact or consultation form.
  • Technical data: IP address, browser user agent, referring page, date and time of the visit — collected automatically.
  • Cookies and similar technologies — for the operation of the Website (strictly necessary) and for behavior analytics (see Section 9).
  • UTM tags — parameters of the advertising campaign through which you reached the Website (passed in the URL).

4. Purposes of Processing

  • Contacting you at your request: a call, a consultation, property selection, an answer to your question.
  • Forwarding your request to the Operator’s partners (including foreign partners) so that they can contact you and prepare offers for the property you are interested in — based on your consent (see the Consent and Section 6 below).
  • Sending marketing and informational communications (new properties, curated selections, promotions) — only with your separate voluntary consent, which you may withdraw at any time.
  • Improving the Website and the quality of the service (behavior analytics in anonymized form).
  • Protection against spam and automated attacks (honeypot, rate limiting).
  • Fulfilling obligations to government authorities of the Russian Federation.

5. Data Localization and Cross-Border Transfer

Under Part 5 of Article 18 of Law 152-FZ, the operator must ensure that the recording, systematization, accumulation, storage, clarification, and retrieval of personal data of citizens of the Russian Federation are carried out using databases located in the Russian Federation.

Part of the Website’s technical infrastructure is located outside the Russian Federation. The Operator is taking steps to bring the infrastructure into compliance with Part 5 of Article 18 of Law 152-FZ. Until compliance is achieved, personal data are processed only to the extent necessary to contact the requester and provide the services, using technical safeguards (TLS encryption, access control, auditing).

Cross-border transfer. Because the Website provides services related to property abroad, when you submit a request your contact details and the parameters of your request may be transferred to the Operator’s partners located outside the Russian Federation (realtors, agencies, and property sellers in the country where the property of interest is located) so that they can contact you and prepare an offer. Such transfer is carried out under Article 12 of Law 152-FZ on the basis of your consent, including to countries that do not provide adequate protection of the rights of personal data subjects (Part 4, Article 12 of Law 152-FZ); you are informed of the related risks in the Consent. Cross-border transfer takes place only after the Operator has filed the relevant notification with Roskomnadzor (Part 3, Article 12 of Law 152-FZ). No cross-border transfer is carried out for marketing purposes.

6. Categories of Recipients

Personal data are disclosed to third parties only to the extent and for the purposes set out in this Policy and the Consent, or in cases expressly provided for by the laws of the Russian Federation. Recipients may include:

  • The Operator’s partners — Russian (real estate agencies, lawyers, partner banks, listing aggregators) and foreign (real estate and development companies, real estate agencies, and property sellers in the country where the property of interest is located). Data are transferred so that they can contact you and prepare an offer in response to your request, based on your consent (see Section 5 and the Consent).
  • The operator’s employees — to process your request.
  • Hosting providers — for technical hosting and storage of data (see Section 5).
  • Telegram — for sending internal notifications about a new request to managers. Only the data you entered in the form are transmitted.
  • Government authorities of the Russian Federation — upon an official request, in the manner prescribed by law.

7. Retention Periods

Contact details are retained until you withdraw your consent or for 3 (three) years from the last interaction, whichever occurs first. Technical logs are retained for up to 90 days. Accounting records containing personal data are retained for the periods established by the tax laws of the Russian Federation.

8. Age of the Data Subject

The Website is not intended for persons under 18. The Operator does not collect or process personal data of minors. By submitting a form, you confirm that you are at least 18 years old.

9. Cookies and Analytics

The Website uses three categories of cookies:

  • Strictly necessary — ensure the operation of the Website (sessions, CSRF protection, remembering your cookie choices). They cannot be disabled without loss of functionality.
  • Analytics — traffic and behavior counters. The Website uses Yandex.Metrica, including the Webvisor technology, which records a visitor’s actions on the page (clicks, scrolling, cursor movement) to analyze the usability of the Website. The data are processed by YANDEX LLC as a processor; input into form fields containing personal data is masked in Webvisor recordings.
  • Marketing — advertising network pixels for retargeting. None are in use as of this edition.

On your first visit, the cookie banner lets you accept or decline optional cookies. You may change your choice at any time by clearing your browser cookies or through the “Cookie settings” link in the Website footer (where available).

10. Your Rights

  • Obtain confirmation that the operator processes your personal data.
  • Request a copy of your personal data.
  • Request correction or deletion of data that are incomplete, outdated, or unlawfully obtained.
  • Withdraw your consent to the processing of personal data.
  • Appeal the operator’s actions to Roskomnadzor or in court.

To exercise your rights, send a request to [email protected] with the subject line “Request under Law 152-FZ”. We will respond within 10 business days.

Users outside the Russian Federation

Wherever you live, you may ask the Operator to:

  • give you access to the personal data the Operator holds about you;
  • correct inaccurate or incomplete personal data;
  • delete your personal data;
  • stop processing your personal data on the basis of your consent by withdrawing that consent;
  • stop processing your personal data for a particular purpose, including sending marketing communications, if you object to it.

Send your request to [email protected]. We will respond within 10 business days. Where the law requires the Operator to keep certain data (see Section 7), those data are retained for the period required by law.

11. Security Measures

The Operator applies legal, organizational, and technical measures to protect personal data in accordance with Articles 18.1 and 19 of Law 152-FZ, including:

  • encryption of the data transmission channel (HTTPS / TLS);
  • role-based access control for employees (the admin role in the CMS);
  • protection of forms against automated submission (honeypot, rate limiting);
  • masking of data in logs (phone numbers and emails are masked);
  • regular updates of infrastructure and software.

12. Changes to This Policy

We may update this Policy. The current version is always available at /privacy/. The version of the document is shown at the top of the page. The operator will announce material changes on the Website.

13. Contact for Questions

Questions about the processing of personal data: [email protected].