Privacy Policy
IP Pominenko, TIN 540590007083, OGRN 310547628700262, 630017, Novosibirsk, ul. The territory of the Military Town, military unit 22316, apt. total
COMPANY POLICY REGARDING PERSONAL DATA PROCESSING
CONTENT
1. General Provisions
2. Principles and conditions for the processing of personal data
2.1 Principles of processing personal data
2.2 Terms of processing personal data
2.3 Confidentiality of personal data
2.4 Public Sources of Personal Data
2.5 Special categories of personal data
2.6 Biometric personal data
2.7 Instruction for processing personal data to another person
2.8 Cross-border transfer of personal data
3. Rights of the subject of personal data
3.1 Consent of the subject of personal data to the processing of his personal data
3.2 Rights of the subject of personal data
4. Ensuring the security of personal data
5. Final Provisions
1. GENERAL PROVISIONS
The policy for the processing of personal data (hereinafter - the Policy) is developed in accordance with the Federal Law of 07.27.2006. No152-FO "On personal data" (hereinafter - FO-152).
This Policy defines the procedure for processing personal data and measures to ensure the security of personal data in FE Pominenko TIN 540590007083, OGRN 310547628700262 (hereinafter referred to as the Operator) in order to protect the rights and freedoms of man and citizen when processing his personal data, including the protection of rights to privacy, personal and family secrets.
The following basic concepts are used in the Policy:
• Automated processing of personal data - processing of personal data using computer technology;
• Blocking of personal data - temporary suspension of the processing of personal data (unless the processing is necessary to clarify personal data);
• Information system of personal data - a set of personal data contained in databases, and ensuring their processing of information technologies and technical means;
• Depersonalization of personal data - actions, as a result of which it is impossible to determine without the use of additional information the belonging of personal data to a specific subject of personal data;
• Personal data processing - any action (operation) or a set of actions (operations) performed using automation tools or without using such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data;
• Operator - a state body, municipal body, legal or natural person, independently or jointly with other persons, organizing and (or) processing personal data, as well as determining the purposes of processing personal data, the composition of personal data to be processed, actions (operations) performed with personal data;
• Personal data - any information relating to a directly or indirectly determined or determined individual (subject of personal data);
• Provision of personal data - actions aimed at the disclosure of personal data to a specific person or a certain circle of persons;
• Distribution of personal data - actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or familiarizing with personal data of an unlimited number of persons, including disclosing personal data in the media, posting on information and telecommunication networks or providing access to personal data in any other way;
• Cross-border transfer of personal data - the transfer of personal data to the territory of a foreign state to a foreign state authority, a foreign individual or foreign legal entity.
destruction of personal data - actions, as a result of which it is impossible to restore the content of personal data in the personal data information system and (or) as a result of which material carriers of personal data are destroyed;
• The company is obliged to publish or otherwise provide unlimited access to this Policy for the processing of personal data in accordance with Part 2 of Art. 18.1. FZ-152.
2. PRINCIPLES AND TERMS OF PROCESSING PERSONAL DATA
2.1 Principles of processing personal data
•. The processing of personal data by the Operator is based on the following principles:
legality and fair basis;
• restrictions on the processing of personal data by achieving specific, predetermined and legitimate goals;
• preventing personal data processing incompatible with the purposes of collecting personal data;
• preventing the unification of databases containing personal data, the processing of which is carried out for purposes incompatible with each other;
• processing only those personal data that meet the purposes of their processing;
• compliance of the content and volume of processed personal data with the stated processing goals;
• preventing the processing of personal data excessive in relation to the stated purposes of their processing;
• ensuring the accuracy, sufficiency and relevance of personal data in relation to the purposes of processing personal data;
• destruction or depersonalization of personal data upon achievement of the purposes of their processing or in case of loss of necessity to achieve these goals, if it is impossible to eliminate the committed violations of personal data by the Operator, unless otherwise provided by federal law.
2.2 Terms of processing personal data
The operator processes personal data in the presence of at least one of the following conditions:
• Processing of personal data is carried out with the consent of the subject of personal data to the processing of his personal data;
• the processing of personal data is necessary to achieve the goals stipulated by the international treaty of the Russian Federation or the law, to carry out and fulfill the functions, powers and duties assigned to the operator by the legislation of the Russian Federation;
• processing of personal data is necessary for the administration of justice, the execution of a judicial act, an act of another body or official, subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings;
• the processing of personal data is necessary for the execution of a contract to which either the beneficiary or guarantor is the subject of personal data, as well as for the conclusion of a contract on the initiative of the personal data subject or contract under which the personal data subject will be the beneficiary or guarantor;
• processing of personal data is necessary to exercise the rights and legitimate interests of the operator or third parties or to achieve socially significant goals, provided that this does not violate the rights and freedoms of the subject of personal data;
• processing of personal data is carried out, access to an unlimited number of persons to which is provided by the subject of personal data or at his request (hereinafter referred to as publicly available personal data);
• the processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.
2.3 Confidentiality of personal data
The operator and other persons who have gained access to personal data are required not to disclose to third parties and not to distribute personal data without the consent of the subject of personal data, unless otherwise provided by federal law.
2.4 Public Sources of Personal Data
For the purposes of information support, the Operator may create publicly accessible sources of personal data of entities, including directories and address books. With the written consent of the subject, public sources of personal data may include his last name, first name, middle name, date and place of birth, position, contact phone numbers, email address and other personal data communicated by the subject of personal data.
Information about the subject should be excluded from public sources of personal data at any time at the request of the subject or by decision of the court or other authorized state bodies.
2.5 Special categories of personal data
Processing by the Operator of special categories of personal data relating to race, nationality, political views, religious or philosophical beliefs, state of health, intimate life is allowed in cases if:
• The personal data subject has given written consent to the processing of his personal data;
• Personal data is made publicly available by the subject of personal data;
• Processing of personal data is carried out in accordance with the legislation on state social assistance, labor legislation, the legislation of the Russian Federation on pensions for state pensions, and labor pensions;
• Processing of personal data is necessary to protect the life, health or other vital interests of the subject of personal data or the life, health or other vital interests of others, and obtaining the consent of the subject of personal data is impossible;
• Processing of personal data is carried out for medical and preventive purposes, in order to establish a medical diagnosis, provide medical and medical social services, provided that the processing of personal data is carried out by a person who is professionally engaged in medical activities and is obliged to keep medical confidentiality in accordance with the legislation of the Russian Federation;
• Processing of personal data is necessary to establish or exercise the rights of the subject of personal data or third parties, as well as in connection with the administration of justice;
Processing of personal data is carried out in accordance with the legislation on compulsory types of insurance, with insurance legislation. Processing of special categories of personal data should be immediately stopped if the reasons that led to their processing have been eliminated, unless otherwise provided by federal law.
Processing of personal criminal record data may be carried out. The operator only in cases and in the manner that are determined in accordance with federal laws.
2.6 Biometric personal data
Information that characterizes the physiological and biological characteristics of a person, on the basis of which it is possible to establish his personality - biometric personal data - can be processed by the Operator only with the written consent of the subject.
2.7 Instruction for processing personal data to another person
The operator has the right to entrust the processing of personal data to another person with the consent of the subject of personal data, unless otherwise provided by federal law, on the basis of an agreement concluded with this person. A person who processes personal data on behalf of the Operator is required to comply with the principles and rules for the processing of personal data provided for in Federal Law-152.
2.8 Cross-border transfer of personal data
The operator must make sure that the foreign state into whose territory it is supposed to transfer personal data provides adequate protection of the rights of the subjects of personal data before such a transfer begins.
Cross-border transfer of personal data on the territory of foreign states that do not provide adequate protection of the rights of subjects of personal data may be carried out in the following cases:
• Еhe written consent of the personal data subject to the cross-border transfer of his personal data;
• Execution of the contract to which the subject of personal data is a party.
3. RIGHTS OF A SUBJECT OF PERSONAL DATA
3.1 Consent of the subject of personal data to the processing of his personal data
The personal data subject makes a decision on the provision of his personal data and agrees to its processing freely, by his will and in his interest. Consent to the processing of personal data may be given by the subject of personal data or his representative in any form allowing confirming the fact of its receipt, unless otherwise provided by federal law.
The obligation to provide evidence of the consent of the subject of personal data to the processing of his personal data or proof of the existence of the grounds specified in FZ-152 rests with the Operator.
3.2 Rights of the subject of personal data
The personal data subject has the right to receive information from the Operator regarding the processing of his personal data, if such a right is not limited in accordance with federal laws. The personal data subject has the right to require the Operator to clarify his personal data, block it or destroy it if the personal data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated processing purpose, and also take measures prescribed by law to protect their rights .
The processing of personal data in order to promote goods, works, services on the market through direct contacts with a potential consumer using communication means, as well as for political campaigning, is allowed only with the prior consent of the subject of personal data. The specified processing of personal data is recognized as being carried out without the prior consent of the subject of personal data, unless the Company proves that such consent was obtained.
The operator is obliged to immediately stop at the request of the personal data subject the processing of his personal data for the above purposes.
It is forbidden to make decisions on the basis of exclusively automated processing of personal data that give rise to legal consequences in relation to the subject of personal data or otherwise affect his rights and legitimate interests, with the exception of cases provided for by federal laws, or if there is written consent of the subject of personal data.
If the subject of personal data considers that the Operator is processing his personal data in violation of the requirements of Federal Law-152 or otherwise violates his rights and freedoms, the subject of personal data has the right to appeal the actions or omissions of the Operator to the authorized body for the protection of the rights of subjects of personal data or in court .
The personal data subject has the right to protect his rights and legitimate interests, including compensation for losses and (or) compensation for non-pecuniary damage in court.
4. SECURITY OF PERSONAL DATA
The security of personal data processed by the Operator is ensured by the implementation of legal, organizational and technical measures necessary to ensure the requirements of federal legislation in the field of personal data protection.
To prevent unauthorized access to personal data by the Operator, the following organizational and technical measures are applied:
• Appointment of officials responsible for organizing the processing and protection of personal data;
• Limiting the composition of persons having access to personal data
• Introducing subjects to the requirements of federal law and regulatory documents of the Operator for the processing and protection of personal data;
• Organization of accounting, storage and circulation of information carriers;
• Detection of threats to the security of personal data during their processing, the formation of threat models on their basis;
• Development of a personal data protection system based on the threat model;
• Checking the readiness and effectiveness of the use of information security tools;
• Distribution of user access to information resources and software and hardware for information processing;
• Registration and accounting of the actions of users of personal data information systems;
• Use of anti-virus and recovery tools for personal data protection systems;
• Use of firewalls, intrusion detection, security analysis and cryptographic information protection tools, if necessary;
• Organization of access control to the Operator's territory, security of premises with technical means for processing personal data.
5. FINAL PROVISIONS
Other rights and obligations of the Operator as the operator of personal data are determined by the legislation of the Russian Federation in the field of personal data.
Operator officials guilty of violating the rules governing the processing and protection of personal data bear material, disciplinary, administrative, civil or criminal liability in the manner prescribed by federal laws.
COMPANY POLICY REGARDING PERSONAL DATA PROCESSING
CONTENT
1. General Provisions
2. Principles and conditions for the processing of personal data
2.1 Principles of processing personal data
2.2 Terms of processing personal data
2.3 Confidentiality of personal data
2.4 Public Sources of Personal Data
2.5 Special categories of personal data
2.6 Biometric personal data
2.7 Instruction for processing personal data to another person
2.8 Cross-border transfer of personal data
3. Rights of the subject of personal data
3.1 Consent of the subject of personal data to the processing of his personal data
3.2 Rights of the subject of personal data
4. Ensuring the security of personal data
5. Final Provisions
1. GENERAL PROVISIONS
The policy for the processing of personal data (hereinafter - the Policy) is developed in accordance with the Federal Law of 07.27.2006. No152-FO "On personal data" (hereinafter - FO-152).
This Policy defines the procedure for processing personal data and measures to ensure the security of personal data in FE Pominenko TIN 540590007083, OGRN 310547628700262 (hereinafter referred to as the Operator) in order to protect the rights and freedoms of man and citizen when processing his personal data, including the protection of rights to privacy, personal and family secrets.
The following basic concepts are used in the Policy:
• Automated processing of personal data - processing of personal data using computer technology;
• Blocking of personal data - temporary suspension of the processing of personal data (unless the processing is necessary to clarify personal data);
• Information system of personal data - a set of personal data contained in databases, and ensuring their processing of information technologies and technical means;
• Depersonalization of personal data - actions, as a result of which it is impossible to determine without the use of additional information the belonging of personal data to a specific subject of personal data;
• Personal data processing - any action (operation) or a set of actions (operations) performed using automation tools or without using such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data;
• Operator - a state body, municipal body, legal or natural person, independently or jointly with other persons, organizing and (or) processing personal data, as well as determining the purposes of processing personal data, the composition of personal data to be processed, actions (operations) performed with personal data;
• Personal data - any information relating to a directly or indirectly determined or determined individual (subject of personal data);
• Provision of personal data - actions aimed at the disclosure of personal data to a specific person or a certain circle of persons;
• Distribution of personal data - actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or familiarizing with personal data of an unlimited number of persons, including disclosing personal data in the media, posting on information and telecommunication networks or providing access to personal data in any other way;
• Cross-border transfer of personal data - the transfer of personal data to the territory of a foreign state to a foreign state authority, a foreign individual or foreign legal entity.
destruction of personal data - actions, as a result of which it is impossible to restore the content of personal data in the personal data information system and (or) as a result of which material carriers of personal data are destroyed;
• The company is obliged to publish or otherwise provide unlimited access to this Policy for the processing of personal data in accordance with Part 2 of Art. 18.1. FZ-152.
2. PRINCIPLES AND TERMS OF PROCESSING PERSONAL DATA
2.1 Principles of processing personal data
•. The processing of personal data by the Operator is based on the following principles:
legality and fair basis;
• restrictions on the processing of personal data by achieving specific, predetermined and legitimate goals;
• preventing personal data processing incompatible with the purposes of collecting personal data;
• preventing the unification of databases containing personal data, the processing of which is carried out for purposes incompatible with each other;
• processing only those personal data that meet the purposes of their processing;
• compliance of the content and volume of processed personal data with the stated processing goals;
• preventing the processing of personal data excessive in relation to the stated purposes of their processing;
• ensuring the accuracy, sufficiency and relevance of personal data in relation to the purposes of processing personal data;
• destruction or depersonalization of personal data upon achievement of the purposes of their processing or in case of loss of necessity to achieve these goals, if it is impossible to eliminate the committed violations of personal data by the Operator, unless otherwise provided by federal law.
2.2 Terms of processing personal data
The operator processes personal data in the presence of at least one of the following conditions:
• Processing of personal data is carried out with the consent of the subject of personal data to the processing of his personal data;
• the processing of personal data is necessary to achieve the goals stipulated by the international treaty of the Russian Federation or the law, to carry out and fulfill the functions, powers and duties assigned to the operator by the legislation of the Russian Federation;
• processing of personal data is necessary for the administration of justice, the execution of a judicial act, an act of another body or official, subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings;
• the processing of personal data is necessary for the execution of a contract to which either the beneficiary or guarantor is the subject of personal data, as well as for the conclusion of a contract on the initiative of the personal data subject or contract under which the personal data subject will be the beneficiary or guarantor;
• processing of personal data is necessary to exercise the rights and legitimate interests of the operator or third parties or to achieve socially significant goals, provided that this does not violate the rights and freedoms of the subject of personal data;
• processing of personal data is carried out, access to an unlimited number of persons to which is provided by the subject of personal data or at his request (hereinafter referred to as publicly available personal data);
• the processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.
2.3 Confidentiality of personal data
The operator and other persons who have gained access to personal data are required not to disclose to third parties and not to distribute personal data without the consent of the subject of personal data, unless otherwise provided by federal law.
2.4 Public Sources of Personal Data
For the purposes of information support, the Operator may create publicly accessible sources of personal data of entities, including directories and address books. With the written consent of the subject, public sources of personal data may include his last name, first name, middle name, date and place of birth, position, contact phone numbers, email address and other personal data communicated by the subject of personal data.
Information about the subject should be excluded from public sources of personal data at any time at the request of the subject or by decision of the court or other authorized state bodies.
2.5 Special categories of personal data
Processing by the Operator of special categories of personal data relating to race, nationality, political views, religious or philosophical beliefs, state of health, intimate life is allowed in cases if:
• The personal data subject has given written consent to the processing of his personal data;
• Personal data is made publicly available by the subject of personal data;
• Processing of personal data is carried out in accordance with the legislation on state social assistance, labor legislation, the legislation of the Russian Federation on pensions for state pensions, and labor pensions;
• Processing of personal data is necessary to protect the life, health or other vital interests of the subject of personal data or the life, health or other vital interests of others, and obtaining the consent of the subject of personal data is impossible;
• Processing of personal data is carried out for medical and preventive purposes, in order to establish a medical diagnosis, provide medical and medical social services, provided that the processing of personal data is carried out by a person who is professionally engaged in medical activities and is obliged to keep medical confidentiality in accordance with the legislation of the Russian Federation;
• Processing of personal data is necessary to establish or exercise the rights of the subject of personal data or third parties, as well as in connection with the administration of justice;
Processing of personal data is carried out in accordance with the legislation on compulsory types of insurance, with insurance legislation. Processing of special categories of personal data should be immediately stopped if the reasons that led to their processing have been eliminated, unless otherwise provided by federal law.
Processing of personal criminal record data may be carried out. The operator only in cases and in the manner that are determined in accordance with federal laws.
2.6 Biometric personal data
Information that characterizes the physiological and biological characteristics of a person, on the basis of which it is possible to establish his personality - biometric personal data - can be processed by the Operator only with the written consent of the subject.
2.7 Instruction for processing personal data to another person
The operator has the right to entrust the processing of personal data to another person with the consent of the subject of personal data, unless otherwise provided by federal law, on the basis of an agreement concluded with this person. A person who processes personal data on behalf of the Operator is required to comply with the principles and rules for the processing of personal data provided for in Federal Law-152.
2.8 Cross-border transfer of personal data
The operator must make sure that the foreign state into whose territory it is supposed to transfer personal data provides adequate protection of the rights of the subjects of personal data before such a transfer begins.
Cross-border transfer of personal data on the territory of foreign states that do not provide adequate protection of the rights of subjects of personal data may be carried out in the following cases:
• Еhe written consent of the personal data subject to the cross-border transfer of his personal data;
• Execution of the contract to which the subject of personal data is a party.
3. RIGHTS OF A SUBJECT OF PERSONAL DATA
3.1 Consent of the subject of personal data to the processing of his personal data
The personal data subject makes a decision on the provision of his personal data and agrees to its processing freely, by his will and in his interest. Consent to the processing of personal data may be given by the subject of personal data or his representative in any form allowing confirming the fact of its receipt, unless otherwise provided by federal law.
The obligation to provide evidence of the consent of the subject of personal data to the processing of his personal data or proof of the existence of the grounds specified in FZ-152 rests with the Operator.
3.2 Rights of the subject of personal data
The personal data subject has the right to receive information from the Operator regarding the processing of his personal data, if such a right is not limited in accordance with federal laws. The personal data subject has the right to require the Operator to clarify his personal data, block it or destroy it if the personal data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated processing purpose, and also take measures prescribed by law to protect their rights .
The processing of personal data in order to promote goods, works, services on the market through direct contacts with a potential consumer using communication means, as well as for political campaigning, is allowed only with the prior consent of the subject of personal data. The specified processing of personal data is recognized as being carried out without the prior consent of the subject of personal data, unless the Company proves that such consent was obtained.
The operator is obliged to immediately stop at the request of the personal data subject the processing of his personal data for the above purposes.
It is forbidden to make decisions on the basis of exclusively automated processing of personal data that give rise to legal consequences in relation to the subject of personal data or otherwise affect his rights and legitimate interests, with the exception of cases provided for by federal laws, or if there is written consent of the subject of personal data.
If the subject of personal data considers that the Operator is processing his personal data in violation of the requirements of Federal Law-152 or otherwise violates his rights and freedoms, the subject of personal data has the right to appeal the actions or omissions of the Operator to the authorized body for the protection of the rights of subjects of personal data or in court .
The personal data subject has the right to protect his rights and legitimate interests, including compensation for losses and (or) compensation for non-pecuniary damage in court.
4. SECURITY OF PERSONAL DATA
The security of personal data processed by the Operator is ensured by the implementation of legal, organizational and technical measures necessary to ensure the requirements of federal legislation in the field of personal data protection.
To prevent unauthorized access to personal data by the Operator, the following organizational and technical measures are applied:
• Appointment of officials responsible for organizing the processing and protection of personal data;
• Limiting the composition of persons having access to personal data
• Introducing subjects to the requirements of federal law and regulatory documents of the Operator for the processing and protection of personal data;
• Organization of accounting, storage and circulation of information carriers;
• Detection of threats to the security of personal data during their processing, the formation of threat models on their basis;
• Development of a personal data protection system based on the threat model;
• Checking the readiness and effectiveness of the use of information security tools;
• Distribution of user access to information resources and software and hardware for information processing;
• Registration and accounting of the actions of users of personal data information systems;
• Use of anti-virus and recovery tools for personal data protection systems;
• Use of firewalls, intrusion detection, security analysis and cryptographic information protection tools, if necessary;
• Organization of access control to the Operator's territory, security of premises with technical means for processing personal data.
5. FINAL PROVISIONS
Other rights and obligations of the Operator as the operator of personal data are determined by the legislation of the Russian Federation in the field of personal data.
Operator officials guilty of violating the rules governing the processing and protection of personal data bear material, disciplinary, administrative, civil or criminal liability in the manner prescribed by federal laws.
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