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Personal Data Processing Policy

1. General Provisions:

1.1. Agropromkomplektatsiya LLC (OGRN: 1027700328523) (hereinafter referred to as the “Operator”), being the operator performing the processing of personal data, considers it its most important task to comply with the principles of legality, fairness and confidentiality when processing personal data, as well as to ensure the security of their processing.

1.2. This Policy establishes common goals, principles, conditions and methods of processing personal data by the Operator, and also defines the main measures implemented by the Operator to ensure the protection of personal data.

1.3. The main purpose of this Policy is to protect the rights of individuals when processing their personal data by the Operator.

2. Terms and definitions:

2.1.Personal data means any information relating directly or indirectly to a specific or identifiable individual (subject of personal data);

2.2. Operator — Agropromkomplektatsiya LLC (OGRN: 1027700328523);

2.3. Processing of personal data - any action (operation) or a set of actions (operations) performed with personal data using automation tools or without using such tools, including collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data;

2.4. Automated processing of personal data — processing of personal data using computer technology;

2.5. Dissemination of personal data — actions aimed at disclosing personal data to an indefinite circle of persons;

2.6. Provision of personal data — actions aimed at disclosing personal data to a certain person or a certain circle of persons;

2.7. Blocking of personal data — temporary termination of the processing of personal data (except for cases where processing is necessary to clarify personal data);

2.8. Destruction of personal data — actions as a result of which it is 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;

2.9. Depersonalization of personal data — actions as a result of which it is impossible to determine, without the use of additional information, the belonging of personal data to a specific subject of personal data;

2.10.Biometric personal data — information that characterizes the physiological and biological characteristics of a person, on the basis of which it is possible to establish his identity;

2.11. Confidentiality of personal data is a mandatory requirement for the Operator not to disclose to third parties and not to distribute personal data without the consent of the subject of personal data, unless otherwise provided by federal law.

3. Purposes of processing personal data by the Operator:

3.1. Providing answers to requests and complaints of personal data subjects received by the Operator:

• by the hotline number 8-800-770-07-74 (hereinafter referred to as the “Hotline”);

• through the feedback window with the Operator on the website apkholding.ru (hereinafter referred to as the “Operator's site”).

3.2. Search and selection of candidates for filling vacant positions, candidates for internship / internship, decision-making on hiring / refusing to hire, hiring for internships / internships, forming the Operator's talent pool.

3.3. Improvement of communication methods and functionality of the Operator's website.

4. Legal basis for the processing of personal data

4.1. The processing of personal data is carried out by the Operator on the basis of the consent of the subjects of personal data to the processing of personal data received in the manner prescribed by clause 6.3 of this Policy.

5. The volume and categories of processed personal data, categories of personal data subjects: The operator processes the following personal data:

• In relation to subjects of personal data leaving requests and complaints in accordance with clause 3.1. of this Policy, as well as those who subscribed to the newsletter and site events:

- Full Name,

- phone number, email address.

• In relation to candidates for filling vacant positions, passing of industrial practice / internship:овки:

- Full Name;

- the photo;

- phone number, email address;

- information about accounts in social networks;

- age, date and year of birth;

- information about marital status;

- information about the place of residence (address);

- information about education, advanced training, training, certification, courses, internships, training and additional professional education, the availability of an academic degree / academic title, including the name of the educational institution, the timing and form of training;

- information about previous work experience indicating the month and year of admission and dismissal, the name of the organization, position, job responsibilities, total length of service;

- information about professional achievements, about corporate, industry and state awards;

- information on foreign language proficiency, level of proficiency;

- information on the availability of rights to drive vehicles,

- information about personal qualities,

- other personal data provided by the subject of personal data for making a decision on admission or refusal to hire, making a decision on admission to industrial practice / internship.

6. The procedure and conditions for the processing of personal data by the Operator:

6.1. The operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), retrieves, uses, transfers (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.

6.2.The operator has the right to entrust the processing of personal data to other legal entities. 6.3. The processing of personal data is carried out only subject to the consent of the subject of personal data to its processing in the following order:е:

6.3.1. The subject of personal data, by ticking the box on the consent to the processing of personal data and clicking the “Send” button in the feedback form on the Operator's website, provides the Operator with his consent to the processing of personal data in the following volume:

• The subject of personal data, acting freely, by his own will and in his interest, agrees to the processing of all his personal data specified in the feedback form, including: last name, first name, patronymic, email address, telephone number in order to provide an answer to his request / complaint received through the feedback form on the Operator's website.

• The subject of personal data permits the following actions with his personal data: collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction, with the use of automation tools and without the use of such tools.

• The subject of personal data agrees to entrust the processing of personal data to legal entities.

• Consent is valid for 5 (Five) years from the date of its provision and can be withdrawn by the subject of personal data at any time by submitting a written application in the manner prescribed by clause 7.3 of this Policy.

6.3.2. The subject of personal data, by ticking the box on the consent to the processing of personal data and clicking the “Subscribe” button in the form for subscribing to news and mailings of the site, provides the Operator with his consent to the processing of personal data in the following volume:

• The subject of personal data, acting freely, of his own free will and in his own interest, agrees to the processing of all his personal data: last name, first name, patronymic, e-mail address, telephone number in order to receive news and mailings from the site.

• The subject of personal data permits the following actions with his personal data: collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction, with and without the use of automation tools.

• The subject of personal data agrees to entrust the processing of personal data to legal entities.

• Consent is valid for 5 (Five) years from the date of its provision and can be withdrawn by the subject of personal data at any time by submitting a written application in the manner prescribed by clause 7.3 of this Policy.

6.3.3. The subject of personal data, by ticking the box on the consent to the processing of personal data and clicking the “Send” button in the form “Fill in the form” and / or “Sign up for an internship” on the Operator's website, provides the Operator with his consent to the processing of personal data in the following volume:

• The subject of personal data, acting freely, of his own free will and in his own interest, agrees to the processing of all his personal data provided by him in the resume and / or on the website, including biometric ones, including but not limited to: surname, first name, middle name, photo, phone number, e-mail address, information about accounts in social networks, age, date and year of birth; information about marital status; information about the place of residence (address); information about education, advanced training, training, certification, courses, internships, training and additional vocational education, the availability of an academic degree/ academic title, including the name of the educational institution, the timing and form of training; information about previous work experience indicating the month and year of hiring and dismissal, the name of the organization, position, job duties, total work experience; information on professional achievements, on awarding corporate, industry and government awards; information about the knowledge of foreign languages, the level of proficiency; information on the availability of rights to drive vehicles, information on personal qualities; other personal data provided by the subject of personal data for making a decision on hiring or refusing to hire, in order to search and select candidates for filling vacant positions, making a decision on hiring / refusing to hire, accepting for industrial practice / internship, forming personnel reserve of the Operator.

• The subject of personal data permits the following actions with his personal data: collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction, with and without the use of automation tools.

• The subject of personal data agrees to entrust the processing of personal data to legal entities.

• Consent is valid for 5 (Five) years from the date of its provision and can be withdrawn by the subject of personal data at any time by submitting a written application in the manner prescribed by clause 7.3 of this Policy.

6.3.4. The subject of personal data, making a call to the Hotline and continuing a conversation with an employee of the Operator, provides the Operator with consent to the processing of those provided during a telephone conversation with an employee of the Operator. Calls to the Hotline may be recorded for the purposes stated in clause 3.1 of this Policy. The consent is valid for 5 (Five) years from the date of its provision and can be revoked by the subject of personal data at any time by submitting a written application.

6.4. The operator guarantees the conscientious collection of personal data and the preservation of their confidentiality during the processing.

6.5. The processing of personal data can be carried out by the Operator both using automation tools and without using such tools.

7. The subject of personal data has the right:

7.1. To receive information regarding the processing of his personal data. The operator provides the subject of personal data with information regarding the processing of his personal data, within 30 (Thirty) days from the date of receipt of the relevant request from the subject.

7.2. Require the Operator to clarify his personal data, to block or destroy them if the personal data is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing. In the cases described in this clause of the Policy, the Personal Data Subject sends the Operator a written request (statement) to the Operator's address info@apkholding.ru.

7.3.At any time, withdraw consent to the processing of personal data by sending a written application to the Operator's info@apkholding.ru, indicating in the subject line “Withdrawal of consent to the processing of personal data”.

Upon receipt of a revocation of consent to the processing of personal data, the Operator stops processing personal data and ensures their destruction within 30 (Thirty) days from the date of receipt of the revocation, unless otherwise provided by the legislation of the Russian Federation.Upon receipt of a revocation of consent to the processing of personal data, the Operator stops processing personal data and ensures their destruction within 30 (Thirty) days from the date of receipt of the revocation, unless otherwise provided by the legislation of the Russian Federation.

In case of withdrawal of consent to the processing of 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 clauses 2-11 of part 1 of article 6, part 2 of article 10 and part 2 of article 11 of Federal Law No. 152-FZ “On Personal Data” dated 27.07.2006 g.

7.4.Exercise other rights provided for by the legislation of the Russian Federation.

8. Ensuring the security and confidentiality of personal data.

8.1. The operator takes all necessary and sufficient legal, organizational and technical measures to protect personal data from unauthorized access, destruction, modification, blocking, copying, distribution, as well as from other illegal actions by third parties.

8.2. The measures taken by the Operator to protect personal data, among others, include:

• limiting the number of employees who have access to personal data, the appointment of employees responsible for organizing the processing of personal data;

• establishing rules for access to personal data, issuing local regulations on the processing and protection of personal data, monitoring their compliance;

• familiarization of the Operator's employees who are directly processing personal data with the requirements of the current legislation, as well as local regulations of the Operator in the field of personal data processing;

• identification of threats to the security of personal data during their processing and development of measures and measures to protect personal data;

• identification and elimination of violations of the requirements for the protection of personal data, carrying out preventive work with the Operator's employees to prevent the disclosure of personal data;

• implementation of internal control and (or) audit of the compliance of personal data processing with the requirements of legislation in the field of personal data;

• separate storage of personal data, the processing of which is carried out for various purposes;

• storage of material carriers of personal data in compliance with the conditions ensuring the safety of personal data and excluding unauthorized access to them;

• other measures established by the legislation of the Russian Federation in the field of personal data processing.

9. Actualization, correction and destruction of personal data.

9.1. In case of establishing the fact of inaccuracy of the processed personal data, the operator ensures their correction and updating.

9.2. The processing of personal data is terminated, and personal data are subject to destruction in the following cases:

• achieving the goals of processing personal data,

• expiration of the consent to the processing of personal data,

• revocation by the subject of personal data of consent to the processing of his personal data;

• identification of illegal processing of personal data (including when the subject of personal data applies).

10. Access to the Policy

The current version of this Policy is posted and constantly available on the Operator's website at: https://www.apkholding.ru/en/politika-konfidentsialnosti


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