Annex No. 1 to Order of R2AM, LLC dd. 04.08.2020 No. 04-08/01
1. This Privacy Policy Regarding the Processing of Personal Data of R2AM, Limited Liability Company (hereinafter referred to as the Policy) regulates Personal Data processing procedure and method of R2AM, Limited Liability Company (hereinafter referred to as the Company or R2AM), and sets out the personal data processing principles and implementation methods for such principles.
2. The Company processes Personal Data as per the rules set out in Federal Law No. 152-FZ “On Personal Data” dated 27.07.2006, the Labor Code of the Russian Federation, Government Resolution No. 687 “On Approval of the Regulation on the Specifics of Personal Data Processing without the Use of Automation Tools” dated 15.09.2008, Government Resolution No. 211 dated 21.03.2012 “On Approval of the List of Measures Aimed at Ensuring the Fulfillment of Obligations under Federal Law ‘On Personal Data’” and other legal acts regulating the personal data processing.
3. The following terms shall be used herein as follows:
Personal Data shall mean any information related directly or indirectly to a specific or identifiable individual (Personal Data Subject).
Operator shall mean R2AM, Limited Liability Company (location: 5 Prechistensky Lane, 2nd floor, prem. VI, room 2, Moscow, 119034, PSRN 1197746689227, TIN 9704006407, tel. +7 495 796 50 30). The Operator is included in the register of persons processing Personal Data under registration number 77-20-017827 pursuant to Roskomnadzor Order No. 124 dated 10.08.2020.
Personal Data Processing shall mean any action (operation) or a set of actions (operations) performed with or without the use of automation tools with Personal Data, including the collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, destruction of Personal Data, inter alia, by filling in the Personal Data Subject forms posted on the Company website at www.r2am.ru (hereinafter, the Website).
Operator shall mean a state or municipal authority, legal entity or individual that independently or jointly with other persons arranges for and (or) performs the Personal Data processing, as well as determines the Personal Data processing purposes, the composition of Personal Data to be processed, actions (operations) performed with the Personal Data;
Personal Data Provision shall mean actions aimed at Personal Data disclosure to a certain person or a certain group of persons;
Personal Data Blocking shall mean temporary termination of Personal Data processing (except for cases when processing is necessary to clarify Personal Data);
Personal Data Destruction shall mean actions that make it impossible to restore the contents of Personal Data in the Personal Data information system and (or) as a result of which the tangible media of Personal Data are destroyed;
4. Personal Data processing purposes are as follows:
• activities stipulated by the Company Articles of Association, the applicable law of the Russian Federation, in particular, Federal Law: “On Personal Data”, Civil Code of the Russian Federation, Labor Code of the Russian Federation, other legal acts of the Russian Federation and regulatory documents of competent state authorities;
• review of CVs and selection of candidates for vacant positions for the further employment with the Company;
• maintenance and management of personnel records in the Company;
• entering into, performance and termination of civil transactions with individuals, legal entities, individual entrepreneurs and other persons, as stipulated by the applicable law and the Company Articles of Association;
• providing access to the Company Website and services to the Personal Data Subject;
• providing personalized services to the Personal Data Subject;
• targeting of advertising materials;
• creation, management and monitoring of a Personal Data Subject’s account created on the Company Website, in particular, to verify access rights to services and software;
• communication with the Personal Data Subject in order to inform the latter about the availability or changes in services provided by the Company;
• assessment of the service level, monitoring of traffic and demand for various service options;
• marketing activities;
• compliance with this Policy;
• mailing of Company news and special offers;
• complaint correspondence with the Personal Data Subject;
• other purposes for which the Company has the right to process Personal Data of the Personal Data Subject in accordance with the law of the Russian Federation.
5. For the purposes specified in Cl. 4 hereof, the Company processes the following personal data of subjects:
• last name, first name, patronymic, former last name, first name, patronymic, date, place and reason for change (if changed);
• date and place of birth;
• nationality;
• taxpayer identification number (TIN);
• obligatory pension insurance certificate number;
• gender;
• knowledge of a foreign language;
• education (educational institution, diploma number and series, date of graduation, field of study or specialty according to the diploma, qualification according to the diploma);
• postgraduate professional education (name of educational or scientific institution, year of graduation), academic degree, academic title (if any, numbers of diplomas, certificates);
• work performed since the beginning of employment (including military service, part-time work, entrepreneurial activities, etc.);
• family composition, degree of kinship, last names, first names, patronymics, dates of birth of close relatives (father, mother, brothers, sisters and children), as well as husband (wife);
• details of the principal identity document: type, series and number of the document, information about the date of issue and the issuing authority;
• address of registration and actual residence;
• military service details;
• data about family members;
• contact details;
• information about the presence (absence) of a criminal record and (or) the fact of criminal prosecution or dismissal of the criminal proceeding;
• information about the property owned by the Personal Data Subject;
• other information necessary for the Company to carry out the activities stipulated by the Company Articles of Association.
6. Personal Data Subjects (individuals) are:
• Company employees;
• applicants for Company vacancies;
• Company customers;
• users of www.r2am.ru;
• other individuals directly or indirectly related to the Company.
7. This Policy is accepted by the Personal Data Subject by checking the ‘I agree with the terms of service’ box when filling out the forms on the Website and such acceptance shall constitute the consent of the Personal Data Subject to the Personal Data processing.
8. By checking the ‘I agree with the terms of service’ box, the Personal Data Subject confirms the decision to provide their personal data and agrees to the processing thereof, except for the cases provided for in Part 2 Art. 9 of Federal Law No. 152-FZ “On Personal Data” dd. 27.07.2006.
9. The Operator shall not provide or disclose the information specified in Cl. 5 hereof to any third parties without the due written consent of the Personal Data Subject, except in cases of preventing a threat to life and health, as well as in other cases stipulated by Federal Laws.
10. In cases stipulated by law, Personal Data may be transferred without the consent of the Personal Data Subject to the following organizations:
• to judicial authorities in connection with the administration of justice;
• to judicial authorities in connection with the administration of justice;
• to state security agencies;
• to prosecution authorities;
• to the police;
• to investigation authorities;
• to other authorities and organizations in cases stipulated by any binding regulatory legal acts.
Personal Data of Personal Data Subjects may be transferred to the above authorities only upon a reasoned request received by the Company.
Company employees processing Personal Data must not answer any questions directly or indirectly related to the use of Personal Data, including by phone or fax.
11. The Company may transfer the Subject’s Personal Data to third parties in the following cases:
• with the written consent of the personal data subject to such distribution;
• the transfer of the Subject’s Personal Data is required for the purpose of using a certain service by the Personal Data Subject or for providing a service to the Personal Data Subject by the Company;
• the transfer of the Subject’s Personal Data takes place within the framework of transactions related to the full or partial sale of property owned by the Company or the Personal Data Subject, or rights to such property. At the same time, the acquirer shall assume all the Company obligations to comply with the terms of this Policy in relation to the Personal Data received by the acquirer.
• ensuring the protection of the rights and legitimate interests of the Company, the Website or third parties where the Personal Data Subject violates the User Agreement for the Website services.
12. In accordance with Art. 14 of the Federal Law “On Personal Data”, Personal Data Subjects may request the Operator to amend their personal data, block or destroy the same if the personal data is incomplete, outdated, inaccurate, illegally obtained or not required for the stated purpose of processing, as well as take legal measures to protect their rights.
13. In order to implement the provisions of Cl. 9 hereof, the Personal Data Subject shall contact the Company with a request to amend, block or delete Personal Data.
The Personal Data Operator may request the Personal Data Subject to provide any documents necessary to establish the identity of the person who made the request to the Company, as well as request the Personal Data Subject for additional information.
In case of violation of the rights of the Personal Data Subject, the latter may appeal against actions (omissions) of the Operator related to the processing of personal data to the Prosecutor’s Office or court.
14. In order to protect Personal Data, in accordance with Art. 18.1 and Art. 19 of Federal Law No. 152-FZ “On Personal Data” dd. July 27, 2006, and Government Resolution No. 687 “On Approval of the Regulation on the Specifics of Personal Data Processing without the Use of Automation Tools” dd. September 15, 2008, the Operator shall take all measures aimed at protecting Personal Data, namely:
14.1 appoint persons responsible for the Personal Data processing procedure and ensuring the security of Personal Data;
14.2 develop and implement Regulations on Personal Data Protection;
14.3 appoint persons responsible for the Personal Data processing procedure and ensuring the security of Personal Data;
14.4 instruct the persons processing Personal Data about the provisions related to the processing of Personal Data, including regulatory legal acts that set out the procedure for the Personal Data operation and protection;
14.5 make a distinction of access rights to the Personal Data processed and being processed;
14.6 check for Personal Data processing conditions;
14.7 perform internal control over the personal data processing procedure compliance with the applicable law;
14.8 perform other actions necessary to protect the processed Personal Data and maintain security.
15. All information related to Personal Data that has become known in the course of implementing the purposes specified in Cl. 4 hereof is confidential and not subject to disclosure.
16. The consequences of disclosure of any information treated as Personal Data, including possible disciplinary, administrative, civil or criminal liability, have been explained to the persons having access to Personal Data.
17. The provisions of this Policy may be amended. Any amendments made shall be submitted for review to all Personal Data Subjects concerned, inter alia, by posting on the Website.
