Politics of X-TECH LLC in relation to the processing of personal data

"APPROVED"
Protocol No. 4.1
extraordinary general meeting of participants
dated 01/20/2017


Politics
of X-TECH LLC
in relation to the processing of personal data



1. General provisions

1.1. The policy regarding the processing of personal data in X-TECH LLC (hereinafter referred to as the Policy) is aimed to protect the rights and freedoms of individuals when processing their personal data in X-TEC LLC.
1.2. The policy is developed in accordance with paragraph 2 of Part 1 of Art. 18.1 of the Federal Law of July 27, 2006 No. 152 On Personal Data (hereinafter - the Federal Law On Personal Data).
1.3. The policy contains information to be disclosed in accordance with Part 1 of Art. 14 of Federal Law On personal data, and it is a public document.

2. Operator Information

2.1. X-TECH LLC is an operator of personal data.
2.2. X-TECH LLC conducts its activities at the address 109044, Moscow, Krutitskiy Val st., bld. 14, office 315.
2.3. General Director Dmitry Polstyanov was appointed responsible for organizing the processing of personal data in X-TECH LLC.


3. Information about the processing of personal data

3.1. The processing of personal data in X-TECH LLC is carried out on a lawful and fair basis for the implementation and fulfillment of the functions, powers and responsibilities assigned by the legislation, implementation of rights and legitimate interests of X-TECH LLC, employees of X-TECH LLC and third parties.
3.2. X-TECH LLC receives personal data directly from the subjects of personal data.
3.3. The processing of personal data in X-TECH LLC is conducted in automated and non-automated ways, using computer facilities and without using such means.
3.4. Actions for the processing of personal data include the collection, recording, systematization, accumulation, storage, refinement (update, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion and destruction.


4. Processing of personal data of employees

4.1. X-TECH LLC processes personal data of X-TECH LLC employees in the framework of legal relations regulated by Labor Code of the Russian Federation No. 197- Federal Law dated December 30, 2001 (hereinafter referred to as the Labor Code of the RF).
4.2. The processing of personal data of employees is carried out in order to ensure compliance with laws and other regulatory legal acts, assist in employment, training and promotion, ensure personal safety, control the quantity and quality of work performed and ensure the safety of property in accordance with Part 1 of Art. 86 of the Labor Code of the Russian Federation.
4.3. Processing of personal data of employees is carried out with their written consent, provided for the duration of the employment contract.
4.4. The processing of personal data of employees is carried out during the term of the employment contract. The processing of personal data of dismissed workers is carried out during the period established by paragraph 5 of Part 3 of Art. 24 parts of the first Tax Code of the Russian Federation dated July 31, 1998 of Federal Law No. 146, Part 1 of Art. 29 of the Federal Law On Accounting dated December 6, 2011 Federal Law No. 402- and other regulatory legal acts.
4.5. In X-TECH LLC, processing of special categories of personal data of employees (health information relating to the issue of their ability to perform labor functions) can be carried out on the basis of clause 2.3 of Part 2 of Art. 10 of the Federal Law "On Personal Data".
4.6. X-TECH LLC does not process biometric personal data of employees.
4.7. The following employee personal data is processed:
- Full Name
- Type, series and number of identity document
- Date of issuance of identity document and issuing authority
- Date of Birth
- Place of Birth
- Residence address
- Post address
- Mobile phone
- E-mail
- Taxpayer Identification Number
- Number of insurance certificate of state pension insurance
- Personnel Number
- Position
- Photo

4.8. In the manner prescribed by law, and in accordance with Art. 7 of the Federal Law On Personal Data to achieve the purposes of processing personal data and with the consent of employees, X-TECH LLC provides personal data of employees or entrusts their processing to the following persons: - State bodies (Social Security Fund, Federal Tax Service, Social Insurance Fund, etc.)

5. Processing of personal data of applicants

5.1. X-TECH LLC processes personal data of job applicants (hereinafter referred to as job seekers).
5.2. The processing of personal data of applicants is carried out in order to make a decision on the admission or refusal of employment and maintaining personnel reserve.
5.3. The processing of personal data of applicants is carried out with their written consent, provided for the period necessary for making a decision on acceptance or refusal in employment. The exceptions are cases when a recruitment agency with which it has entered into a relevant agreement, as well as when the applicant independently publishes his resume, accessible to an unlimited number of persons, on the Internet acts on behalf of the applicant.

5.4. The processing of personal data of applicants is carried out within the period necessary for making a decision on the acceptance or refusal of employment. In case of a refusal in recruitment, the processing of the applicant's personal data is terminated within 30 days in accordance with Part 4 of Art. 21 of the Federal Law "On Personal Data". If the applicant has given his consent to be included in the personnel reserve, the processing of personal data may be continued for the period specified in the consent.

5.5. X-TECH LLC does not process special categories of personal data of applicants and biometric personal data of applicants.
5.6. The following personal data of applicants is being processed:
- Full Name
- Type, series and number of identity document
- Date of issuance of identity document and issuing authority
- Date of Birth
- Place of Birth
- Residence address
- Post address
- Mobile phone
- E-mail
- Taxpayer Identification Number
- Number of insurance certificate of state pension insurance
- Personnel Number
- Position
- Photo

6. Processing customer personal data

6.1. X-TECH LLC processes personal data of individuals within the framework of legal relations with X-TECH LLC, regulated by Part Two of the Civil Code of the Russian Federation Federal Law No. 14 of January 26, 1996 (hereinafter referred to as clients).
6.2. The processing of clients' personal data is carried out in order to fulfill the contracts concluded with them.
6.3. The processing of clients' personal data is carried out with their consent, provided for the duration of the contracts concluded with them. Consent is given at the conclusion of the contract in writing or when performing conclusive actions.
6.4. The processing of clients' personal data is carried out within the terms of the contracts concluded with them. Processing of personal data of customers after the expiration of the contracts concluded with them may be carried out within the period specified in paragraph 5 of Part 3 of Art. 24 parts of the first Tax Code, Part 1 of Art. 29 of the Federal Law "On Accounting" and other regulatory legal acts.
6.5. The following personal customer data is being processed:
- Full name
- Type, series and number of identity document
- Date of issuance of identity document and issuing authority
- Date of Birth
- Place of Birth
- Residence address
- Post address
- Mobile phone
- E-mail
- Information about purchased items

7. Information about the security of personal data

7.1. In order to ensure the fulfillment of the obligations stipulated by the Federal Law On Personal Data and the regulatory legal acts adopted in accordance with it, X-TECH LLC is responsible for organizing the processing of personal data.
7.2. To ensure the confidentiality of personal data and their protection against misconduct, X-TECH LLC uses a set of legal, organizational and technical measures to ensure the security of personal data:
- unlimited access to the Policy is provided, a copy of which is located at the address of X-TECH LLC;
- pursuant to the Policy, the Regulation on the processing of personal data (hereinafter - the Regulation) and other local acts is approved and enforced;
- familiarization of X-TECH LLC employees with the provisions of the legislation on personal data, as well as with the Policy and the Regulations;
- employees are allowed to access personal data processed in the information system of H-TECH LLC, as well as to their material carriers only for the performance of employment duties;
- set the rules for access to personal data processed in the information system of X-TECH LLC, and also ensure the registration and accounting of all actions with them;
- evaluates the harm that may be caused to the personal data subjects in the case of a violation of the Federal Law On Personal Data;
- identifies threats to the security of personal data when they are processed in the information system of X-TECH LLC;
- organizational and technical measures are applied and information security tools are used to achieve the established level of personal data protection;
- detection of facts of unauthorized access to personal data is carried out and response measures are taken, including the restoration of personal data modified or destroyed due to unauthorized access to them;
- an assessment of the effectiveness of measures taken to ensure the security of personal data prior to the commissioning of the information system of X-TECH LLC is made;
- internal control is carried out on the compliance of personal data processing with the Federal Law On Personal Data, the regulatory legal acts adopted in accordance with it, the requirements for personal data protection, the Policy, the Regulations and other local acts, including control over the measures taken to ensure the security of personal data and their level of security in the processing in the information system of X-TECH LLC.

8. Rights of personal data subjects

8.1. The subject of personal data has the right to:
- to obtain personal data relating to the subject, and information relating to their processing;
- to clarify, block or destroy his personal data in case they are incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing;
- withdrawal of consent given by him for the processing of personal data;
- to protect their rights and legitimate interests, including damages and moral damages in court;
- to appeal against actions or omissions of X-TECH LLC to an authorized body for the protection of the rights of personal data subjects or through legal action.

8.2. In order to exercise their rights and legitimate interests, personal data subjects have the right to contact X-TECH LLC or send a request personally or with the help of a representative. The request must contain the information specified in Part 3 of Art. 14 of the Federal Law "On Personal Data".