INTILED LLC Personal Data Processing Policy
Legal address of INTILED LLC: 192102, St. Petersburg, Vnutrenniy territorialny okrug Volkovskoe, Bukharestskaya St., 32, Lit. A, Room 12-N, Ch. Room 33, Office 4-41, 4th floor.
Purpose and Scope of the Document
The "INTILED LLC Personal Data Processing Policy" (hereinafter referred to as the Policy) defines the position and intentions of INTILED regarding the processing and protection of personal data, aiming to uphold and protect the rights and freedoms of each individual, particularly the right to privacy, personal and family secrets, and the protection of their honor and good name. The Policy is strictly adhered to by the management and employees of all departments and branches of INTILED LLC. The Policy applies to all personal data of subjects processed at INTILED, both with and without the use of automation tools. This Policy is accessible to any personal data subject.
Definitions
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Personal Data – any information relating to an identified or identifiable natural person (citizen). This information includes, but is not limited to: full name, date, month, year, and place of birth, address, family, social, and property status, as well as other information.
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Personal Data Processing – any action (operation) or a set of actions (operations) with personal data, performed using or without the use of automation tools. Such actions include: collection, receipt, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (dissemination, provision, access), anonymization, blocking, deletion, and destruction of personal data.
Personal Data Subjects
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Employees of INTILED LLC;
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Individuals with whom civil law contracts are concluded;
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Candidates for vacant positions at INTILED LLC;
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Clients and partners of INTILED LLC;
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Registered users of the INTILED LLC website.
Principles and Conditions of Personal Data Processing
INTILED LLC defines the security of personal data as the protection of personal data from unauthorized or accidental access, destruction, alteration, blocking, copying, provision, dissemination, or other illegal actions. INTILED takes necessary legal, organizational, and technical measures to protect personal data.
Personal data processing and protection in INTILED LLC are carried out in accordance with the Constitution of the Russian Federation, Federal Law No. 152-FZ "On Personal Data," subordinate acts, other federal laws of the Russian Federation defining cases and features of personal data processing, and guidelines from the Federal Service for Technical and Export Control of Russia (FSTEC) and the Federal Security Service of Russia (FSB).
INTILED LLC adheres to the following principles when processing personal data:
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Legality and fairness of the basis for processing;
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Limiting data processing to specific, pre-determined, and lawful purposes;
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Prohibition of data processing incompatible with the purposes of collection;
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Prohibition of merging databases containing personal data processed for incompatible purposes;
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Processing personal data that aligns with the objectives of their processing.
INTILED processes personal data only when at least one of the following conditions is met:
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The data subject's consent for the processing of their personal data has been obtained;
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Processing is necessary to achieve objectives prescribed by law, for the fulfillment of functions assigned to the operator by Russian legislation;
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Processing is necessary for the performance of a contract, where the data subject is a party, beneficiary, or guarantor, or for the conclusion of a contract at the data subject's request;
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Processing is necessary for the legitimate interests of INTILED or third parties or for achieving socially significant objectives, provided that such processing does not violate the rights and freedoms of the data subject;
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Processing is carried out with the data subject's voluntary consent, or for personal data required by law to be disclosed.
In accordance with Russian Federation legislation, INTILED LLC has the right to transfer personal data to third parties. INTILED may create publicly available sources of personal data for employees, including directories and address books. With the employee's consent, their name, surname, patronymic, date and place of birth, position, phone numbers, and email address may be included in such sources. Personal data can be excluded from publicly available sources at any time upon the employee's request or by court decision. INTILED will destroy or anonymize personal data when the purpose of processing is achieved or if processing is no longer required.
Rights of the Personal Data Subject
An individual whose personal data is processed by INTILED has the right to:
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Receive from INTILED confirmation of the fact that their personal data is being processed; the legal grounds and purposes of processing; information on the processing methods used; the name and location of INTILED; information about those who have access to personal data or to whom it may be disclosed based on an agreement with INTILED or federal law; a list of the personal data processed concerning the individual and its source, unless otherwise provided by federal law; information about the duration of personal data processing, including storage periods; information on how the individual can exercise their rights under Federal Law No. 152-FZ "On Personal Data"; details on potential cross-border data transfers; the name and address of the entity processing personal data on behalf of INTILED; other information provided by Federal Law No. 152-FZ or other federal laws;
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Request the correction of personal data, its blocking, or destruction if the data is incomplete, outdated, inaccurate, illegally obtained, or no longer necessary for the declared purpose of processing;
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Withdraw their consent to the processing of personal data;
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Demand the cessation of unlawful actions by INTILED regarding their personal data;
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Appeal to the Federal Service for Supervision of Communications, Information Technology, and Mass Media (Roskomnadzor) or in court if they believe INTILED is processing their personal data in violation of Federal Law No. 152-FZ "On Personal Data" or otherwise infringing on their rights and freedoms;
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Seek protection of their rights and lawful interests, including compensation for damages and/or moral harm in court.
Liability
In case of non-compliance with the provisions of this Policy, INTILED LLC will bear responsibility in accordance with the current legislation of the Russian Federation.