The policy for the processing of personal data (hereinafter - the Policy) is developed in accordance with the Federal Law of 07.27.2006. No. 152-FZ “On Personal Data” (hereinafter - FZ-152).

This Policy defines the procedure for processing personal data and measures to ensure the security of personal data in RusTehnology Limited Liability Company, located at 299008, Sevastopol, Mechnikov St., house No. 5, room 2A and on the domain name http://rs-tech.ru/ (hereinafter referred to as the Operator) in order to protect the rights and freedoms of man and citizen during the processing of his personal data, including protecting the rights to privacy, personal and family secrets.

The following basic concepts are used in the Policy:

Automated processing of personal data – processing personal data using computer technology;

Personal data blocking - temporary termination of the processing of personal data (unless the processing is necessary to clarify personal data);

Personal Data Information System - the totality of the personal data contained in the databases and the information technologies and technical means that ensure their processing;

Anonymization of personal data - actions as a result of which it is impossible to determine without the use of additional information the ownership of personal data to a specific subject of personal data;

Personal data processing - any action (operation) or 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), extraction, use, transfer ( distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data;

Operator - 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 related to a directly or indirectly determined or determined individual (subject of personal data);

Personal data providing – actions aimed at disclosing personal data to a specific person or a certain circle of persons;

Personal data dissemination - actions aimed at the disclosure of personal data to an indefinite number of persons (transfer of personal data) or to familiarization with personal data of an unlimited number of persons, including the publication of personal data in the media, posting on information and telecommunication networks or providing access to personal data as in any other way;

Cross-border transfer of personal data - transfer of personal data to the territory of a foreign state to the authority of a foreign state, to 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. FZ152.

2.1. Principles for the processing of 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 declared processing goals;
• preventing the processing of personal data excessive in relation to the stated purposes of their processing;
• ensure 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 need 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. Personal data processing conditions

The operator processes personal data in the presence of at least one of the following conditions:

• personal data processing is carried out with the consent of the personal data subject 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 obligations assigned to the operator by the legislation of the Russian Federation;
• the processing of personal data is necessary for the administration of justice, the execution of a judicial act, an act of another body or official to be executed in accordance with the legislation of the Russian Federation on enforcement proceedings;
• the processing of personal data is necessary for the execution of an agreement to which either the beneficiary or guarantor is a party under which the personal data subject is, as well as for the conclusion of an agreement on the initiative of the personal data subject or an agreement 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;
• there is a processing of personal data, 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);
• processing of personal data subject to publication or mandatory disclosure in accordance with federal law.

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

In order to provide information support, the Operator may create publicly accessible sources of personal data of personal data subjects, including directories and address books. Public sources of personal data with the written consent of the subject 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 of personal data should be excluded from public sources of personal data at any time at the request of the subject of personal data, the authorized body for the protection of the rights of subjects of personal data or by decision of the court. Only with the consent of the subject of personal data in writing.

2.5. Instruction for the processing of 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 and this Policy.

2.6. Processing of personal data of citizens of the Russian Federation

In accordance with Article 2 of the Federal Law of July 21, 2014 N 242-ФЗ “On Amending Certain Legislative Acts of the Russian Federation in Part of Specifying the Procedure for Processing Personal Data in Information and Telecommunication Networks” when collecting personal data, including through information and telecommunication network "Internet", the operator is obliged to record, systematize, accumulate, store, clarify (update, change), extract personal data of citizens of the Russian Federation using databases located on the territory of the Russian Federation, with the exception of cases:

• 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 obligations assigned to the operator by the legislation of the Russian Federation;
• the processing of personal data is necessary for the administration of justice, the execution of a judicial act, an act of another body or official to be executed in accordance with the legislation of the Russian Federation on enforcement proceedings (hereinafter - the execution of a judicial act);
• the processing of personal data is necessary to fulfill the powers of federal executive bodies, bodies of state extra-budgetary funds, executive bodies of state power of the constituent entities of the Russian Federation, local governments and the functions of organizations involved in the provision of state and municipal services, respectively, provided for by the Federal Law of July 27, 2010 N 210-ФЗ “On the organization of the provision of state and municipal services”, including registration of a personal data subject on a single portal of state and municipal services and (or) regional portals of state and municipal services;
• the processing of personal data is necessary for the professional activities of a journalist and (or) the legitimate activities of the media or scientific, literary or other creative activities, provided that this does not violate the rights and legitimate interests of the subject of personal data.

2.7. 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.

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 cases:

• the written consent of the personal data subject to the cross-border transfer of his personal data;
• execution of a contract to which the data subject is a party.

3.1. Consent of the personal data subject to the processing of his personal data

The personal data subject decides to provide his personal data and agrees to its processing freely, by his own 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.

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 not necessary for the stated processing purpose, as well as 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 the subject of personal data (potential consumers) by means of communication, as well as for political campaigning, is allowed only with the prior consent of the subject of personal data.

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 personal data subject 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 personal data subject is entitled to appeal the actions or omissions of the Operator to the Authorized body for the protection of the rights of personal data subjects 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 moral damage.

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;
• restriction of the composition of persons allowed to process personal data;
• familiarization of subjects with 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 media containing information with personal data;
• identification 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;
• verification of the readiness and effectiveness of the use of information security tools;
• differentiation of user access to information resources and software and hardware information processing;
• registration and accounting of actions of users of personal data information systems;

Other rights and obligations of the Operator in connection with the processing of personal data are determined by the legislation of the Russian Federation in the field of personal data.

Operator employees 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.