Personal Data Regulations

Effective from July 1, 2020

1. General Provisions

1.1. This document (hereinafter referred to as the Policy) defines the policy regarding the processing of personal data by LLC NPO "LIT" (hereinafter referred to as the Operator or the Company) in accordance with Federal Law No. 152-FZ "On Personal Data" dated July 27, 2006 (hereinafter referred to as the Personal Data Law).

1.2. This Policy has been developed in compliance with Clause 2, Part 1, Article 18.1 of the Personal Data Law.

1.3. The terms contained in Article 3 of the Personal Data Law are used in this Policy with identical meaning.

1.4. Key rights and obligations of the Operator and personal data subjects:

1.4.1. The Operator has the right to:

• Obtain accurate information and/or documents containing personal data from the subject;
• Request timely updates to the provided personal data from the subject;
• Exercise other rights provided by the Personal Data Law.

1.4.2. The Operator is obliged to:

• Process personal data in accordance with applicable Russian legislation;
• Review inquiries from personal data subjects regarding processing and provide responses;
• Organize protection of personal data in compliance with Russian legislation requirements;
• Fulfill other obligations stipulated by the Personal Data Law.

1.4.3. The personal data subject has the right to:

• Full information about their processed personal data
• Withdraw consent for personal data processing;
• Exercise other rights provided by the Personal Data Law and legislation.

1.4.4. The personal data subject is obliged to:

• Provide only accurate data about themselves to the Operator;
• Submit documents containing personal data necessary for processing purposes;
• Notify the Operator about updates (modifications or changes) to their personal data;
• Fulfill other obligations stipulated by the Personal Data Law and Russian legislation.

1.5. Individuals who submit false information about themselves or information about another subject without their consent are liable under Russian legislation.

2. Purposes of Collecting Personal Data

2.1. The purpose of collecting and processing personal data is for:

• Subscription to marketing newsletters from the Company and other purposes, such as;
• Entering into agreements with personal data subjects and fulfilling them;
• Conducting promotions, surveys, interviews, testing, and research on websites;
• Informing about new products and services developed by the Operator, including advertising content;
• Providing feedback to personal data subjects, including processing inquiries and informing about website operations;
• Monitoring and improving service quality offered by the Company on its websites.;
• Generating statistical reports;
• Developing personalized offers;
• Sending information and promotional materials via mail, SMS, phone calls, push notifications, or newsletters;
• Sharing information about tools, applications, products, events, and promotions of the Company;
• Performing other functions and obligations assigned to the Operator under Russian legislation;
• Other purposes explicitly stated in consent for processing or those specified by law where consent may not be required.

3. LEGAL GROUNDS FOR PERSONAL DATA PROCESSING

3.1. The legal basis for the processing of personal data includes::

• The Constitution of the Russian Federation;
• The Labor Code of the Russian Federatio;
• ГThe Civil Code of the Russian Federation;
• Federal Law No. 149-FZ of July 27, 2006 "On Information, Information Technologies and Information Protection";
• The Law of the Russian Federation of December 27, 1991 No. 2124-1 "On Mass Media";
• Federal Law No. 294-FZ of December 26, 2008 "On the Protection of the Rights of Legal Entities and Individual Entrepreneurs in the Exercise of State Control (Supervision) and Municipal Control";
• Decree of the President of the Russian Federation No. 188 dated March 6, 1997 "On approval of the List of confidential information";
• Decree of the Government of the Russian Federation No. 512 dated July 06, 2008 "On Approval of Requirements for Physical Carriers of Biometric Personal Data and Technologies for Storing Such Data outside of Personal Data Information Systems";
• Resolution of the Government of the Russian Federation of September 15, 2008 No. 687 "On Approva;

4. SCOPE AND CATEGORIES OF PERSONAL DATA PROCESSED. CATEGORIES OF PERSONAL DATA SUBJECTS

4.1. The list of personal data processed by the Operator may include (scope and categories of personal data):

• фlast name, first name, patronymic,
• email address,
• phone number,
• country of residence, place of residence (city, region),
• company name and information about it,
• information about your area of interest and professional activity, specialty,
• istory of requests and views on the website and its services (for visitors to websites), other information (the above list is not exhaustive and may be changed depending on the specific case and the purposes of processing).

4.2. Categories of subjects of personal data.

The Operator may process the personal data of the following personal data subjects:

• Operator's employees, former Operator's employees, candidates for employment;
• Clients and counterparties of the Company (individuals);
• Representatives/employees of clients and counter.

5. PROCEDURE AND CONDITIONS OF PERSONAL DATA PROCESSING

5.1. In order to fulfill the above purposes, the Company will store Personal Data, analyze the behavior of personal data subjects and, on this basis, create a profile on Websites, in various Company applications or Company tools to which the personal data subject has access, including a personal account..

To analyze the behavior of personal data subjects, the Company uses visitor identifiers, which the Company uses to identify visitors and their interests on the Company's Websites and applications through cookies. For more information about how cookies are used, please refer to the relevant Company policy.

In addition, if you have an account registered on the Company's Website or in the Company's application, the personal data subject will be assigned a regular user ID, which will be registered and saved each time the personal data subject requests.

6. UPDATING, CORRECTION, DELETION AND DESTRUCTION OF PERSONAL DATA, RESPONDING TO REQUESTS FROM PERSONAL DATA SUBJECTS FOR ACCESS TO PERSONAL DATA

6.1. In case of confirmation of the inaccuracy of personal data processing, personal data must be updated and corrected by the Operator, and in case of illegality of their processing, the processing of personal data must be terminated.

6.2. Upon achieving the purposes of personal data processing, as well as in the case of revocation by the personal data subject of consent to their processing, personal data is subject to destruction if:

• Nothing else is provided for in the contract to which the personal data subject is a party, beneficiary or guarantor;
• The operator does not have the right to process personal data without the consent of the personal data subject on the grounds provided for by the Law on Personal Data or other federal laws.; otherwise, no other agreement is provided for between the Operator and the subject of personal data;

6.3. The operator is obliged to inform the personal data subject or his representative of the information about the processing of personal data of such subject at the request of the latter in accordance with applicable law.

7. FINAL PROVISIONS

7.1. All relations related to the processing of personal data that are not reflected in this Policy are regulated in accordance with the provisions of the legislation of the Russian Federation.

7.2. Changes to the Personal Data Processing Policy. The Company reserves the right to make changes or additions to this Policy at any time. The Operator informs the subjects of personal data about all changes made to this Policy by publishing a new Policy (a new version of the Policy) on the Company's official website.