Clean Agent Fire Suppression System   «ZARYA»

PRIVACY POLICY REGARDING THE PROCESSING OF PERSONAL DATA

06.06.2017

1. GENERALITIES

The personal data processing policy (hereinafter – the Policy) is developed in accordance with the Federal law of 27.07.2006. 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 of LLC "I. S. P." (hereinafter-the Operator) in order to protect the rights and freedoms of man and citizen in the processing of his personal data, including the protection of the rights to privacy, personal and family secrets.

The following basic concepts are used in the Policy:

automated processing of personal data – processing of personal data by means of computer technology;

blocking of personal data-temporary termination of the processing of personal data (except if the processing is necessary to clarify personal data);

information system of personal data - a set of personal data contained in databases, and providing their processing of information technologies and technical means;

depersonalization of personal data-actions, as a result of which it becomes impossible without the use of additional information to determine the identity of personal data to a particular subject of personal data;

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

operator - a state body, municipal body, legal entity or individual, independently or jointly with other persons organizing and (or) carrying out the processing of personal data, as well as determining the purpose 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 identifiable individual (subject of personal data);

provision of personal data – actions aimed at disclosure of personal data to a certain person or a certain circle of persons;

dissemination of personal data-actions aimed at disclosure of personal data to an indefinite circle of persons;

cross-border transfer of personal data - transfer of personal data to the territory of a foreign state to the authority of a foreign state, a foreign individual or a foreign legal entity;

destruction of personal data - actions as a result of which it becomes impossible to restore the content of personal data in the information system of personal data and (or) as a result of which the material carriers of personal data are destroyed.

The operator is obliged to publish or otherwise provide unrestricted access to this personal data processing Policy in accordance with part 2 of article 18.1. Federal law "on personal data".

2. PRINCIPLES AND CONDITIONS OF PERSONAL DATA PROCESSING

2.1. Principles of personal data processing

The processing of personal data the Operator is based on the following principles: lawful and fair manner; limiting the processing of personal data by the specified, explicit and lawful purposes; prevent the processing of personal data, incompatible with the objectives of processing personal data; prevent the merging of databases containing personal data the processing of which is carried out for the purposes incompatible with each other; the processing of only those personal data that meet the purposes of processing; matching the content and scope of processed personal data to the declared processing purposes; prevent the processing of personal data, excessive in relation to the declared purposes of their processing; ensure accuracy, adequacy and relevance of personal data in relation to the purpose of processing personal data; destruction or depersonalization of personal data when the purposes of processing or in case of loss necessary to achieve these purposes, unless otherwise provided by Federal law.

2.2. Terms of personal data processing

The operator performs the processing of personal data in the following cases: personal data shall be processed with the consent of personal data subject to the processing of personal data; processing of personal data necessary to achieve the objectives stipulated by international Treaty of the Russian Federation or by law, to implement and fulfill the legislation of the Russian Federation to the operator functions, powers and duties; the processing of personal data is necessary for the administration of justice, 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 the contract to which the personal data subject is a party or a beneficiary or guarantor, 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 a beneficiary or guarantor; 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, access of an unlimited number of persons to which is provided by the subject of personal data or at his request (hereinafter - public personal data); processing of personal data subject to publication or mandatory disclosure in accordance with Federal law.

2.3. Privacy of personal data

The operator and other persons who have gained access to personal data are obliged 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, the Operator may create publicly available sources of personal data of personal data subjects, including directories and address books. The publicly available sources of personal data with the written consent of the subject of personal data may include his surname, first name, patronymic, date and place of birth, position, contact phone numbers, e-mail address and other personal data reported by the subject of personal data.

Data on the subject of personal data shall be excluded at any time from publicly available sources of personal data 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 a court decision.

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 in cases where: the subject of personal data has consented in writing to the processing of their personal data; personal data are made public by the subject of personal data; personal data shall be processed in accordance with the law on state social assistance, labour legislation, pension legislation of the Russian Federation; processing of personal data is necessary to protect the life, health or other vital interests of the data subject or the life, health or other vital interests of other persons and obtaining the consent of personal data subject is impossible; 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 implementation of justice. Processing special categories of personal data carried out in the cases stipulated by article 10 FZ-152 must be stopped immediately if eliminated the reasons for which they were processed, unless otherwise provided by Federal law.

Processing of personal data on criminal record may be carried out by the Operator only in cases and in the manner determined in accordance with Federal laws.

2.6. Biometric personal data

Information that characterize the physiological and biological characteristics of a person, on the basis of which it is possible to establish his identity - biometric personal data - can be processed by the Operator only with the consent of the subject of personal data in writing.

2.7. Assignment of personal data processing 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 the contract concluded with this person. A person processing personal data on behalf of the Operator is obliged to comply with the principles and rules of personal data processing provided for by Federal law 152 and this Policy.

2.8. When collecting personal data, including through information-telecommunication network "Internet", the operator is obliged to provide recording, systematization, accumulation, storage, clarification (updating, changing), extraction of personal data of Russian citizens using databases located on the territory of the Russian Federation, except:
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the processing of personal data necessary to achieve the objectives stipulated by international Treaty of the Russian Federation or by law, to implement and fulfill the legislation of the Russian Federation to the operator functions, powers and duties; processing of personal data necessary for the implementation of justice, the execution of the judicial act, act of another body or official to be executed in accordance with the legislation of the Russian Federation on enforcement proceedings (hereinafter - the execution of a judicial act); the processing of personal data is necessary for the professional activities of a journalist and (or) the legitimate activities of the mass media or scientific, literary or other creative activities, provided that the rights and legitimate interests of the subject of personal data are not violated.

2.9.Cross-border transfer of personal data

The operator is obliged to make sure that the foreign state to whose territory the transfer of personal data is supposed to be carried out provides adequate protection of the rights of the subjects of personal data before the start of such transfer.

Cross-border transfer of personal data on the territory of foreign States that do not provide adequate protection of the rights of personal data subjects may be carried out in the following cases:

availability of written consent of the personal data subject to cross-border transfer of his personal data; execution of the contract to which the personal data subject is a party.

3. RIGHTS OF THE PERSONAL DATA SUBJECT

3.1. Consent of the personal data subject to the processing of his personal data

The subject of personal data decides to provide his personal data and agrees to their processing freely, by his will and in his interest. Consent to the processing of personal data may be given by the personal data subject or his representative in any form that allows to confirm the fact of its receipt, unless otherwise established by Federal law.

3.2. Rights of the personal data subject the personal data Subject has the right to receive information from the Operator concerning the processing of his personal data, if such right is not limited in accordance with Federal laws. The subject of personal data has the right to require the Operator to clarify his personal data, block or destroy them if the personal data are incomplete, outdated, inaccurate, illegally obtained or are not necessary for the stated purpose of processing, as well as to take measures provided by law to protect their rights.

Processing of personal data in order to promote goods, works, services on the market through direct contacts with the subject of personal data (potential consumer) by means of communication, as well as for the purpose of 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 prohibited to make decisions on the basis of exclusively automated processing of personal data that generate legal consequences with respect to the subject of personal data or otherwise affect his rights and legitimate interests, except in cases provided for by Federal laws, or if there is a written consent of the subject of personal data.

thus, the personal data subject has the right to appeal against the actions or inaction of the Operator to the Authorized body for the protection of the rights of personal data subjects or in court.

The subject of personal data has the right to protect their rights and legitimate interests, including compensation for losses and (or) compensation for moral damage.

4. PERSONAL DATA SECURITY

The security of personal data processed by the Operator is ensured by the implementation of legal, organizational and technical measures necessary to meet 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:

appointment of officials responsible for organizing the processing and protection of personal data; restriction of the persons admitted to processing of personal data; to familiarize participants with requirements of the Federal legislation and normative documents of the Operator on the processing and protection of personal data; registration, storage and handling of media containing information with personal data; definition of threats to the security of personal data during their processing, formation on their basis of models of threats; development of a model-based threats to the personal data protection system; check of readiness and efficiency of use of means of protection of information; differentiation of access of users to information resources and software and hardware of information processing; registration and accounting of actions of users of information systems of personal data; use of anti-virus means and means of restoration of system of protection of personal data; application in necessary cases of means of; organization of access to the Operator's territory, protection of premises with technical means of personal data processing.

5. FINAL PROVISION

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.