The company's policy in relation to the processing of personal data
1. GENERALITIES

1.1. Personal data processing policy (hereinafter 'Policy') was developed in accordance with the Federal law of 27.07.2006. № 152 on personal data.

1.2. This Policy defines the procedure for processing personal data and measures to ensure the security of personal data in 'Battery Monitoring' (hereinafter 'Operator') in order to protect the rights and freedoms of man and citizen in the processing of his personal data, including protection of the rights to privacy, personal and family secrets.

1.3. The following concepts are used in the Policy:

- automated processing of personal data – processing of personal data by means of computer technology;
- blocking of personal data-temporary cessation of the processing of personal data (except if the processing is necessary to clarify the personal data);
- information system of personal data-a set of personal data contained in databases, and ensuring their processing of information technologies and technical means;
- depersonalization of personal data - actions as a result of which it is impossible to determine, without the use of additional information, the belonging of personal data to a specific personal data subject;
- processing of personal data - any action (operation) or a set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data;
- operator - state body, municipal body, legal or natural person, independently or jointly with other persons organizing and (or) carrying out processing of personal data, as well as defining the purposes of processing of personal data, the composition of personal data to be processed, actions (operations) performed with personal data;
- personal data - any information directly or indirectly related to a specific or identifiable natural person (the subject of personal data);
- provision of personal data-actions aimed at disclosure of personal data to a certain person or a certain circle of persons;
- dissemination of personal data - actions aimed at disclosure of personal data to an indefinite circle of persons (transfer of personal data) or acquaintance with personal data of an unlimited number of persons, including disclosure of personal data in the media, placement in information and telecommunication networks or providing access to personal data in any other way;
- cross-border transfer of personal data - transfer of personal data to the territory of a foreign state authority of a foreign state, foreign natural or foreign legal entity;
- destruction of personal data - actions as a result of which it is impossible to restore the content of personal data in the information system of personal data and (or) as a result of which material carriers of personal data are destroyed.

1.4. The company is obliged to publish or otherwise provide unlimited access to this personal data processing Policy in accordance with part 2 of Art. 18.1. №152.

2. THE PRINCIPLES AND CONDITIONS OF PERSONAL DATA PROCESSING

2.1. Principles of personal data processing

Processing of personal data of the Operator is based on the following principles:

- legality and fair basis;
- restrictions on the processing of personal data for specific, predetermined and legal purposes;
- prevention of personal data processing incompatible with the purposes of personal data collection;
- preventing the consolidation of databases containing personal data, the processing of which is carried out for purposes incompatible with each other;
- processing only those personal data that meet the purposes of their processing;
- compliance of the content and volume of personal data processed with the stated purposes of processing;
- prevention of processing of personal data excessive in relation to the stated purposes of their processing;
- ensuring the accuracy, sufficiency and relevance of personal data in relation to the purposes of personal data processing;
- destruction or depersonalization of personal data upon achievement of the purposes of their processing or in case of loss of need for achievement of these purposes, at impossibility of elimination by the Operator of the allowed violations of personal data if other is not provided by the Federal law.

2.2. Personal data processing conditions

The operator performs the processing of personal data in the presence of at least one of the following conditions:

- processing of personal data is carried out with the consent of the personal data subject to the processing of his personal data;
- processing of personal data is necessary to achieve the objectives stipulated in the international Treaty of the Russian Federation or the law, for the implementation and execution of the functions, powers and duties assigned by the legislation of the Russian Federation to the operator;
- processing of personal data is necessary for the administration of justice, the execution of a judicial act, an act of another body or an official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings;
- processing of personal data is necessary for the execution of the contract, the party of which is either the beneficiary or the guarantor for which is the subject of personal data, as well as for the conclusion of the contract on the initiative of the subject of personal data or the contract under which the subject of personal data will be the beneficiary or the guarantor;
- processing of personal data is necessary for the exercise of the rights and legitimate interests of the operator or third parties or for the achievement of socially significant goals, provided that the rights and freedoms of the personal data subject are not violated;
- processing of personal data is carried out, the access of an unlimited number of persons to whom is provided by the subject of personal data or at his request ('publicly available personal data');
- processing of the personal data which are subject to publication or obligatory disclosure according to the Federal law is performed.

2.3. Confidentiality of personal data

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

2.4. Public sources of personal data

For information purposes, the Operator may create publicly available sources of personal data of subjects, including directories and address books. The subject's surname, name, patronymic, date and place of birth, position, contact phone numbers, e-mail address and other personal data communicated by the subject of personal data may be included in the publicly available sources of personal data with the written consent of the subject.

Data on the subject shall be excluded at any time from publicly available sources of personal data at the request of the subject or by the decision of the court or other authorized state bodies.

2.5. Special categories of personal data

Processing by the Operator of special categories of personal data relating to race, nationality, political views, religious or philosophical beliefs, health, sexual life, is allowed in cases where:

- the subject of personal data has agreed in writing to the processing of their personal data;
- personal data made publicly available by the subject of personal data;
- processing of personal data is carried out in accordance with the legislation on state social assistance, labor legislation, the legislation of the Russian Federation on state pensions, labor pensions;
- processing of personal data is necessary to protect the life, health or other vital interests of the subject of personal data or the life, health or other vital interests of other persons and obtaining the consent of the subject of personal data is impossible;
- processing of personal data is carried out for medical and preventive purposes, in order to establish a medical diagnosis, provide medical and medical social services, provided that the processing of personal data is carried out by a person professionally engaged in medical activities and is obliged in accordance with the legislation of the Russian Federation to maintain medical secrecy;
- processing of personal data is necessary to establish or exercise the rights of the subject of personal data or third parties, as well as in connection with the administration of justice;
- processing of personal data is carried out in accordance with the legislation on compulsory types of insurance.

The 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.
Processing of personal data on criminal records may be carried out by the Operator only in cases and in the manner determined in accordance with Federal laws.

2.6. Biometric personal data

Information that characterizes the physiological and biological characteristics of a person, on the basis of which it is possible to establish his identity (biometric personal data) can be processed by the Operator only with the consent in writing of the subject.

2.7. The order of processing of personal data by another person

The operator has the right to entrust the processing of personal data to another person with the consent of the personal data subject, unless otherwise provided by the Federal law, on the basis of the contract concluded with that person. The person processing personal data on behalf of the Operator is obliged to comply with the principles and rules of processing of personal data provided by the Federal law-152.

2.8. Cross-border transfer of personal data

The operator is obliged to ensure that the foreign state, on the territory of which it is supposed to carry out the transfer of personal data, provides adequate protection of the rights of subjects of personal data, before the start of such transfer.

Cross-border transfer of personal data in the territory of foreign States that do not provide adequate protection of the rights of personal data subjects may be carried out in the following cases:

- consent in writing of the personal data subject to cross-border transfer of his/her personal data;
- execution of the contract, the party of which is the subject of personal data.

3. RIGHTS OF THE DATA SUBJECT

3.1. Consent of the personal data subject to the processing of his / her personal data

The personal data subject makes a decision to provide his / her personal data and agrees to its processing freely, by his / her own will and in his / her interest. Consent to the processing of personal data can be given by the subject of personal data or his representative in any form that allows to confirm the fact of its receipt, unless otherwise established by Federal law.

The obligation to provide proof of obtaining the consent of the personal data subject to the processing of his personal data or proof of the grounds specified in the Federal law-152 rests with the Operator.

3.2. Rights of the personal data subject

The personal data subject has the right to obtain from the Operator information concerning the processing of his/her personal data, if such right is not limited in accordance with Federal laws. The personal data subject has the right to demand from the Operator the specification of his personal data, their blocking or destruction if the personal data are incomplete, outdated, inaccurate, illegally obtained or are not necessary for the stated purpose of processing, as well as to take legal measures to protect their rights.

Processing of personal data for the purposes of promotion of goods, works, services on the market through direct contacts with potential consumers through means of communication, as well as for the purposes of political agitation is allowed only subject to prior consent of the subject of personal data. The specified processing of personal data is recognized as being carried out without the prior consent of the personal data subject, unless the Company proves that such consent was obtained.

The operator is obliged to immediately stop the processing of his/her personal data for the above purposes at the request of the personal data subject.

It is prohibited to make decisions on the basis of exclusively automated processing of personal data that have legal consequences with respect to the subject of personal data or otherwise affect his rights and legitimate interests, except in cases provided for by Federal laws, or with the consent in writing of the subject of personal data.

If the personal data subject believes that the Operator performs the processing of his personal data in violation of the requirements of FZ-152 or otherwise violates his rights and freedoms, the personal data subject has the right to appeal against the actions or omissions of the Operator to the Authorized body for the protection of the rights of personal data subjects or in court.

The personal data subject has the right to protection of his / her rights and legitimate interests, including compensation for damages and / or compensation for moral damage in court.

4. SECURITY OF PERSONAL DATA

The security of personal data processed by the Operator is ensured by the implementation of legal, organizational and technical measures necessary to ensure the requirements of Federal legislation in the field of personal data protection.

To prevent unauthorized access to personal data by the operator, the Following organizational and technical measures are used:

- appointment of officials responsible for the organization of processing and protection of personal data;
- restriction of the composition of persons having access to personal data;
- familiarization of subjects with the requirements of Federal legislation and regulatory documents of the Operator on processing and protection of personal data;
- organization of accounting, storage and circulation of information carriers;
- identification of threats to the security of personal data during their processing, the formation of threat models based on them;
- development of a system of personal data protection based on the threat model;
- verification of readiness and effectiveness of the use of information security;
- delineation of users access to information resources and hardware and software for information processing;
- registration and record keeping of actions of users of information systems of personal data;
- the use of antivirus tools and means of restoring the system of protection of personal data;
- application, where necessary, of means of inter-network shielding, intrusion detection, security analysis and means of cryptographic protection of information;
- organization of access control to the territory of the Operator, protection of premises with technical means of personal data processing.

5. FINAL PROVISION

Other rights and obligations of the Operator as a personal data Operator are determined by the legislation of the Russian Federation in the field of personal data.

The Operator's officials, who are guilty of violating the rules governing the processing and protection of personal data, bear material, disciplinary, administrative, civil or criminal liability in the manner prescribed by Federal laws.

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