PRIVACY POLICY GVA LLC

Approved by Order No. b / n dated 07.10.2019

General Director of LLC "GVA"

1. General Provisions

   1.1. This Personal Data Processing Policy (hereinafter referred to as the Policy) has been drawn up in accordance with paragraph 2 of Article 18.1 of the Federal Law "On Personal Data" No. 152-FZ dated July 27, 2006, as well as other regulatory legal acts of the Russian Federation in the field of protection and processing of personal data and applies to all personal data (hereinafter referred to as data) that the Organization (hereinafter referred to as the Operator, Company) can receive from the subject of personal data, which is a party to a civil law contract, from an Internet user (hereinafter referred to as the User) during the time of use by him of any of the sites, services, services, programs, products or services of GVA LLC, as well as from the subject of personal data, which is with the Operator in a relationship regulated by labor legislation (hereinafter referred to as the Employee).
   1.2. The operator ensures the protection of processed personal data from unauthorized access and disclosure, misuse or loss in accordance with the requirements of the Federal Law of July 27, 2006 No. 152-FZ "On Personal Data".
   1.3. The Operator has the right to make changes to this Policy. When changes are made, the heading of the Policy indicates the date of the last revision of the revision. The new version of the Policy comes into force from the moment it is posted on the Internet at https://mil-team.ru/privacy., unless otherwise provided by the new version of the Policy.

2. Terms and accepted abbreviations

   Personal data - any information relating to a directly or indirectly identified or identifiable natural person (subject of 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, but is not limited to, the collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion and 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.
   Providing personal data - actions aimed at disclosing personal data to a certain person or a certain circle of persons.
   Personal data information system (PDIS) - a set of personal data contained in databases and information technologies and technical means that ensure their processing.
   Blocking of personal data is a 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.
   Cross-border transfer of personal data is 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.
   Operator - an organization that independently or jointly with other persons organizes the processing of personal data, as well as determines the purposes of processing personal data to be processed, actions (operations) performed with personal data. The operator is the Limited Liability Company “JVIA”, located at the address: 107140, Moscow, 1st Krasnoselsky per., 3, under / p / k / office 1 / I / 75 / 3g. The Operator's website in this Policy and other local documents of the Operator means the following websites: https://mil-team.ru/ or http://mil-team.com/.

3. Processing of personal data

   3.1. Receiving personal data.
     3.1.1. All personal data should be obtained from the subject himself. If the personal data of the subject can only be obtained from a third party, then the subject must be notified of this or consent must be obtained from him.
     3.1.2. The operator must inform the subject of the purposes, intended sources and methods of obtaining personal data, the nature of the personal data to be obtained, the list of actions with personal data, the period during which the consent is valid and the procedure for its withdrawal, as well as the consequences of the subject's refusal to give written consent to receiving them.
     3.1.3. Documents containing personal data are created by:
     – copies of original documents (passport, education certificate, TIN certificate, pension certificate, etc.);
     – entering information into accounting forms;
     – obtaining the originals of the necessary documents (employment record, medical report, characteristics, resume, etc.).
   3.2. Processing of personal data.
     3.2.1. The processing of personal data is carried out:
     – with the consent of the subject of personal data to the processing of his personal data;
     – in cases where the processing of personal data is necessary for the implementation and fulfillment of the functions, powers and duties assigned by the legislation of the Russian Federation;
     – in cases where the processing of personal data is carried out, access to an unlimited number of persons to which is provided by the subject of personal data or at his request (hereinafter referred to as personal data made public by the subject of personal data).
     3.2.2. Purposes of personal data processing:
     – implementation of labor relations;
     – implementation of civil law relations;
     – to discuss employment prospects with the User;
     – to consider the User for an open vacant position;
     – to test the User's skills, qualifications and business qualities; – to make a final decision on the employment of the User;
     – to prepare for the conclusion of an employment contract in case of successful selection of the User for an open vacant position;
     – to inform Users about suitable vacancies in terms of length of service and specialization;
     – to comply with the requirements of applicable law;
     – to conduct analytics to improve the efficiency of recruitment processes;
     – to check for conflicts of interest;
     – to send invitations to events held by the Operator;
     – for sending information and other materials related to the activities of the Operator;
     – to collect feedback on the employment process;
     – to communicate with representatives/employees of the Operator's clients and contractors to discuss proposals for joint projects;
     – to communicate with the User, in connection with filling out the feedback form on the site, including sending notifications, requests and information for processing, agreeing on proposals and discussing them, executing agreements and contracts.
     3.2.3. Categories of personal data subjects.
The personal data of the following personal data subjects are processed:
     – individuals who are in labor relations with the Company; – individuals who resigned from the Company;
     – individuals who are candidates for employment;
     – individuals who are representatives/employees of the Operator's clients and counterparties;
     – individuals who are in civil law relations with the Company;
     – individuals who are Users of the site https://mil-team.ru/ or http://mil-team.com/.
     3.2.4. Personal data processed by the Operator:
     – data obtained during the implementation of labor relations;
     – data obtained for the selection of candidates for work;
     – data obtained for discussion of proposals for joint projects with representatives/employees of the Operator's clients and counterparties;
     – data obtained in the course of civil law relations;
     – data received from Users of the site https://mil-team.ru/ or http://mil-team.com/.
     3.2.5. The processing of personal data is carried out:
     – using automation tools;
     – without the use of automation tools.
   3.3. Storage of personal data.
     3.3.1. Personal data of subjects can be obtained, further processed and transferred to storage both on paper and in electronic form.
     3.3.2. Personal data recorded on paper are stored in locked cabinets or in locked rooms with limited access rights.
     3.3.3. Personal data of subjects processed using automation tools for different purposes are stored in different folders.

     3.3.4. It is not allowed to store and place documents containing personal data in open electronic catalogs (file hosting) in ISPD.

     3.3.5. The storage of personal data in a form that allows determining the subject of personal data is carried out no longer than the purposes of their processing require, and they are subject to destruction upon achievement of the purposes of processing or in case of loss of the need to achieve them.
   3.4. Destruction of personal data.
     3.4.1. The destruction of documents (carriers) containing personal data is carried out by burning, crushing (grinding), chemical decomposition, turning into a shapeless mass or powder. A shredder may be used to destroy paper documents.
     3.4.2. Personal data on electronic media is destroyed by erasing or formatting the media.
   3.5. Transfer of personal data.
     3.5.1. The operator transfers personal data to third parties in the following cases:
     – the subject has expressed his consent to such actions;
     – the transfer is provided for by Russian or other applicable legislation within the framework of the procedure established by law.
     3.5.2. List of persons to whom personal data is transferred.
     – The Pension Fund of the Russian Federation for accounting (legally);
     – Tax authorities of the Russian Federation (legally);
     – The Social Insurance Fund of the Russian Federation (legally);
     – Territorial fund of obligatory medical insurance (legally);
     – insurance medical organizations for compulsory and voluntary medical insurance (legally);
     – banks for payroll (on the basis of an agreement);

     – bodies of the Ministry of Internal Affairs of Russia in cases established by law.


4. Basic rights and obligations of the subject of personal data and the Operator

   4.1. Basic rights of the subject of personal data.
The subject has the right to access his personal data and the following information:
     – confirmation of the fact of processing personal data by the Operator;
     – legal grounds and purposes for the processing of personal data;
     – the purposes and methods used by the Operator for processing personal data; – the name and location of the Operator, information about persons (excluding employees of the Operator) who have access to personal data or to whom personal data may be disclosed on the basis of an agreement with the Operator or on the basis of federal law;
     – terms of processing personal data, including the terms of their storage;
     – the procedure for the exercise by the subject of personal data of the rights provided for by the Federal Law;
     – the name or surname, name, patronymic and address of the person who processes personal data on behalf of the Operator, if the processing is or will be entrusted to such a person;
     – contacting the Operator and sending requests to him;
     – appeal against the actions or inaction of the Operator.
In order to protect their personal data stored by the Operator, the subject of personal data has the right to:
     – request the deletion or correction of incorrect or incomplete personal data;
     – receive free, free access to your personal data, including the right to receive copies of any record containing personal data;
     – supplement personal data of an evaluative nature with a statement expressing his own point of view;
     – designate their representatives to protect their personal data;
     – demand the preservation and protection of their personal and family secrets;
     – appeal in court any illegal actions or omissions of the Operator in the processing and protection of his personal data.
   4.2. PD subjects whose personal data is processed by the Operator are obliged to:
     – provide reliable information about yourself and provide documents containing personal data, the composition of which is established by the legislation of the Russian Federation and the Operator's local regulations to the extent necessary for the purpose of processing;
     – inform the Operator about the clarification (updating, changing) of their personal data.
   4.3. Persons who have provided the Operator with false information about themselves or information about another subject of personal data without the consent of the latter, are liable in accordance with the legislation of the Russian Federation
   4.4. The operator has the right:
     – receive from the subject of personal data reliable information and / or documents containing personal data;
     – in the event that the subject of personal data withdraws consent to the processing of personal data, as well as sending an appeal with a request to stop processing 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;

     – 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.

   4.5. The operator is obliged:
     – when collecting personal data, provide information on the processing of personal data;
     – in cases where personal data was not obtained from the subject of personal data, notify the subject;
     – in case of refusal to provide personal data, the consequences of such refusal are explained to the subject;
     – publish or otherwise provide unrestricted access to a document that defines its policy regarding the processing of personal data, to information about the implemented requirements for the protection of personal data;
     – take the necessary legal, organizational and technical measures or ensure their adoption to protect personal data from unauthorized or accidental access to them, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other illegal actions in relation to personal data;
     – respond to requests and appeals of personal data subjects, their representatives and the authorized body for the protection of the rights of personal data subjects;
     – to eliminate the violations committed or, if it is impossible to eliminate, destroy personal data, as well as notify the personal data subject or the authorized body of their actions in case of revealing false personal data or illegal actions with them, upon contact or at the request of the personal data subject or his a legal representative or an authorized body for the protection of the rights of subjects of personal data;
     – the Operator's employees, whose duty is to process requests and appeals of personal data subjects, are obliged to provide each subject with the opportunity to familiarize themselves with documents and materials containing their personal data, unless otherwise provided by the legislation of the Russian Federation;
     – make the necessary changes, destroy or block them, as well as notify the personal data subject of his actions in the event that the PD subject provides facts about incomplete, outdated, inaccurate or illegally obtained personal data;

     – make the necessary changes, destroy or block them, as well as notify the personal data subject of his actions in the event that the PD subject provides facts about incomplete, outdated, inaccurate or illegally obtained personal data.


5. Composition of personal data processed by the Operator

   5.1. The operator processes personal data of the following categories of personal data subjects:
     5.1.1. Personal data of the Operator's employees.
When employed by an employee of the Operator responsible for personnel records management, for the implementation of personnel records, a personal file of the employee is drawn up, in which documents / copies of documents containing the following personal and biographical data of the employee are placed:
     – general information (full name of the employee, date of birth, place of birth, citizenship (citizenship), education, profession, work experience, marital status, family composition, passport details, address of residence);
     – information about military registration;
     – other data required when applying for a job in accordance with the requirements of labor legislation.
In the future, the personal file of the employee is entered:
     – information about transfers to another job;
     – information about certification;
     – information about advanced training;
     – information about social benefits to which the employee is entitled in accordance with the law.
The purposes of processing personal data of the Operator's employees:
     – maintenance of personnel records of employees regulated by the legislation of the Russian Federation;
     – accounting of the working time of employees;
     – calculation of wages of employees;
     – maintaining tax records;
     – maintenance of military records;
     – provision of regulated reporting to state bodies;
     – archival data storage;
     – assistance to the employee in advanced training, training, promotion, use of various types of benefits.
The receipt and processing of personal data of an employee of the Operator must be carried out exclusively for the specified purposes.
The received personal data necessary to achieve the above goals are reflected in the employee's personal file in accordance with the requirements of labor legislation and the Operator's internal regulatory documents governing personnel records management and accounting.
The receipt and processing of personal data of an employee should not infringe on the rights and freedoms guaranteed to him by the Constitution of the Russian Federation as a citizen of the Russian Federation.
   5.1.2. Personal data of relatives of the Operator's employees.
The processing of personal data of close relatives of an employee of the Operator is carried out in the amount provided for by the unified form No. T-2, approved by the Decree of the State Statistics Committee of the Russian Federation of 05.01.2004 No. 1 "On approval of unified forms of primary accounting documentation for accounting for labor and its payment", or in cases established by the legislation of the Russian Federation (receiving alimony, registration of access to state secrets, registration of social payments).
The purposes of processing personal data of relatives of the Operator's employees:

     – ensuring compliance with the laws of the Russian Federation and other regulatory legal acts, providing guarantees and compensations to the Operator's employees and their close relatives established by the current legislation and local regulations of the Operator.

     5.1.3. Personal data of former employees of the Operator.
The processing of personal data of former employees of the Operator is carried out to the extent necessary in the framework of accounting and tax accounting, as well as compliance with federal laws and other regulatory legal acts of the Russian Federation.
Purposes of processing personal data of former employees of the Operator:
     – ensuring compliance with the laws of the Russian Federation and other regulatory legal acts, including in terms of accounting and tax accounting, ensuring archival storage of documents, providing guarantees and compensations established by the current legislation and local regulations of the Operator.
     5.1.4. Personal data of the Operator's participants.
When processing the personal data of the Operator's participants, an authorized employee processes the following personal data:
     – Full Name;
     – passport data (series and number of the identity document, date of issue of the identity document, and information about the issuing authority);
     – address of registration and actual residence;
     – contact phone number;
     – E-mail address;
     – information about the participation share in the authorized capital of the Operator, its payment and the date of transition;
     – information about the participant's affiliates capable of influencing the activities of the Operator;
     – information about the personal (settlement) account, as well as about the credit institution (bank) in which an account is opened for transferring dividends;
The purposes of processing personal data of the Operator's participants:
     – maintaining a list of the Operator's participants;
     – keeping records of dividend payments;
     – Ensuring compliance with the provisions of Federal Law No. 14-FZ of February 8, 1998 “On Limited Liability Companies” and other legal acts of the Russian Federation.
     5.1.5. Personal data of the candidates of the Operator (individuals).
The composition and volume of personal data of candidates and representatives of other companies (individuals) is determined in accordance with the legislation of the Russian Federation, which include:
     – Full Name;
     – passport data (series and number of the identity document, date of issue of the identity document, and information about the issuing authority);
     – address of registration;
     – contact details (email, phone number, postal address, telegram);
     – Date of Birth;
     – Place of Birth;
     – citizenship / residence permit;
     – floor;
     – Family status;
     – work permit;
     – data from other documents;
     – profiles in social networks;
     – information about education and specialization;
     – information about seniority and work experience;
     – characteristics from previous jobs;
     – information about the expected salary;
     – information about skills and business qualities;
     – information about health (if required to participate in the competition for an open vacant position);
     – photo;
     – test task results;
     – information required to pass the conflict of interest screening;
     – other information specified by the subject of personal data in the summary or otherwise provided to the Operator for the purposes listed in section 3 of the Policy. The purposes of processing personal data of candidates of the Operator (individuals):
     – implementation of the Operator's statutory goals;
     – preparation, conclusion, execution and termination of civil law contracts;
     – implementation of other transactions in accordance with the legislation of the Russian Federation.
     5.1.6. Personal data of representatives/employees of the Operator's clients and contractors (legal entities).
The personal data of representatives/employees of the Operator's clients and counterparties (legal entities) includes:
     – Full Name;
     – contact details (email, phone number, postal address, telegram);
The purposes of processing personal data of representatives/employees of the Operator's clients and counterparties (legal entities):
     – confirmation of the authority of the PD subject (representative/employee) to act on behalf of the Operator’s clients and counterparties (legal entities);

     – execution of concluded contracts.

     5.1.7. Passive collection of personal data about the current connection in terms of the User's statistical information. The Operator's websites may collect statistical data about the user, including:
     – visited pages;
     – the number of page visits;
     – duration of the user session;
     – entry points (third-party sites from which the user follows the link to the Operator's sites);
     – exit points (links on the Operator's websites, through which the user goes to third-party websites);
     – country of the User;
     – User's region;
     – User's provider;
     – User's browser;
     – system languages of the User;
     – OS of the User;
     – screen resolution of the User;
     – number of colors of the User's screen.
The purposes of processing the User's personal data:
     – provision of services offered on the Operator's website;
      – facilitating the use of the website and improving the quality of the Operator’s website;
     – informing about important news, services and promotional offers of the Operator's website.
     5.1.8. Processing of special categories of personal data relating to race, nationality, political views, religious or philosophical beliefs, health status, intimate life is not allowed, except as provided by the legislation of the Russian Federation.

     5.1.9. The processing of biometric personal data can be carried out only with the consent in writing of the subject of personal data.


6. Principles of personal data processing

   6.1. The processing of personal data is carried out on the basis of the principle of compliance with the volume and nature of the processed personal data, as well as the methods of processing personal data with the stated purposes of processing personal data.

   6.2. Collection, accumulation, storage, modification, use and distribution, as well as other actions understood as the processing of personal data, can be carried out only with the consent of the individual, except as otherwise provided by the legislation of the Russian Federation.

   6.3. 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.

   6.4. Only personal data that meet the purposes of their processing are subject to processing.

   6.5. When processing personal data, the accuracy of personal data, their sufficiency, and, if necessary, relevance in relation to the purposes of processing personal data, is ensured. The operator takes the necessary measures and / or ensures their adoption to remove or clarify incomplete or inaccurate data.

   6.6. It is not allowed to receive and process personal data of employees and other PD subjects about their political, religious and other beliefs, private life, as well as their membership in public associations or their trade union activities, except as otherwise provided by the legislation of the Russian Federation.

   6.7. According to the legislation of the Russian Federation and the policy of the Operator, information containing personal data is classified as information with restricted access.

   6.8. In all cases, the waiver of the employee and other PD subjects of their rights to preserve and protect the secrecy of personal data is invalid if the employee or other PD subject himself has not made them publicly available.

7. Procedure and conditions for processing personal data

   7.1. The processing of personal data may include the collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
   7.2. The direct collection, recording, systematization, accumulation, clarification (updating, change), extraction and use of personal data is carried out by:
     – obtaining information containing personal data, in oral and written form, directly from the subjects of personal data;
     – provision by the subjects of personal data of originals or duly certified copies of documents containing personal data;
     – obtaining personal data when sending requests to state authorities, state non-budgetary funds, other state bodies, local governments, commercial and non-profit organizations, individuals in cases and in the manner prescribed by the legislation of the Russian Federation;
     – the use of other means and methods of fixing personal data received as part of the activities carried out by the Operator and in the manner prescribed by the legislation of the Russian Federation.
   7.3. The processing of personal data is carried out with the consent of the subject of personal data to the processing of personal data, unless otherwise provided by the legislation of the Russian Federation in the field of personal data.
   7.4. When collecting personal data, the Operator's employees are obliged to provide the individual (the subject of personal data) at his request with information about the purposes and methods of processing his personal data, information about persons who have access to personal data (with the exception of the Operator's employees), a list of processed personal data and the source their receipt, information about the terms of processing and storage of personal data.
   7.5. When considering appeals (applications) of citizens, it is not allowed to disclose the information contained in them, as well as information relating to the private life of a citizen, without his consent. It is not a disclosure of the information contained in the appeal, sending a written appeal to a state body, local government or official, other legal entity, whose competence includes resolving the issues raised in the appeal, with notification of the citizen who sent the appeal.
   7.6. Written consents of PD subjects are subject to storage by the Operator.
   7.7. If the provision of personal data is mandatory in accordance with federal law, the Operator's employees who collect and subsequently process personal data are required to explain to the PD subject the legal consequences of refusing to provide his personal data.

   7.8. If the fact of inaccuracy of personal data is confirmed, the Operator’s employee processing personal data, on the basis of information provided by the Operator’s employee or other PD subject, or their representatives or the authorized body for the protection of the rights of personal data subjects, or other necessary documents, clarifies personal data or ensures their clarification (if the processing of personal data is carried out by another person acting on behalf of the Operator) within 7 (seven) working days from the date of submission of such information;

   7.9. Only employees of the Operator holding positions included in the list of persons admitted to the processing of personal data are allowed to process personal data.

   7.10. The processing of personal data by the Operator is carried out 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.
   7.11. The personal data processed by the Operator contains:
     – on paper, including in personal files, in cards, magazines, registers and other documents;
     – in electronic form in the information systems of the Operator's personal data, as well as on external electronic and flexible media, in files stored at automated workstations.
   7.12. For the purposes of internal information support, the Operator may create internal reference materials, which, with the written consent of the PD subject, unless otherwise provided by the legislation of the Russian Federation, may include the last name, first name, patronymic, place of work, position, telephone number, e-mail address, other personal data reported by the subject of personal data.
  7.13. The information provided by the employee upon employment with the Operator must be in documentary form. When concluding an employment contract in accordance with Art. 65 of the Labor Code of the Russian Federation, a person applying for a job presents to the employer:
     – passport or other identity document;
     – a work book, except for cases when an employment contract is concluded for the first time or an employee goes to work on a part-time basis;
     – insurance certificate of state pension insurance;
     – military registration documents - for those liable for military service and persons subject to military registration;
     – a document on education and (or) qualifications or the availability of special knowledge - when applying for a job that requires special knowledge or special training;
     – a certificate of the presence (absence) of a criminal record and (or) the fact of criminal prosecution or the termination of criminal prosecution on rehabilitating grounds, issued in the manner and in the form established by the federal executive body responsible for the development and implementation of state policy and regulatory legal regulation in the field of internal affairs - when applying for a job related to activities, to the implementation of which, in accordance with the Labor Code of the Russian Federation, other federal law, persons who have or had a criminal record, are or have been subjected to criminal prosecution are not allowed;
     – in some cases, taking into account the specifics of work, the Labor Code of the Russian Federation, other federal laws, decrees of the President of the Russian Federation and decrees of the Government of the Russian Federation may provide for the need to present additional documents containing the employee's personal data when concluding an employment contract.
   7.14. The processing of personal data of close relatives of an employee of the Operator is carried out to the extent provided for by the legislation of the Russian Federation (obtaining alimony, filling out a unified form No. T-2, processing social benefits, etc.), in other cases, obtaining the consent of close relatives of an employee is a prerequisite for processing their personal data .

  7.15. The processing of personal data of former employees of the Operator is carried out only within the framework of accounting and tax accounting, ensuring archival storage of documents, providing guarantees and compensations established by the current legislation and local regulations of the Operator, as well as compliance with federal laws and other regulatory legal acts of the Russian Federation. In other cases, obtaining the consent of the former employees of the Operator is a prerequisite for the processing of their personal data.


8. Procedure and conditions for processing personal data

   8.1. The processing of personal data by the Operator is carried out within the following terms:
     – The operator processes the personal data of employees during the term of the employment contract. The operator processes the personal data of former employees within the period established by clause 5, part 3, art. 24 of the Tax Code of the Russian Federation, part 1 of Art. 29 of the Federal Law of December 6, 2011 No. 402-FZ “On Accounting” and other regulatory legal acts.
     – The Operator processes personal data of relatives of the Operator’s employee during the term of the employment contract with the Operator’s employee, unless otherwise provided by the legislation of the Russian Federation.
     – The Operator processes the personal data of the Operator's participant during the period of ownership by the participant of shares in the authorized capital of the Operator. Upon termination of participation in the authorized capital of the Operator, the term for processing personal data of the withdrawing participant is set no more than the period provided for in paragraph 5 of part 3 of Art. 24 of the Tax Code of the Russian Federation, part 1 of Art. 29 of the Federal Law of December 6, 2011 No. 402-FZ “On Accounting” and other regulatory legal acts.
     – The Operator processes the personal data of the Operator’s candidates (individuals) with their consent, provided for the period of achieving the purposes of processing personal data specified in section 3 of the Policy. If you consent to being informed about vacancies suitable for seniority and specialization, your personal data will be processed for the periods specified in such consent, but in any case no longer than is necessary to achieve the stated purpose of processing.
     – The Operator processes personal data of representatives/employees of the Operator’s clients and counterparties (legal entities) with their consent, provided within the period necessary to represent the interests of third parties with the Operator.
   8.2. The storage of personal data by the Operator is carried out in a form that allows you to determine the subject of personal data no longer than the purpose of their processing requires. When the purposes of processing personal data are achieved, as well as in the event that the subject of personal data withdraws consent to their processing, personal data are subject to destruction, unless otherwise provided by the agreement to which the subject of personal data is a party, beneficiary or guarantor, another agreement between the Operator and the subject of personal data. data.
   8.3. Databases of information containing personal data of citizens of the Russian Federation are located on the territory of the Russian Federation.

9. Access to personal data

   9.1. Employees of the Operator who, by virtue of their official duties, constantly work with PD, receive admission to the necessary categories of PD for the duration of their respective job duties based on the list of persons admitted to the processing of personal data, which is approved by the head of the Operator.
   9.2. The list of persons authorized to process personal data for the information system must be kept up to date.
   9.3. The operator has established a permissive procedure for access to PD. The Operator's employees are granted access to work with PD only to the extent and to the extent necessary for them to perform their official duties based on the decision of the head.
   9.4. A temporary or one-time permit to work with PD due to a business need may be obtained by an employee of the Operator by order of the head of the Operator.
   9.5. The Operator's employees are allowed to process personal data after becoming familiar with the rules for working with personal data, as well as with the Operator's internal regulatory and administrative documents for the protection of personal data.
   9.6. Access to PD by third parties who are not employees of the Operator without the consent of the PD subject is prohibited, with the exception of access by employees of executive authorities carried out as part of measures to control and supervise the implementation of legislation, the implementation of the functions and powers of the relevant state authorities. The provision of information at the request or request of a public authority is carried out with the notification of the head of the Operator.

   9.7. In case of detection of violations of the procedure for granting access rights to personal data, the head of the Operator is obliged to suspend the provision of personal data to users who process PD (obtained access) in violation of the procedure, until the causes of violations are identified and eliminated.


10. Cross-border transfer of personal data

     10.1. The operator, prior to the commencement of activities for the cross-border transfer of personal data, is obliged to notify the authorized body for the protection of the rights of subjects of personal data of his intention to carry out a cross-border transfer of personal data (such a notification is sent separately from the notification of the intention to process personal data).
     10.2. Before submitting the above notification, the operator is obliged to obtain relevant information from the authorities of a foreign state, foreign individuals, foreign legal entities to whom the cross-border transfer of personal data is planned.

11. Confidentiality of personal data

The operator and other persons who have gained access to personal data are obliged not to disclose to third parties and not to distribute personal data without the consent of the subject of personal data, unless otherwise provided for in Part 2 of Art. 18.1, part 1 of Art. 19 of the Federal Law "On Personal Data".

12. Final provisions

     12.1. The subject of personal data can receive any clarifications on issues of interest regarding the processing of his personal data by contacting the Operator via e-mail info@mil-team.com.

     12.2. This document will reflect any changes in the policy of processing personal data by the Operator. The policy is valid indefinitely until it is replaced by a new version.




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