RULES OF Innovations in Education LLC ON THE PROCESSING OF PERSONAL DATA Moscow OGRN: 1217800173250 TIN: 7810932734 / KPP: 780101001
1. GENERAL PROVISIONS 1.1. This document sets out the rules of Innovations in Education LLC (hereinafter referred to as the Company) regarding the processing of personal data and the implementation of requirements for their protection (hereinafter referred to as the Policy) in accordance with Federal Law No. 152-FZ of July 27, 2006 "On Personal Data". (All clauses of Section 1, including the definitions of terms, remain unchanged.)
2. PERSONAL DATA SUBJECTS The Company processes the personal data of the following persons:
employees of Innovations in Education LLC;
subjects with whom civil law contracts have been concluded;
candidates for vacant positions;
clients of the Company;
registered users of the website;
representatives of legal entities;
suppliers (sole proprietors).
3. PRINCIPLES AND CONDITIONS OF PERSONAL DATA PROCESSING Innovations in Education LLC understands the security of personal data as the protection of personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision, or dissemination of personal data, as well as from other unlawful actions with respect to personal data, and takes the necessary legal, organizational, and technical measures to protect personal data. The processing and security of personal data at Innovations in Education LLC are carried out in accordance with the requirements of the Constitution of the Russian Federation, Federal Law No. 152-FZ “On Personal Data”, secondary legislation, and other federal laws of the Russian Federation that define the cases and specifics of personal data processing. 3.1. Principles of personal data processing. The Company processes personal data in accordance with the following principles: • lawfulness and fairness; • limiting the processing of personal data to the achievement of specific, predetermined, and legitimate purposes; • preventing the processing of personal data that is incompatible with the purposes for which the personal data were collected; • databases containing personal data processed for mutually incompatible purposes shall not be combined; • processing only those personal data that are relevant to the purposes of their processing; • ensuring that the content and scope of the personal data processed correspond to the stated purposes of processing; • preventing the processing of personal data that is excessive in relation to the stated purposes of processing; • ensuring the accuracy, sufficiency and relevance of the personal data in relation to the purposes of processing the personal data; • personal data shall be destroyed or anonymized once the purposes of processing have been achieved or the need to achieve those purposes no longer exists, where the Company is unable to remedy violations committed in relation to the personal data, unless otherwise provided by federal law. 3.2. Conditions for the processing of personal data • personal data is processed with the consent of the personal data subject to the processing of their personal data; • the processing of personal data is necessary to achieve purposes provided for by law, and to exercise and perform the functions, powers, and duties imposed on the operator by the legislation of the Russian Federation; • the processing of personal data is necessary for the performance of a contract to which the personal data subject is a party, beneficiary or guarantor, as well as for the conclusion of a contract initiated by the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor; • the processing of personal data is necessary to exercise the rights and legitimate interests of the Company or third parties, or to achieve socially significant purposes, provided that the rights and freedoms of the personal data subject are not violated; • personal data is processed to which access for an unlimited number of persons has been granted by the personal data subject or at their request; • the personal data being processed are subject to publication or mandatory disclosure in accordance with federal law. Innovations in Education LLC has the right to entrust the processing of citizens' personal data to third parties on the basis of a contract concluded with such parties. Persons processing personal data on behalf of Professional Leaders LLC undertake to comply with the principles and rules for the processing and protection of personal data provided for by Federal Law No. 152-FZ "On Personal Data". For each such person, a list of actions (operations) with personal data to be performed by the legal entity processing the personal data and the purposes of processing are defined, the obligation of such person to maintain the confidentiality and ensure the security of personal data during processing is established, and the requirements for the protection of the personal data being processed are specified. In the cases established by the legislation of the Russian Federation, Innovations in Education LLC has the right to transfer citizens' personal data. For information purposes, the Company may create publicly accessible sources of employees' personal data, including directories and address books. With the consent of the personal data subject, such publicly accessible sources may include their surname, first name, patronymic, date and place of birth, position, contact telephone numbers and email address. Information about a personal data subject must be removed from publicly accessible sources of personal data at any time upon the request of the personal data subject or by decision of a court or other authorized government bodies. The Company destroys or anonymizes personal data once the purposes of processing have been achieved or when achieving the purpose of processing is no longer necessary.
4. RIGHTS OF THE PERSONAL DATA SUBJECT A natural person whose personal data is processed by the Company has the right to: 4.1. To receive from Innovations in Education LLC:
confirmation that the data is being processed;
information on the purposes, methods, and terms of processing;
other information in accordance with Article 14 of Federal Law No. 152-FZ.
4.2. to demand that their personal data be clarified, blocked, or destroyed if the personal data is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing; 4.3 to withdraw their consent to the processing of personal data; 4.4 demand that Innovations in Education LLC cease any unlawful actions in relation to his or her personal data; 4.5 to appeal against the actions or inaction of Innovations in Education LLC to the Federal Service for Supervision of Communications, Information Technology and Mass Media (Roskomnadzor) or in court if the individual believes that Innovations in Education LLC is processing their personal data in violation of the requirements of Federal Law No. 152-FZ “On Personal Data” or is otherwise violating their rights and freedoms; 4.6 to the protection of their rights and legitimate interests, including compensation for losses and/or compensation for moral damage in court.
5. DATA SECURITY The Company takes the necessary organizational and technical measures, including:
appointment of persons responsible for data protection;
restricting access to personal data;
use of antivirus and cryptographic tools.
6. FINAL PROVISIONS The rights and obligations of Innovations in Education LLC as a personal data operator are defined by the legislation of Russia.