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Personal data processing policy of the Sole Proprietor Rak I.G.

1. General provisions

1.1. Personal Data Processing Policy of the Sole Proprietorship Rak I.G. (hereinafter referred to as “Policy”) stipulates the basic principles, objectives, conditions and methods for personal data processing, lists of data subjects and personal data processed in Sole Proprietorship Rak I.G. (hereinafter referred to as “SP Rak I.G.”), it’s functions while processing personal data, rights of data subjects, as well as requirements to the personal data protection established in the Sole Proprietorship Rak I.G.

1.2. The Policy is developed based on the requirements of the Constitution of the Russian Federation, legislative and other statutory acts of the Russian Federation related to personal data.

1.3. The Policy provisions serve as the basis for developing corporate statutory acts, which stipulate processing personal data of SP Rak I.G.’s employees and other data subjects.

 

2. Legislative and other statutory acts of Russian Federation stipulating Personal Data Processing Policy of the SP Rak I.G.

2.1. SP Rak I.G.’s Personal Data Processing Policy is based on the following statutory acts:

2.2. In order to implement the Policy provisions, SP Rak I.G. develops relevant corporate statutory acts and other documents, including:

In addition to the above-mentioned acts the following documents can be the legal basis for personal data processing:

 

3. Basic terms and definitions used in corporate statutory acts of SP Rak I.G related to personal data processing.

Personal data – any information related to directly or indirectly specified natural person (data subject).

Information – details (reports, data) regardless their presentation form.

Operator – state authority, municipal authority, legal or private person, who autonomously or jointly arranges and/or performs personal data processing, as well as defines the aims of personal data processing, the volume of personal data subject to processing and the actions on personal data.

Personal data processing – any action or a series of actions performed towards personal data with or without the software, including the personal data acquisition, recording, systematization, accumulation, storage, update and alteration, extraction, use, transfer (distribution, presentation, providing access), depersonalization, blocking, deleting and annihilation.

Automated personal data processing – personal data processing via PC software.

Personal data presentation – personal data disclosure to particular person or certain group of persons.

Personal data distribution – actions aimed to personal data disclosure to uncertain group of persons.

Trans-border personal data transfer – personal data transfer to the territory of any foreign country to the foreign state authority and foreign natural or legal person.

Personal data blocking – temporary interruption of personal data processing (unless the processing is required for personal data update or alteration).

Personal data annihilation – actions that make it impossible to restore personal data substance in the data information system and/or resulting in the elimination of tangible personal data carriers.

Personal data depersonalization – actions that make it impossible to identify personal data as related to a certain data subject without using an additional information.

Personal data information system – a set of personal data contained in the personal data databases, as well as the software and tools used for their processing.

4. Principles and purposes for personal data processing.

4.1. SP Rak I.G. as a personal data operator performs personal data processing for the employees of SP Rak I.G. and other personal data subjects not employed by SP Rak I.G.

4.2. SP Rak I.G. performs data processing with due regard for the protection of rights and freedoms of SP Rak I.G. employees as well as other data subjects, including the protection of privacy right, personal and family secrets, based on the following principles:

4.3. SP Rak I.G. processes personal data for the purpose of:

 

5. List of subjects, which have their personal data processed at SP Rak I.G.

5.1. SP Rak I.G. provides personal data processing of the following data subjects:

 

6. List of personal data processed at SP Rak I.G.

6.1. The list of personal data processed by SP Rak I.G. is stipulated by the Law of the Russian Federation and corporate statutory acts considering the personal data processing purposes stated in Section 4 of the Policy.

6.2. Special personal data categories concerning race and national identity, political commitment, religious or philosophic views and private life are not subject to processing at SP Rak I.G.

 

7. Functions of SP Rak I.G. in personal data processing

7.1. While processing personal data, SP Rak I.G.:

 

8. Conditions of personal data processing at SP Rak I.G.

8.1. Personal data is processed at SP Rak I.G. with consent of a data subject to have his/her personal data processed, unless otherwise is provided by the Law of the Russian Federation related to personal data.

8.2. SP Rak I.G. shall not disclose or distribute personal data to third parties without consent of the data subject, unless otherwise is provided by the Law of the Russian Federation.

8.3. SP Rak I.G. is entitled to entrust personal data processing to a third party with the data subject consent and upon an agreement with such a third party. An agreement shall include the list of personal data operations to be accomplished by a person in charge for the data processing, processing purposes, liabilities of such a person to keep personal data confidential and protected in course of processing, as well as requirements to the processed personal data protection as per Article 19 of the Federal Act On Personal Data.

8.4. For the purpose of in-house data support SP Rak I.G. is entitled to develop corporate reference documents, which include the subject name, family name, occupation, position, date of birth, address, subscriber number, e-mail address, other personal data associated with (SP Rak I.G. employee)personal data subject.

8.5. Access to personal data processed in is only allowed to SP Rak I.G.’s employees covered by the list of positions for structural units of SP Rak I.G., substitution of which is subject to personal data processing.

 

9. Actions with personal data and ways of its processing

9.1. SP Rak I.G. provides for acquisition, logging, ranging, accumulation, storage, update and alteration, extraction, usage, depersonalization, blocking, deletion and annihilation of personal data.

9.2. Personal data processing in SP Rak I.G. is provided in the following ways:

 

10.   Rights of personal data subjects

10.1. Data subjects are entitled for:

 

11. Actions taken by SP Rak I.G. to ensure proper personal data processing.

Actions, essential and sufficient to ensure proper personal data processing by SP Rak I.G. in accordance with the Law of the Russian Federation related to personal data, are as following:

 

12. Control over compliance with Law of Russian Federation and SP Rak I.G.’s corporate statutory acts related to personal data, including personal data protection requirements

12.1. Control over the adherence of structural units of SP Rak I.G. to the Law of the Russian Federation and corporate statutory acts of SP Rak I.G. related to personal data, including the personal data protection requirements, is aimed at ensuring the compliance of personal data processing by structural units of SP Rak I.G.’s administration, its branches and representative offices to the Law of the Russian Federation and corporate statutory acts of SP Rak I.G. related to personal data, including the personal data protection requirements, as well as to measures aimed at prevention and identification of infringements of the Law of the Russian Federation related to personal data, identification of potential channels for the leakage of and the unauthorized access to personal data and the removal of consequences of such infringements.

12.2. In-house control over the adherence of structural units of SP Rak I.G.’s administration, its branches and representative offices to the Law of the Russian Federation and corporate statutory acts of SP Rak I.G. related to personal data, including the personal data protection requirements, is exeсuted by a person in charge for the arrangement of personal data processing in SP Rak I.G.

12.3. In-house control over the compliance of personal data processing to the Federal Law ‘On Personal Data’ and relevant statutory acts, the personal data protection requirements, the Policy and SP Rak I.G.’s corporate statutory acts is exercised by the legal consultant of SP Rak I.G.

12.4. Personal liability for the adherence of a structural unit of SP Rak I.G.’s administration to the Law of the Russian Federation and corporate statutory acts of SP Rak I.G. related to personal data, as well as for ensuring the personal data confidentiality and safety within the mentioned divisions of SP Rak I.G. is imposed upon their executives.

 

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