1.1. This Personal Data Processing and Protection Policy (hereinafter referred to as the “Policy”) is adopted and enforced by Bellerage Outsourcing and Consulting Limited Liability Company, TIN 7707743155, located at: 115054, Moscow, Shchipok St., 11, building 1 (“Operator”).
1.2. This Policy is a publicly available document of the Operator and provides for the possibility of free access to it by all third parties.
1.3. All terms and definitions used in this Policy are used in the same meaning as in the Federal Law “On Personal Data” No. 152-FZ.
1.4. The scope of this Policy extends to the processing of personal data of all individuals (hereinafter referred to as “Subject”) who provide the Operator with their personal data, including - employees of the Operator and its clients, as well as - individuals who provide their personal data on a voluntary basis for the purpose of participating in events organized and conducted by the Operator, including events for the personnel recruitment by the Operator, obtaining assistance from the Operator in establishing business contacts by the Subject in areas of interest.
1.5. The scope of this Policy extends to all structural units of the Operator, including its separate subdivisions, as well as to all third parties involved in the process of processing personal data by the Operator, including the transfer of personal data to them based on concluded agreements or assignments for the processing of personal data.
2.1. Processing of personal data is carried out by the Operator either with or without the use of automation means.
2.2. Processing of personal data by the Operator includes collection, recording, systematization, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), blocking, deletion, and destruction of personal data.
2.3. The content and scope of personal data being processed are determined by the Operator based on the purpose of processing. The purposes of processing personal data by the Operator include:
2.3.1. Registration of the Subject on the Operator’s website and for providing the Subject with access to its separate sections;
2.3.2. Providing the Subject with information about the Operator, its services, and events;
2.3.3. Responding to inquiries from the Subject and providing answers to requests for additional information;
2.3.4. Organizing the Subject’s participation in events and surveys conducted by the Operator;
2.3.5. Sending news materials to the Subject;
2.3.6. Distributing requested reference materials;
2.3.7. Entering into an agreement;
2.3.8. Performing client’s onboarding procedures;
2.3.9. Developing services and areas of activity of the Operator (in particular, determining customer needs and opportunities for improving the efficiency and quality of service delivery);
2.3.10. Implementing measures to ensure security, quality, and risk management, including detection, investigation, and elimination of security threats.
2.3.11. Providing and receiving professional services;
2.3.12. Other purposes with the consent of the Subject;
2.3.13. Achieving other goals that do not contradict the law.
2.4. The Operator does not process special categories of personal data relating to racial and ethnic origin, political opinions, religious and philosophical beliefs, health, intimate life, and criminal record of individuals, except when the Subject has given their written consent to the processing of such data.
2.5. The Operator does not carry out cross-border transfer of personal data, unless the Subject has given their written consent to this.
2.6. The Operator does not process biometric personal data, except when the Subject has given their written consent to the processing of such data.
2.7. When processing personal data, the Operator ensures the accuracy of personal data, their sufficiency, and relevance to the purposes of processing. Upon discovering inaccurate or incomplete personal data, their clarification and updating is carried out.
2.8. Confidentiality is ensured for personal data that is not publicly available.
2.9. Processing and storage of personal data are carried out within the period necessary for the purposes of processing personal data, if there are no legal grounds for further processing of personal data, for example, if their storage period is not established by federal law, by an agreement with the Subject, or by the consent of the Subject. Processed personal data is subject to destruction upon the occurrence of the following conditions:
3.1. The Operator takes the necessary legal, organizational, and technical measures, implements requirements for the protection of personal data to ensure the security of personal data, to protect it from unauthorized (including accidental) access, destruction, modification, blocking of access, and other unauthorized actions. Such measures include, in particular:
4.1. The Subject has the right to withdraw consent to the processing of personal data by sending a corresponding request to the Operator in the form of an original by mail or provided in person to the Operator, as well as it can be sent in the form of a scanned copy to the email address russia@bellerage.com.
4.2. The Subject has the right to receive information relating to the processing of their personal data, including containing:
4.3. The Subject has the right to demand from the Operator that their personal data be clarified, blocked, or destroyed if the personal data is incomplete, outdated, inaccurate, obtained unlawfully, or is not necessary for the stated purpose of processing, as well as to take measures provided for by law to protect their rights.
4.4. If the Subject believes that the Operator is processing their personal data in violation of the requirements of the law or is otherwise violating their rights and freedoms, the data subject has the right to challenge the actions or inaction of the Operator to the authorized body for the protection of the rights of data subjects or in court.
4.5. The data subject has the right to protect their rights and legitimate interests, including to seek compensation for damages and (or) compensation for moral harm in court.
5.1. Control over the implementation of the requirements of this Policy is carried out by the person responsible for organizing the processing of personal data at the Operator within their powers.
5.2. The Operator, its officials, and employees bear civil and other liability for non-compliance with the procedures, scope, and conditions of processing personal data, as well as for disclosure or illegal use of personal data in accordance with the law.
5.3. You can contact the Operator with a request or complaint regarding the processing of your personal data by sending us a letter with the subject line “Request for Personal Data” indicating the purposes for providing us with your data and the operations carried out by the Operator for their processing to the email address: russia@bellerage.com or to the address: 115054, Moscow, Shchipok St., 11, building 1.The Operator may request additional information regarding your request, which is necessary to prepare a response.
5.4. This Policy is reviewed and updated by the Operator as needed. In case of a conflict of versions of the Policies, the Policy posted on the Operator’s website is considered current.
5.5. Suggestions for improving this Policy can be sent to the email address russia@bellerage.com.
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