Personal Data Processing Policy

1. General provisions

This personal data processing policy is drawn up in accordance with the requirements of the Federal Law of 27.07.2006. No. 152-FZ "On Personal Data" (hereinafter referred to as the Law on Personal Data) and defines the procedure for processing personal data and measures to ensure the security of personal data taken by JSC "NPF "System-Service" (hereinafter referred to as the Operator).

1.1. The operator sets as its most important goal and condition for the implementation of its activities to respect human and civil rights and freedoms in the processing of his personal data, including the protection of the rights to privacy, personal and family secrets.

1.2. This Operator's policy regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator may receive about visitors to the website https://systserv.spb.ru.

2. Basic concepts used in the Policy

2.1. Automated processing of personal data - processing of personal data using computer equipment.

2.2. Blocking of personal data - temporary suspension of personal data processing (unless the processing is necessary to clarify personal data).

2.3. Website - a set of graphic and information materials, as well as computer programs and databases that ensure their availability on the Internet at the network address https://systserv.spb.ru.

2.4. Personal data information system is a set of personal data contained in databases and ensuring their processing of information technologies and technical means.

2.5. Depersonalization of personal data - actions as a result of which it is impossible to determine without the use of additional information the ownership of personal data to a specific User or other subject of personal data.

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

2.7. Operator - a state body, municipal body, legal entity or individual, independently or jointly with other persons organizing and (or) processing personal data, as well as determining the purposes of personal data processing, the composition of personal data to be processed, actions (operations) performed with personal data.

2.8. Personal data - any information relating directly or indirectly to a specific or identifiable User of the website https://systserv.spb.ru.

2.9. Personal data authorized by the subject of personal data for distribution - personal data, access of an unlimited number of persons to which is provided by the subject of personal data by consent to the processing of personal data authorized by the subject of personal data for distribution in the manner prescribed by the Law on Personal Data (hereinafter referred to as personal data allowed for distribution).

2.10. User - any visitor to the website https://systserv.spb.ru.

2.11. Provision of personal data - actions aimed at disclosing personal data to a certain person or a certain circle of persons.

2.12. Dissemination of personal data - any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or at familiarization with personal data of an unlimited number of persons, including publication of personal data in the media, placement in information and telecommunication networks or providing access to personal data in any other way.

2.13. Cross-border transfer of personal data - transfer of personal data to the territory of a foreign state to the authority of a foreign state, foreign individual or foreign legal entity.

2.14. Destruction of personal data - any actions as a result of which personal data are destroyed irrevocably with the impossibility of further restoration of the content of personal data in the personal data information system and (or) material carriers of personal data are destroyed.

3. Basic rights and obligations of the Operator

3.1. The operator has the right to:

- receive reliable information and/or documents containing personal data from the subject of personal data;

- in case of withdrawal by the subject of personal data of consent to the processing of personal data, the Operator has the right to continue processing personal data without the consent of the subject of personal data if there are grounds specified in the Law on Personal Data;

- independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of the obligations provided for by the Law on Personal Data and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Law on Personal Data or other federal laws.

3.2. The operator is obliged:

- to provide the subject of personal data, at his request, with information regarding the processing of his personal data;

- organize the processing of personal data in accordance with the procedure established by the current legislation of the Russian Federation;

- respond to appeals and requests of personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;

- to report to the authorized body for the protection of the rights of personal data subjects at the request of this body the necessary information within 30 days from the date of receipt of such a request;

- publish or otherwise provide unlimited access to this Policy regarding the processing of personal data;

- take legal, organizational and technical measures to protect personal data from unauthorized or accidental access to them, destruction, modification, blocking, copying, provision, dissemination of personal data, as well as from other illegal actions in relation to personal data;

- stop the transfer (distribution, provision, access) of personal data, stop processing and destroy personal data in the manner and cases provided for by the Law on Personal Data;

- perform other duties provided for by the Law on Personal Data.

4. Basic rights and obligations of personal data subjects

4.1. Personal data subjects have the right to:

- receive information regarding the processing of his personal data, except in cases provided for by federal laws. The information is provided to the subject of personal data by the Operator in an accessible form, and they should not contain personal data relating to other subjects of personal data, except when there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it is established by the Law on Personal Data;

- require the operator to clarify his personal data, block or destroy them if the personal data are incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing, as well as to take measures provided for by law to protect their rights;

- to put forward a condition of prior consent when processing personal data in order to promote goods, works and services on the market;

- to withdraw consent to the processing of personal data;

- appeal to the authorized body for the protection of the rights of personal data subjects or in court against illegal actions or omissions of the Operator in the processing of his personal data;

- to exercise other rights provided for by the legislation of the Russian Federation.

4.2. Personal data subjects are obliged:

- to provide the Operator with reliable data about yourself;

- inform the Operator about the clarification (update, change) of their personal data.

4.3. Persons who have transmitted false information about themselves to the Operator, or information about another subject of personal data without the consent of the latter, are liable in accordance with the legislation of the Russian Federation.

5. The Operator may process the following personal data of the User

5.1. Surname, first name, patronymic.

5.2. E-mail address.

5.3. The site also collects and processes anonymized data about visitors (including cookies) using Internet statistics services (Yandex Metrics and Google Analytics and others).

5.4. The above data are further united in the text of the Policy by the general concept of Personal Data.

5.5. The Operator does not process special categories of personal data relating to race, nationality, political views, religious or philosophical beliefs, intimate life.

5.6. Processing of personal data allowed for distribution from among the special categories of personal data specified in Part 1 of Art. 10 of the Law on Personal Data is allowed if the prohibitions and conditions provided for in Art. 10.1 of the Personal Data Act.

5.7. The User's consent to the processing of personal data allowed for distribution is formalized separately from other consents to the processing of his personal data. At the same time, the conditions provided for, in particular, Art. 10.1 of the Personal Data Act. The requirements for the content of such consent are established by the authorized body for the protection of the rights of personal data subjects.

5.7.1 Consent to the processing of personal data authorized for distribution is provided by the User directly to the Operator.

5.7.2 The Operator is obliged, no later than three working days from the date of receipt of the specified consent of the User, to publish information on the conditions of processing, on the existence of prohibitions and conditions for the processing by an unlimited number of persons of personal data allowed for distribution.

5.7.3 The transfer (distribution, provision, access) of personal data authorized by the subject of personal data for distribution must be terminated at any time at the request of the subject of personal data. This requirement must include the surname, first name, patronymic (if any), contact information (phone number, e-mail address or postal address) of the subject of personal data, as well as a list of personal data, the processing of which is subject to termination. The personal data specified in this requirement may be processed only by the Operator to whom it is sent.

5.7.4 Consent to the processing of personal data allowed for distribution terminates from the moment the Operator receives the requirement specified in paragraph 5.7.3 of this Policy regarding the processing of personal data.

6. Principles of personal data processing

6.1. The processing of personal data is carried out on a legal and fair basis.

6.2. The processing of personal data is limited to the achievement of specific, predetermined and legitimate goals. Processing of personal data incompatible with the purposes of personal data collection is not allowed.

6.3. It is not allowed to combine databases containing personal data, the processing of which is carried out for purposes incompatible with each other.

6.4. Only personal data that meet the purposes of their processing are subject to processing.

6.5. The content and volume of personal data processed correspond to the stated purposes of processing. Redundancy of processed personal data in relation to the stated purposes of their processing is not allowed.

6.6. When processing personal data, the accuracy of personal data, their sufficiency and, if necessary, relevance to the purposes of personal data processing are ensured. The operator takes the necessary measures and/or ensures that they are taken to delete or clarify incomplete or inaccurate data.

6.7. Storage of personal data is carried out in a form that allows to determine the subject of personal data, no longer than required by the purpose of processing personal data, if the period of storage of personal data is not established by federal law, a contract to which the subject of personal data is a party, beneficiary or guarantor. The processed personal data are destroyed or depersonalized upon achievement of the processing goals or in case of loss of the need to achieve these goals, unless otherwise provided by federal law.

7. Purposes of personal data processing

7.1. The purpose of processing the User's personal data:

- informing the User by sending emails;

- providing the User with access to the services, information and/or materials contained on the website https://systserv.spb.ru.

7.2. The Operator also has the right to send the User notifications about new products and services, special offers and various events. The User can always opt out of receiving information messages by sending a letter to the Operator to the e-mail address info@systserv.spb.su with the note "Refusal of notifications of new products and services and special offers".

7.3. Anonymized User data collected through Internet statistics services is used to collect information about the actions of Users on the site, improve the quality of the site and its content.

8. Legal grounds for personal data processing

8.1. The legal grounds for processing personal data by the Operator are:

- Federal Law "On Information, Information Technologies and Information Protection" of 27.07.2006 N 149-FZ;

- federal laws, other regulatory legal acts in the field of personal data protection;

- consent of Users to the processing of their personal data, to the processing of personal data allowed for distribution.

8.2. The Operator processes the User's personal data only if they are filled in and/or sent by the User independently through special forms located on the website https://systserv.spb.ru or sent to the Operator by e-mail. By filling out the relevant forms and/or sending his personal data to the Operator, the User agrees to this Policy.

8.3. The Operator processes anonymized data about the User if it is allowed in the User's browser settings (the preservation of cookies and the use of JavaScript technology are enabled).

8.4. The subject of personal data independently decides to provide his personal data and consents freely, by his own will and in his own interest.

9. Terms of personal data processing

9.1. Processing of personal data is carried out with the consent of the subject of personal data to the processing of his personal data.

9.2. The processing of personal data is necessary to achieve the goals provided for by an international treaty of the Russian Federation or the law, for the implementation of the functions, powers and duties assigned to the operator by the legislation of the Russian Federation.

9.3. The processing of personal data is necessary for the administration of justice, execution of a judicial act, an act of another body or official to be executed in accordance with the legislation of the Russian Federation on enforcement proceedings.

9.4. Processing of personal data is necessary for the execution of a contract to which the personal data subject is either a beneficiary or guarantor, as well as for the conclusion of a contract on the initiative of the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor.

9.5. The processing of personal data is necessary for the exercise of the rights and legitimate interests of the operator or third parties or to achieve socially significant goals, provided that the rights and freedoms of the subject of personal data are not violated.

9.6. Personal data is processed, access of an unlimited number of persons to which is provided by the subject of personal data or at his request (hereinafter referred to as publicly available personal data).

9.7. Personal data subject to publication or mandatory disclosure in accordance with federal law is processed.

10. Procedure for collection, storage, transfer and other types of personal data processing

The security of personal data processed by the Operator is ensured through the implementation of legal, organizational and technical measures necessary to fully comply with the requirements of the current legislation in the field of personal data protection.

10.1. The operator ensures the safety of personal data and takes all possible measures to exclude access to personal data of unauthorized persons.

10.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to the implementation of the current legislation or if the subject of personal data has agreed to the Operator to transfer data to a third party to fulfill obligations under the civil law contract.

10.3. In case of inaccuracies in personal data, the User can update them independently by sending the Operator a notification to the Operator's e-mail address info@systserv.spb.su marked "Updating personal data".

10.4. The period of processing of personal data is determined by the achievement of the purposes for which personal data were collected, unless otherwise provided for by the contract or current legislation.
The User can withdraw his consent to the processing of personal data at any time by sending a notification to the Operator by e-mail to the Operator's e-mail address info@systserv.spb.su with the note "Withdrawal of consent to the processing of personal data".

10.5. All information collected by third-party services, including payment systems, means of communication and other service providers, is stored and processed by these persons (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data and/or the User is obliged to familiarize themselves with these documents in a timely manner. The operator is not responsible for the actions of third parties, including the service providers specified in this paragraph.

10.6. The prohibitions established by the subject of personal data on the transfer (except for granting access), as well as on the processing or conditions for processing (except for access) of personal data allowed for distribution, do not apply in cases of processing personal data in the state, public and other public interests determined by the legislation of the Russian Federation.

10.7. The operator ensures the confidentiality of personal data when processing personal data.

10.8. The operator stores personal data in a form that allows to determine the subject of personal data, no longer than required by the purpose of processing personal data, if the period of storage of personal data is not established by federal law, a contract to which the subject of personal data is a party, beneficiary or guarantor.

10.9. A condition for the termination of personal data processing may be the achievement of the goals of personal data processing, the expiration of the consent of the personal data subject or the withdrawal of consent by the personal data subject, as well as the identification of illegal processing of personal data.

11. List of actions performed by the Operator with the received personal data

11.1. The operator collects, records, organizes, accumulates, stores, clarifies (updates, changes), extracts, uses, transfers (distribution, provision, access), depersonalizes, blocks, deletes and destroys personal data.

11.2. The operator carries out automated processing of personal data with or without receipt and/or transmission of received information over information and telecommunication networks.

12. Cross-border transfer of personal data

12.1. Before starting the 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 ensures reliable protection of the rights of personal data subjects.

12.2. Cross-border transfer of personal data on the territory of foreign countries that do not meet the above requirements may be carried out only if there is a written consent of the personal data subject to the cross-border transfer of his personal data and/or the performance of the contract to which the subject of personal data is a party.

13. Confidentiality of personal data

The operator and other persons who have gained access to personal data are obliged not to disclose to third parties or distribute personal data without the consent of the subject of personal data, unless otherwise provided by federal law.

14. Final provisions

14.1. The User can get any clarifications on issues of interest related to the processing of his personal data by contacting the Operator via e-mail info@systserv.spb.su.

14.2. This document will reflect any changes in the personal data processing policy by the Operator. The policy is valid indefinitely until it is replaced with a new version.

14.3. The current version of the Policy is freely available on the Internet at https://systserv.spb.ru/privacy/