COMPANY POLICY WITH RESPECT TO PERSONAL DATA PROCESSING

COMPANY POLICY WITH RESPECT TO PERSONAL DATA PROCESSING

GENERAL PROVISIONS

The policy for the processing of personal data (hereinafter referred to as the Policy) was developed in accordance with the Federal Law of July 27, 2006. No. 152-FZ “On Personal Data” (hereinafter - FZ-152).

This Policy determines the procedure for the processing of personal data and measures to ensure the security of personal data in LLC OLD QUARTERS (hereinafter referred to as the Operator) in order to protect the rights and freedoms of a person and citizen when processing their personal data, including the protection of privacy rights, personal and family secrets.

The Policy uses the following basic concepts:

automated processing of personal data - processing of personal data using computer equipment;
personal data blocking - temporary suspension of personal data processing (unless it is necessary to process personal data);
personal data information system - a set of personal data contained in databases, and information technologies and technical means ensuring their processing;
de-identification of personal data - actions, as a result of which it is impossible to determine without the use of additional information that the personal data belong to a specific personal data subject;
personal data processing - any action (operation) or a set of actions (operations) performed with the use of automation tools or without using such tools with personal data, including the collection, recording, systematization, accumulation, storage, refinement (update, change), 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 personal data processing, 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 disclosing 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 circle of persons (transfer of personal data) or to get acquainted with personal data of an unlimited number of persons, including public disclosure of personal data in the media, placement in information and telecommunication networks or providing access to personal data in some 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, foreign natural 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 information system of personal data and (or) as a result of which the material carriers of personal data are destroyed.

The company is obliged to publish or otherwise provide unrestricted access to this Policy for the processing of personal data in accordance with Part 2 of Art. 18.1. FZ-152.

2. PRINCIPLES AND CONDITIONS OF PERSONAL DATA PROCESSING

2.1. Principles of personal data processing

The processing of personal data by the Operator is carried out on the basis of the following principles:

- legality and fair basis;
- restrictions on the processing of personal data to the achievement of specific, predetermined and legitimate goals;
- to prevent the processing of personal data that is incompatible with the purposes of collecting personal data;
- prevent the merging of databases containing personal data that are processed for purposes that are 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 objectives;
- prevent processing of personal data, redundant in relation to the stated objectives of their processing;
- ensuring the accuracy, sufficiency and relevance of personal data in relation to the purposes of personal data processing;
- destruction or depersonalization of personal data on achieving the goals of their processing or in case of loss of the need to achieve these goals, if it is impossible for the Operator to correct the violations of personal data, 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:

- processing of personal data is carried out with the consent of the subject of personal data