Personal Data Processing Policy

1. GENERAL

1.1. This Personal Data Processing Policy (hereinafter - the Policy) is established by Tekhnologii Ideala, Center for Research Psychology, a limited liability company (OOO TsNP Tekhnologii Ideala), PSRN 1175476058801, to ensure compliance with the requirements of the current legislation of the Russian Federation.

Terms and Definitions

1.2. Personal data owned by data subjects is processed by OOO TsNP Tekhnologii Idela (Tekhnologii Ideala, Center for Research Psychology, a limited liability company) with legal address at: Suite 41, 16 Gogolya Str., Novosibirsk, Russia, 630005, TIN 5406976032, PSRN 1175476058801, registered in accordance with the current legislation of the Russian Federation.

- Personal Data Subject — a person identified through personal data.

- Personal Data — any information directly or indirectly related to a defined/identified person.

- Personal Data Processing — automated or non-automated operations with personal data performed by OOO TsNP Tekhnologii Ideala, including collection, recording, systematization, accumulation, storage, verification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.

- Automated Personal Data Processing — processing of personal data with computers.

- Personal Data Information System — a database owned by OOO TsNP Tekhnologii Ideala containing personal data, as well as information technology and equipment that allow personal data processing with or without the use of automation tools.

- Protection of Personal Data — a set of organizational and technical operations performed by OOO TsNP Tekhnologii Ideala to protect personal data.

- Blocking of Personal Data — temporary cessation of personal data processing (except if processing is required to improve personal data).

- Depersonalization of Personal Data — actions making it impossible to determine ownership of personal data by a specific data subject without any additional information.

- Provision of Personal Data — actions intended to disclose personal data to a specified person or a scope of persons.

- Dissemination of Personal Data — actions intended to disclose personal data to the public.

- Confidentiality of Personal Data — a requirement mandatory to be performed by OOO TsNP Tekhnologii Ideala or other person who has got access to personal data, claiming not to allow disclosure of personal data to third parties, or their dissemination without the consent of the data subject or a legal basis.

- Storage of Personal Data — actual content of personal data in the Personal Data Information System of OOO TsNP Tekhnologii Ideala.

- Destruction of Personal Data — actions (operations) resulting in impossibility to restore the content of personal data in the Personal Data Information System and (or) in destruction of personal data storage media.

2. GENERAL PRINCIPLES AND PURPOSES OF PERSONAL DATA PROCESSING

2.1. Principles of Personal Data Processing

- processing of personal data shall be made on a legal and fair basis;

- processing of personal data inconsistent with the purposes of their collection or obtaining shall not be allowed;

- processing of personal data shall be limited to achievement of certain legitimate goals;

- processing of personal data shall be allowed only with the consent of the data subject;

- only those personal data meeting the purposes of data processing specified in paragraph 2.2. hereof shall be processed;

- processing of personal data that does not correspond to the purposes of such processing shall not be allowed;

- personal data shall be stored in the form that allows to determine the data subject within the timeframe which corresponds to the purposes of personal data processing if such timeframe has not been established by the federal law or a contract, where the data subject is the party, the beneficiary or the guarantor.

2.2. Purposes of Personal Data Processing

- enforcement of the applicable Russian laws;

- proper maintenance of personnel records, payroll, medical insurance and payments under independent contractor agreements by OOO TsNP Tekhnologii Ideala;

- provision of services to and execution of contracts and agreements with individuals by OOO TsNP Tekhnologii Ideala;

- any other purposes where OOO TsNP Tekhnologii Ideala requires personal data processing in accordance with the current legislation of the Russian Federation.

3. DATA SUBJECTS

3.1. The following persons shall be classified as data subjects:

3.1.1. with respect to employment relations:

- employees of OOO TsNP Tekhnologii Ideala working on the basis of concluded employment contracts;

- applicants for the vacant positions of OOO TsNP Tekhnologii Ideala.

3.1.2. with respect to civil relations:

- any legally capable individuals entering into independent contractor agreements with OOO TsNP Tekhnologii Ideala;

- any legally capable individuals who are going to conclude or have already concluded agreements with OOO TsNP Tekhnologii Ideala, and act as a party, beneficiary or guarantor under such agreements.

3.1.3. in any related fields:

- visitors to the office of OOO TsNP Tekhnologii Ideala;

- representatives (employees) of contractors of OOO TsNP Tekhnologii Ideala;

- other persons whose personal data processing may be required by OOO TsNP Tekhnologii Ideala in accordance with the requirements (or based on) the current legislation of the Russian Federation.

4. RIGHTS OF DATA PRIVACY

4.1. In accordance with current legislation, the Data Subject shall be entitled to receive information relating to processing of his personal data.

4.2. With a view to exercise his or her rights and legitimate interests, the Data Subject shall be entitled to address to OOO TsNP Tekhnologii Ideala for information regarding personal data processing and protection. OOO TsNP Tekhnologii Ideala considers inquiries of the Data Subjects, gives explanations and undertakes measures on personal data protection. In case of claims and complaints from the Data Subjects, OOO TsNP Tekhnologii Ideala shall takes all necessary measures to eliminate possible violations, identify responsible persons and settle disputes out of court.

4.3. The right of the Data Subject to access his or her personal data may be restricted as established by the current legislation of the Russian Federation.

4.4. Other rights are defined by the Federal Law ‘On Personal Data’.

5. CATEGORIES OF PROCESSABLE PERSONAL DATA AND THEIR SOURCES

5.1. OOO TsNP Tekhnologii Ideala shall perform processing of the following categories of personal data in the Personal Data Information System:

5.1.1. Pursuant to Paragraph. 3.1.1. Section 3 hereof:

For employees of OOO TsNP Tekhnologii Ideala:

Full name, patronymic;

Passport details;

Date and place of birth;

Registered address;

Residential address;

Marital status;

Education;

Occupation;

Taxpayer ID;

Bank details;

Pension certificate details;

Health insurance policy details;

Children’s birth data, marriage details;

Military registration data;

Place of work;

Job title;

Employment record;

E-mail address;

Phone number.

For family members of employees of OOO TsNP Tekhnologii Ideala

Full name, patronymic;

Date of birth;

Degree of relation.

5.1.2. Pursuant to Paragraph 3.1.2., Section 3 hereof:

For individuals working with OOO TsNP Tekhnologii Ideala under independent contractor agreements

Full name, patronymic;

Passport details;

Date and place of birth;

Registered address;

Residential address;

Taxpayer ID;

Pension certificate details;

Bank details;

E-mail address;

Phone number;

other information that might relate to these individuals.

5.1.3. Pursuant to Paragraph 3.1.3., Section 3 hereof:

Full name, patronymic;

Passport details;

E-mail address;

Phone number;

other information that might relate to these individuals.

5.1.4. Sources of personal data shall include:

For maintaining labor relations, keeping employment records, dealing with independent contractors and other persons whose personal data may be required by OOO TsNP Tekhnologii Ideala — documents and information personally provided by employees and independent contractors.

For individuals who are going to enter into or have already entered into contracts with OOO TsNP Tekhnologii Ideala acting as a party, beneficiary or guarantor — information personally provided by such persons when registering, creating accounts, using software and website owned by OOO TsNP Tekhnologii Ideala, or filling out the appropriate e-forms. Information mandatory to be provided shall be marked in a special way. Any other information shall be provided by individuals at their discretion.

6. CONFIDENTIALITY OF PERSONAL DATA

6.1. All information qualified as personal data that has come to be known to OOO TsNP Tekhnologii Ideala in connection with processing of such data shall be deemed confidential and be protected by applicable laws of the Russian Federation. OOO TsNP Tekhnologii Ideala shall take appropriate measures to protect such information.

6.2. Employees of OOO TsNP Tekhnologii Ideala and other persons who have gained access to the personal data being processed must sign a non-disclosure agreement and shall be warned about potential disciplinary, administrative, civil and criminal liability for violation of the current legislation of the Russian Federation with regard to processing and protection of personal data.

7. ARRANGEMENTS FOR PERSONAL DATA SECURITY

7.1. OOO TsNP Tekhnologii Ideala takes all necessary legal, organizational and technical measures to protect personal data from illegal or accidental access, destruction, modification, blocking, copying, provision, distribution, and other illegal actions in the course of data processing.

7.2. Key measures of personal data protection taken by OOO TsNP Tekhnologii Ideala:
- assignment of employees of OOO TsNP Tekhnologii Ideala responsible for personal data processing;

- internal control (audit) of compliance of personal data processing with the requirements of the Federal Law No. 152-FZ ‘On Personal Data’ dated July 27, 2006  and other governing laws and regulations;

- introducing current legislation of the Russian Federation on personal data, requirements for personal data processing and protection, local regulations, and this Policy to employees of OOO TsNP Tekhnologii Ideala who immediately perform processing of personal data;

- organizational and technical measures on personal data security in the course of their processing by personal data information systems to comply with personal data processing and protection requirements;

- keeping inventory of material data storage media (PCs);

- finding unauthorized access to personal data and taking appropriate measures;

- recovery of personal data modified or deleted as a result of unauthorized access;

- establishment of rules to access personal data processed by the personal data information system, ensuring registration and logging of all operations with personal data within the system;

- control over measures taken to ensure personal data security.

8. FINAL PROVISIONS

8.1. OOO TsNP Tekhnologii Ideala shall be entitled to make changes to this Policy. A new edition shall become effective from the moment of signing by a person authorized by OOO TsNP Tekhnologii Ideala and official publication of its electronic version on the website https://7spsy.com owned by OOO TsNP Tekhnologii Ideala.
8.2. Control over compliance with the requirements of the Policy shall be carried out by persons responsible for ensuring personal data security.