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regarding the processing of personal data of site visitors
1. General Provisions
1.1. This Policy regarding the processing of personal data (hereinafter referred to as the “Policy”) was prepared in accordance with clause 2, part 1, art. 18.1 of the Federal Law of the Russian Federation “On Personal Data” No. 152-FZ of July 27, 2006 (hereinafter referred to as the “Law”) and determines the position of the legal entity Alargo LLC (OGRN: 1117847317653, INN: 7814507900, registration address: 197342, St. Petersburg, Lisichanskaya street, building 6, letter A, room 15-N, office 431 and/or its affiliates, (hereinafter referred to as the “Company”) in the field of processing and protection of personal data (hereinafter referred to as “Data”), respect for the rights and freedoms of every person and, in particular, the right to privacy, personal and family secrets.
2. Scope of application
2.1. This Policy applies to Data received both before and after the entry into force of this Policy.
2.2. Understanding the importance and value of the Data, as well as caring about respecting the constitutional rights of citizens of the Russian Federation and citizens of other states, the Company ensures reliable protection of the Data.
3. Definitions
3.1. Data refers to any information relating to a directly or indirectly identified or identifiable individual (citizen), i.e. Such information, in particular, includes: last name, first name, patronymic, registration/sending address, email, telephone number, location, photograph, IP address.
3.2. Data processing means any action (operation) or set of actions (operations) with Data performed using automation tools and/or without the use of such tools. Such actions (operations) include: collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of Data.
3.3. Data security means the protection of Data from unlawful and/or unauthorized access to it, destruction, modification, blocking, copying, provision, distribution of Data, as well as from other unlawful actions in relation to Data.
4. Legal grounds and purposes of Data processing
4.1. Processing and ensuring the security of Data in the Company is carried out in accordance with the requirements of the Constitution of the Russian Federation, the Law, the Labor Code of the Russian Federation, by-laws, other federal laws of the Russian Federation defining cases and features of Data processing, guidelines and methodological documents of the FSTEC of Russia and the FSB of Russia.
4.2. Subjects of Data processed by the Company are:
- candidates for vacant positions, including candidates filling out a candidate questionnaire on the Company’s Internet resource: “Extender24”
- employees of the Company, relatives of employees of the Company, within the limits determined by the legislation of the Russian Federation, if information about them is provided by the employee;
- persons included in the management bodies of the Company and who are not employees; individuals with whom the Company enters into civil contracts;
- clients – consumers, incl. visitors to the website https://extender24.ru, owned by the Company, including for the purpose of placing an order on the Website https://extender24.ru with subsequent delivery to the client, recipients of services;
4.3. The Company processes Subject Data for the following purposes:
- implementation of the functions, powers and responsibilities assigned to the Company by the legislation of the Russian Federation in accordance with federal laws, including, but not limited to: the Civil Code of the Russian Federation, the Tax Code of the Russian Federation, the Labor Code of the Russian Federation, the Family Code of the Russian Federation, the Federal Law of 01.04 .1996 No. 27-FZ “On individual (personalized) accounting in the compulsory pension insurance system”, Federal Law of July 27, 2006 No. 152-FZ “On Personal Data”, Federal Law of March 28, 1998 No. 53 -FZ “On military duty and military service”, Federal Law dated 02.26.1997 No. 31-FZ “On mobilization preparation and mobilization in the Russian Federation”, Federal Law dated 02.8.1998 No. 14-FZ “On societies with limited liability”, Federal Law of 02/07/1992 No. 2300-1 “On the Protection of Consumer Rights”, Federal Law of 11/21/1996 No. 129-FZ “On Accounting”, Federal Law of 11/29/2010 No. 326- Federal Law “On Compulsory Medical Insurance in the Russian Federation”,
- Employees in order to comply with labor, tax and pension legislation of the Russian Federation, namely: 1. assistance to employees in employment, training and promotion; 2. calculation and payroll; 3. organizing business trips (business trips) for employees; 4. execution of powers of attorney (including for representing the interests of the Company to third parties); 5. ensuring personal safety of workers; o control the quantity and quality of work performed; 6. ensuring the safety of property; 7. compliance with access control on the Company’s premises;
- Candidates for vacant positions in order to: 1. make a decision on the possibility of concluding an employment contract with persons applying for open vacancies;
- Persons included in the management bodies of the Company who are not employees, in order to: 1. fulfill the requirements provided for by law, incl. mandatory disclosure of information, audit, verification of the possibility of completing transactions, including interested party transactions and/or major transactions.
- Clients - consumers for the purposes of: 1. providing information on goods/services, ongoing promotions and special offers; 2. analyzing the quality of the service provided by the Company and improving the quality of service to the Company’s clients; 3. informing about the status of the order; 4. execution of the contract, incl. purchase and sale agreements, incl. concluded remotely on the Site, paid provision of services; provision of services, as well as accounting for services provided to consumers for mutual settlements; 5. delivery of the ordered goods to the client who placed an order on the Site, return of the goods.
5. Principles and conditions for Data processing.
5.1. When processing Data, the Company adheres to the following principles: Data processing is carried out on a legal and fair basis; Data is not disclosed to third parties and is not distributed without the consent of the Data subject, except for cases requiring disclosure of Data at the request of authorized government bodies or legal proceedings; identification of specific legitimate purposes before processing (including collection) of Data; Only those Data are collected that are necessary and sufficient for the stated purpose of processing; combining databases containing Data, the processing of which is carried out for purposes incompatible with each other is not permitted; the processing of Data is limited to the achievement of specific, predetermined and legitimate purposes; The processed Data is subject to destruction or depersonalization upon achievement of the processing goals or in the event of the loss of the need to achieve these goals, unless otherwise provided by federal law.
5.2. The Company may include the Subjects' Data in publicly available Data sources, and the Company takes the subject's written consent to process his Data, or by expressing consent through the website form (checkbox), by clicking which the subject of the personal data expresses his consent.
5.3. The Company does not process Data relating to race, nationality, political views, religious, philosophical and other beliefs, intimate life, membership in public associations, including trade unions.
5.4. The Company may process data on the health status of the Data subject in the following cases: 1) in accordance with the legislation on state social assistance, labor legislation, the legislation of the Russian Federation on state pensions, and labor pensions; 2) to protect the life, health or other vital interests of an employee or to protect the life, health or other vital interests of other persons and obtaining the consent of the Data subject is impossible; 3) to establish or exercise the rights of an employee or third parties, as well as in connection with the administration of justice; 4) in accordance with the legislation on compulsory types of insurance, with insurance legislation.
5.5. Biometric Data (information that characterizes the physiological and biological characteristics of a person, on the basis of which his identity can be established and which is used by the operator to establish the identity of the Data subject) is not processed by the Company.
5.6. The Company does not carry out cross-border transfer of Data.
5.7. In cases established by the legislation of the Russian Federation, the Company has the right to transfer Data to third parties (federal tax service, state pension fund and other government bodies) in cases provided for by the legislation of the Russian Federation.
5.8. Transfer of personal data to third parties can be carried out only in cases established by the legislation of the Russian Federation, an agreement with the participation of the User or with his consent. With this Consent, the User confirms his consent to the Company providing the User’s personal data to the partners and bodies listed below, and also consents to the processing of the User’s personal data by the specified partners (bodies) in the volumes, methods and for the period specified in this consent, but no more than required to ensure the processing purposes specified on the website at the Internet address https://extender24.ru, to perform certain functions of the Company, namely: - LOGNEX LLC (Address: 121205, Moscow, Skolkovo Innovation Center, Bolshoi b-r, 42 building 1, room 1617, TIN: 7736570901) – for the processing of personal data (name, address, telephone, e-mail) of this Policy, for the following purposes: for warehouse accounting
using the website at the Internet address https://extender24.ru.
- Index-Express LLC (Address: 192007, St. Petersburg, Kurskaya street, building No. 27, letter A, room 4N, Taxpayer Identification Number: 7816581338) - for the processing of personal data (full name, address, phone number, email) hereof Policy, for the following purposes: for delivery of orders
using the website at the Internet address https://extender24.ru.
— “EMS Russian Post” branch of the Federal State Unitary Enterprise “Russian Post” (Address: 195009, St. Petersburg, Komsomol St., 37, building 3, letter A, INN: 7724261610) – for the processing of personal data (full name , address, telephone) of this Policy, for the following purposes: for delivery of orders
using the website at the Internet address https://extender24.ru.
— LLC “Network of automated pick-up points” (Address: 109316, Moscow, Volgogradsky Prospekt, 42. building 23, Taxpayer Identification Number: 7723763977) – for the processing of personal data (full name, address, telephone, email) hereof Policy, for the following purposes: for delivery of orders
using the website at the Internet address https://extender24.ru.
— IP Pavlov Vyacheslav Sergeevich (Address: 410062, Saratov, Motornaya str., 6, apt. 36, Taxpayer Identification Number: 645399265598) – for the processing of personal data (full name, phone number, e-mail) of this Policy, for the following purposes: for tracking shipments by courier companies
using the website at the Internet address https://extender24.ru.
5.9. Persons processing Data on the basis of an agreement concluded with the Company (operator's instructions) undertake to comply with the principles and rules for processing and protecting Data provided for by the Law. For each third party, the contract defines a list of actions (operations) with the Data that will be performed by the third party processing the Data, the purposes of the processing, establishes the obligation of such a person to maintain confidentiality and ensure the security of the Data during their processing, and specifies the requirements for the protection of the processed Data in accordance with the Law.
5.10. In order to fulfill the requirements of the current legislation of the Russian Federation and its contractual obligations, Data processing in the Company is carried out both with and without the use of automation tools. The set of processing operations includes collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (provision, access), depersonalization, blocking, deletion, destruction of Data.
5.11. The Company prohibits making decisions based solely on automated processing of Data that give rise to legal consequences in relation to the Data subject or otherwise affect his rights and legitimate interests, except in cases provided for by the legislation of the Russian Federation.
6. Rights and obligations of Data subjects, as well as the Company regarding Data processing
6.1. The subject whose data is processed by the Company has the right:
— receive from the Company:
- confirmation of the fact of Data processing and information about the availability of Data relating to the relevant Data subject;
- information about the legal grounds and purposes of Data processing;
- information about the methods of Data processing used by the Company;
- information about the name and location of the Company;
- information about persons (except for the Company’s employees) who have access to the Data or to whom the Data may be disclosed on the basis of an agreement with the Company or on the basis of federal law;
- a list of processed Data related to the Data subject and information about the source of their receipt, unless a different procedure for providing such Data is provided for by federal law;
- information about the terms of Data processing, including the periods of their storage;
- information on the procedure for the Data subject to exercise the rights provided for by the Law;
- name (full name) and address of the person processing the Data on behalf of the Company;
- other information provided for by the Law or other regulations of the Russian Federation;
— demand from the Company:
- clarification of your Data, blocking or destruction of it if the Data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated purpose of processing;
- withdraw your consent to the processing of Data at any time; demand elimination of unlawful actions of the Company in relation to his Data;
- appeal the actions or inaction of the Company to the Federal Service for Supervision of Communications, Information Technology and Mass Communications (Roskomnadzor) or in court if the Data subject believes that the Company is processing his Data in violation of the requirements of the Law or otherwise violates his rights and freedom;
— to protect their rights and legitimate interests, including compensation for losses and/or compensation for moral damage in court.
6.2. In the process of processing Data, the Company is obliged to:
- provide the Data subject, upon his request, with information regarding the processing of his personal data, or legally provide a refusal within thirty days from the date of receipt of the request of the Data subject or his representative;
- explain to the Data subject the legal consequences of refusal to provide Data if the provision of Data is mandatory in accordance with federal law;
- before the start of Data processing (if the Data is not received from the Data subject), provide the Data subject with the following information, except for the cases provided for in Part 4 of Article 18 of the Law: 1) name or surname, first name, patronymic and address of the Company or its representative; 2) the purpose of Data processing and its legal basis; 3) intended users of the Data; 4) the rights of Data subjects established by law; 5) source of the Data.
- take the necessary legal, organizational and technical measures or ensure their adoption to protect the Data from unauthorized or accidental access to it, destruction, modification, blocking, copying, provision, distribution of Data, as well as from other unlawful actions in relation to the Data;
- publish on the Internet and provide unrestricted access via the Internet to a document defining its policy regarding Data processing, to information about the implemented requirements for Data protection;
- provide Data subjects and/or their representatives with the opportunity to familiarize themselves with the Data free of charge when making a corresponding request within 30 days from the date of receipt of such a request;
- block illegally processed Data relating to the Data subject, or ensure their blocking (if the Data processing is carried out by another person acting on behalf of the Company) from the moment of application or receipt of a request for the verification period, in case of detection of unlawful processing of Data upon application by the Data subject or his a representative or at the request of the Data subject or his representative or an authorized body for the protection of the rights of personal data subjects;
- clarify the Data or ensure its clarification (if the Data processing is carried out by another person acting on behalf of the Company) within 7 working days from the date of submission of the information and remove the blocking of the Data if the fact of inaccuracy of the Data is confirmed based on the information provided by the Data subject or his representative;
- stop unlawful processing of Data or ensure the termination of unlawful processing of Data by a person acting on behalf of the Company, in the event of detection of unlawful processing of Data carried out by the Company or a person acting on the basis of an agreement with the Company, within a period not exceeding 3 business days from the date of this detection;
- stop Data processing or ensure its termination (if Data processing is carried out by another person acting under an agreement with the Company) and destroy the Data or ensure its destruction (if Data processing is carried out by another person acting under an agreement with the Company) upon achieving the purpose of Data processing, unless otherwise not provided for by the agreement to which the Data subject is a party, beneficiary or guarantor, if the purpose of Data processing is achieved;
- stop the processing of Data or ensure its termination and destroy the Data or ensure their destruction if the Data subject withdraws consent to Data processing, if the Company does not have the right to process Data without the consent of the Data subject;
- keep a log of requests from PD subjects, which should record the requests of Data subjects to receive Data, as well as the facts of providing Data in response to these requests.
7. Data protection requirements
7.1. When processing Data, the Company takes the necessary legal, organizational and technical measures to protect Data from unlawful and/or unauthorized access to it, destruction, modification, blocking, copying, provision, distribution of Data, as well as from other unlawful actions in relation to Data.
7.2. Such measures in accordance with the Law, in particular, include:
- appointment of a person responsible for organizing Data processing and a person responsible for ensuring Data security;
- development and approval of local regulations on the processing and protection of Data;
- application of legal, organizational and technical measures to ensure Data security: · identification of threats to Data security during their processing in personal data information systems; · application of organizational and technical measures to ensure the security of Data during their processing in personal data information systems necessary to fulfill the requirements for Data protection, the implementation of which ensures the levels of Data security established by the Government of the Russian Federation; · use of information security means that have passed the compliance assessment procedure in accordance with the established procedure; · assessment of the effectiveness of measures taken to ensure Data security before putting into operation the personal data information system; · accounting of computer data storage media, if data storage is carried out on computer storage media; · detecting facts of unauthorized access to Data and taking measures to prevent similar incidents in the future; · restoration of Data modified or destroyed due to unauthorized access to it; · establishing rules for access to Data processed in the personal data information system, as well as ensuring registration and accounting of all actions performed with Data in the personal data information system.
- control over the measures taken to ensure Data security and the level of security of personal data information systems;
- assessment of the harm that may be caused to Data subjects in case of violation of the requirements of the Law, the relationship between the said harm and the measures taken by the Company aimed at ensuring the fulfillment of the obligations provided for by the Law;
- compliance with conditions that exclude unauthorized access to material storage media of Data and ensure the safety of Data;
- familiarizing the Company's employees directly involved in Data processing with the provisions of the legislation of the Russian Federation on Data, including the requirements for Data protection, local regulations on the processing and protection of Data, and training of the Company's employees.
8. Terms of processing (storage) of Data
8.1. The terms of processing (storage) of Data are determined based on the purposes of Data processing, in accordance with the duration of the contract with the Data subject, the requirements of federal laws, the requirements of Data operators on whose behalf the Company processes Data, the basic rules for the operation of archives of organizations, and the statute of limitations.
8.2. Data whose processing (storage) period has expired must be destroyed, unless otherwise provided by federal law. Storage of Data after termination of its processing is permitted only after its depersonalization.
9. The procedure for obtaining clarification on Data processing issues
9.1. Persons whose Data is processed by the Company can receive clarification on the processing of their Data by contacting the Company personally or sending a corresponding written request to the Company's location: 197342, St. Petersburg, st. Lisichanskaya, building 6, letter A, room 15-N, office 431.
9.2. If an official request is sent to the Company, the text of the request must indicate:
- last name, first name, patronymic of the Data subject or his representative;
- the number of the main document identifying the Data subject or his representative, information about the date of issue of the specified document and the issuing authority;
- information confirming that the Data subject has a relationship with the Company; information for feedback for the purpose of sending the Company a response to the request;
- signature of the Data subject (or his representative). If the request is sent electronically, then it must be issued in the form of an electronic document and signed with an electronic signature in accordance with the legislation of the Russian Federation.
10. Features of processing and protection of Data collected by the Company using the Internet
10.1. The Company processes Data received from users of the Site, including Data of Candidates for vacant positions from the resource: https://extender24.ru (hereinafter collectively referred to as the Site), as well as received to the Company’s telephone number: 88005550486, to the Company’s email address, via Company feedback form located at: .
10.2. Data collection
There are two main ways in which the Company obtains Data via the Internet:
10.2.1. Providing Data
Providing Data (independent data entry):
- surname
- Name
- surname
- registration/sending address
- phone number
- photo
10.2.2. Subjects of Data by receiving the Company's phone number: 88005550486, to the Company's email address, through the Company's feedback form located at: .
10.3. Automatically collected information
The company may collect and process information that is not personal data:
- location determination
- ip address
- information about the interests of users on the Site based on the entered search queries of Site users about goods sold and offered for sale by the Company in order to provide up-to-date information to the Company's clients when using the Site, as well as generalization and analysis of information about which sections of the Site and products are in greatest demand among the Company's clients;
- processing and storing search queries of Site users for the purpose of summarizing and creating client statistics on the use of sections of the Site.
The Company automatically receives certain types of information obtained during user interaction with the Site, correspondence by e-mail, etc. We are talking about technologies and services such as web protocols, cookies, web tags, as well as applications and tools of the specified third party. sides.
However, web tags, cookies and other monitoring technologies do not automatically obtain Data. If a user of the Site voluntarily provides his Data, for example, when filling out a feedback form or sending an email, then only processes for automatically collecting detailed information for the convenience of using the websites and/or to improve the user experience are started.
10.4. Data usage
The Company has the right to use the provided Data in accordance with the stated purposes of their collection with the consent of the Data subject, if such consent is required in accordance with the requirements of the legislation of the Russian Federation in the field of Data.
The obtained Data in a generalized and anonymized form can be used to better understand the needs of buyers of goods and services sold by the Company and improve the quality of service.
10.5. Data transfer
The Company may entrust Data processing to third parties only with the consent of the Data subject. Data may also be transferred to third parties in the following cases:
a) As a response to legitimate requests from authorized government bodies, in accordance with laws, court decisions, etc.
b) Data may not be transferred to third parties for marketing, commercial or other similar purposes, unless the prior consent of the Data subject is obtained.
10.6. The Site contains links to other web resources where information may be useful and interesting to Site users. However, this Policy does not apply to such other sites. Users who follow links to other sites are advised to review the Data Processing Policies posted on such sites.
10.7. The Site User may at any time withdraw his consent to the processing of Data by sending a message by calling the Company's phone number: 88005550486, to the Company's email address, through the Company's feedback form located at: , or by sending a written notification to the Company's address: 197342 , St. Petersburg, st. Lisichanskaya, building 6, letter A, room 15-N, office 431. After receiving such a message, the processing of the User's Data will be stopped and his Data will be deleted, except in cases where the processing can be continued in accordance with the law. Final provisions This Policy is a local regulatory act of the Company. This Policy is publicly available. The public availability of this Policy is ensured by publication on the Company’s Website. This Policy may be revised in any of the following cases:
- when the legislation of the Russian Federation in the field of processing and protection of personal data changes;
- in cases of receiving instructions from competent government authorities to eliminate inconsistencies affecting the scope of the Policy;
- by decision of the Company’s management;
- when the purposes and terms of Data processing change;
- when changing the organizational structure, structure of information and/or telecommunication systems (or introducing new ones);
- when using new technologies for processing and protecting Data (including transmission, storage);
- when there is a need to change the Data processing process related to the Company’s activities. In case of failure to comply with the provisions of this Policy, the Company and its employees are liable in accordance with the current legislation of the Russian Federation. Control of compliance with the requirements of this Policy is carried out by persons responsible for organizing the processing of Company Data, as well as for the security of personal data.
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