Privacy policy
Personal data processing policy of Limkorm Group LLC
1. GENERAL PROVISIONS
1.1. The purpose of this Policy is to protect the personal data of individuals by the Limited Liability Company " Limkorm " Group" ( LLC " Limkorm Group") from unauthorized access, their unauthorized use or loss.
1.2. This Policy has been developed in in accordance with The Constitution of the Russian Federation, Federal Law of 27.07.2006 No. 152-FZ "On Personal Data", Federal Law No. 115-FZ, Federal Law of 27.07.2006 No. 149-FZ "On informatization, information technology and on information protection”, By Government Decrees RF from November 1, 2012 No. 1119 “On approval of requirements for the protection of personal data when processing them in personal data information systems” and from September 15, 2008 No. 687 "On approval of the Regulation on the specifics of personal data processing, carried out without the use of automation equipment”, and other regulatory acts in force on the territory of the Russian Federation Federations.
1.3. In this Policy are used next terms And definitions:
Limkorm Group LLC (hereinafter referred to as the Company ), organizer of PR events (competitions, seminars, conferences, PR campaigns ).
Participant - an individual who is a client of the Company, a representative of an organization that is a client of the Company, or a representative of an organization that is a potential client of the Company.
Personal data Participant - information, necessary To the operator V connections with participation in PR events x, concerning a specific Participant, including his/her last name, first name, patronymic, place of work, position held, email address, telephone number, and other information specified by the applicant.
Processing of personal data is any action (operation) or set of actions (operations) performed with the use of automation tools or without the use of such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
Subject personal data x — Participant.
Protection of the Participant's personal data is the Company's activity to ensure the procedure for processing personal data and organizational and technical measures for information confidentiality using local regulation.
Confidentiality of personal data — a requirement that must be observed by a person who has received access to personal data, not to allow their dissemination without the consent of the subject of the personal data or the availability of other legal basis.
1.4. Actions of this Policy is spreading on all Participants.
2. PROCESSING PERSONAL DATA
The goal processing personal data is:
— ensuring the protection of human and civil rights and freedoms when processing his personal data, V volume number protection right on inviolability private life, personal and family secret;
- promotion of goods, works, services of the Operator on market through direct implementation contacts With potential consumer;
Personal data is received by the Company directly at the Participant himself. If the Participant is a minor, the consent of the parent or person replacing him is required. his official representative.
Processing organized Operator on principles:
- legality goals And ways processing personal data, integrity and justice V activities Operator;
the reliability of personal data, their sufficiency for the purposes of processing, inadmissibility processing personal data, redundancy By relation to the goals, declared at collection personal data;
processing only personal data, which answer goals their processing;
compliance of content and volume processed personal data for the stated purposes processing. Processed personal data not should be redundant By relation to stated goals their processing; inadmissibility associations bases data, containing personal data, the processing of which is carried out V purposes, Not compatible between by yourself; provision accuracy personal data, their sufficiency, A V necessary cases and relevance By relation To purposes of processing personal data. Operator accepts necessary measures or provides their acceptance by deletion or clarification of incomplete or inaccurate data;
storing personal data in a form that allows the identification of the subject of the personal data for no longer than is required for the purposes of processing the personal data.
TO processing, transfer And storage personal data can have access:
Director Societies;
Employees responsible for organizing and conducting these events;
other employees OOO " Limkorm Group" according to regular the organization's schedule when their performance their own service responsibilities.
At identification Participant Society Maybe demand presentation of documents, certifying personality.
Not It is allowed to answer questions related to transfer of personal information, by phone or fax.
Storage personal data should happen V in order, excluding them loss or their misuse.
3. PROCEDURE AND CONDITIONS FOR PROCESSING PERSONAL DATA
3.1. The processing of personal data is carried out by the Operator in accordance with the requirements of the legislation of the Russian Federation.
3.2. Personal data Participants are being processed And are stored at event organizer .
3.3. The processing of personal data is carried out with the consent of the subjects of personal data to the processing of their personal data, as well as without such consent in cases stipulated by the legislation of the Russian Federation.
3.4. Disclosure to third parties and distribution of personal data without the consent of the personal data subject is prohibited, unless otherwise provided by federal law. Consent to the processing of personal data permitted by the personal data subject for distribution is drawn up separately from other consents of the personal data subject to the processing of his personal data.
The requirements for the content of consent to the processing of personal data permitted by the subject of personal data for distribution are approved by Order of Roskomnadzor dated 02.24.2021 N 18.
3.5. The transfer of personal data to inquiry and investigation bodies, the Federal Tax Service, the Social Fund of Russia and other authorized executive bodies and organizations is carried out in accordance with the requirements of the legislation of the Russian Federation.
3.6. The operator shall take the necessary legal, organizational and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, distribution and other unauthorized actions, including:
• identifies threats to the security of personal data during their processing;
• adopts local regulations and other documents governing relations in the field of processing and protection of personal data;
• appoints persons responsible for ensuring the security of personal data in the structural divisions and information systems of the Operator;
• creates the necessary conditions for working with personal data;
• organizes the registration of documents containing personal data;
• organizes work with information systems in which personal data is processed;
• stores personal data under conditions that ensure their safety and prevent unauthorized access to them;
• organizes training for the Operator’s employees who process personal data.
3.7. The operator shall store personal data in a form that allows the identification of the subject of personal data, no longer than required for each purpose of processing personal data, unless the storage period for personal data is established by federal law or agreement.
3.7.1. Personal data on paper media are stored in Limkorm Group LLC for the storage periods of documents for which these periods are stipulated by the legislation on archival affairs in the Russian Federation (Federal Law of 22.10.2004 N 125-FZ "On Archival Affairs in the Russian Federation", List of standard management archival documents generated in the course of activities of state bodies, local governments and organizations, indicating their storage periods (approved by Order of Rosarchive of 20.12.2019 N 236)).
3.7.2. The storage period of personal data processed in personal data information systems corresponds to the storage period of personal data on paper media.
3.8. The operator shall cease processing personal data in the following cases:
• the fact of their illegal processing is revealed. Deadline - within three working days from the date of detection;
• the purpose of their processing has been achieved;
• the consent of the personal data subject to the processing of the specified data has expired or has been revoked, when, according to the Law on Personal Data, the processing of these data is permitted only with consent.
3.9. Upon achieving the goals of personal data processing, as well as in the event of the personal data subject’s withdrawal of consent to their processing, the Operator shall cease processing these data if:
• otherwise provided by an agreement to which the subject of personal data is a party, beneficiary or guarantor ;
• The operator does not have the right to carry out processing without the consent of the subject of personal data on the grounds provided for by the Law on Personal Data or other federal laws;
• unless otherwise provided by another agreement between the Operator and the subject of personal data.
3.10. If a personal data subject applies to the Operator with a request to stop processing personal data within a period not exceeding 10 working days from the date of receipt by the Operator of the relevant request, the processing of personal data shall be terminated, except for cases stipulated by the Law on Personal Data. The specified period may be extended, but not more than by five working days. To do this, the Operator must send the personal data subject a reasoned notice indicating the reasons for the extension of the period.
3.11. When collecting personal data, including through the Internet information and telecommunications network, the Operator ensures the recording, systematization, accumulation, storage, clarification (updating, modification), and extraction of personal data of citizens of the Russian Federation using databases located on the territory of the Russian Federation, except for cases specified in the Law on Personal Data.
4. TRANSFER PERSONAL DATA
When transferring personal data of a Participant, the Company must comply with the following requirements.
4.1 Do not report personal data Participant third side without the written consent of the Participant.
4.2. Warn persons, received personal data Participant, O that this data can be used only V purposes, For which They reported, And demand from these persons confirmation Togo, What This the rule is observed. Persons, received personal data The participant is obliged observe the regime secrecy (confidentiality). This Regulation Not is spreading on exchange personal data Participants V in the manner established by federal laws.
5. UPDATING, CORRECTION, DELETION, DESTRUCTION OF PERSONAL DATA, RESPONSES TO REQUESTS FROM SUBJECTS FOR ACCESS TO PERSONAL DATA
5.1. Confirmation of the fact of personal data processing by the Operator, the legal grounds and purposes of personal data processing, as well as other information specified in Part 7 of Article 14 of the Law on Personal Data, shall be provided by the Operator to the personal data subject or his representative within 10 working days from the date of the request or receipt of the request of the personal data subject or his representative. This period may be extended, but not more than by five working days. To this end, the Operator should send the personal data subject a reasoned notice indicating the reasons for extending the period for providing the requested information.
The information provided does not include personal data relating to other personal data subjects, except in cases where there are legal grounds for disclosing such personal data.
The request must contain:
• the number of the main document certifying the identity of the subject of personal data or his representative, information on the date of issue of the specified document and the body that issued it;
• information confirming the participation of the personal data subject in relations with the Operator (contract number, date of conclusion of the contract, conventional verbal designation and (or) other information), or information otherwise confirming the fact of processing of personal data by the Operator;
• signature of the subject of personal data or his representative.
The request may be sent in the form of an electronic document and signed with an electronic signature in accordance with the legislation of the Russian Federation.
The operator provides the information specified in Part 7 of Article 14 of the Law on Personal Data to the subject of personal data or his representative in the form in which the relevant request or appeal was sent, unless otherwise specified in the request or appeal.
If the personal data subject’s request (appeal) does not reflect all the necessary information in accordance with the requirements of the Law on Personal Data or the subject does not have the right to access the requested information, then a reasoned refusal is sent to him.
The right of the personal data subject to access his personal data may be limited in accordance with Part 8 of Article 14 of the Law on Personal Data, including if the personal data subject's access to his personal data violates the rights and legitimate interests of third parties.
5.2. In the event that inaccurate personal data is discovered upon an appeal by the personal data subject or his/her representative or at their request or at the request of Roskomnadzor, the Operator shall block the personal data related to this personal data subject from the moment of such appeal or receipt of the specified request for the verification period, if the blocking of the personal data does not violate the rights and legitimate interests of the personal data subject or third parties.
In the event of confirmation of the fact of inaccuracy of personal data, the Operator, on the basis of information provided by the subject of personal data or his representative or Roskomnadzor, or other necessary documents, clarifies the personal data within seven working days from the date of submission of such information and removes the blocking of the personal data.
5.3. In the event of detection of unlawful processing of personal data upon an appeal (request) from the subject of personal data or his representative or Roskomnadzor, the Operator shall block the unlawfully processed personal data related to this subject of personal data from the moment of such appeal or receipt of the request.
5.4. If the Operator, Roskomnadzor or another interested party discovers a fact of unlawful or accidental transfer (provision, distribution) of personal data (access to personal data) that has resulted in a violation of the rights of personal data subjects, the Operator:
• within 24 hours - notifies Roskomnadzor of the incident that occurred, the alleged reasons that led to the violation of the rights of personal data subjects, the alleged harm caused to the rights of personal data subjects, and the measures taken to eliminate the consequences of the incident, and also provides information about the person authorized by the Operator to interact with Roskomnadzor on issues related to the incident;
• within 72 hours - notifies Roskomnadzor of the results of the internal investigation of the identified incident and provides information about the persons whose actions caused it (if any).
5.5. Procedure for destruction of personal data by the Operator.
5.5.1. Conditions and terms for destruction of personal data by the Operator:
• achievement of the purpose of processing personal data or loss of the need to achieve this purpose - within 30 days;
• achieving the maximum storage period for documents containing personal data - within 30 days;
• provision by the subject of personal data (his representative) of confirmation that the personal data were obtained illegally or are not necessary for the stated purpose of processing - within seven working days;
• withdrawal by the subject of personal data of consent to the processing of his personal data, if their storage for the purpose of their processing is no longer required, within 30 days.
5.5.2. Upon achieving the purpose of processing personal data, as well as in the event of the withdrawal of consent to their processing by the subject of personal data, personal data are subject to destruction if:
• otherwise provided by an agreement to which the subject of personal data is a party, beneficiary or guarantor ;
• The operator does not have the right to carry out processing without the consent of the subject of personal data on the grounds provided for by the Law on Personal Data or other federal laws;
• unless otherwise provided by another agreement between the Operator and the subject of personal data.
5.5.3. The destruction of personal data is carried out by a commission created by order of the head of Limkorm Group LLC.
5.5.4. Methods for destruction of personal data are established in the Operator’s local regulations.
6. RESPONSIBILITY FOR VIOLATION HOPM, REGULATING PROCESSING PERSONAL DATA
6.1. Workers Societies, guilty V violation order appeals With personal data, carry disciplinary, administrative, civil law or criminal liability V in accordance With federal laws.