1. General Provisions
This policy of processing personal data is compiled in accordance with the requirements of the Federal Law of 27.07.2006. № 152-FL “On Personal Data” and defines the procedure for processing personal data and measures to ensure the security of personal data of SP-CAPITAL LLC.
This Policy determines the procedure for processing personal data and controls to ensure the security of personal data in SP-CAPITAL LLC (hereinafter referred to as the “Company”) in order to protect the rights of subjects when processing their personal data.
Basic concepts used in the Policy:
2.1 Principles of personal data processing
Personal data processing in the Company shall be performed based on
the following principles:
2.2 Conditions of Personal Data Processing
The Company processes personal data if at least one of the following
2.3 Personal Data Confidentiality
The Company and other persons who have access to personal data shall not disclose to third parties or distribute personal data without the consent of the personal data subject, unless otherwise prescribed by a Federal law.
2.4 Publicly Available Personal Data Sources
For the purpose of information support, the Company can create publicly available sources of personal data including directories and address books. In the public sources of personal data with the written consent of the personal data subject their data may include his/her last name, first name, patronymic, date, and place of birth, position, contact phone numbers, e-mail address and other personal data reported by the personal data subject.
Information about the personal data subject shall be deleted at any time from the publicly available sources of personal data at the request of the personal data subject or by a court or other authorized government agency.
2.5 Special Categories of Personal Data
Processing by the Company of special categories of personal data relating to race, nationality, political views, religious or philosophical beliefs, health status, intimate life shall be allowed in cases where:
Processing of special categories of personal data shall be immediately terminated if the reasons for their processing have been eliminated, unless otherwise provided by Federal law.
Personal data processing on the criminal record may be performed by the Company only in cases and in the manner determined in compliance with the Federal laws.
2.6 Biometric Personal Data
Information that are descriptive of the physiological and biological characteristics of a person whereby it is possible to establish their identity (biometric personal data) and used by the Company to establish the identity of the personal data subject may be processed by the Company only if there is consent in writing to the personal data subject.
2.7 Another Person to be Instructed to Process Personal Data
The Company shall be entitled to entrust personal data processing to another person with the consent of the personal data subject, unless otherwise provided by the Federal law, based on a contract entered into with that person. A person engaged in the personal data processing on the Company’s behalf shall be required to comply with the principles and rules for personal data processing set forth by the Federal Law No. 152.
2.8 Cross-Border Personal Data Transfer
The company shall ensure that the foreign state to which the transfer of personal data is intended is able and willing to provide adequate protection of the rights of subjects of personal data, prior to the commencement of such transfer.
Cross-border transfer of personal data to the territory of foreign states that do not provide adequate protection of the rights of subjects of personal data may be performed in the following cases:
3. Rights of the personal data subject
3.1 Consent of the Personal Data Subject to the Processing of Their Personal Data
Personal data subject shall decide on the provision of their personal data and agrees to process thereof freely, by their will and in their interest. Consent to the personal data processing may be given by the personal data subject or their representative in any form that allows confirming the fact of its receipt, unless otherwise provided by the Federal law.
The obligation to provide evidence of the consent of the personal data subject to the processing of their personal data or evidence of the grounds specified in FZ No. 152 shall be vested in the Company.
3.2 Rights of Personal Data Subject
Personal data subject shall be empowered to obtain from the Company information concerning the processing of their personal data, unless such right is restricted in compliance with the Federal laws. The personal data subject shall be entitled to demand from the Company the specification of their personal data, blocking, or destruction thereof in the event that personal data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated purpose of processing, and also take adequate steps provided by applicable laws to protect their rights.
Personal data processing in order to promote goods, works, and services on the market by making direct contacts with a potential consumer by means of communication means, as well as for the purposes of political agitation is allowed only with the prior consent of the personal data subject. The said personal data processing is recognized as being performed without the prior consent of the personal data subject, unless the Company proves that such consent has been obtained prior thereto.
The company shall immediately cease, at the request of the personal data subject, the processing of their personal data for the above purposes.
It is prohibited to make decisions based solely on the automated personal data processing that generate legal consequences with respect to the personal data subject or otherwise affect their rights and legitimate interests, with the exception of cases prescribed by the Federal laws or with the written consent of the personal data subject.
If the personal data subject considers that the Company processes their personal data in violation of the requirements set forth by the Federal Law No. 152 or otherwise violates their rights and freedoms, the personal data subject shall be empowered to appeal against the actions or omission by the Company by filing a complaint with the Authorized body for the protection of the rights of subjects of personal data or judicial procedure.
The personal data subject shall be empowered to protect their rights and legitimate interests including compensation for damages and/or compensation for non-pecuniary damage in court.4. Ensuring personal data security
Personal data security processed by the Company shall be ensured by the implementation of legal, organizational, and technical controls necessary to ensure the requirements of federal legislation in the field of personal data protection.
To prevent unauthorized access to personal data, the Company applies the following organizational and technical measures:
5. Final Provisions
Other rights and obligations of the Company as an operator of personal data shall be determined by the applicable laws of the Russian Federation in the field of personal data
Officials of the Company who are guilty of violating the rules governing the processing and protection of personal data shall be subject to material, disciplinary, administrative, civil or criminal liability in compliance with the procedure established by the applicable Federal laws.
Адрес: 123112, город Москва, Пресненская набережная,
дом 6 строение 2, этаж 44 помещение 4414