Policy on personal data processing

Policy of the Limited Liability Company
“Zagorodnaya Usadba"
in relation to the processing of personal data and information about the implemented requirements for the protection of personal data
TIN 6950231857, OGRN 1196952011486

1. General provisions
1.1. This Policy of Zagorodnaya Usadba LLC regarding the processing of personal data and information on implemented requirements for personal data protection (hereinafter referred to as the Policy) has been developed in compliance with the requirements of clause 2, Part 1, Article 18.1 of Federal Law No. 152-FZ of 27.07.2006 “On Personal Data” (hereinafter referred to as the Personal Data Law) in in order to ensure the protection of human and civil rights and freedoms when processing 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 the limited liability company “Zagorodnaya Usadba” (hereinafter referred to as the Operator).
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 compliance with the requirements of Part 2 of Article 18.1 of the Law on Personal Data, this Policy is published freely on the Internet 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 (personal data subject);
personal data operator (operator) is a state body, municipal body, legal entity or individual who independently or jointly with other persons organize and (or) process personal data, as well as determine the purposes of personal data processing, the composition of personal data to be processed, actions (operations) performed with personal data.;
personal data processing is any action (operation) or set of actions (operations) with personal data performed with or without automation tools. The processing of personal data includes, but is not limited to:
collection;
record;
systematization;
accumulation;
keeping;
clarification (update, change);
extraction;
usage;
transmission (distribution, provision, access);
depersonalization;
blocking;
removal;
destruction;
automated personal data processing is the processing of personal data using computer technology;
dissemination of personal data - actions aimed at disclosing personal data to an unspecified group of people;
providing personal data is an action aimed at disclosing personal data to a specific person or a specific group of people.;
blocking of personal data is the temporary termination of the processing of personal data (except in cases where 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 personal data information system and (or) as a result of which the material carriers of personal data are destroyed;
Depersonalization of personal data is an action that makes it impossible to determine whether personal data belongs to a specific personal data subject without using additional information.;
The personal data information system is a set of personal data contained in databases and information technologies and technical means that ensure their processing.
1.6. Basic rights and obligations of the Operator.
1.6.1. The Operator has the right to:
independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations stipulated by the Law on Personal Data and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Law on Personal Data or other federal laws.;
to entrust the processing of personal data to another person with the consent of the personal data subject, unless otherwise provided by federal law, on the basis of a contract concluded with this person. The person who processes personal data on behalf of the Operator is obliged to comply with the principles and rules of personal data processing provided for by the Law on Personal Data, to respect the confidentiality of personal data, and to take the necessary measures to ensure compliance with the obligations provided for by the Law on Personal Data.;
if the personal data subject withdraws consent to the processing of personal data, the Operator has the right to continue processing personal data without the consent of the personal data subject, provided there are grounds specified in the Personal Data Act.
1.6.2. The Operator is obliged to:
organize the processing of personal data in accordance with the requirements of the Law on Personal Data;
respond to requests and requests from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Act;
notify the authorized body for the protection of the rights of personal data subjects (the Federal Service for Supervision of Communications, Information Technology and Mass Communications (Roskomnadzor)) upon request of this body, the necessary information is provided within 10 working days from the date of receipt of such request. This period may be extended, but not for more than five business days. To do this, the Operator must send a reasoned notification to Roskomnadzor indicating the reasons for extending the deadline for providing the requested information.;
in accordance with the procedure established by the federal executive governmental body authorized in the field of security, to ensure interaction with the state system for detecting, preventing and eliminating the consequences of computer attacks on information resources of the Russian Federation, including informing it about computer incidents that have resulted in the unlawful transfer (provision, dissemination, access) of personal data.
1.7. Basic rights of the personal data subject. The personal data subject has the right to:
receive information regarding the processing of his personal data, except in cases provided for by federal laws. The information is provided to the personal data subject by the Operator in an accessible form, and it should not contain personal data related to other personal data subjects, except in cases where there are legitimate grounds for the disclosure of such personal data. The list of information and the procedure for obtaining it are established by the Law on Personal Data;
to require the operator to clarify his personal data, block or destroy them if the personal data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated purpose of processing, as well as to take legal measures to protect their rights.;
give prior consent to the processing of personal data in order to promote goods, works and services on the market;
to appeal to Roskomnadzor or in court against illegal actions or omissions of the Operator when processing his personal data.
1.8. Control over the fulfillment of the requirements of this Policy is carried out by the Operator.
1.9. Responsibility for violation of the requirements of the legislation of the Russian Federation and regulations in the field of personal data processing and protection is determined in accordance with the legislation of the Russian Federation.

2. Purposes of personal data collection
2.1. The processing of personal data is limited to the achievement of specific, predetermined and legitimate purposes. Processing of personal data incompatible with the purposes of personal data collection is not allowed.
2.2. Only personal data that meets the purposes of their processing is subject to processing.
2.3. The processing of personal data by the Operator is carried out for the following purposes:
carrying out its activities, including the conclusion and execution of contracts with counterparties;
enforcement of labor legislation within the framework of labor and other directly related relations,
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 personal data processing
3.1. The legal basis for the processing of personal data is a set of regulatory legal acts, in compliance with which and in accordance with which the Operator processes personal data, including:
The Constitution of the Russian Federation;
The Civil Code of the Russian Federation;
The Labor Code of the Russian Federation;
The Tax Code of the Russian Federation;
other regulatory legal acts regulating relations related to the Operator's activities.
3.2. The legal basis for the processing of personal data are also:
contracts concluded between the Operator and the subjects of personal data;
consent of personal data subjects to the processing of their personal data.

4. Scope and categories of personal data processed,categories of personal data subjects
4.1. The content and scope of the personal data being processed must comply with the stated purposes of processing provided for in sec. 2 of this Policy. The personal data being processed should not be redundant 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. Candidates for employment with the Operator - for the purposes of implementing labor legislation within the framework of labor and other directly related relations:
last name, first name, patronymic;
floor;
citizenship;
date and place of birth;
contact information;
information about education, work experience, qualifications;
other personal information provided by candidates in resumes and cover letters.
4.2.2. Employees and former employees of the Operator - for the purposes of implementing labor legislation within the framework of labor and other directly related relations:
last name, first name, patronymic;
floor;
citizenship;
date and place of birth;
image (photo);
passport data;
address of registration at the place of residence;
actual residence address;
contact information;
taxpayer's individual number;
insurance number of an individual personal account (SNILS);
information about education, qualifications, professional training and professional development;
marital status, children, family ties;
information about employment, including the availability of incentives, awards and (or) disciplinary penalties;
marriage registration data;
information about military registration;
disability information;
information about withholding alimony;
information about income from a previous job;
other personal data provided by employees in accordance with the requirements of labor legislation.
4.2.3. Clients and counterparties of the Operator (individuals) - for the purposes of carrying out their activities:
last name, first name, patronymic;
address of registration at the place of residence;
contact information;
other personal data provided by clients and counterparties (individuals) necessary for the conclusion and execution of contracts.
4.2.4. Representatives (employees) of the Operator's clients and counterparties (legal entities) - for the purposes of carrying out their activities:
last name, first name, patronymic;
passport data;
contact information;
current position;
other personal data provided by representatives (employees) of clients and counterparties necessary for the conclusion and execution of contracts.
4.3. The Operator does not process biometric personal data and special categories of personal data related to race, nationality, political views, religious or philosophical beliefs, health status, intimate life, except in cases provided for by the legislation of the Russian Federation.

5. Procedure and conditions of personal data processing
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 processes personal data for each purpose of their processing in the following ways:
non-automated processing of personal data;
automated processing of personal data with or without transmission of the received information via information and telecommunication networks;
mixed processing of personal data.
5.4. The processing of personal data for each purpose of processing specified in clause 2.3 of the Policy is carried out by:
obtaining personal data in writing via the Internet directly from the subjects of personal data;
using other methods of personal data processing.
5.5. Disclosure and dissemination of personal data to third parties is prohibited without the consent of the personal data subject, unless otherwise provided by federal law.
5.6. The transfer of personal data to the bodies of inquiry and investigation, the Federal Tax Service, the Social Fund of Russia and other authorized executive authorities and organizations is carried out in accordance with the requirements of the legislation of the Russian Federation.
5.7. The Operator takes the necessary legal, organizational and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, distribution and other unauthorized actions.
5.8. The operator stores personal data in a form that makes it possible to identify the subject of personal data, no longer than required by each purpose of personal data processing, unless the period of storage of personal data is established by federal law, contract.
5.8.1. Personal data on paper media is stored during the retention periods of documents for which these periods are stipulated by the legislation on archival affairs in the Russian Federation (Federal Law No. 125-FZ of 22.10.2004 "On Archival Affairs in the Russian Federation", a list of standard administrative archival documents formed in the course of the activities of state bodies, local governments and organizations, indicating the terms of their storage (approved by the Order of the Federal Archive dated December 20, 2019 N 236)).
5.8.2. The storage period of personal data processed in personal data information systems corresponds to the storage period of personal data on paper.
5.9. The Operator stops processing personal data in the following cases::
the fact of their illegal processing has been revealed. The deadline is within three working days from the date of detection.;
the goal of their processing has been achieved;
the consent of the personal data subject to the processing of the specified data has expired or been revoked when, according to the Law on Personal Data, the processing of this data is allowed only with consent.
5.10. Upon achieving the purposes of personal data processing, as well as in the event that the personal data subject withdraws consent to their processing, the Operator stops processing this data, unless
otherwise provided by an agreement to which the personal data subject is a party, beneficiary or guarantor.;
The operator does not have the right to process personal data without the consent of the personal data subject on the grounds provided for by the Law on Personal Data or other federal laws.;
no other agreement is provided for between the Operator and the personal data subject.
5.11. When 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 is terminated, except in cases provided for by the Law on Personal Data. The specified period may be extended, but not more than five working days. To do this, the Operator must send a reasoned notification to the subject of personal data indicating the reasons for the extension of the period.
5.12. When collecting personal data, including through the Internet information and telecommunications network, the Operator ensures the recording, systematization, accumulation, storage, clarification (updating, modification), extraction of personal data of citizens of the Russian Federation using databases located on the territory of the Russian Federation, except for the cases specified in the Law on Personal Data. data.

6. Updating, correction, deletion, destruction of personal data, responses to requests from subjects for access to personal data
6.1. 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, are provided by the Operator to the personal data subject or his representative within 10 working days from the date of request or receipt of a request from the personal data subject or his representative. This period may be extended, but not for more than five business days. To do this, the Operator should send a reasoned notification to the personal data subject indicating the reasons for extending the deadline for providing the requested information.
The information provided does not include personal data related to other subjects of personal data, except in cases where there are legitimate grounds for the disclosure of such personal data.
6.2. In case of detection of inaccurate personal data when contacting a personal data subject or his representative, or at their request or at the request of Roskomnadzor, the Operator blocks personal data related to this personal data subject from the moment of such request or receipt of the specified request for the verification period, if blocking personal data does not violate the rights and legitimate interests of the subject personal data or third parties.
In case of confirmation of the inaccuracy of personal data, the Operator, based on information provided by the personal data subject 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 personal data.
6.3. In case of detection of unlawful processing of personal data when contacting (requesting) a personal data subject or his representative or Roskomnadzor, the Operator shall block unlawfully processed personal data related to this personal data subject from the moment of such request or receipt of the request.
6.4. If the Operator, Roskomnadzor or any other interested person identifies the fact of unlawful or accidental transfer (provision, dissemination) of personal data (access to personal data), which has resulted in a violation of the rights of personal data subjects, the Operator:
within 24 hours, notifies Roskomnadzor of the incident, the alleged causes 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, as well as 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).
6.5. Procedure for the destruction of personal data by the Operator.
6.5.1. Conditions and deadlines for the destruction of personal data by the Operator:
achievement of the purpose of personal data processing or loss of the need to achieve this goal - in within 30 days;
achieving the maximum retention period for documents containing personal data is within 30 days.;
the provision by the personal data subject (his representative) of confirmation that the personal data was obtained illegally or is not necessary for the stated purpose of processing - within seven working days.;
revocation by the personal data subject of consent to the processing of his personal data, if their retention is no longer required for the purpose of their processing, within 30 days.
6.5.2. Upon achieving the purpose of personal data processing, as well as in the case of revocation by the personal data subject of consent to their processing, personal data is subject to destruction if:
nothing else is provided for in the contract to which the personal data subject is a party, beneficiary or guarantor.;
The operator does not have the right to process personal data without the consent of the personal data subject on the grounds provided for by the Law on Personal Data or other federal laws.;
no other agreement is provided for between the Operator and the personal data subject.