Personal Data Processing Policy
LIMITED LIABILITY COMPANIES "EIDOS-ROBOTICS"
REGARDING THE PROCESSING OF PERSONAL DATA
1. GENERAL PROVISIONS
1.1. This Policy of the limited Liability Company "Eidos-Robotics" regarding the processing of personal data (hereinafter referred to as the Policy) has been developed in compliance with the requirements of paragraph 2 of Part 1 of Article 18.1 of the Federal Law of 27.07.2006 N 152-FZ "On Personal Data" (hereinafter referred to as the Law on Personal Data) in order to ensure the protection of rights and the freedoms of a person and a citizen in the processing of his personal data, including the protection of the rights to privacy, personal and family secrets.
1.2. The Policy applies to all personal data processed by the limited liability company "Eidos-Robotics" (hereinafter referred to as the Operator, LLC "Eidos-Robotics").
1.3. The Policy applies to relations in the field of personal data processing that arose with the Operator both before and after the approval of this Policy.
1.4. In compliance with the requirements of Part 2 of Article 18.1 of the Law on Personal Data, this Policy is published in free access on the Internet information and telecommunications network on the Operator's website.
1.5. Basic concepts used in the Policy:
personal data - any information relating directly or indirectly to a specific or identifiable individual (subject of personal data);
personal data operator (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 processing personal data, the composition of personal data to be processed, actions (operations) performed with personal data;
personal data processing is any action (operation) or a set of actions (operations) with personal data performed without the use of automation tools. The processing of personal data includes, inter alia:
• collection;
• recording;
• systematization;
• accumulation;
• storage;
• clarification (update, change);
• extraction;
• usage;
• transfer (distribution, provision, access);
• depersonalization;
• blocking;
• removal;
• destruction;
dissemination of personal data - actions aimed at disclosure of personal data to an indefinite circle of persons;
provision of personal data - actions aimed at disclosure of personal data to a certain person or a certain circle of persons;
blocking of personal data - temporary termination of processing of personal data (except in cases where processing is necessary to clarify personal data);
destruction of personal data - actions as a result of which it becomes impossible to restore the content of personal data in the personal data information system and (or) as a result of which the material carriers of personal data are destroyed;
depersonalization of personal data - actions as a result of which it becomes impossible to determine the identity of personal data to a specific personal data subject without the use of additional information;
personal data information system - a set of personal data contained in databases and information technologies and technical means that ensure their processing;
cross-border transfer of personal data is the transfer of personal data to the territory of a foreign state to an authority of a foreign state, a foreign individual or a foreign legal entity.
1.6. Basic rights and obligations of the Operator.
1.6.1. The Operator has the right to:
1) independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of 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;
2) entrust the processing of personal data to another person with the consent of the subject of personal data, unless otherwise provided by federal law, on the basis of a contract concluded with this person. A person processing personal data on behalf of the Operator is obliged to comply with the principles and rules of personal data processing provided for by the Personal Data Law;
3) if the personal data subject withdraws consent to the processing of personal data, the Operator has the right to continue processing personal data without the consent of the personal data subject if there are grounds specified in the Personal Data Law.
1.6.2. The Operator is obliged to:
1) organize the processing of personal data in accordance with the requirements of the Law on Personal Data;
2) respond to the requests and requests of personal data subjects and their legal representatives in accordance with the requirements of the Law on Personal Data;
3) report to the authorized body for the protection of the rights of personal data subjects (Federal Service for Supervision of Communications, Information Technology and Mass Communications (Roskomnadzor)) at the request of this body, the necessary information within 30 days from the date of receipt of such a request.
1.7. Basic rights of the subject of personal data. The subject of personal data has the right to:
1) receive information concerning the processing of his personal data, except in cases provided for by federal laws. The information is provided to the personal data subject by the Operator in an accessible form, and it should not contain personal data related to other personal data subjects, except in cases where there are legitimate grounds for disclosure of such personal data. The list of information and the procedure for obtaining it is established by the Law on Personal Data;
2) require the operator to clarify his personal data, block or destroy them if the personal data are incomplete, outdated, inaccurate, illegally obtained or are not necessary for the stated purpose of processing, as well as take measures provided by law to protect their rights;
3) to put forward the condition of prior consent when processing personal data in order to promote goods, works and services on the market;
4) appeal to Roskomnadzor or in court against illegal actions or inaction of the Operator when processing his personal data.
1.8. Control over the fulfillment of the requirements of this Policy is carried out by an authorized person responsible for organizing the processing of personal data from the Operator.
1.9. Liability for violation of the requirements of the legislation of the Russian Federation and regulations of LLC "Eidos-Robotics" in the field of processing and protection of personal data is determined in accordance with the legislation of the Russian Federation.
2. PURPOSES OF PERSONAL DATA COLLECTION
2.1. 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.
2.2. Only personal data that meet the purposes of their processing are subject to processing.
2.3. The processing of personal data by the Operator is carried out for the following purposes:
• ensuring compliance with the Constitution of the Russian Federation, federal laws and other regulatory legal acts of the Russian Federation;
• carrying out its activities in accordance with the charter of LLC "Eidos-Robotics";
• HR records management;
• assistance to employees in finding employment, obtaining education and promotion, ensuring personal safety of employees, monitoring the quantity and quality of work performed, ensuring the safety of property;
• recruitment and selection of candidates to work with the Operator;
• organization of individual (personalized) registration of employees in the mandatory pension insurance system;
• filling in and submitting to the executive authorities and other authorized organizations the required reporting forms;
• implementation of civil law relations;
• accounting;
• implementation of the access regime.
2.4. Processing of personal data of employees may be carried out solely for the purpose of ensuring compliance with laws and other regulatory legal acts.
3. LEGAL GROUNDS FOR PROCESSING PERSONAL DATA
3.1. The legal basis for the processing of personal data is a set of regulatory legal acts, pursuant to which and in accordance with which the Operator processes personal data, including:
• Constitution of the Russian Federation;
• The Civil Code of the Russian Federation;
• Labor Code of the Russian Federation;
• Tax Code of the Russian Federation;
• Federal Law No. 14-FZ of 08.02.1998 "On Limited Liability Companies";
• Federal Law No. 402-FZ dated 06.12.2011 "On Accounting";
• Federal Law No. 167-FZ of 15.12.2001 "On Compulsory Pension Insurance in the Russian Federation";
• other regulatory legal acts regulating relations related to the Operator's activities.
3.2. The legal basis for the processing of personal data is also:
• the charter of LLC "Eidos-Robotics";
• contracts concluded between the Operator and personal data subjects;
• consent of personal data subjects to the processing of their personal data.
4. SCOPE AND CATEGORIES OF PERSONAL DATA PROCESSED,
CATEGORIES OF PERSONAL DATA SUBJECTS
4.1. The content and volume of the processed personal data must comply with the stated processing purposes provided for in section. 2 of this Policy. The processed personal data should not be redundant in relation to the stated purposes of their processing.
4.2. The Operator may process personal data of the following categories of personal data subjects.
4.2.1. Candidates for employment with the Operator:
• last name, first name, patronymic;
• gender;
• citizenship;
• date and place of birth;

5. PROCEDURE AND CONDITIONS OF PERSONAL DATA PROCESSING
5.1. The processing of personal data is carried out by the Operator in accordance with the requirements of the legislation of the Russian Federation.
5.2. The processing of personal data is carried out with the consent of personal data subjects to the processing of their personal data, as well as without it in cases provided for by the legislation of the Russian Federation.
The consent can be provided to the Operator both in writing and by putting appropriate marks on the Operator's website.
5.3. The Operator performs non-automated processing of personal data.
5.4. The Operator's employees, whose job responsibilities include processing personal data, are allowed to process personal data.
5.5. Personal data processing is carried out by:
• receiving personal data in oral and written form directly from the subjects of personal data;
• obtaining personal data from publicly available sources;
• entering personal data into the Operator's logs, registers and information systems;
• use of other methods of processing personal data.
5.6. Disclosure to third parties and dissemination of personal data without the consent of the subject of personal data is not allowed, unless otherwise provided by federal law. Consent to the processing of personal data authorized by the subject of personal data for distribution is issued separately from other consents of the subject of personal data to the processing of his personal data.
The requirements for the content of consent to the processing of personal data authorized by the subject of personal data for distribution are approved by the Order of Roskomnadzor dated 24.02.2021 N 18.
5.7. The transfer of personal data to the bodies of inquiry and investigation, to the Federal Tax Service, the Pension Fund of the Russian Federation, the Social Insurance Fund and other authorized executive authorities and organizations is carried out in accordance with the requirements legislation of the Russian Federation.
5.8. The Operator takes the necessary legal, organizational and technical measures to protect personal data from unauthorized or accidental access to them, destruction, modification, blocking, distribution and other unauthorized actions, including:
• identifies threats to the security of personal data during their processing;
• adopts local regulations and other documents regulating relations in the field of personal data processing and protection;
• appoints persons responsible for ensuring the security of personal data in the structural divisions and information systems of the Operator;
• creates the necessary conditions for working with personal data;
• organizes the accounting of documents containing personal data;
• organizes work with information systems in which personal data is processed;
• stores personal data in conditions that ensure their safety and exclude unauthorized access to them;
• organizes training of the Operator's employees who process personal data.
5.9. The Operator stores personal data in a form that allows determining the subject of personal data, no longer than the purposes of personal data processing require, unless the period of personal data storage is established by federal law, contract or consent to the processing of personal data.
The period of storage of personal data of candidates for employment with the Operator is 3 (three) years from the date of providing consent on the Operator's website or providing written consent.
5.10. When collecting personal data, including through the Internet information and telecommunications network, the Operator ensures the recording, systematization, accumulation, storage, clarification (updating, modification), extraction of personal data of citizens of the Russian Federation using databases located on the territory of the Russian Federation, except for the cases specified in the Law on Personal Data data.
6. UPDATING, CORRECTION, DELETION AND DESTRUCTION
PERSONAL DATA, RESPONSES TO THE REQUESTS OF SUBJECTS
ACCESS TO PERSONAL DATA
6.1. Confirmation of the fact of personal data processing by the Operator, the legal grounds and purposes of personal data processing, as well as other information specified in Part 7 of Article 14 of the Law on Personal Data, are provided by the Operator to the personal data subject or his representative when contacting or receiving a request from the personal data subject or his representative.
The information provided does not include personal data relating to other personal data subjects, except in cases where there are legitimate grounds for the disclosure of such personal data.
The request must contain:
• the number of the main identity document of the personal data subject or his representative, information about the date of issue of the specified document and the issuing authority;
• information confirming the participation of the subject of personal data in relations with the Operator (contract number, date of conclusion of the contract, conditional verbal designation and (or) other information), or information otherwise confirming the fact of processing of personal data by the Operator;
• signature of the personal data subject or his representative.
The request can be sent in the form of an electronic document and signed with an electronic signature in accordance with the legislation of the Russian Federation.
If the personal data subject's request does not reflect all the necessary information in accordance with the requirements of the Law on Personal Data, or the subject does not have access rights to the requested information, then a reasoned refusal is sent to him.
The right of the subject of personal data to access his personal data may be restricted in accordance with Part 8 of Article 14 of the Law on Personal Data, including if the access of the subject of personal data to his personal data violates the rights and legitimate interests of third parties.
6.2. If inaccurate personal data is detected when the personal data subject or his representative is contacted, or at their request or at the request of Roskomnadzor, the Operator blocks personal data related to this personal data subject from the moment of such request or receipt of the specified request for the verification period, if the blocking of personal data does not violate the rights and legitimate interests of the subject personal data or third parties.
In case of confirmation of the fact of inaccuracy of personal data, the Operator, based on the information provided by the subject of personal data or his representative or Roskomnadzor, or other necessary documents, clarifies personal data within seven working days from the date of submission of such information and removes the blocking of personal data.
6.3. In case of detection of unlawful processing of personal data when contacting (requesting) a personal data subject or his representative or Roskomnadzor, the Operator blocks the unlawfully processed personal data relating to this personal data subject from the moment of such request or receipt of the request.
6.4. Upon achievement of the purposes of personal data processing, as well as in the case of withdrawal by the subject of personal data of consent to their processing, personal data are subject to destruction if:
• nothing else is provided for in the contract to which the subject of personal data is a party, beneficiary or guarantor;
• the operator is not entitled to process without the consent of the subject of personal data on the grounds provided for by the Law on Personal Data or other federal laws;
• other is not provided for by another agreement between the Operator and the subject of personal data.