Policy of INTILED Ltd regarding processing of personal data

Registered office and place of business of INTILED Ltd: 3A, Progonnaja st., 192007 St.Petersburg.

Purpose and validities of the document

“The policy of INTILED Ltd (hereinafter also referred to as INTILED) with respect to processing of personal data” (hereinafter referred to as the Policy) determines the position and intentions of INTILED in the field of processing and protecting of personal data in order to respect and protect the rights and freedoms of each person and, in particular, the right to a private life , personal and family secrets, protection of one’s honor and honest name.

The Policy is strictly enforced by managers and employees of all divisions and branches of INTILED Ltd.

The Policy applies to all personal data of the subjects processed in Intiled, with or without the use of any automation tools.

Any subject of personal data shall have an access to the Policy.

Definitions

Personal data: any information related to a physical person (citizen) who is directly or indirectly defined or definable. In particular, such information includes the following: full name, year, month, date and place of birth, address, information about family, social, property status, and other information.

Personal data processing: any action (operation) or set of actions (operations) with personal data, performed with or without the use of any automation tools. Such actions (operations) may include the following: collection, receipt, record, systemization, accumulation, storage, rectification (updates, changes), extraction, usage, transfer (distribution, provision, access), anonymization, blocking, deleting, destroying of any personal data.

Subjects of personal data

INTILED Ltd processes the personal data of the following persons: employees of INTILED Ltd; subjects with whom civil law contracts are concluded; candidates for any vacant posts of INTILED Ltd; clients and partners of INTILED Ltd; registered users of INTILED Ltd website.

Principles and conditions for personal data processing

The personal data security is understood by INTILED Ltd as protection of personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, dissemination of personal data, and other illegal actions in relation to personal data; INTILED Ltd takes necessary legal, organizational, and technical measures to protect such personal data.

Processing and security measures in respect of personal data in INTILED Ltd are carried out in accordance with the requirements of the Federal Law No. 152-FZ “On Personal Data” of the Constitution of the Russian Federation, regulations thereunder, other defining cases and peculiarities of processing of personal data as per any federal laws of the Russian Federation, directive and methodological documents of the FSTEC of Russia and of the Russian Federal Security Service.

When processing any personal data, INTILED Ltd adheres to the following principles: legality and equitable basis; limiting of personal data processing in order to achieve specific, pre-determined, and legitimate purposes; prevention of personal data processing incompatible with any purposes of such collection of personal data; prevention of combining databases containing personal data, processing of which is carried out for any purposes incompatible with each other; processing of personal data that meet the purposes of such processing; content compliance.

INTILED Ltd processes personal data only if at least one of the following conditions exists: processing of personal data is carried out with the consent of the subject of personal data to such processing of his or her personal data; processing of personal data is necessary in oder to achieve the objectives provided for by law for implementation and performance of functions, powers and responsibilities imposed by the legislation of the Russian Federation on operator of functions, authorities and liabilities; processing of personal data is necessary for performance of any contract to which the subject of personal data is presented by a beneficiary or a guarantor, and for conclusion of any contract on the initiative of a personal data subject or any contract where the personal data subject will be a beneficiary or a guarantor; processing of personal data is necessary for implementation of rights and legitimate interests of INTILED Ltd or third parties or for achievement of socially significant purposes, provided that the rights and freedoms of a subject of personal data are not thereby violated; processing of personal data, access of an unlimited circle of persons to which is provided by a subject of personal data or at his or her request; processing of personal data subject to publication or mandatory disclosure in accordance with the federal law.

In cases stipulated in the legislation of the Russian Federation, INTILED Ltd has the right to transfer the personal data of citizens. For the purposes of information support, public sources of personal data of employees, including directories and address books, may be created in INTILED Ltd. Any public sources of personal data, with the consent of the employee, may include surname, name, patronymic, date and place of birth, position, contact phone numbers, e-mail address of such employee. Any information about an employee must be deleted at any time from any publicly available sources of personal data at the request of such employee or by decision of the court or other competent public authority. INTILED Ltd destroys or anonymizes any personal data upon its achievement of processing purposes or in case of loss of any need to achieve such processing purposes.

Rights of a subject of personal data

A citizen whose personal data is processed by INTILED Ltd has the right:

• to receive the following from INTILED Ltd: confirmation of any fact of processing of personal data by INTILED Ltd; legal grounds and purposes for processing of personal data; information on methods of processing of personal data used by INTILED Ltd; name and location of INTILED Ltd; information on persons who have access to personal data or who can disclose personal data on the basis of a contract with INTILED Ltd or on the basis of the federal law; a list of processed personal data in relation to the citizen from whom the request was received and the source of their receipt, unless another procedure for providing such data is stipulated in the federal law; information on terms of processing of personal data, including times of their storage; information on procedures for exercise by a citizen of his or her rights provided for by the Federal Law No. 152-FZ “On Personal Data”; information on transfrontier transfer of personal data that is being carried out or about to be expected; name and address of any person carrying out such processing of personal data on behalf of INTILED Ltd; other information provided for by the Federal Law No. 152-FZ “On Personal Data” or other federal laws;
• to ask for rectification of his or her personal data, blocking or destruction of such personal data in the event that such personal data are incomplete, outdated, inaccurate, illegally obtained, or are not necessary for any stated purpose of processing;
• to withdraw his or her consent to any processing of his or her personal data;
• to demand any remedies for illegal actions of INTILED Ltd in respect of his or her personal data;
• to appeal against any actions or inactions of INTILED Ltd to the Federal Service for Supervision in the Sphere of Communications, Information Technology and Mass Communications (Roskomnadzor) or to appeal to a court if such citizen believes that INTILED Ltd processes his or her personal data in violation of the requirements of the Federal Law No. 152-FZ “On Personal Data” or otherwise violates his or her rights and freedoms;
• to protect his or her rights and legitimate interests, including compensation for damages and/or compensation for moral harm in court.

Liability

In case of failure to comply with any provisions of this Policy, INTILED Ltd shall be liable in accordance with the current legislation of the Russian Federation.