1. general provisions
1.1 The policy on personal data processing (hereinafter - the Policy) is aimed at protecting the rights and freedoms of individuals whose personal data is processed by ALKAR LLC (hereinafter - the Operator).
1.2 The Policy is developed in accordance with cl. 2 para. 1 part 1 of Article 18.1 of the Federal Law of July 27, 2006 № 152-FZ "On Personal Data" (hereinafter - the Federal Law "On Personal Data").
1.3 The Policy contains information subject to disclosure in accordance with Part 1, Article 14, Paragraph 1 of the Federal Law "On Personal Data" and is a publicly available document.
2. Information about the Operator
2.1 The Operator conducts its business at the address 1, Partiyniy Lane, Moscow, office 339.
2.2 General Director Dan Nikolaevich Tikhomirov (phone number +7 (978) 208-4133) is appointed responsible for organization of personal data processing.
2.3 The database of information containing personal data of citizens of the Russian Federation is located at: http://alkargroup.com.
3. Information on personal data processing
3.1 The Operator processes personal data on a lawful and fair basis to fulfill the functions, powers and duties assigned by the legislation, to exercise the rights and legitimate interests of the Operator, the Operator's employees and third parties.
3.2 The Operator receives personal data directly from personal data subjects.
3.3 The Operator shall process personal data by automated and non-automated methods, with or without the use of computer facilities.
3.4 Actions of personal data processing include collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion and destruction.
3.5 Databases of information containing personal data of citizens of the Russian Federation are located in the territory of the Russian Federation.
4. Processing of personal data of employees
4.1 The Operator processes personal data of the Operator's employees within the framework of legal relations regulated by the Labor Code of the Russian Federation No. 197-FZ dated December 30, 2001 (hereinafter referred to as the RF Labor Code), including Chapter 14 of the RF Labor Code concerning protection of employees' personal data.
4.2 The Operator processes employees' personal data for the purpose of fulfillment of labor contracts, compliance with the RF legislation, as well as for the purpose of:
keep personnel records;
keep accounting records;
to fulfill the functions, powers and duties assigned to the Operator by the legislation of the Russian Federation, including the provision of personal data to state authorities, the Pension Fund of the Russian Federation, the Social Insurance Fund of the Russian Federation, the Federal Compulsory Medical Insurance Fund, as well as to other state authorities;
comply with the norms and requirements for labor protection and ensuring personal safety of ALKAR LLC employees, safety of property;
control the quantity and quality of work performed; - provide benefits and compensations stipulated by the legislation of the Russian Federation.
4.3 The Operator shall not make decisions affecting the interests of employees based on their personal data received electronically or solely as a result of automated processing.
4.4 The Operator shall protect employees' personal data at its own expense in accordance with the procedure established by the Labor Code of the Russian Federation, the Federal Law "On Personal Data" and other federal laws.
4.5 The Operator shall familiarize the employees and their representatives with the documents establishing the procedure of personal data processing, as well as with their rights and obligations in this area, against signature.
4.6 The Operator shall allow access to personal data of employees only to authorized persons who have the right to receive only those data that are necessary for the performance of their functions.
4.7 The Operator obtains all personal data of employees from them. If the employee's data can only be obtained from a third party, the Operator shall notify the employee in advance and obtain his/her written consent. The Operator informs the employee about the purposes, sources, methods of obtaining the data, as well as the nature of the data to be obtained and the consequences of the employee's refusal to give written consent to obtain it.
4.8 The Operator processes personal data of employees with their written consent provided for the term of the employment contract.
4.9 The Operator processes personal data of employees during the term of the employment contract. The Operator processes the personal data of dismissed employees during the period specified in cl. 5 ч. 3, part 3, article 24, part one of the Tax Code of the Russian Federation dated July 31, 1998 No. 146-FZ, part 1, article 29 of the Federal Law "On Taxation". 1 of Article 29 of the Federal Law "On Accounting" dated December 6, 2011 No. 402-FZ and other regulatory legal acts.
4.10. The Operator may process special categories of personal data of employees (information on their health status related to the issue of their ability to perform labor functions) on the basis of clause 2.3 of part 2 of article 10 of the Federal Law "On Accounting" No. 402-FZ and other normative legal acts. 2.3 of Art. 10 of the Federal Law "On Personal Data".
4.11. The Operator does not process biometric personal data of employees.
4.12. The Operator does not receive data on employees' membership in public associations or their trade union activities, except in cases provided for by the Labor Code of the Russian Federation or other federal laws.
4.13. The Operator processes the following personal data of employees:
Surname, first name, patronymic;
Type, series and number of the identity document;
Date of issue of the identity document and information about the issuing authority;
Year of birth;
Month of birth;
Date of birth;
Place of birth;
Address;
Taxpayer Identification Number;
State pension insurance certificate number;
Nationality;
Occupation;
Income;
Insurance premiums for OPS;
Insurance premiums for MHI;
Tax deductions;
Retirement;
Position;
Job number;
Length of service.
4.14. The Operator shall not disclose the employee's personal data to any third party without his/her written consent, except for cases when it is necessary to prevent a threat to the employee's life and health, as well as in other cases stipulated by the Labor Code of the Russian Federation, Federal Law "On Personal Data" or other federal laws.
4.15. The Operator shall not disclose the employee's personal data for commercial purposes without the employee's written consent.
4.16. The Operator transfers personal data of employees to their representatives in accordance with the procedure established by the Labor Code of the Russian Federation, the Federal Law "On Personal Data" and other federal laws, and limits this information to only those data that are necessary for the representatives to perform their functions.
4.17. The Operator shall warn the persons receiving the employee's personal data that such data may be used only for the purposes for which they are communicated, and shall require confirmation from such persons that this rule is observed.
4.18. In the manner prescribed by law and in accordance with Article 7 of the Federal Law "On Personal Data", in order to achieve the purposes of personal data processing and with the consent of the employees, the Operator provides personal data of employees or entrusts their processing to the following persons: - State bodies (PFR, FTS, FSS, etc.).
4.19. The employee can get free access to information about his/her personal data and about the processing of such data. An employee may obtain a copy of any record containing his/her personal data, except in cases provided for by federal law.
4.20. An employee may obtain access to medical records reflecting his/her health status with the assistance of a health care provider of his/her choice.
4.21. An employee may designate a representative to protect his/her personal data.
4.22. The employee may request to exclude or correct his/her incorrect or incomplete personal data, as well as data processed in violation of the requirements of the Labor Code of the Russian Federation, the Federal Law "On Personal Data" or other federal law. If the Operator refuses to exclude or correct the employee's personal data, the employee may declare in writing his/her disagreement and justify such disagreement. The employee may supplement personal data of an evaluative nature with a statement expressing his/her own point of view.
4.23. The employee may request to notify all persons to whom his/her incorrect or incomplete personal data were previously disclosed of all exceptions, corrections or additions made thereto.
4.24. The employee may appeal to the court against any unlawful acts or omissions of the Operator in the processing and protection of his/her personal data.
5. Processing of clients' personal data

• 5.1 The Operator processes personal data of clients within the framework of legal relations with the Operator regulated by Part Two of the Civil Code of the Russian Federation No. 14-FZ dated January 26, 1996 (hereinafter referred to as clients).
• 5.2 The Operator processes personal data of the clients in order to comply with the norms of the legislation of the Russian Federation, as well as in order to:
• to conclude and fulfill obligations under contracts with clients;
• to carry out activities stipulated by the constituent documents of ALKAR LLC;
• to inform about new products, special promotions and offers.
• 5.3 The Operator processes personal data of clients with their consent provided for the term of validity of the contracts concluded with them. In cases stipulated by the Federal Law "On Personal Data", the consent shall be provided in writing. In other cases, the consent shall be deemed to have been obtained at the conclusion of the contract or by performing conclusory actions.
• 5.4 The Operator processes personal data of the clients during the validity period of the contracts concluded with them. The Operator may process personal data of the clients after the expiration of the validity terms of the contracts concluded with them during the period specified in cl. 5 ч. 3 part 3 of Article 24 of Part One of the Tax Code of the Russian Federation, part 1 of Article 29 of the Federal Law "On Accounting" and other regulatory legal acts.
• 5.5 The Operator processes special categories of personal data of underage customers with the written consent of their legal representatives on the basis of part 1 of article 9, paragraph 1 of part 2 of article 10 of the Federal Law "On Accounting" and other legal acts. 2 part 2 of Article 10 of the Federal Law "On Personal Data".
• 5.6 The Operator processes the following personal data of clients:
• Surname, first name, patronymic;
• Type, series and number of the identity document;
• Date of issue of the identity document and information about the issuing authority;
• Year of birth;
• Month of birth;
• Date of birth;
• Place of birth;
• Address;
• Contact telephone number;
• Taxpayer Identification Number;
• State pension insurance certificate number;
• Nationality;
• Occupation;
• Income;
• Insurance premiums for OPS;
• Insurance premiums for MHI;
• Tax deductions;
• Retirement;
• Position;
• Job number;
• Length of service.

6. Processing of personal data of job seekers

• 6.1 The Operator processes personal data of applicants for vacant positions (hereinafter referred to as applicants).
• 6.2 The Operator processes personal data of job seekers in order to: - make decisions on hiring or refusal to hire.
• 6.3 The Operator processes applicants' personal data with their written consent, which is provided for the period necessary to make a decision on hiring or refusal to hire them. The exception is when a recruitment agency with which the job seeker has concluded a relevant contract acts on behalf of the job seeker, as well as when the job seeker independently posts his/her resume, which is available to an unlimited number of persons, on the Internet.
• 6.4 The Operator processes personal data of job seekers during the period necessary for making a decision on hiring or refusal to hire. In case of refusal to hire the applicant, the Operator stops processing the applicant's personal data within 30 days in accordance with part 4 of Article 21 of the Federal Law "On Personal Data". If the applicant has given his/her consent to be included in the personnel reserve, the Operator may continue processing personal data within the period specified in the consent.
• 6.5 The Operator does not process special categories of personal data of job seekers and biometric personal data of job seekers.
• 6.6 The Operator processes the following personal data of job seekers:
• Surname, first name, patronymic;
• Year of birth;
• Month of birth;
• Date of birth;
• Contact phone number;
• E-mail address;
• Marital Status;
• Education;
• Length of service;
• Type, series and number of identity document;
• Date of issue of the identity document and information on the issuing authority;
• Place of birth;
• Address;
• Taxpayer Identification Number;
• State pension insurance certificate number;
• Nationality;
• Occupation;
• Income;
• Insurance premiums for OPS;
• Insurance premiums for MHI;
• Tax deductions;
• Retirement;
• Position;
• Job number.

7. Information on personal data security

• 7.1 The Operator appoints a person responsible for organization of personal data processing to fulfill the obligations stipulated by the Federal Law "On Personal Data" and regulatory legal acts adopted in accordance with it.
• 7.2 The Operator shall apply a set of legal, organizational and technical measures to ensure security of personal data to ensure confidentiality of personal data and their protection from unlawful actions:
• provides unrestricted access to the Policy, a copy of which is posted at the Operator's location address and may also be posted on the Operator's website (if available);
• in pursuance of the Policy approves and enforces the document "Regulation on Personal Data Processing" (hereinafter referred to as the Regulation) and other local acts;
• familiarize employees with the provisions of the legislation on personal data, as well as with the Policy and Regulations;
• authorizes employees to access personal data processed in the Operator's information system, as well as their tangible carriers only to perform their work duties;
• establishes rules of access to personal data processed in the Operator's information system, as well as ensures registration and accounting of all actions with them;
• assesses the damage that may be caused to personal data subjects in case of violation of the Federal Law "On Personal Data";
• determines threats to the security of personal data during their processing in the Operator's information system;
• applies organizational and technical measures and uses information protection means necessary to achieve the established level of personal data protection;
• Detects the facts of unauthorized access to personal data and takes response measures, including restoration of personal data modified or destroyed due to unauthorized access to them;
• assesses the effectiveness of the measures taken to ensure personal data security before the Operator's information system is put into operation;
• performs internal control over compliance of personal data processing with the Federal Law "On Personal Data", regulatory legal acts adopted in accordance with it, personal data protection requirements, Policy, Regulations and other local acts, including control over the measures taken to ensure personal data security and their level of protection during processing in the Operator's information system.

8. Rights of personal data subjects
8.1 The subject of personal data has the right:
to receive personal data relating to the subject and information concerning their processing;
to clarify, block or destroy his/her personal data if they are incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing;
to withdraw his/her consent to the processing of personal data;
to protect his/her rights and legitimate interests, including compensation of losses and moral damages in court;
to appeal the actions or inaction of the Operator to the authorized body for the protection of the rights of personal data subjects or in court.
8.2 To realize their rights and legitimate interests, personal data subjects have the right to apply to the Operator or send a request personally or with the help of a representative. The request shall contain the information specified in part 3 of Article 14 of the Federal Law "On Personal Data".