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Policy on the Processing of Personal Data

Policy on the processing of personal data on the kt-team.ru website and the third-level domains associated with the site.

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1. General Provisions

  1. This personal data processing policy is drawn up in accordance with the requirements of

  2. Federal Law No. 152-FZ of 27.07.2006 "On Personal Data" (hereinafter —

  3. Personal Data Law) and defines the procedure for processing personal data and the measures taken to ensure the security of personal data, undertaken by

  4. Limited Liability Company "COMPLICERTE TECHNOLOGIE RUS" (hereinafter — the Operator). 1.1.

  5. The Operator regards as its paramount objective and a condition of its activity the observance of the rights and freedoms of the individual and citizen when processing their personal data, including the protection of the rights to privacy and to personal and family confidentiality. 1.2.

  6. the Operator regarding the processing of personal data (hereinafter — the Policy) applies to all information that

  7. the Operator may obtain about visitors to the website https://kt-team.ru.

2. Key Terms Used in the Policy

Automated processing of personal data — the processing of personal data by means of computing technology. 2.2.

Blocking of personal data — the temporary suspension of personal data processing (except where processing is necessary to refine the personal data). 2.3. Website — a collection of graphic and information materials, as well as computer programs and databases ensuring their availability on the Internet at the network address https://kt-team.ru. 2.4.

Personal data information system — a collection of personal data contained in databases together with the information technologies and technical means ensuring its processing. 2.5.

Depersonalization of personal data — actions as a result of which it becomes impossible, without the use of additional information, to determine the attribution of personal data to a specific

to the User or another personal data subject. 2.6.

Processing of personal data — any action (operation) or set of actions (operations) performed on personal data with or without the use of automation tools, including collection, recording, systematization, accumulation, storage, refinement (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion and destruction of personal data. 2.7.

Operator — a state body, municipal body, legal entity or individual that, independently or jointly with others, organizes and/or carries out the processing of personal data, as well as determines the purposes of personal data processing, the composition of the personal data to be processed, and the actions (operations) performed on the personal data. 2.8.

Personal data — any information relating directly or indirectly to an identified or identifiable

to the User of the website https://kt-team.ru. 2.9.

Personal data permitted by the personal data subject for distribution — personal data to which access by an unlimited number of persons has been granted by the personal data subject by giving consent to the processing of personal data permitted by the personal data subject for distribution in the manner provided for by

the Personal Data Law (hereinafter — personal data permitted for distribution). 2.10.

User — any visitor to the website https://kt-team.ru. 2.11.

Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific group of persons. 2.12.

Distribution of personal data — any actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or at making personal data known to an unlimited number of persons, including the publication of personal data in the mass media, posting in information and telecommunications networks, or providing access to personal data by any other means. 2.13.

Cross-border transfer of personal data — the transfer of personal data to the territory of a foreign state to a foreign state authority, a foreign individual or a foreign legal entity. 2.14.

Destruction of personal data — any actions as a result of which personal data is irretrievably destroyed, making it impossible to further restore the content of the personal data in the personal data information system, and/or the material carriers of the personal data are destroyed.

3. Principal Rights and Obligations of the Operator

The Operator has the right to: 3.1.1. receive from the personal data subject accurate information and/or documents containing personal data; 3.1.2. in the event that the personal data subject withdraws consent to the processing of personal data, as well as submits a request demanding the cessation of personal data processing,

The Operator is entitled to continue processing personal data without the consent of the personal data subject where there are grounds specified in

the Personal Data Law; 3.1.3. independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of the obligations provided for by

the Personal Data Law and the regulatory legal acts adopted in accordance with it, unless otherwise provided by

the Personal Data Law or other federal laws. 3.2.

The Operator shall: 3.2.1. provide the personal data subject, upon request, with information concerning the processing of their personal data; 3.2.2. organize the processing of personal data in the manner established by the applicable legislation of the CIS; 3.2.3. respond to requests and inquiries from personal data subjects and their legal representatives in accordance with the requirements of

the Personal Data Law; 3.2.4. provide the authorized body for the protection of the rights of personal data subjects, upon that body's request, with the necessary information within 10 days of receiving such a request; 3.2.5. publish or otherwise ensure unrestricted access to this

the Policy on the processing of personal data; 3.2.6. take legal, organizational and technical measures to protect personal data against unlawful or accidental access, destruction, modification, blocking, copying, provision, distribution of personal data, as well as against other unlawful actions in respect of personal data; 3.2.7. cease the transfer (distribution, provision, access) of personal data, cease processing and destroy the personal data in the manner

and in the cases provided for by

the Personal Data Law; 3.2.8. fulfill other obligations provided for by

4. Principal Rights and Obligations of Personal Data Subjects

Personal data subjects have the right to: 4.1.1. receive information concerning the processing of their personal data, except in the cases provided for by federal laws.

The information is provided to the personal data subject

by the Operator in an accessible form, and they must not contain personal data relating to other personal data subjects, except where there are lawful grounds for disclosing such personal data.

The list of information and the procedure for obtaining it are established by

the Personal Data Law; 4.1.2. require the operator to refine their personal data, to block or destroy it where the personal data is incomplete, outdated, inaccurate, unlawfully obtained or not necessary for the stated processing purpose, and to take measures provided by law to protect their rights; 4.1.3. impose the condition of prior consent for the processing of personal data for the purpose of promotion on

the market for goods, works and services; 4.1.4. withdraw consent to the processing of personal data, as well as submit a request demanding the cessation of personal data processing; 4.1.5. appeal, to the authorized body for the protection of the rights of personal data subjects or through the courts, against unlawful actions or inaction

of the Operator in the processing of their personal data; 4.1.6. exercise other rights provided for by the legislation of the CIS. 4.2.

Personal data subjects shall: 4.2.1. provide

the Operator with accurate information about themselves; 4.2.2. notify

the Operator about the refinement (updating, modification) of their personal data. 4.3. Persons who have provided

the Operator with inaccurate information about themselves, or information about another personal data subject without the latter's consent, shall be held liable in accordance with the legislation of the CIS.

5. Principles of Personal Data Processing

  1. The processing of personal data is carried out on a lawful and fair basis. 5.2.

  2. The processing of personal data is limited to the achievement of specific, predefined and lawful purposes.

  3. Processing of personal data that is incompatible with the purposes of collecting the personal data is not permitted. 5.3.

  4. The merging of databases containing personal data processed for mutually incompatible purposes is not permitted. 5.4.

  5. Only personal data that meets the purposes of its processing is subject to processing. 5.5.

  6. The content and volume of the personal data processed correspond to the stated purposes of processing.

  7. The personal data processed must not be excessive in relation to the stated purposes of its processing. 5.6.

  8. When processing personal data, the accuracy, sufficiency and, where necessary, the currency of the personal data relative to the purposes of personal data processing are ensured.

  9. The Operator takes the necessary measures and/or ensures that they are taken to delete or refine incomplete or inaccurate data. 5.7.

  10. Personal data is stored in a form that allows the personal data subject to be identified for no longer than required by the purposes of personal data processing, unless the personal data retention period is established by federal law or by a contract to which the personal data subject is a party, beneficiary or guarantor.

  11. The personal data being processed is destroyed or depersonalized once the purposes of processing have been achieved or where the need to achieve those purposes has been lost, unless otherwise provided by federal law.

6. Purposes of Personal Data Processing

Purpose of Processing

informing the User by sending emails and arranging telephone calls

Personal Data

email address; telephone numbers; surname and first name

Legal Grounds

Federal Law "On Information, Information Technologies and the Protection of Information" No. 149-FZ of 27.07.2006

Types of Personal Data Processing

Collection, recording, systematization, accumulation, storage, destruction and depersonalization of personal data. Sending informational emails to the email address

7. Conditions for Personal Data Processing

  1. The processing of personal data is carried out with the consent of the personal data subject to the processing of their personal data. 7.2.

  2. Processing of personal data is necessary to achieve the purposes provided for by an international treaty

  3. of the Federation or by law, for the performance of the functions, powers and duties vested by legislation

  4. of the Federation in the operator. 7.3.

  5. Processing of personal data is necessary for the administration of justice, the enforcement of a judicial act or an act of another body or official subject to enforcement in accordance with the legislation

  6. of the Federation on enforcement proceedings. 7.4.

  7. Processing of personal data is necessary for the performance of a contract to which the personal data subject is a party, beneficiary or guarantor, as well as for the conclusion of a contract initiated by the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor. 7.5.

  8. Processing of personal data is necessary to exercise the rights and legitimate interests of the operator or third parties or to achieve socially significant purposes, provided that the rights and freedoms of the personal data subject are not thereby violated. 7.6.

  9. Personal data is processed to which access by an unlimited number of persons has been granted by the personal data subject or at their request (hereinafter — publicly available personal data). 7.7.

  10. Personal data subject to publication or mandatory disclosure in accordance with federal law is processed.

8. Procedure for Collection, Storage, Transfer and Other Types of Personal Data Processing

  1. The security of personal data processed by the Operator is ensured through the implementation of legal, organizational and technical measures necessary to fully comply with the requirements of applicable legislation on personal data protection. 8.1.

  2. The Operator ensures the safekeeping of personal data and takes all possible measures to prevent access to personal data by unauthorized persons. 8.2.

  3. of the User will never, under any circumstances, be transferred to third parties, except in cases related to compliance with applicable legislation or where the personal data subject has given consent

  4. the Operator to transfer the data to a third party for the fulfillment of obligations under a civil law contract. 8.3. In the event that inaccuracies in the personal data are identified,

  5. The User may update it independently by sending

  6. the Operator a notification to the email address

  7. the Operator at corporate@kt-team.ru→ marked "Update of personal data". 8.4.

  8. The period of personal data processing is determined by the achievement of the purposes for which the personal data was collected, unless a different period is provided for by a contract or by applicable legislation.

  9. The User may withdraw their consent to the processing of personal data at any time by sending

  10. the Operator a notification by email to the email address

  11. the Operator at corporate@kt-team.ru→ marked "Withdrawal of consent to the processing of personal data". 8.5.

  12. All information collected by third-party services, including payment systems, communication tools and other service providers, is stored and processed by such persons (Operators) in accordance with their

  13. the personal data subject and/or with the specified documents.

  14. The Operator is not liable for the actions of third parties, including the service providers referred to in this clause. 8.6.

  15. The prohibitions imposed by the personal data subject on the transfer (other than the provision of access), as well as on the processing or the conditions of processing (other than the receipt of access) of personal data permitted for distribution, do not apply where personal data is processed in state, social and other public interests defined by the legislation of the CIS. 8.7.

  16. When processing personal data, the Operator ensures the confidentiality of the personal data. 8.8.

  17. The Operator stores personal data in a form that allows the personal data subject to be identified for no longer than required by the purposes of personal data processing, unless the personal data retention period is established by federal law or by a contract to which the personal data subject is a party, beneficiary or guarantor. 8.9.

  18. The grounds for ceasing the processing of personal data may be the achievement of the purposes of personal data processing, the expiry of the personal data subject's consent, the withdrawal of consent by the personal data subject or a demand to cease the processing of personal data, as well as the discovery of unlawful processing of personal data.

9. List of Actions Performed by the Operator with the Personal Data Received

9.1. The Operator performs collection, recording, systematization, accumulation, storage, refinement (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion and destruction of personal data. 9.2. The Operator carries out automated processing of personal data with or without the receipt and/or transfer of the information obtained over information and telecommunications networks.

10. Cross-Border Transfer of Personal Data

10.1. Before commencing cross-border transfer of personal data, the Operator shall notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out cross-border transfer of personal data (such notification shall be sent separately from the notification of the intention to process personal data). 10.2.

Before submitting the above notification, the Operator shall obtain the relevant information from the authorities of the foreign state, foreign individuals and 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 obtained access to personal data shall not disclose to third parties or distribute personal data without the consent of the personal data subject, unless otherwise provided by federal law.

12. Final Provisions

12.1. The User may obtain any clarifications on questions of interest regarding the processing of their personal data by contacting the Operator via email at corporate@kt-team.ru→. 12.2. This document will reflect any changes to the Operator's personal data processing policy. The Policy is valid indefinitely until replaced by a new version. 12.3. The current version of the Policy is freely available on the Internet at https://kt-team.ru/service/policy.

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