1. GENERAL PROVISIONS
The policy for the processing of personal data (hereinafter referred to as the “Policy”) is developed in accordance with the Federal Law of July 27, 2006 No. 152-FZ “On Personal Data” (hereinafter - FZ-152).
This Policy defines the procedure for processing personal data and measures to ensure the security of personal data at Overseas property PLC (hereinafter referred to as the Operator) in order to protect the rights and freedoms of a person and citizen in the processing of his personal data, including the protection of privacy rights , personal and family secrets.
The following basic concepts are used in the Policy:
- automated processing of personal data - processing of personal data using computer technology;
- blocking of personal data - temporary termination of the processing of personal data (unless the processing is necessary to clarify personal data);
- information system of personal data - a set of personal data contained in databases, and ensuring their processing of information technologies and technical means;
- 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;
- personal data processing - any action (operation) or a set of actions (operations) performed using automation tools or without using such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data;
- operator - a state body, municipal body, legal or natural person, independently or jointly with other persons, organizing and (or) processing personal data, as well as determining the purposes of processing personal data, the composition of personal data to be processed, actions (operations) performed with personal data;
- personal data - any information relating directly or indirectly to a specific or determinable natural person (subject of personal data);
- provision of personal data - actions aimed at the disclosure of personal data to a specific person or a certain circle of persons;
- distribution of personal data - actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or familiarizing with personal data of an unlimited number of persons, including disclosing personal data in the media, posting on information and telecommunication networks or providing access to personal data in any other way;
- 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 foreign legal entity.
- destruction of personal data - actions, as a result of which it is impossible to restore the content of personal data in the personal data information system and (or) as a result of which material carriers of personal data are destroyed.
The subjects, the personal data of which are processed in Overseas property PLC with or without automation, are:
- job candidates for the Operator;
- Operator's employees and members of their families (spouses and close relatives);
- persons who have previously had an employment relationship with the Operator;
- persons having the civil law nature of contractual relations with the Operator, or at the stage of pre-contractual or completed relations of a similar nature;
- persons undergoing various kinds of practice (internship) with the Operator;
- founders (participants) of the Operator;
Operator counterparties represented by individual entrepreneurs, their employees; founders, managers, representatives (persons acting on the basis of powers of attorney) and employees of legal entities having or having a contractual relationship with the Operator, or wishing to enter into agreements with the Operator;
Operator’s office visitors;
Overseas property PLC website subscribers on the Internet;
other persons whose PD processing is necessary for the Operator to achieve the goals specified in this Policy.
The receipt of personal data from the Operator is organized in such a way as not to violate the confidentiality of the collected personal data. The list of cases when it is necessary to obtain the written consent of the personal data subject to the processing of his personal data, as well as the procedure and form for obtaining consent are determined by the documents of the Company in accordance with the provisions of the Federal Law “On Personal Data”.
In case of incapacity of the subject of personal data, written consent to the processing of his personal data is obtained from his legal representative. Personal data may be received by the Operator from a person who is not the subject of personal data, provided that the operator is provided with confirmation of the existence of the grounds specified in paragraphs. 2-11 h. 1 tbsp. 6, part 2, article 10 and part 2 of article 11 Federal Law "On Personal Data".
When collecting personal data, including through the information and telecommunication network "Internet", recording, systematization, accumulation, storage, updating (updating, changing), extraction of personal data must be carried out by the Operator using databases located in the Russian Federation, for with the exception of cases provided for by the Federal Law "On Personal Data".
Overseas property PLC is obliged to publish or otherwise provide unlimited access to this Personal Data Processing Policy in accordance with Part 2 of Art. 18.1 of the Federal Law "On Personal Data".
2. PRINCIPLES AND TERMS OF PROCESSING PERSONAL DATA
2.1. Principles of processing personal data
The processing of personal data by the Operator is based on the following principles:
- legality and fair basis;
- restrictions on the processing of personal data by achieving specific, predetermined and legitimate goals;
- preventing personal data processing incompatible with the purposes of collecting personal data;
- preventing the unification of databases containing personal data, the processing of which is carried out for purposes incompatible with each other;
- processing only those personal data that meet the purposes of their processing;
- compliance of the content and volume of processed personal data with the stated processing goals;
- preventing the processing of personal data excessive in relation to the stated purposes of their processing;
- ensuring the accuracy, sufficiency and relevance of personal data in relation to the purposes of processing personal data;
- destruction or depersonalization of personal data upon achievement of the purposes of their processing or in case of loss of necessity to achieve these goals, if it is impossible to eliminate the committed violations of personal data by the Operator, unless otherwise provided by federal law.
2.2. Personal data processing conditions
The operator processes personal data in the presence of at least one of the following conditions:
- personal data processing is carried out with the consent of the personal data subject to the processing of his personal data;
- the processing of personal data is necessary to achieve the goals stipulated by the international treaty of the Russian Federation or the law, to carry out and fulfill the functions, powers and obligations assigned to the operator by the legislation of the Russian Federation;
- the processing of personal data is necessary for the administration of justice, the execution of a judicial act, an act of another body or official, subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings;
- the processing of personal data is necessary for the execution of a contract to which either the beneficiary or guarantor is the subject of personal data, as well as for the conclusion of the contract on the initiative of the personal data subject or the contract under which the personal data subject will be the beneficiary or guarantor;
- the 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 this does not violate the rights and freedoms of the subject of personal data;
- processing of personal data is carried out, access to an unlimited circle of persons to which is provided by the subject of personal data or at his request (hereinafter referred to as publicly available personal data);
- processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.
2.3. Confidentiality of personal data
The operator and other persons who have gained access to personal data are required 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.
2.4. Public Sources of Personal Data
In order to provide information support, the Operator may create publicly accessible sources of personal data of personal data subjects, including directories and address books. Public sources of personal data with the written consent of the subject of personal data may include his last name, first name, middle name, date and place of birth, position, contact phone numbers, email address and other personal data communicated by the subject of personal data.
Information about the subject of personal data should be excluded from public sources of personal data at any time at the request of the subject of personal data, the authorized body for the protection of the rights of subjects of personal data or by decision of the court.
2.5. Special categories of personal data
Processing by the Operator of special categories of personal data relating to race, nationality, political views, religious or philosophical beliefs, health status, intimate life is allowed only in relation to the Operator's employees or persons who are candidates for occupying the Operator's vacant positions, if:
- the personal data subject has given written consent to the processing of his personal data;
- personal data is made publicly available by the subject of personal data;
- processing of personal data is carried out in accordance with the legislation on state social assistance, labor legislation, the legislation of the Russian Federation on pensions for state pensions, and labor pensions;
- the processing of personal data is necessary to protect the life, health or other vital interests of the subject of personal data or the life, health or other vital interests of others, and obtaining the consent of the subject of personal data is impossible;
- the processing of personal data is necessary to establish or exercise the rights of the subject of personal data or third parties, as well as in connection with the administration of justice;
- processing of personal data is carried out in accordance with the legislation on compulsory types of insurance, with insurance legislation;
- the processing of special categories of personal data carried out in the cases provided for in paragraph 4 of Article 10 of FZ-152 shall be stopped immediately if the reasons due to which they were processed are eliminated, unless otherwise provided by federal law;
- processing of personal data on a criminal record may be carried out by the Operator exclusively in cases and in the manner that are determined in accordance with federal laws.
2.6. 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 personality - biometric personal data - can be processed by the Operator only in relation to the employees of the Operator or persons who are job seekers to fill the vacant positions of the Operator, subject to written consent of the personal data subject .
2.7. Instruction for processing personal data to another person
The operator has the right to entrust the processing of personal data to another person with the consent of the subject of personal data, unless otherwise provided by federal law, on the basis of an agreement concluded with this person. A person who processes personal data on behalf of the Operator is required to comply with the principles and rules for the processing of personal data provided for in Federal Law-152 and this Policy.
2.8. Cross-border transfer of personal data
The operator is obliged to make sure that the foreign state into whose territory it is supposed to transfer personal data provides adequate protection of the rights of the subjects of personal data before such a transfer begins.
Cross-border transfer of personal data on the territory of foreign states that do not provide adequate protection of the rights of subjects of personal data may be carried out in the following cases:
- the availability of written consent (including using the hardware of the site of Overseas property PLC on the Internet) of the personal data subject to the cross-border transfer of his personal data;
- execution of a contract to which the subject of personal data is a party.
2.9. Automatic collection of personal information
2.9.1. IP addresses
An IP address is a number assigned to your computer every time you access the Internet. It allows computers and servers to recognize each other and exchange information. The IP addresses of visitors to our sites can be taken into account for information security and system diagnostics purposes. This information can also be used in aggregated form to analyze the trends in the use of sites and their effectiveness.
2.9.2. Cookie technology
A cookie is a file placed on your computer or device connected to the Internet each time you visit our site. This allows the site to remember your computer or device. In addition, the technology of cookies can be used for other purposes.
An information window appearing on some of our websites will request your consent to the collection of cookies. To maintain the functionality of the site, you may need a second type of cookie, called “user cookies”. Using an information banner does not block these cookies. The item you select will be stored in a cookie and valid for 90 days. If you want to cancel it, you can do this by deleting cookies in your browser.
Despite the fact that most browsers accept cookies automatically, you can configure your browser so that only you can decide whether to accept a cookie or block it (see the Tools menu or the Settings menu of your browser). You can delete cookies from your device at any time. It should be remembered that if you do not accept cookies, some functions of the site may be lost.
More information about managing cookies can be found in the help file of your browser or on specialized sites, for example www.allaboutcookies.org.
Third-party tools and widgets can be used on our individual web pages to provide online visitors with additional options. In this case, a cookie may be placed on your device, which will make it more convenient to use tools and widgets and correctly reflect the process of your communication with other users on our web pages.
Cookies themselves do not tell us your email address and do not otherwise identify you. In our analytical reports, we can use other identifiers, including IP addresses, but only for the purpose of determining the number of unique online visitors to our websites and collecting information about their geographical location, and not to identify individual online visitors.
By browsing our websites or entering your credentials for upload to the system in order to gain access to areas that only registered users can enter, you agree to our placement of cookies on your computer or device connected to the Internet.
2.9.3. Google Analytics Online Service
Overseas property PLC uses the Google Analytics Internet service. You can find more information about using Google Analytics here: http://www.google.com/analytics/learn/privacy.html
2.9.4. Web beacons (web beacon technology)
A web beacon is a small graphic file on a web page that can be used to receive certain information from your computer, such as IP address, duration of the study of the contents of the web page, browser type, as well as the availability of cookies, previously created by the same server.
Overseas property PLC uses these web beacons in strict accordance with applicable law.
Overseas property PLC or service provider organizations may use web beacons to monitor the performance of third-party websites that provide us with recruitment or marketing services, or to collect aggregated statistics about online visitors to the site and cookie management.
You have the option to disable some web beacons by blocking cookies associated with them. In this case, the web beacon will be able to register an anonymous visit from your IP address, but the information in the cookie will not be recorded.
In the case of subscribing to our newsletters or other materials, we can monitor the actions of recipients, for example, through the built-in links inside messages, we can collect information about the number of recipients who opened a particular message. The collection of this information is carried out in order to evaluate which sections of the site are of most interest to users, and to improve user settings.
2.9.5. Location Services
Overseas property PLC may collect and use information about the geographical location of your computer or mobile device. The purpose of collecting this data is to provide you with information about services in your area that might be of interest to you and improve the products and services it offers.
3. RIGHTS OF A SUBJECT OF PERSONAL DATA
3.1. Consent of the personal data subject to the processing of his personal data
The personal data subject decides to provide his personal data and agrees to its processing freely, by his will and in his interest. Consent to the processing of personal data may be given by the subject of personal data or his representative in any form allowing confirming the fact of its receipt, unless otherwise provided by federal law.
3.2. Rights of the subject of personal data
The personal data subject has the right to receive information from the Operator regarding the processing of his personal data, if such a right is not limited in accordance with federal laws. The personal data subject has the right to require the Operator to clarify his personal data, block it or destroy it if the personal data is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated processing purpose, and also take measures prescribed by law to protect their rights .
The processing of personal data in order to promote goods, works, services on the market through direct contacts with the subject of personal data (potential consumers) by means of communication, as well as for political campaigning, is allowed only with the prior consent of the subject of personal data.
The operator is obliged to immediately stop at the request of the personal data subject the processing of his personal data for the above purposes.
It is forbidden to make decisions on the basis of exclusively automated processing of personal data that give rise to legal consequences in relation to the subject of personal data or otherwise affect his rights and legitimate interests, with the exception of cases provided for by federal laws, or if there is written consent of the subject of personal data.
If the subject of personal data considers that the Operator is processing his personal data in violation of the requirements of Federal Law-152 or otherwise violates his rights and freedoms, the subject of personal data has the right to appeal the actions or omissions of the Operator to the Authorized Body for the Protection of the Rights of Subjects of Personal Data or in court .
The personal data subject has the right to protect his rights and legitimate interests, including compensation for losses and (or) compensation for moral damage.
4. SECURITY OF PERSONAL DATA
The security of personal data processed by the Operator is ensured by the implementation of legal, organizational and technical measures necessary to ensure the requirements of federal legislation in the field of personal data protection.
To prevent unauthorized access to personal data by the Operator, the following organizational and technical measures are applied:
- the appointment of officials responsible for organizing the processing and protection of personal data;
- restriction of the composition of persons allowed to process personal data;
- familiarization of subjects with the requirements of federal legislation and regulatory documents of the Operator for the processing and protection of personal data;
- organization of accounting, storage and circulation of media containing information with personal data;
- definition of threats to the security of personal data during their processing, the formation of threat models on their basis;
- development of a personal data protection system based on the threat model;
- verification of the readiness and effectiveness of the use of information security tools;
- differentiation of user access to information resources and hardware and software information processing;
- registration and accounting of actions of users of personal data information systems;
- the use of antivirus and recovery tools for personal data protection;
- the use, if necessary, of firewalls, intrusion detection, security analysis and cryptographic information protection tools;
- organization of access control to the territory of the Operator, security of premises with technical means for processing personal data.
5. DATE OF PROCESSING (STORAGE) OF PERSONAL DATA
The terms for processing (storing) personal data are determined in accordance with the term of the contract with the subject of personal data, the limitation period, as well as other periods established by the legislation of the Russian Federation and the documents of the Operator.
Personal data whose processing (storage) period has expired must be destroyed, unless otherwise provided by federal law or regulatory documents of the Operator.
Storage of personal data after the expiration of the storage period is allowed only after their depersonalization.
6. FINAL PROVISIONS
Other rights and obligations of the Operator in connection with the processing of personal data are determined by the legislation of the Russian Federation in the field of personal data.
Operator employees who are guilty of violating the rules governing the processing and protection of personal data bear material, disciplinary, administrative, civil or criminal liability in the manner prescribed by federal laws.