Personal Data Processing Policy
English translation. The Russian-language version is available here.
1. General Provisions
1.1. This Personal Data Processing Policy of Mavzoley-Sochi LLC(hereinafter referred to as the Policy and Mavzoley-Sochi LLC, respectively) sets out the basic principles and conditions for processing personal data.
1.2. The Policy has been developed in accordance with the Constitution of the Russian Federation, the Labour Code of the Russian Federation, Federal Law No. 152-ФЗ of 27.07.2006 “On Personal Data” and other regulatory legal acts of the Russian Federation concerning personal data.
1.3. The Policy applies to all personal data that Mavzoley-Sochi LLC may obtain from data subjects.
1.4. The Policy applies to personal data obtained both before and after approval of this Policy.
1.5. For the purposes of implementing this Policy, terms are used as defined in the current legislation of the Russian Federation.
2. Legal Bases for Processing Personal Data
Mavzoley-Sochi LLC processes personal data in accordance with the Constitution of the Russian Federation, Articles 86–90 of the Labour Code of the Russian Federation, Federal Law No. 152-ФЗ of 27.07.2006 “On Personal Data”, and other regulatory legal acts of the Russian Federation concerning personal data.
3. Purposes of Processing Personal Data
Mavzoley-Sochi LLC processes data subjects’ personal data for the following purposes:
- performing the functions, exercising the powers and fulfilling the obligations assigned to Mavzoley-Sochi LLC by law;
- entering into and performing contracts with individuals, legal entities and individual entrepreneurs;
- complying with labour legislation and other regulatory acts;
- providing social guarantees and fulfilling the employer’s obligations;
- protecting the vital interests of data subjects;
- pursuing other lawful purposes provided for by the charter of Mavzoley-Sochi LLC and by legislation, including processing enquiries submitted through the website mavzolei-sochi.ru.
4. Personal Data Processed and Categories of Data Subjects
4.1. The categories of personal data processed by Mavzoley-Sochi LLC are determined by legislation and the organisation’s internal regulations. The website may process names, telephone numbers, email addresses, information voluntarily provided in messages, and technical request data (IP address, date and time of the enquiry, and browser information).
4.2. Mavzoley-Sochi LLC does not process special categories of personal data (concerning racial or ethnic origin, political views, religious or philosophical beliefs, or intimate life), except in cases expressly provided for by law.
4.3. Mavzoley-Sochi LLC processes personal data relating to the following categories of data subjects:
- employees (including former employees);
- employees’ family members (where guarantees and compensation are provided);
- applicants for vacant positions;
- individuals who have contacted Mavzoley-Sochi LLC;
- representatives and employees of counterparties;
- other data subjects, for the purposes specified in Section 3.
5. Rights and Obligations
5.1. Mavzoley-Sochi LLC has the right to:
- provide personal data to third parties in cases provided for by the legislation of the Russian Federation;
- refuse to provide personal data in cases specified by the legislation of the Russian Federation;
- use personal data without the data subject’s consent in cases established by law.
5.2. Mavzoley-Sochi LLC must:
- take the necessary and sufficient measures to fulfil the obligations established by legislation;
- ensure the security of personal data;
- provide data subjects with information about their personal data and the periods and purposes of processing;
- update, rectify, block and delete data on the grounds provided for by legislation.
5.3. A data subject has the right to:
- request the rectification, blocking or destruction of their personal data if it is incomplete, outdated, inaccurate, unlawfully obtained or unnecessary for the stated purpose of processing;
- take measures provided for by law to protect their rights;
- obtain information about the periods of processing and storage of personal data, and the sources from which it was obtained;
- challenge, before the competent authority or a court, unlawful acts or omissions by the personal data controller in processing their personal data.
To exercise your rights, send a request to mavz2024@yandex.ru or contact us by telephone at 8 800 77 00 611 / +7 862 261 05 69.
6. Principles and Conditions of Personal Data Processing
6.1. Personal data is processed in accordance with the following principles:
- lawfulness and fairness;
- limiting processing to specific, predetermined and lawful purposes;
- ensuring that the volume and nature of the data processed are consistent with the purposes of processing;
- ensuring the accuracy, sufficiency and currency of personal data, and not processing excessive data;
- retaining personal data no longer than required for the purposes of processing;
- destroying personal data once the purposes of processing have been achieved or the need to achieve them no longer exists.
6.2. Processing is carried out with the data subject’s consent, except in cases expressly provided for by the legislation of the Russian Federation.
6.3. Personal data must not be transferred or disclosed to third parties without the data subject’s consent, except in cases established by law.
7. Ensuring the Security of Personal Data
7.1. Mavzoley-Sochi LLC takes the necessary legal, organisational and technical measures to protect personal data against unlawful or accidental access, destruction, alteration, blocking, copying, disclosure and other unlawful acts.
7.2. The person responsible for organising the processing and security of personal data is appointed by an order of the head of Mavzoley-Sochi LLC.
8. Final Provisions
8.1. This Policy takes effect upon its approval and remains in force indefinitely until replaced by a new version.
8.2. If new regulatory acts affecting the processing and protection of personal data are adopted, this Policy must be brought into conformity with those acts.
8.3. Compliance with the requirements of this Policy is monitored by the persons responsible for organising the processing and protection of personal data at Mavzoley-Sochi LLC.
8.4. Persons responsible for violating the established rules for processing and protecting personal data are liable in accordance with the legislation of the Russian Federation.
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