Policy of АО Economy Development Center on personal data processing

1. Introduction

1.1. Aimed at maintaining its business reputation and complying with the legislation of the Russian Federation, AO Economy Development Center recognizes ensuring confidentiality and security of personal data in the course of its business processes as an imperative task. To deliver thereon, personal data protection system has been introduced at AO Economy Development Center, is currently in effect and is reviewed (inspected) on a regular basis.

2. Personal data processing principles

2.1. Personal data are processed at AO Economy Development Center subject to the following principles:

lawfulness and fairness of personal data processing purposes and methods;
compliance of personal data processing purposes with those predefined and stated when collecting the personal data, as well as with the scope of authority of AO Economy Development Center;
compatibility of the scope and nature of the processed personal data, as well as personal data processing methods, to the purposes for which they are processed;
accuracy of the personal data, their relevance and sufficiency to the purposes for which they are processed, unacceptability of processing the personal data being excessive to the purposes for which they are processed;
ensuring personal data confidentiality and security.

3. Purposes of personal data processing

The main purposes of personal data processing at AO Economy Development Center are:

3.1. Implementation of functions, powers and duties of an employer in accordance with the Civil Code of the Russian Federation and the Labor Code of the Russian Federation;

3.2. Implementation of functions, powers and duties of an e-platform operator in accordance with the current legislation of the Russian Federation;

3.3. Reporting to the public supervisory authorities in accordance with the requirements of the current legislation of the Russian Federation;

3.4. Marketing of the products and services of the AO Economy Development Center;

3.5. Ensuring access control at the facilities of AO Economy Development Center.

4. Personal data processing procedures

4.1. AO Economy Development Center processes personal data of personal data subjects of the following categories:

For the purposes set forth in clause 3.1 of Section 3 of this Policy:

company employees;
immediate relatives of the employees.

For the purposes set forth in clauses 3.2 – 3.5 of Section 3 of this Policy:

authorized persons of the counterparties;
counterparties’ employees.

4.2. AO Economy Development Center may process the following personal data of personal data subjects not being employees of AO Economy Development Center, for the purposes set forth in clauses 3.2-3.5 of Section 3 of this Policy

first name, patronymic, last name;
passport details or those of any other personal identity document;
job-related information;
contact details (phone/fax number, еmail).

4.3. AO Economy Development Center may process personal data of job applicants and the employees of AO Economy Development Center for the purposes set forth in clause 3.1 of Section 3 of this Policy, to the extent established by the Labor Code of the Russian Federation, as well as other data subject to the consent of a personal data subject.

4.4. The terms of processing and storage of the personal data, as well as destruction procedure, are established for each of the purposes set forth in this Section 3 by an internal regulation of AO Economy Development Center, specifying, inter alia, the procedure of personal data processing.

4.5. Processing of special categories of personal data related to race, nationality, political opinions, religious or philosophical beliefs, health status and (or) private life, is prohibited at AO Economy Development Center, except for the cases stipulated by Part 2, Article 10, of the Federal Law No.152-FZ "On the Personal Data" of 27.07.2006.

4.6. AO Economy Development Center shall not process biometric data.

4.7. AO Economy Development Center shall not perform transboundary personal data transfer.

4.8. AO Economy Development Center shall not place the personal data in publicly available sources without a prior consent of the personal data subject, unless otherwise provided for by the legislation of the Russian Federation.

4.9. AO Economy Development Center may obtain a subject's personal data from a person not being a personal data subject, provided that AO Economy Development Center confirms availability of the grounds referred to in items 2-11, Part 1 of Article 6, Part 2 of Article 10 and Part 2 of Article 11 of the Federal Law No. 152-FZ "On the Personal Data" of 27.07.2006 or other grounds provided for by the Russian federal legislation.

4.10. Personal data may be processed at AO Economy Development Center both with and without automation tools applied.

4.11. Employees of AO Economy Development Center shall have the right of access to the personal data of personal data subjects on paper and electronic media within the scope of their job-related duties.

4.12. Transfer of the personal data of personal data subjects to the third persons shall be carried out in accordance with the requirements of applicable law.

4.13. AO Economy Development Center shall be entitled to assign processing of the personal data to a third party upon the consent of the personal data subject and in other cases provided for by the applicable laws of the Russian Federation, based on a contract concluded with such third party (hereinafter – the “Assignment”). A third party performing personal data processing upon assignment by AO Economy Development Center shall be obliged to comply with requirements for ensuring personal data protection in the course of their processing in personal data information systems, established by the regulatory acts of the Russian Federation.

5. Personal data security requirements fulfilled

5.1. Senior management of AO Economy Development Center are aware of the need of and interested in ensuring an appropriate level of protection of the personal data processed in the course of the company’s operating activities.

5.2. AO Economy Development Center implements legal, organizational and technical measures or causes to implement those to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision or distribution, as well as from any other unlawful actions to the personal data. Particularly, but not exclusively, AO Economy Development Center provides for the following:

appointed are the persons responsible for arranging personal data processing and ensuring personal data security;
potential damage that may be caused to personal data subjects has been assessed, and threats to the security of personal data have been identified and defined;
developed and implemented are internal regulations on personal data processing, as well as on establishing procedures aimed at prevention and detection of violations of the established procedures of personal data processing and elimination of the consequences of such violations;
when processing the personal data in the information systems, in place is a personal data protection system built with account taken of the current personal data threats and in compliance with the requirements of a federal executive authority in charge of security and a federal executive authority in charge of technical information protection and countering technical intelligence.

6. Operator’s details

6.1. Name: АО Economy Development Center (INN (TIN): 5034031535)

6.2. Registered address: 142600 Russia, Moscow region, Orekhovo-Zuyevo, 2А Babushkina St., room 37

6.3. Phone number: + 7 (495) 532 85 19

6.4. No. assigned in the Personal Data Operators Register: № 10-0164398

6.5. Officer responsible for personal data processing: Iliya Mikhailovich Burgasov

6.6. Responsible officer’s email: i.burgasov@b2b-center.ru