1. GENERAL PROVISIONS 1.1. The Personal Data Processing Policy of ANYTIE LLC has been developed in accordance with the requirements of Part 2, Article 18.1 of Federal Law No. 152-FZ of July 27, 2006 "On Personal Data" and is intended to provide unlimited access to information regarding the processing of personal data, as well as information on the implemented requirements for the protection of personal data at ANYTIE LLC.
1.2. This policy describes the procedure for processing and protecting the personal data of individuals in connection with the implementation of labor relations, the conclusion of contracts and fulfillment of contractual obligations of ANYTIE LLC, and the execution of the organization’s statutory activities.
1.3. Personal data belongs to the category of confidential information and is protected from unauthorized, including accidental, access.
2. TERMS AND DEFINITIONS 2.1.
Personal data – any information relating directly or indirectly to an identified or identifiable individual (personal data subject);
2.2.
Operator – a state body, municipal body, legal entity, or individual, independently or jointly with other persons organizing and (or) processing personal data, as well as determining the purposes of personal data processing, the composition of personal data to be processed, and the actions (operations) performed with personal data. Within the framework of this policy, the Operator is ANYTIE LLC (hereinafter referred to as the Operator);
2.3.
Processing of personal data – any action (operation) or a set of actions (operations) performed with or without the use of automation tools with personal data, including the collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data;
2.4.
Automated processing of personal data – processing of personal data using computer technology;
2.5.
Distribution of personal data – actions aimed at disclosing personal data to an undefined circle of persons;
2.6.
Provision of personal data – actions aimed at disclosing personal data to a specific person or a specific circle of persons;
2.7.
Blocking of personal data – a temporary suspension of personal data processing (except when processing is necessary to clarify personal data);
2.8.
Destruction of personal data – actions that make it impossible to restore the content of personal data in the personal data information system and (or) as a result of which physical carriers of personal data are destroyed;
2.9.
Anonymization of personal data – actions as a result of which it becomes impossible to determine the ownership of personal data by a specific personal data subject without using additional information;
2.10.
Personal data information system – a set of personal data contained in databases and the information technologies and technical means that ensure their processing;
2.11.
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;
2.12.
Website – a website controlled and managed by the Operator, available on the Internet under the unique domain name
https://anytie.ru/;
2.13.
User – an individual who has visited the Website pages on their device.
3. PURPOSES AND LEGAL GROUNDS FOR PERSONAL DATA PROCESSING 3.1. The processing of personal data by the Operator is carried out for the purpose of:
3.1.1. Fulfilling the requirements of the legislation of the Russian Federation (including the purpose of exercising and fulfilling the functions, powers, and duties imposed on the Operator by the legislation of the Russian Federation);
3.1.2. Exercising and fulfilling rights and obligations arising from labor relations, including for the purpose of assisting employees in employment, obtaining education and career advancement, ensuring the personal safety of employees, monitoring the quantity and quality of work performed and ensuring the safety of property, paying wages and other payments due to the employee in accordance with the legislation of the Russian Federation or a contract, and making tax and social contributions stipulated by the legislation of the Russian Federation;
3.1.3. Carrying out recruiting (personnel selection), including to ensure candidates for vacant positions have the opportunity to undergo the selection process, and to employ those who successfully pass the selection for the respective vacant positions;
3.1.4. Executing a judicial act, an act of another body, or an official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings;
3.1.5. Concluding, executing, and terminating civil law contracts in cases stipulated by the legislation of the Russian Federation and the Charter of the Operator;
3.1.6. Filling out the feedback form on the Website;
3.1.7. Exercising and fulfilling the rights and obligations imposed on the Operator by contracts, including for the purpose of executing a contract to which the personal data subject is a party, beneficiary, or guarantor, as well as concluding a contract at the initiative of the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor;
3.1.8. Exercising the rights and legitimate interests of the Operator or third parties;
3.1.9. Carrying out activities stipulated by the Charter of the Operator;
3.1.10. Providing paid and free services to personal data subjects;
3.1.11. Making settlements with personal data subjects;
3.1.12. Improving the quality of services provided by the Operator;
3.1.13. Promoting goods, works, and services on the market by making direct contact with personal data subjects;
3.1.14. Communicating with the personal data subject if necessary, including sending notifications, information, and requests related to the Operator's activities in providing services to personal data subjects, as well as processing statements, applications, and other messages from personal data subjects.
3.2. The Operator may use the User's personal information for the purposes of:
3.2.1. Establishing and maintaining communication between the User and the Operator, consulting on the provision of services by the Operator.
3.2.2. Performing marketing tasks (including sending marketing mailings to Users via email or phone number), conducting statistical and other research. Separate consent is requested for this purpose in the Website interface.
3.2.3. Implementing the Operator's provision of anonymized cookie data to third parties so that third parties can display targeted advertising and information materials to Users on the Internet and (or) for third parties to provide other services to Users in accordance with the law.
3.2.4. Improving the quality of User service and modernizing the Website by processing requests and applications from the User.
3.3. The legal grounds for processing personal data are:
3.3.1. The Constitution of the Russian Federation;
3.3.2. The Civil Code of the Russian Federation;
3.3.3. The Tax Code of the Russian Federation;
3.3.4. The Labor Code of the Russian Federation;
3.3.5. Federal Law No. 27-FZ of April 1, 1996 "On Individual (Personalized) Accounting in the Compulsory Pension Insurance System";
3.3.6. Federal Law No. 402-FZ of December 6, 2011 "On Accounting";
3.3.7. Federal Law No. 53-FZ of March 28, 1998 "On Military Duty and Military Service";
3.3.8. Other regulatory legal acts of the Russian Federation and regulatory documents of authorized state authorities;
3.3.9. The Charter of ANYTIE LLC; 3.2.10. The consent of personal data subjects to the processing of their personal data.
(Note: Original text uses 3.2.1-3.2.10 under section 3.3, kept as in the original).4. BASIC RIGHTS AND OBLIGATIONS OF THE OPERATOR AND PERSONAL DATA SUBJECTS 4.1. Subjects whose personal data is processed have the right to:
4.1.1. Free familiarization with their personal data, except in cases stipulated by Federal Law No. 152-FZ of July 27, 2006 "On Personal Data";
4.1.2. Receive information concerning the processing of their personal data, including containing:
4.1.2.1. Confirmation of the fact of personal data processing by the Operator;
4.1.2.2. Legal grounds and purposes of personal data processing;
4.1.2.3. Purposes and methods of personal data processing used by the Operator;
4.1.2.4. The name and location of the Operator, information about persons (excluding Operator’s employees) who have access to personal data or to whom personal data may be disclosed based on a contract with the Operator or federal law;
4.1.2.5. Processed personal data relating to the respective personal data subject, and the source of its receipt, unless another procedure for submitting such data is stipulated by federal law;
4.1.2.6. Terms of processing personal data, including terms of their storage;
4.1.2.7. The procedure for the personal data subject to exercise the rights stipulated by the Federal Law "On Personal Data";
4.1.2.8. Information on the absence of cross-border data transfer;
4.1.2.9. The name or surname, first name, patronymic, and address of the person processing personal data on behalf of the Operator, if the processing is or will be entrusted to such a person;
4.1.2.10. Other information stipulated by the legislation of the Russian Federation;
4.1.3. Require the Operator to clarify, block, or destroy their personal data if the personal data is incomplete, outdated, inaccurate, illegally obtained, or is not necessary for the stated purpose of processing, as well as take legal measures to protect their rights;
4.1.4. Appeal the actions or inactions of the Operator to the authorized body for the protection of the rights of personal data subjects or in court;
4.1.5. Protect their rights and legitimate interests, including claiming damages and (or) compensation for moral harm in court.
4.2. Subjects whose personal data is processed are obliged to:
4.2.1. Provide accurate information about themselves and provide documents containing personal data, the composition of which is established by the legislation of the Russian Federation and local regulatory documents of the Operator, in the volume necessary for the purpose of processing;
4.2.2. Notify the Operator regarding the clarification (update, modification) of their personal data.
4.3. Employees of the Operator who process personal data, depending on the purposes of processing specified in this policy, have the right to:
4.3.1. Receive documents containing personal data;
4.3.2. Require the personal data subject to provide timely clarification of the provided personal data.
4.4. Employees of the Operator processing the personal data of personal data subjects are obliged to:
4.4.1. Process personal data obtained in the manner prescribed by current legislation;
4.4.2. Consider requests from the personal data subject (the legal representative of the personal data subject, the authorized body for the protection of the rights of personal data subjects) regarding the processing of their personal data and provide reasoned responses within a period not exceeding 7 (seven) working days from the date of receipt of the appeal (request);
4.4.3. Provide the personal data subject (the legal representative of the personal data subject) with the opportunity for free access to their personal data processed by the Operator;
4.4.4. Take measures to clarify or destroy the personal data of the personal data subject in connection with their (or their legal representative's) appeal containing legal and justified demands;
4.4.5. Organize the operational and archival storage of the Operator's documents containing the personal data of personal data subjects in accordance with the requirements of the legislation of the Russian Federation.
5. PROCEDURE AND CONDITIONS FOR PERSONAL DATA PROCESSING 5.1. When filling out a feedback form – regarding personal data that the User provides to the Operator when filling out the feedback form, the User is deemed to have provided consent to the processing of their personal data entered in the fields of the feedback form at the moment of clicking the button confirming the submission of the application (buttons may be called "Send," "Leave an application," and similarly).
5.2. During any use of the Website – regarding personal data and cookies automatically transmitted to the Operator while using the Website via software installed on the User's device, the User is deemed to have provided consent to the processing of their personal data and the collection of cookies at the moment they begin using the Website.
5.3. The Operator assumes that when providing personal data on the Website, the User:
5.3.1. Is a legally capable person. In case of incapacity of such a person, consent to the processing of personal data is provided by the legal representative of the User, who has read and agreed to the conditions of personal data processing specified in this policy.
5.3.2. Indicates accurate information about themselves in the volume necessary to use the Website and keeps the provided personal data up to date. The Operator does not verify the accuracy of the personal information provided by Users during any use of the Website.
5.3.3. Has read the Policy and expresses their informed and conscious consent to it.
5.4. The processing of personal data is carried out by the Operator based on the following principles:
5.1.1. The existence of legal grounds for personal data processing;
5.1.2. Limitation of personal data processing to the achievement of specific, predetermined, and legitimate purposes;
5.1.3. Prohibition of merging databases containing personal data whose processing is carried out for incompatible purposes;
5.1.4. Processing only personal data that meets the purposes of its processing; 5.1.5. Conformity of the content and volume (prevention of redundancy) of the processed personal data to the stated purposes of processing;
5.1.6. Ensuring the accuracy of personal data, its sufficiency, and, where necessary, relevance in relation to the purposes of personal data processing;
5.1.7. Storing personal data in a form that allows identifying the personal data subject for no longer than the purposes of personal data processing require, unless the storage period for personal data is established by federal law, a contract to which the personal data subject is a party, beneficiary, or guarantor.
(Note: Numbering 5.1.1-5.1.7 kept as in original text). 5.5. The processing of personal data may be carried out by the Operator in the following cases:
5.2.1. Consent of the subject to the processing of their personal data has been obtained;
5.2.2. Processing of personal data is necessary to exercise and fulfill the functions, powers, and duties imposed on the operator by the legislation of the Russian Federation;
5.2.3. Processing of personal data is carried out in connection with the participation of the personal data subject in civil and arbitration proceedings;
5.2.4. Processing of personal data is necessary to execute a judicial act in accordance with the legislation of the Russian Federation on enforcement proceedings;
5.2.5. Processing of personal data is necessary for the execution of a contract to which the personal data subject is a party, beneficiary, or guarantor, as well as for the conclusion of a contract at the initiative of the personal data subject;
5.2.6. Processing of personal data is necessary to protect the life, health, or other vital interests of the personal data subject if obtaining consent from the personal data subject is impossible;
5.2.7. Processing of personal data is necessary to exercise the rights and legitimate interests of the operator or third parties, or to achieve socially significant goals, provided that the rights and freedoms of the subject are not violated;
5.2.8. Processing of personal data is carried out for statistical or other research purposes, subject to mandatory anonymization of personal data;
5.2.9. Processing of personal data subject to publication or mandatory disclosure in accordance with the legislation of the Russian Federation is being carried out.
(Note: Numbering 5.2.1-5.2.9 kept as in original text). 5.6. Processing of personal data may be carried out using computer technology (automated processing) or with the direct participation of a person without the use of computer technology (non-automated processing).
5.7. Only employees of the Operator whose job duties include processing personal data are allowed to process personal data. These employees have the right to receive only the personal data necessary to perform their job duties.
5.8. The processing of personal data is carried out by:
5.8.1. Receiving information containing personal data in oral and written form directly from personal data subjects;
5.8.2. Receiving original required documents from personal data subjects;
5.8.3. Receiving duly certified copies of documents containing personal data or copying original documents;
5.8.4. Receiving personal data by sending requests to public authorities, state extra-budgetary funds, other state bodies, local governments, commercial and non-commercial organizations, and individuals in cases and in the manner stipulated by the legislation of the Russian Federation;
5.8.5. Receiving personal data from publicly available sources;
5.8.6. Fixing (registering) personal data in journals, books, registers, and other accounting forms;
5.8.7. Entering personal data into the Operator's information systems;
5.8.8. Using other means and methods of recording personal data obtained in the framework of the Operator's activities.
5.9. The transfer of personal data to third parties (including cross-border transfer) is allowed with the written consent of personal data subjects, except in cases where it is necessary to prevent a threat to the life and health of personal data subjects, as well as in other cases established by the legislation of the Russian Federation.
5.10. When transferring personal data to third parties in accordance with concluded contracts, the Operator ensures mandatory compliance with the requirements of the legislation of the Russian Federation and the Operator's regulatory acts in the field of personal data.
5.11. The transfer of personal data to authorized executive bodies and organizations (Ministry of Internal Affairs of the Russian Federation, Ministry of Foreign Affairs of the Russian Federation, Federal Tax Service, Pension Fund of the Russian Federation, Federal Compulsory Medical Insurance Fund of the Russian Federation, and others) is carried out in accordance with the requirements of the legislation of the Russian Federation.
5.12. The Operator has the right to entrust the processing of personal data to another legal entity or individual entrepreneur with the consent of the personal data subjects based on a concluded contract. A legal entity or individual entrepreneur processing personal data on behalf of the Operator is obliged to comply with the principles and rules of personal data processing stipulated by the legislation of the Russian Federation in the field of personal data.
5.13. If the Operator, based on a contract, transfers or entrusts the processing of personal data to another legal entity or individual entrepreneur, a material condition of the contract must be the obligation of that person to ensure confidentiality and personal data security during its transfer or processing.
