ENERGYGROUP DEVELOPMENT LIMITED LIABILITY COMPANY

                                          regarding the processing of personal data

1. GENERAL


1.1. This Policy of ENERGYGROUP DEVELOPMENT LIMITED LIABILITY COMPANY regarding the processing of personal data (hereinafter referred to as the Policy) has been developed in pursuance of the requirements of paragraph 2 of part 1 of Art. 18.1 of the Federal Law of July 27, 2006 N 152-FZ “On Personal Data” (hereinafter referred to as the Law on Personal Data) in order to ensure the protection of the rights and freedoms of a person and citizen in the processing of his personal data, including the protection of the rights to privacy, personal and family secrets.
1.2. The Policy applies to all personal data processed by ENERGYGROUP DEVELOPMENT LIMITED LIABILITY COMPANY (hereinafter referred to as the Operator, ENERGYGROUP DEVELOPMENT LLC).
1.3. The Policy applies to relations in the field of personal data processing that arose with the Operator both before and after the approval of this Policy.
1.4. In pursuance of the requirements h. 2 Article. 18.1 of the Law on Personal Data, this Policy is published in the public domain on the Internet information and telecommunications network on the Operator's website.
1.5.Basic concepts used in the Policy:
personal data - any information relating directly or indirectly to a specific or identifiable natural person (subject of personal data);
personal data operator (operator) - a state body, municipal body, legal entity or individual, independently or jointly with other persons organizing and (or) carrying out the processing of personal data, as well as determining the purposes of processing personal data, the composition of personal data to be processed, actions (operations) performed with personal data;
processing of personal data - any action (operation) or a set of actions (operations) with personal data performed using automation tools or without their use. The processing of personal data includes, among other things:
• collection; 
• record;
 • systematization;
 • accumulation;
 • storage;
 • refinement (update, change); 
• extraction; 
• usage; 
• transfer (distribution, provision, access); 
• depersonalization; 
• blocking;
 • removal; 
• destruction;

automated processing of personal data - processing of personal data using computer technology;
dissemination of personal data - actions aimed at disclosing personal data to an indefinite circle of persons;
provision of personal data - actions aimed at disclosing personal data to a certain person or a certain circle of persons;
blocking of personal data - temporary suspension of the processing of personal data (unless the processing is necessary to clarify personal data);
destruction of personal data - actions, as a result of which it becomes impossible to restore the content of personal data in the information system of personal data and (or) as a result of which material carriers of personal data are destroyed;
depersonalization of personal data - actions as a result of which it becomes impossible to determine the ownership of personal data by a specific subject of personal data without the use of additional information;
personal data information system - a set of personal data contained in databases and information technologies and technical means that ensure their processing;
cross-border transfer of personal data - the transfer of personal data to the territory of a foreign state to an authority of a foreign state, a foreign individual or a foreign legal entity.

1.6. Basic rights and obligations of the Operator.
1.6.1. The operator has the right:
1) independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of the obligations provided for by the Law on Personal Data and the regulatory legal acts adopted in accordance with it, unless otherwise provided by the Law on Personal Data or other federal laws;
2) entrust the processing of personal data to another person with the consent of the subject of personal data, unless otherwise provided by federal law, on the basis of an agreement concluded with this person. A person who processes personal data on behalf of the Operator is obliged to comply with the principles and rules for the processing of personal data provided for by the Law on Personal Data;
3) in the event that the subject of personal data withdraws consent to the processing of personal data, the Operator has the right to continue processing personal data without the consent of the subject of personal data if there are grounds specified in the Law on Personal Data.
1.6.2. The operator is obliged:
1) organize the processing of personal data in accordance with the requirements of the Law on Personal Data;
2) respond to requests and requests from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
3) report to the authorized body for the protection of the rights of subjects of personal data (the Federal Service for Supervision of Communications, Information Technology and Mass Communications (Roskomnadzor)) at the request of this body the necessary information within 30 days from the date of receipt of such a request.
1.7. Basic rights of the subject of personal data. The subject of personal data has the right:
receive information regarding the processing of his personal data, except as otherwise provided by federal laws. The information is provided to the subject of personal data by the Operator in an accessible form, and it should not contain personal data relating to other subjects of personal data, unless there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it is established by the Law on Personal Data;
1) require the operator to clarify his personal data, block or destroy them if the personal data is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing, as well as take legal measures to protect their rights;
2) put forward the condition of prior consent when processing personal data in order to promote goods, works and services on the market;
3) appeal to Roskomnadzor or in court against illegal actions or inaction of the Operator when processing his personal data.
1.8. Control over the fulfillment of the requirements of this Policy is carried out by an authorized person responsible for organizing the processing of personal data by the Operator.
1.9. Responsibility for violation of the requirements of the legislation of the Russian Federation and regulations of ENERGYGROUP DEVELOPMENT LLC  the field of processing and protection of personal data is determined in accordance with the legislation of the Russian Federation.

2. Purposes of collecting personal data


2.1. The processing of personal data is limited to the achievement of specific, predetermined and legitimate purposes. It is not allowed to process personal data that is incompatible with the purposes of collecting personal data.
2.2. Only personal data that meet the purposes of their processing are subject to processing.2.3. The processing by the Operator of personal data is carried out for the following purposes:
• Ensuring compliance with the Constitution of the Russian Federation, federal laws and other regulatory legal acts of the Russian Federation;
 • implementation of its activities in accordance with the charter of ENERGYGROUP DEVELOPMENT LLC; 
• implementation of civil law relations; 
• accounting; 
• informing the subject of personal data by sending e-mails; 
• granting access to the personal data subject to the services, information and/or materials contained on the website;
 • sending notifications to the subject of personal data about new products and services, special offers and various events;

 • collection of information about the actions of the personal data subject on the Operator's website.
2.4. The processing of personal data of employees may be carried out solely for the purpose of ensuring compliance with laws and other regulatory legal acts.

3. Legal grounds for the processing of personal data


3.1. The legal basis for the processing of personal data is a set of regulatory legal acts, in pursuance of which and in accordance with which the Operator processes personal data, including:
• The Constitution of the Russian Federation; 
• Civil Code of the Russian Federation; 
• Labor Code of the Russian Federation;
• Tax Code of the Russian Federation; 
• Federal Law No. 14-FZ of 08.02.1998 “On Limited Liability Companies”; 
• Federal Law No. 402-FZ of 06.12.2011 “On Accounting”; 
• Federal Law No. 167-FZ of December 15, 2001 “On Mandatory Pension Insurance in the Russian Federation”; 
• other regulatory legal acts regulating relations related to the activities of the Operator.
3.2. The legal basis for the processing of personal data is also:
• charter of ENERGYGROUP DEVELOPMENT LLC;
 • agreements concluded between the Operator and subjects of personal data;
 • consent of personal data subjects to the processing of their personal data.

4. The scope and categories of personal data processed, categories of personal data subjects


4.1. The content and scope of the processed personal data must comply with the stated purposes of processing, provided for in sect. 2 of this Policy. The processed personal data should not be excessive in relation to the stated purposes of their processing.
4.2. The Operator may process personal data of the following categories of personal data subjects.
4.2.1. Clients of the Operator (their representatives):
• Full Name; 
• Male/Female
• citizenship; 
• Date and place of birth; 
• contact details, including e-mail address, telephone number; 
• cookies; 
• address of registration (including temporarily) at the place of residence/stay; 
• personal signature, including electronic; 
• other personal data provided by clients and contractors (individuals) necessary for the conclusion and execution of contracts.
4.2.2. Candidates for employment with the Operator:
Full name
Male/Female; 
• citizenship; 
• Date and place of birth; 
• Contact details; 
• information about education, work experience, qualifications; 
• other personal data provided by candidates in resumes and cover letters.
4.2.3. Employees and former employees of the Operator:
• Full Name; 
• Male/Female; 
• citizenship;
 • Date and place of birth; 
• image (photo); 
• passport data; 
• address of registration at the place of residence; 
• address of the actual residence;
 • Contact details; 
• individual taxpayer number;
 • insurance number of an individual personal account (SNILS); 
• information about education, qualifications, professional training and advanced training; 
• marital status, presence of children, family ties; 
• information about labor activity, including the presence of incentives, awards and (or) disciplinary sanctions; 
• data on marriage registration;
 • information about military registration; 
• information about disability; 
• information about income from the previous place of work; 
• other personal data provided by employees in accordance with the requirements of labor legislation.
4.2.4. Family members of the Operator's employees:
• Full Name;
 • relation degree;
 • year of birth; 
• other personal data provided by employees in accordance with the requirements of labor legislation.
4.2.5. Representatives (employees) of the Operator's clients and counterparties (legal entities):
• Full Name;
 • passport data; 
• Contact details; 
• replaced position; 
• other personal data provided by representatives (employees) of clients and contractors necessary for the conclusion and execution of contracts.
4.3. The processing by the Operator of biometric personal data (information that characterizes the physiological and biological characteristics of a person, on the basis of which it is possible to establish his identity) is carried out in accordance with the legislation of the Russian Federation.
4.4. The Operator does not process special categories of personal data relating to race, nationality, political views, religious or philosophical beliefs, health status, intimate life, except as provided by the legislation of the Russian Federation.

5. The procedure and conditions for the processing of personal data


5.1. The processing of personal data is carried out by the Operator in accordance with the requirements of the legislation of the Russian Federation. 
5.2. 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 it in cases provided for by the legislation of the Russian Federation.
 5.3. The operator carries out both automated and non-automated processing of personal data.
 5.4. Employees of the Operator whose duties include the processing of personal data are allowed to process personal data. 
5.5. The processing of personal data is carried out by:
• receiving personal data in oral and written form directly from the subjects of personal data;
            • obtaining personal data from publicly available sources; 
• entering personal data into journals, registers and information systems of the Operator; 
• use of other methods of personal data processing.
5.6. It is not allowed to disclose to third parties and distribute personal data without the consent of the subject of personal data, unless otherwise provided by federal law. Consent to the processing of personal data permitted by the subject of personal data for distribution is issued separately from other consents of the subject of personal data to the processing of his personal data.
The requirements for the content of the consent to the processing of personal data permitted by the subject of personal data for distribution are approved by Roskomnadzor.
5.7. The transfer of personal data to the bodies of inquiry and investigation, the Federal Tax Service, and other authorized executive bodies and organizations is carried out in accordance with the requirements of the legislation of the Russian Federation.
5.8. The operator takes the necessary legal, organizational and technical measures to protect personal data from unauthorized or accidental access to them, destruction, modification, blocking, distribution and other unauthorized actions, including:
The requirements for the content of consent to the processing of personal data authorized by the subject of personal data for distribution are approved by Roskomnadzor.
• determines threats to the security of personal data during their processing; 
• adopts local regulations and other documents regulating 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 accounting 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 exclude unauthorized access to them;     • organizes training for the Operator's employees who process personal data.
5.9. The operator stores personal data in a form that allows to determine the subject of personal data, no longer than required by the purposes of processing personal data, if the period of storage of personal data is not established by federal law, contract. 
5.10. When collecting personal data, including through the Internet information and telecommunications network, the Operator ensures recording, systematization, accumulation, storage, clarification (updating, changing), retrieval of personal data of citizens of the Russian Federation using databases located on the territory of the Russian Federation.

6. Update, correction, deletion and destruction personal data, responses to requests from subjects to access personal data


6.1. Confirmation of the fact of personal data processing by the Operator, legal grounds and purposes of personal data processing, as well as other information specified in Part 7 of Art. 14 of the Law on Personal Data are provided by the Operator to the subject of personal data or his representative when applying or upon receipt of a request from the subject of personal data or his representative. The information provided does not include personal data relating to other subjects of personal data, unless there are legal grounds for disclosing such personal data.
The request must contain:
• number of the main identity document of the subject of personal data or his representative, information on the date of issue of the specified document and the authority that issued it; 
• information confirming the participation of the subject of personal data in relations with the Operator (contract number, date of conclusion of the contract, conditional verbal designation and (or) other information), or information otherwise confirming the fact of processing personal data by the Operator;
 • signature of the personal data subject or his representative.
The request can be sent in the form of an electronic document and signed with an electronic signature in accordance with the legislation of the Russian Federation.
If in the appeal (request) of the personal data subject, in accordance with the requirements of the Law on Personal Data, all the necessary information is not reflected 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 subject of personal data to access his personal data may be limited in accordance with Part 8 of Art. 14 of the Law on Personal Data, including if the access of the subject of personal data to his personal data violates the rights and legitimate interests of third parties.
6.2. In the event that inaccurate personal data is detected when the subject of personal data or his representative contacts, or at their request or at the request of Roskomnadzor, the Operator blocks personal data relating to this subject of personal data from the moment of such request or receipt of the specified request for the period of verification, if the blocking of personal data data does not violate the rights and legitimate interests of the subject of personal data or third parties. If the fact of inaccuracy of personal data is confirmed, the Operator, on the basis of information provided by the subject of personal data or his representative or Roskomnadzor, or other necessary documents, clarifies personal data within seven working days from the date of submission of such information and removes the blocking of personal data. 
6.3. If unlawful processing of personal data is detected when a personal data subject or his representative or Roskomnadzor contacts (requests) the Operator blocks the unlawfully processed personal data relating to this personal data subject from the moment of such a request or receipt of a request.
6.4. Upon reaching the goals of processing personal data, as well as in the event that the subject of personal data withdraws consent to their processing, personal data shall be destroyed if:
• otherwise is not provided by the contract, the party to which, the beneficiary or the guarantor of which is the subject of personal data;
 • the operator is not entitled to process without the consent of the subject of personal data on the grounds provided for by the Law on Personal Data or other federal laws; 
• otherwise is not provided by another agreement between the Operator and the subject of personal data.

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