POLICY

REGARDING THE PROCESSING OF PERSONAL DATA

1.Purpose and scope of the document

     The policy regarding the processing of personal data determines the position and intentions of the ‘Uvelka’ Company. LLC ‘Resurs’ in the field of processing and protecting personal data of persons in contractual relations with the ‘Uvelka’ Company. LLC ‘Resurs’, ensuring their integrity and safety.

    The policy is intended for study and strict implementation by managers and employees of all structural divisions of the ‘Uvelka’ Company. LLC ‘Resurs’.

2.Purpose and principles of personal data processing

One of the priority tasks in the work of the ‘Uvelka’ Company. LLC ‘Resurs’ - compliance with the current legislation of the Russian Federation in the field of information security, as well as the requirements of the federal law dated June 27, 2006 No. 152-FZ ‘On personal data’, the main purpose of which is to ensure the protection of human and civil rights and freedoms when processing his personal data, in including protection of the rights to privacy, personal and family secrets.

Personal data means any information relating directly or indirectly to a specific or identifiable individual.

The purpose of collecting, processing, storing, as well as other actions with personal data of employees, students, or third parties (hereinafter personal data subjects) is to fulfill the obligations of the ‘Uvelka’ Company. LLC ‘Resurs’ under an agreement with them.

When processing personal data of subjects, the following principles are implemented:

-observance of the legality of receipt, processing, storage, as well as other actions with personal data;

-processing of personal data solely for the purpose of fulfilling obligations under a service agreement;

-collection of only those personal data that are minimally necessary to achieve the stated processing goals;

-implementation of measures to ensure the security of personal data during their processing and storage;

-observance of the rights of the subject of personal data to access his personal data.

3.Composition and methods of personal data processing

Processed personal data of the ‘Uvelka’ Company. LLC ‘Resurs’ may include:

-surname, name, patronymic;

-date of birth or age;

-passport data;

-address of residence;

-phone number, email address;

-other information necessary for the fulfillment of contractual obligations.

The ‘Uvelka’ Company. LLC ‘Resurs’ shall not process personal data concerning the health status, religion, nationality of the subject.

The ‘Uvelka’ Company. LLC ‘Resurs’ receives personal data only personally from the subject or its representative.

The processing of personal data takes place in both a manual and an automated way.

Only employees who have passed a certain admission procedure are allowed to process personal data, which include:

-familiarizing the employee with legally enforceable enactments (regulations, instructions, etc.) that strictly regulate the procedure and procedure for working with personal data;

-taking a subscription from the employee to maintain confidentiality with respect to personal data when working with them;

-obtaining by an employee and using in work the minimum necessary access rights to information systems containing personal data for the performance of labor duties.

Periodically the ‘Uvelka’ Company. LLC ‘Resurs’ conducts classes with employees processing personal data on information security topics and rules for working with confidential information.

4.Storage of personal data

The personal data of the subjects are stored in paper form (agreement, consent to the processing of personal data) and in electronic form. In electronic form, personal data is stored in the personal data information systems of the ‘Uvelka’ Company. LLC ‘Resurs’, as well as in archival copies of the databases of these systems. When storing personal data, organizational and technical measures are observed to ensure their safety and exclude unauthorized access to them. They include:

-the appointment of a unit or employee responsible for a particular method of storing personal data;

-limiting physical access to storage locations and media;

-accounting of all information systems and electronic media, as well as archival copies.

5.Measures to ensure the security of personal data during their processing

Ensuring the security of personal data in the ‘Uvelka’ Company. LLC ‘Resurs’ is achieved by the following measures:

-the appointment of an employee responsible for organizing the processing of personal data;

-conducting an internal audit of information systems containing personal data;

-development of a private model of threats to the security of personal data;

-the appointment of a responsible administrator for each information system;

-determination of the list of persons admitted to work with personal data;

-development and approval of local regulations governing the procedure for processing personal data, development of work instructions for operators and administrators of information systems;

-implementation of technical measures that reduce the likelihood of the implementation of threats to the security of personal data;

-conducting periodic checks of the security status of information systems.

6.Revision of the Policy

The revision of the provisions of this Policy is carried out periodically at least once a year, as well upon change of the legislation of the Russian Federation in the field of personal data.

After revising the provisions of this Policy, its updated version is published on the website.