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Personal Data Protection and Processing Policy


subjects of personal data

1. General provisions

1.1. This Policy regarding the processing of personal data (hereinafter referred to as the Policy) is compiled in accordance with paragraph 2 of Article 18.1 of the Federal Law "On Personal Data" No. 152-FZ dated July 27, 2006, as well as other regulatory legal acts of the Russian Federation in the field of personal data protection and processing and applies to all personal data (hereinafter referred to as data) that an Organization (hereinafter referred to as the Operator, the Company) may receive from a personal data subject who is a party to a civil contract, from an Internet user (hereinafter referred to as – The User) while using any of the sites, services, services, programs, products or services of Reputation House, as well as from a personal data subject who is in a relationship with the Operator regulated by labor legislation (hereinafter referred to as the Employee).

1.2. The Operator ensures the protection of the processed personal data from unauthorized access and disclosure, misuse or loss in accordance with the requirements of Federal Law No. 152-FZ of July 27, 2006 "On Personal Data".

1.3. The Operator has the right to make changes to this Policy. When making changes, the date of the last revision update is indicated in the Policy header. The new version of the Policy comes into force from the moment it is posted on the website, unless otherwise provided by the new version of the Policy.

2. Terms and accepted abbreviations

Personal data – any information relating directly or indirectly to a specific or identifiable individual (subject of personal data).

Personal data processing is any action (operation) or set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.

Automated processing of personal data is the processing of personal data using computer technology.

The Personal Data Information System (ISPS) is a set of personal data contained in databases and information technologies and technical means that ensure their processing.

Personal data made publicly available by the subject of personal data is personal data, access to which is granted to an unlimited number of persons by the subject of personal data or at his request.

«locking of personal data is a temporary termination of the processing of personal data (except in cases where processing is necessary to clarify personal data).

Destruction of personal data – actions as a result of which it becomes impossible to restore the content of personal data in the personal data information system and (or) as a result of which the material carriers of personal data are destroyed.

Operator is an organization that independently or jointly with other persons organizes the processing of personal data, as well as determines the purposes of processing personal data to be processed, actions (operations) performed with personal data. The operator is a limited liability Company "Reputation House", located at the address: UAE, Dubai, Business Center 1, M Floor, The Meydan Hotel, Nad Al Sheba, Dubai, U.A.E.

3. Processing of personal data

3.1. Receiving personal data.

3.1.1. The list of processed personal data includes, but is not limited to, name; patronymic; gender; date of birth; position; employer's name; location address; industry; region; mobile phone; e-mail.

3.1.2. All personal data should be obtained from the subject himself. If the subject's personal data can only be obtained from a third party, then the subject must be notified of this or consent must be obtained from him.

3.1.3. The operator must inform the subject about the purposes, intended sources and methods of obtaining personal data, the nature of the personal data to be obtained, the list of actions with personal data, the period during which the consent is valid and the procedure for its withdrawal, as well as the consequences of the subject's refusal to give written consent to receive them.

3.1.4. Documents containing personal data are created by:

- copying of original documents (passport, education document, TIN certificate, pension certificate, etc.);

- entering information into accounting forms;

- obtaining the originals of the necessary documents (work record, medical report, characteristics, etc.).

3.1.5. The right of access to the personal data of the subjects is held by persons with appropriate powers in accordance with their official duties. The list of persons with access to personal data is approved by the Operator's executive body.

3.2. Processing of personal data.

3.2.1. Processing of personal data is carried out:

- with the consent of the personal data subject to the processing of his personal data;

– in cases where the processing of personal data is necessary for the implementation and fulfillment of the functions, powers and duties assigned by the legislation of the Russian Federation;

– in cases when personal data is processed, 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 personal data made publicly available by the subject of personal data).

3.2.2. Purposes of personal data processing:

- implementation of labor relations;

- implementation of civil law relations;

– to contact the user in connection with filling out the feedback form on the website, including sending notifications, requests and information regarding the use of the Operator's website or its partners, processing, mailing announcements, registration on the Operator's website, obtaining access to information about events held by the Operator or its partners;

- depersonalization of personal data in order to obtain depersonalized statistical data that is transferred to a third party for conducting research, performing work or providing services on behalf of the Operator.

3.2.3. Categories of personal data subjects.

Personal data of the following personal data subjects are processed:

- individuals who are in labor relations with the Company;

- individuals who have resigned from the Company;

- individuals who are candidates for a job;

- individuals who are in civil law relations with the Company;

- individuals who are Users of the Operator's Website.

3.2.4. Personal data processed by the Operator:

- data obtained during the implementation of labor relations;

- data obtained for the selection of candidates for work;

- data obtained during the implementation of civil law relations;

- data received from Users of the Operator's Website.

3.2.5. Personal data processing is carried out:

– using automation tools;

- without using automation tools.

3.3. Storage of personal data.

3.3.1. Personal data of subjects can be obtained, further processed and transferred to storage both on paper and in electronic form.

3.3.2. Personal data recorded on paper media are stored in lockable cabinets or in lockable rooms with limited access rights.

3.3.3. Personal data of subjects processed using automation tools for different purposes are stored in different folders.

3.3.4. It is not allowed to store and place documents containing personal data in open electronic directories (file sharing sites) in the ISPD.

3.3.5. The storage of personal data in a form that allows to identify the subject of personal data is carried out no longer than the purposes of their processing require, and they are subject to destruction upon achievement of the processing goals or in case of loss of the need to achieve them.

3.4. Destruction of personal data.

3.4.1. The destruction of documents (carriers) containing personal data is carried out by burning, crushing (crushing), chemical decomposition, transformation into a shapeless mass or powder. For the destruction of paper documents, the use of a shredder is allowed.

3.4.2. Personal data on electronic media is destroyed by erasing or formatting the media.

3.4.3. The fact of destruction of personal data is documented by the act of destruction of media.

3.5. Transfer of personal data.

3.5.1. The Operator transfers personal data to third parties in the following cases:

- the subject has expressed his consent to such actions;

- the transfer is provided for by Russian or other applicable legislation within the framework of the procedure established by law.

3.5.2. The list of persons to whom personal data is transferred.

- Pension Fund of the Russian Federation for accounting (legally);

- tax authorities of the Russian Federation (legally);

- Social Insurance Fund of the Russian Federation (legally);

- territorial compulsory health insurance fund (legally);

- insurance medical organizations for compulsory and voluntary medical insurance (legally);

- banks for payroll (based on the contract);

- bodies of the Ministry of Internal Affairs of Russia in cases established by law;

- depersonalized personal data of Site Users is transferred to the Operator's counterparties and/or its partners.

4. Personal data protection

4.1. In accordance with the requirements of regulatory documents, the Operator has created a personal data protection system (NWPD), consisting of subsystems of legal, organizational and technical protection.

4.2. The subsystem of legal protection is a complex of legal, organizational, administrative and regulatory documents that ensure the creation, functioning and improvement of the NWPD.

4.3. The subsystem of organizational protection includes the organization of the management structure of the NWPD, the licensing system, the protection of information when working with employees, partners and third parties.

4.4. The subsystem of technical protection includes a complex of technical, software, software and hardware tools that ensure the protection of personal data.

4.4. The main personal data protection measures used by the Operator are:

4.5.1. Appointment of a person responsible for the processing of personal data, who organizes the processing of personal data, training and instruction, internal control over the compliance of the institution and its employees with the requirements for the protection of personal data.

4.5.2. Identification of current threats to the security of personal data during their processing in the ISPD and development of measures and measures to protect personal data.

4.5.3. Development of a policy regarding the processing of personal data.

4.5.4. Establishment of rules for access to personal data processed in the ISPD, as well as ensuring registration and accounting of all actions performed with personal data in the ISPD.

4.5.5. Establishment of individual passwords for employees' access to the information system in accordance with their work responsibilities.

4.5.6. The use of information security tools that have passed the compliance assessment procedure in accordance with the established procedure.

4.5.7. Certified antivirus software with regularly updated databases.

4.5.8. Compliance with the conditions that ensure the safety of personal data and exclude unauthorized access to them.

4.5.9. Detection of unauthorized access to personal data and taking measures.

4.5.10. Recovery of personal data modified or destroyed due to unauthorized access to them.

4.5.11. Training of the Operator's employees directly engaged in the processing of personal data on the provisions of the legislation of the Russian Federation on personal data, including requirements for the protection of personal data, documents defining the Operator's policy regarding the processing of personal data, local acts on the processing of personal data.

4.5.12. Implementation of internal control and audit.

5. Basic rights of the subject of personal data and obligations of the Operator

5.1. Basic rights of the subject of personal data.

The subject has the right to access his personal data and the following information:

- confirmation of the fact of personal data processing by the Operator;

- legal grounds and purposes of personal data processing;

- purposes and methods of personal data processing used by the Operator;

- the name and location of the Operator, information about persons (with the exception of the Operator's employees) who have access to personal data or to whom personal data may be disclosed on the basis of an agreement with the Operator or on the basis of federal law;

- terms of processing of personal data, including the terms of their storage;

- the procedure for the exercise by the subject of personal data of the rights provided for by Federal Law;

- the name or surname, first name, patronymic and address of the person processing personal data on behalf of the Operator, if processing is or will be entrusted to such a person;

- contacting the Operator and sending him requests;

- appeal against the actions or omissions of the Operator.

5.2. Obligations of the Operator.

The operator is obliged to:

- when collecting personal data, provide information about the processing of personal data;

– in cases where personal data was not received from the subject of personal data, notify the subject;

– in case of refusal to provide personal data to the subject, the consequences of such refusal are explained;

- to publish or otherwise provide unrestricted access to the document defining its policy regarding the processing of personal data, to information about the implemented requirements for the protection of personal data;

- take the necessary legal, organizational and technical measures or ensure their adoption to protect personal data from unauthorized or accidental access to them, destruction, modification, blocking, copying, provision, dissemination of personal data, as well as from other illegal actions with respect to personal data;

- provide answers to requests and requests of personal data subjects, their representatives and the authorized body for the protection of the rights of personal data subjects.