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1.1. The present document (hereinafter – the “Policy” defines purposes and general principles of personal data processing in Bellerage Outsourcing&Consulting LLC (State registration number 5137746160151, Tax ID 7704852029, address: 115054, Moscow, Shchipok str., 11, bld. 1), hereinafter – the “Operator”. The Operator conducts personal data processing together with Bellerag Audit LLC (State registration number 1097746796267m Tax ID 7705905330, address: 115054, Moscow, Shchipok str., 11, bld. 1), which is also referred to as “Operator”.
1.2. The present Policy is a public document of the Operator and provides the possibility of free access to it for all third parties.
1.3. All terms and definitions used herein are used in the meaning equal to the meaning in Federal Law № 152-FZ “On Personal Data”.
1.4. The present Policy covers processing of personal data of all individuals (hereinafter – the “Subject”) that provide the Operator with their personal data.
1.5. The present Policy covers all subdivisions of the Operator including separate subdivisions, as well as third parties participating in personal data processing by the Operator including transfer of personal data under the concluded agreements or instructions on personal data processing. Policy is applied to all personal data subjects including clients, candidates, employees, website and applications users.
2.1. Processing of personal data by the Operator is conducted by means of automation facilities or without such facilities.
2.2. Personal data processing includes gathering, recording, systematizing, accumulating, storing, updating (renewing and altering), retrieving, using, transmitting (disseminating, providing and accessing), depersonalising, blocking, deleting and destroying personal data.
2.3. The content and scope of personal data processed are defined by the Operator based on the purpose of processing. The Purposes of personal data processing include:
2.4. The Operator does not conduct processing of special categories of Personal data related to race or nation, political views, religion and philosophical views, health, intimate life and criminal records of individuals exclusive of cases when the Personal data subject gives its written consent to processing of such data.
2.5. The Operator conducts the cross-border transfer only in cases when the personal data subject gives its written consent.
2.6. Personal data is processed by the Operator on the basis specified by law or under the consent of the personal data subject. If the consent to processing of Personal data received by means of information and telecommunication network Internet is necessary, the consent is deemed to be received at the moment of loading the webpage of the Operator’s website or (is there is an option to do it) at the moment of pressing the button “I agree to processing of my personal data”/putting a tick nearby the similar phrase. The written consent is deemed to be received in case of e-signature including simple e-signature if the rules of usage of e-signature and equation of e-signature and handwritten signature are complied with.
2.7. When processing personal data the Operator ensures the accuracy of the personal data, its adequacy and relevance in relation to purposes of processing. If inaccurate or incomplete personal data is detected the Operator conducts updating of personal data.
2.8. For non-public personal data the Operator ensures its absolute confidentiality.
2.9. Personal data may be transferred by the Operator only in accordance with current legislation to its employees as well as partners which are obliged to keep data confidential.
2.10. Processing and storing of personal data is conducted within the term necessary for purposes of personal data processing if there is no other legal basis for further processing (e.g. if other term of storing is specified by law).
2.11. The personal data processed are deleted or depersonalized by the Operator in case of following conditions present:
2.12. The Operator may process the following personal data:
3.1. The Operator takes necessary legal, organizational and technical measures for security of personal data from unauthorized access, deleting, change, blocking of access and other unauthorized actions. The measures include:
4.1. The personal data subject is entitled to revoke its consent to personal data processing by sending a relevant request in written to the Operator. The Request may be sent in original paper form by post or in person or sent as a scan via email firstname.lastname@example.org.
4.2. The personal data subject is entitled to get information related to its personal data including:
4.3. The personal data subject is entitled to demand the Operator to update its personal data, block or delete it if personal data is incomplete, old, inaccurate, illegally received or not necessary for the declared purpose of processing as well as take measures under law on protection of its rights.
4.4. If the personal data subject thinks that the Operator conducts its personal data processing with breach of law or other violation of its rights and freedoms, personal data subject is entitled to challenge actions or inaction of the Operator to an authorized body or court.
4.5. The personal data subject is entitled to protection of its rights and lawful interests including damages and (or) compensation of moral damage via court procedure.
5.1. Control under meeting with requirements of the present Policy is conducted by the Operator’s persons responsible for arrangement of personal data processing within their powers.
5.2. The Operator and its officers and employees bear civil and other responsibility for non-compliance with order, scope and terms of personal data processing as well as disclosing and illegal use of personal data in accordance with the legislation.
5.3. The present Policy is changed and updated by the Operator if necessary.
5.4. Offers on updating the Policy may be sent to email email@example.com.
5.5. Consent to the Policy is expressed by loading the webpage of the Company’s website or (is there is an option to do it) at the moment of pressing the button “I agree to processing of my personal data”/putting a tick nearby the similar phrase.
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