Policy of the LLC "E-Trans" in respect of processing of personal data
Registered office and place of business of the LLC "E-Trans" address:
E-Trans LLC, 1 Krasny prospekt St., Office 322, 630007 Novosibirsk, Russia
1. Purpose and scope of the document
1. "The policy of the LLC "E-Trans" (hereinafter referred to the Company) in respect of processing of personal data" (hereinafter № the Policy) determines the position and intentions of the Company in the field of processing and protection of personal data with the purpose of observance and protection of human rights and freedoms, and especially the right to personal and family privacy, protection of honor and honest name.
2. The Policy is strictly executed by managers and employees of all organization units and branches of LLC "E-Trans".
3. The Policy is applicable to all personal data of subjects, processed in the Company with the use of automation tools and without such tools.
4. Any personal data subject has access to this Policy.
1. Personal data - any information referring directly or indirectly to a particular or identified individual (subject), i.e. such information, in particular, includes: full name, year, month, date and place of birth, address, information about a family, social, property status, information about education, profession, income, health information etc.
2. Processing of personal data - any action (operation) or a combination of actions (operations) performed both automatically and manually with personal data, including collection, receiving, recording, systematization, accumulation, storage, specification (updating, alteration), extraction, use, transfer (including distributing, providing, access), depersonalization, blocking, deleting and destruction of personal data.
3. LLC "E-Trans" personal data subjects process personal data of the following persons:
LLC "E-Trans" employees;
subjects, with whom civil contracts have been concluded or planned to be concluded;
candidates for vacancies in LLC "E-Trans";
LLC "E-Trans" clients;
registered users of LLC "E-Trans" website;
suppliers legal entities and individuals (including registered as individual entrepreneurs).
4. Principles and conditions of Personal Data Processing
1. LLC "E-Trans" understands security of personal data as a protection of personal data from unauthorized or accidental access, destruction, alteration, blocking, copying, sharing, distribution of personal data, and other illegal acts with personal data and takes all legal, organizational and technical measures necessary to protect personal data.
2. Processing and ensuring the protection of personal data in LLC "E-Trans" is carried out in accordance with the Constitution of the Russian Federation, the federal law № 152-FZ "On personal data", by-laws, other federal laws of the Russian Federation defining cases and features of personal data processing, documents of the FSTEC of Russia and the FSB of Russia.
3. When processing personal data, LLC "E-Trans" adheres to the following principles:
legality and equitable basis;
restrictions of personal data processing by achieving specific, pre-determined and legal purposes;;
preventing the processing of personal data incompatible with the purposes of collecting personal data;
preventing the unification of databases containing personal data, processing of which is carried out for purposes incompatible with each other;
processing of personal data that meet the purposes of their processing;
conformity of content.
4. The Company processes personal data only if at least one of the following conditions exists:
processing of personal data is carried out with the consent of the personal data subject to the processing of his personal data;
personal data processing is necessary to achieve the purposes stipulated by a law, for exercise and fulfillment of functions, powers and obligations imposed on operators by the Russian Federation law;
personal data processing is required for performance of an agreement to which a personal data subject is a party or under which the personal data subject is a beneficiary or surety, or for conclusion of an agreement on the initiative of a personal data subject or an agreement under which a personal data subject shall be a beneficiary or surety;
processing of personal data is required for realization of the rights and legitimate interests of the Company or third parties or for the achievements of socially significant objectives, provided that it does not interfere with the rights and freedoms of the personal data subject;
processing of personal data, access of an unlimited number of persons to which is provided by the subject of personal data or at his request;
the personal data being processed are subject to publication or compulsory disclosure in accordance with federal laws.
5. LLC "E-Trans" has the right to charge the processing of personal data of subjects to third parties on the basis of a contract concluded with these persons.
Persons caring out the processing of personal data on the instruction of LLC "E-Trans", shall be obliged to comply with the principles and rules for the processing and protection of personal data, which are stipulated by the federal law № 152-FZ "On personal data". For each person, there is a set out list of actions (operations) with personal data to be performed with the personal data by the legal person carrying out the processing of personal data, the purposes of processing, the established obligation of that person to observe the confidentiality of personal data and to ensure that the personal data remain secure while being processed, as well as the requirements for protection of the processed personal data. The requirements relating to protection of processed personal data are also stated.
6. In the cases established by the law of the Russian Federation, LLC "E-Trans" has the right to transfer personal data of subjects.
7. Publicly accessible sources of personal data (including directories and address books) may be created by the Company for the purposes of information provision. Subject to the consent of an employee, the surname, first name, patronymic, date and place of birth, occupation details, phone numbers, e-mail address may be included in publicly accessible sources of personal data. Details about an employee shall at any time be excluded from publicly accessible sources of personal data at the request of the employee or by decision of a court or other authorized state bodies.
8. The Company destructs or impersonalizes personal data after achieving processing purposes or in case of no further need in achieving processing purpose.
5. Rights of the subject of personal data
A citizen whose personal data are being processed by LLC "E-Trans", has the right:
get from LLC "E-Trans":
confirmation of the fact of processing personal data of LLC "E-Trans";
legal reasoning and objectives of processing data;
information about the methods used by LLC "E-Trans" in relation to processing of personal data;
name and location of LLC "E-Trans";
information about persons, who have an access to personal data or to whom personal data may be revealed on the bases of the agreement with LLC "E-Trans" or on the bases of federal law;
the list of processed personal data, related to citizen, from whom the request and source were received if another procedure for providing such data is not provided for by federal law;
Information on the terms of processing of personal data, including the time of their storage;
Information on the procedure of the exercise by citizen of rights provided by the federal law № 152-FZ "On personal data";
Information on the cross-border transfer of personal data that is being carried out or about to be expected;
The name and address of the person processing personal data on behalf of LLC "E-Trans";
Other information provided by the federal law № 152-FZ "On personal data" or other federal laws;
To demand the specification of their personal data it's blocking or destruction in case of incomplete, outdated, inaccurate, illegally obtained personal data or data is not necessary for the stated purpose of processing;
To withdraw their consent to the processing of personal data;
To demand the elimination of illegal actions of LLC "E-Trans" in respect of his personal data;
Appeal against LLC "E-Trans"'s actions or inaction to the Federal Service for Supervision of Communications, Information Technology and Mass Communications (Roskomnadzor) or in court if the citizen believes that LLC "E-Trans" carries out processing of his personal data in violation of the requirements of federal law № 152-FZ "On personal data" or otherwise violates his rights and freedoms;;
To protect their rights and legitimate interests, including compensation for damages and / or compensation for moral harm in court.
In case of failure to comply with the provisions of this Policy, LLC "E-Trans" is liable in accordance with the current legislation of the Russian Federation.
To receive an explanation on the issues of processing your personal data that you are interested in, by contacting LLC "E-Trans" personally or by sending an official request to the Russian Post at: E-Trans LLC, 1 Krasny prospekt St., Office 322, 630007 Novosibirsk, Russia.
In case of sending an official request to LLC "E-Trans", following points must be specified in the text of the request:
Number of the main document certifying the identity of the personal data subject or his representative, information on the date of issue of the said document and the issuing agency;
Information confirming your participation in the relationships with LLC "E-Trans" or information otherwise confirming the fact of processing personal data by LLC "E-Trans";
The signature of the citizen (or his legal representative). If the request is sent in electronic form, then it must be issued in the form of an electronic document and signed with an electronic signature in accordance with the legislation of the Russian Federation.
The current version of "Policy" of LLC "E-Trans" regarding the processing of personal data is published on the website "E-Trans.biz".
Information on the current of the requirements for the protection of personal data In processing personal data LLC "E-Trans" takes the necessary legal organizational and technical measures to protect personal data from unauthorized or accidental access to it, destruction, modification, blocking, copying, provision, dissemination of personal data, as well as other illegal actions against personal data.
Such measures in accordance with the federal law № 152-FZ "On personal data" include:
Identification of threats to the security of personal data when processing it in personal data information systems;
Application of organizational and technical measures to provide the security of personal data when processing it in personal data information systems required to meet the requirements for the protection of personal data, the fulfillment of which is ensured by the levels of protection of personal data established by the Government of the Russian Federation;
The use of procedures means that passed the procedure of the accordance evaluation;
Evaluation of the effectiveness of measures taken to ensure the security of personal data prior to commissioning of the personal data information system;
Detection of unauthorized access to personal data and taking measures;
Restoration of personal data modified or destroyed due to unauthorized access;
Establishing rules for access to personal data processed in the personal data information system, as well as ensuring the registration and recording of all actions performed with personal data in the personal data information system;
Control over the measures taken to ensure the security of personal data and the level of security of personal data information systems;
Accounting of computer carriers of personal data;
Organization of the access regime on the territory of the Company;
Placing technical means of processing personal data within the protected area;
Maintenance of technical means of protection and signalization in constant readiness;
Monitoring of user actions, conduct of proceedings on violations of the requirements for the security of personal data;
In order to coordinate actions to ensure the security of personal data, LLC "E-Trans" appoints persons responsible for providing the security of personal data.