Personal data processing policy
1. The most important condition for the implementation of the objectives of the activity of LLC Group Artefact (hereinafter referred to as LLC Group Artefact, Operator, Company; address: 107031, Moscow, Kuznetsky Most str., 7, attic floor, premises II, room 1-11) is to ensure the necessary and sufficient level of security of information, including personal data.
2. The Policy on Personal data processing in LLC Group Artefact (hereinafter referred to as the Policy, Regulation) defines the procedure for collecting, storing, transmitting and other types of personal data processing in LLC Group Artefact, as well as information on the implemented requirements for personal data protection.
3. The policy is developed in accordance with the current legislation of the Russian Federation.
2. COMPOSITION OF PERSONAL DATA AND LIST OF ACTIONS WITH DATA
1. Information constituting personal data is any information relating directly or indirectly to a specific or identifiable individual (subject of personal data). A detailed list of personal data is recorded in the local regulatory documentation of LLC Group Artefact.
2. All personal data processed by LLC Group Artefact is confidential, strictly protected information in accordance with the legislation.
3. List of actions with personal data: collection, analysis, generalization, storage, modification, addition, transfer, destruction of personal data. Methods of processing personal data: automated / non-automated.
3. PURPOSES OF PERSONAL DATA PROCESSING
1. Personal data is processed by LLC Group Artefact for the purposes of registration of labor and other contractual relations, personnel, accounting, tax accounting, as well as for the organization and conduct of LLC Group Artefact, (including with the involvement of third parties) events, competitions, marketing and/or advertising campaigns, research; performance of LLC Group Artefact obligations under service agreements and other agreements; promotion of services and/or products of LLC Group Artefact and / or partners of LLC Group Artefact on the market by making direct contacts with clients of LLC Group Artefact through various means of communication, including, but not limited to, by phone, e-mail, mailing list, on the Internet, etc.; for other purposes, if the actions of LLC Group Artefact do not contradict the current legislation. One of the events organized by the Operator is the Mercedes-Benz Fashion Week Russia event held twice a year, for the purposes of which the Operator, among other things, collects and processes personal data of designers, volunteers participating or planning to participate in this event, as well as collects and processes personal data of media representatives and buyers within the framework of their accreditation for the event. In addition, the Operator conducts various competitions, educational, cultural and other events in the field of fashion, including a competition for young designers, for the purposes of organizing which the Operator also collects and processes personal data of participants.
The operator has the right to transfer personal data to third parties for the purposes of carrying out its activities in accordance with the terms of the current legislation, including the following third parties. The subject of personal data, by providing his personal data to LLC Group Artefact, gives his consent to the transfer of personal data to the specified legal entities and other third parties.
2. LLC Group Artefact processes the following personal data necessary for the proper performance of contractual and other obligations in order to properly perform its duties as an operator:
personal data of employees of the Operator who are in an employment relationship with the Operator, and candidates for vacancies;
personal data of other individuals, including, but not limited to, those who are in contractual, civil relations with the Operator or intend to enter into such relations with the Operator, including, but not limited to, actual or potential: customers, contractors, their employees and representatives, as well as persons who take or plan to take part in events, competitions organized and conducted by the Operator.
4. PROCEDURE FOR THE COLLECTION, STORAGE, TRANSFER AND OTHER TYPES OF PROCESSING OF PERSONAL DATA
1. The processing of personal data, carried out without the use of automation tools, is carried out in such a way that in relation to each category of personal data, it is possible to determine the places of storage of personal data (material carriers). The Operator has established a list of persons who process or have access to personal data. Separate storage of personal data (material carriers) is provided, the processing of which is carried out for various purposes. the operator ensures the safety of personal data and takes measures to prevent unauthorized access to personal data.
2. The processing of personal data carried out with the use of automation, is subject to the following: the Operator carries out technical measures to prevent unauthorized access to personal data and (or) their transfer to persons not having right of access to such information, carries out continuous monitoring of the level of protection of personal data.
5. INFORMATION ABOUT THE MEASURES IMPLEMENTED TO PROTECT PERSONAL DATA.
1. The Operator carries out the following activities:
appoints the person responsible for organizing the processing of personal data;
adopts local regulations and other documents in the field of processing and protection of personal data;
provides unlimited access to the Policy, a copy of which is available at the Operator's location, and can also be posted on the Operator's website;
familiarizes employees with the provisions of the legislation on personal data, as well as with the Policy, organizes training and methodological work with employees;
allows employees to access personal data processed in the Operator's information system, as well as their material carriers, only for the performance of their work duties;
sets rules for access to personal data processed in the Operator's information system;
detects the facts of unauthorized access to personal data and takes measures to respond, including the recovery of personal data modified or destroyed as a result of unauthorized access to them;
performs internal control over the compliance of personal data processing with the Federal Law "On Personal Data" and the regulatory legal acts adopted in accordance with it;
takes other necessary and sufficient legal, organizational and technical measures 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.
6. RIGHTS AND OBLIGATIONS OF THE OPERATOR
1. LLC Group Artefact, as an Operator of personal data, has the right to:
provide personal data of subjects to third parties, if this is provided for by the current legislation (tax, law enforcement agencies, etc.);
refuse to provide personal data in cases provided for by law;
use the personal data of the subject without his consent in cases provided for by law.
7. RIGHTS AND OBLIGATIONS OF THE PERSONAL DATA SUBJECT
1. The subject of personal data has the right to:
receive personal data related to this subject and information related to their processing;
clarify, block or destroy his personal data if they are incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing;
revoke their consent to the processing of personal data;
protect their rights and legitimate interests, including compensation for damages and compensation for non-pecuniary damage in court;
appeal against the actions or omissions of the Operator to the authorized body for the protection of the rights of personal data subjects or in court.
2. In order to exercise their rights and legitimate interests, personal data subjects have the right to contact the Operator or send a request in person or with the help of a representative.
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