Privacy Policy
1. General Provisions
1.1. The personal data processing policy at Optima Log LLC determines the basic principles, goals, conditions and methods for processing personal data, the lists of subjects and personal data processed at Optima Log LLC, the functions of Optima Log LLC when processing personal data, the rights of personal data subjects, as well as the requirements for the protection of personal data implemented in Optima Log LLC.
1.2. The policy has been developed taking into account the requirements of the Constitution of the Russian Federation, legislative and other regulatory legal acts of the Russian Federation in the field of personal data.
1.3. The provisions of the Policy serve as the basis for the development of local regulations governing the processing of personal data of employees of Optima Log LLC and other subjects of personal data in Optima Log LLC.
2. Legislative and other regulatory legal acts of the Russian Federation, in accordance with which the Policy for the processing of personal data in Optima Log LLC is determined
2.1. The personal data processing policy at Optima Log LLC is determined in accordance with the following regulatory legal acts:
· Federal Law of July 27, 2006 №152 On Personal Data;
· Decree of the President of the Russian Federation of March 06, 1997 №188 On Approval of the List of Confidential Information;
· Decree of the Government of the Russian Federation dated September 15, 2008 №687 On approval of the Regulations on the specifics of the processing of personal data carried out without the use of automation tools;
· Decree of the Government of the Russian Federation dated July 6, 2008 №512 On Approval of Requirements for Material Carriers of Biometric Personal Data and Technologies for Storage of Such Data Outside Personal Data Information Systems;
· Decree of the Government of the Russian Federation dated November 1, 2012 №1119 On approval of requirements for the protection of personal data during their processing in personal data information systems;
· Order of Roskomnadzor dated September 05, 2013 №996 On approval of requirements and methods for depersonalization of personal data;
· Other normative legal acts of the Russian Federation and normative documents of authorized state authorities.
2.2. In order to implement the provisions of the Policy, Optima Log LLC develops relevant local regulations and other documents, including:
· Regulations on the processing of personal data in Optima Log LLC;
· Regulations on ensuring the security of personal data during their processing in personal data in information systems of Optima Log LLC;
· other local regulations and documents regulating the processing of personal data in Optima Log LLC.
3. The main terms and definitions used in the local regulations of LLC Optima Log, regulating the processing of personal data
Personal data is considered any information relating to a directly or indirectly identified or identifiable natural person (subject of personal data). Information is considered information (messages, data) regardless of the form of their presentation. Operator is considered a state body, municipal body, legal entity or individual, independently or jointly with other persons organizing and (or) carrying out the processing of personal data, as well as determining the purposes of processing personal data, the composition of personal data to be processed, the actions (operations) performed with personal data. Processing of personal data is applied to any action (operation) or a set of actions (operations) performed with the use of automation tools or without the use of such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
Automated processing of personal data is the processing of personal data using computer technology. Provision of personal data is the set of actions aimed at disclosing personal data to a certain person or a certain circle of persons. Dissemination of personal data is the set of actions aimed at disclosing personal data to an indefinite circle of persons. 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. Blocking of personal data is a temporary suspension of the processing of personal data (except when processing is necessary to clarify personal data). Destruction of personal data is the set of actions, as a result of which it becomes 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. Depersonalization of personal data is the set of actions, as a result of which it becomes impossible to determine the ownership of personal data by a specific subject of personal data without the use of additional information. Personal data information system is a set of personal data contained in databases and information technologies and technical means that ensure their processing.
4. Principles and purposes of personal data processing
4.1. Optima Log LLC, being a personal data operator, processes personal data of Clients and Counterparties.
4.2. The processing of personal data in Optima Log LLC is carried out taking into account the need to ensure the protection of the rights and freedoms of the Clients and Counterparties of Optima Log LLC, including the protection of the right to privacy, personal and family secrets, based on the following principles:
· the processing of personal data is carried out in Optima Log LLC on a legal and fair basis;
· the processing of personal data is limited to the achievement of specific, predetermined and legitimate purposes;
· processing of personal data that is incompatible with the purposes of collecting personal data is not allowed;
· it is not allowed to combine databases containing personal data, the processing of which is carried out for purposes that are incompatible with each other;
· only personal data that meet the purposes of their processing are subject to processing;
· the content and scope of the processed personal data corresponds to the stated purposes of processing. The redundancy of the processed personal data in relation to the stated purposes of their processing is not allowed;
· when processing personal data, the accuracy of personal data, their sufficiency, and, if necessary, relevance in relation to the purposes of processing personal data, are ensured. Optima Log LLC takes the necessary measures or ensures their adoption to delete or clarify incomplete or inaccurate personal data;
· the storage of personal data is carried out in a form that allows determining the subject of personal data, no longer than required by the purposes of processing personal data, if the period for storing personal data is not established by federal law, an agreement to which the subject of personal data is a party, beneficiary or guarantor;
· the processed personal data is destroyed or depersonalized upon reaching the goals of processing or in case of loss of the need to achieve these goals, unless otherwise provided by federal law.
4.3. Personal data is processed by Optima Log LLC for the following purposes:
· Ensuring compliance with the Constitution of the Russian Federation, legislative and other regulatory legal acts of the Russian Federation, local regulations of Optima Log LLC;
· preparation, conclusion, execution and termination of contracts with contractors;
· formation of reference materials for internal information support of LLC Optima Log activity;
· exercising the rights and legitimate interests of Optima Log LLC in the framework of carrying out the types of activities provided for by the Charter and other local regulations of Optima Log LLC, or third parties, or achieving socially significant goals; for other lawful purposes.
5. List of entities whose personal data is processed by Optima Log LLC
5.1. Optima Log LLC processes personal data of the following categories of subjects:
Clients and Counterparties of Optima Log LLC;
6. List of personal data processed by Optima Log LLC
6.1. The list of personal data processed by Optima Log LLC is determined in accordance with the legislation of the Russian Federation and local regulations of Optima Log LLC, taking into account the purposes of personal data processing specified in Section 4 of the Policy.
6.2. Processing of special categories of personal data relating to race, nationality, political views, religious or philosophical beliefs, intimate life is not carried out by Optima Log LLC.
7. Functions of LLC Optima Log in the processing of personal data
7.1. Optima Log LLC when processing personal data:
· takes measures necessary and sufficient to ensure compliance with the requirements of the legislation of the Russian Federation and local regulations of Optima Log LLC in the field of personal data;
· takes legal, organizational and technical measures to protect personal data from unauthorized or accidental access to them, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other illegal actions in relation to personal data;
· appoints a person responsible for organizing the processing of personal data in Optima Log LLC;
· issues local regulations that determine the policy and issues of processing and protecting personal data in Optima Log LLC;
· publishes or otherwise provides unrestricted access to this Policy;
· informs in accordance with the established procedure to the subjects of personal data or their representatives information about the availability of personal data relating to the respective subjects, provides an opportunity to get acquainted with these personal data when applying and (or) receiving requests from the specified subjects of personal data or their representatives, unless otherwise provided by law Russian Federation;
· stop processing and destroy personal data in cases stipulated by the legislation of the Russian Federation in the field of personal data;
· performs other actions stipulated by the legislation of the Russian Federation in the field of personal data.
8. Conditions for the processing of personal data in Optima Log LLC
8.1. The processing of personal data in Optima Log LLC is carried out with the consent of the subject of personal data to the processing of his personal data, unless otherwise provided by the legislation of the Russian Federation in the field of personal data.
8.2. LLC Optima Log without the consent of the subject of personal data does not disclose to third parties and does not distribute personal data, unless otherwise provided by federal law.
8.3. Optima Log LLC has the right to entrust the processing of personal data to another person with the consent of the subject of personal data on the basis of an agreement concluded with this person.The contract must contain a list of actions (operations) with personal data that will be performed by the person processing personal data, the purposes of processing, the obligation of such a person to maintain the confidentiality of personal data and ensure the security of personal data during their processing, as well as requirements for the protection of processed personal data in in accordance with Article 19 of the Federal Law "On Personal Data".
8.4. For the purpose of internal information support, Optima Log LLC may create internal reference materials, which, with the written consent of the subject of personal data, unless otherwise provided by the legislation of the Russian Federation, may include his last name, first name, patronymic, subscriber number, e-mail address, other personal data reported by the subject of personal data.
8.5. Access to personal data processed by Optima Log LLC is permitted only to employees of Optima Log LLC holding positions included in the list of positions of structural divisions of the administration of Optima Log LLC, replacing which personal data is processed.
9. List of actions with personal data and methods of their processing
9.1. Optima Log LLC collects, records, systematizes, accumulates, stores, clarifies (updates, changes), extracts, uses, transfers (distributes, provides, accesses), depersonalizes, blocks, deletes and destroys personal data.
9.2. The processing of personal data in Optima Log LLC is carried out in the following ways:
· non-automated processing of personal data;
· automated processing of personal data with or without transmission of the received information via information and telecommunication networks;
· mixed processing of personal data.
10. Rights of personal data subjects
10.1. Subjects of personal data have the right to:
· full information about their personal data processed by Optima Log LLC;
· clarification of their personal data, their blocking or destruction if the personal data is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing;
· withdrawal of consent to the processing of personal data;
· adoption of legal measures to protect their rights;
· appeal against the action or inaction of Optima Log LLC, carried out in violation of the requirements of the legislation of the Russian Federation in the field of personal data, to the authorized body for the protection of the rights of subjects of personal data or to the court; · exercising other rights stipulated by the legislation of the Russian Federation.
11. Measures taken by Optima Log LLC to ensure the fulfillment of the obligations of the operator when processing personal data
11.1. Measures necessary and sufficient to ensure that Optima Log LLC fulfills the obligations of the operator provided for by the legislation of the Russian Federation in the field of personal data include:
· appointment of a person responsible for organizing the processing of personal data in Optima Log LLC;
· adoption of local regulations and other documents in the field of processing and protection of personal data;
· organizing training and conducting methodological work with employees of the structural divisions of the administration of Optima Log LLC, holding positions included in the list of positions of the structural divisions of the administration of Optima Log LLC, replacing which the processing of personal data is carried out;
· Obtaining the consents of the subjects of personal data to the processing of their personal data, with the exception of cases provided for by the legislation of the Russian Federation;
· Separation of personal data processed without the use of automation tools from other information, in particular by fixing them on separate material carriers of personal data, in special sections;
· storage of material carriers of personal data in compliance with the conditions that ensure the safety of personal data and exclude unauthorized access to them;
· implementation of internal control over the compliance of personal data processing with the Federal Law "On Personal Data" and the regulatory legal acts adopted in accordance with it, the requirements for the protection of personal data, this Policy, local regulations of Optima Log LLC;
· other measures provided for by the legislation of the Russian Federation in the field of personal data.
11.2. Measures to ensure the security of personal data during their processing in personal data information systems are established in accordance with the local regulations of Optima Log LLC, which regulate the issues of ensuring the security of personal data during their processing in personal data information systems of Optima Log LLC.
12. Control over compliance with the legislation of the Russian Federation and local regulations of Optima Log LLC in the field of personal data, including requirements for the protection of personal data
12.1. Control over compliance by the structural divisions of the administration of Optima Log LLC, the legislation of the Russian Federation and local regulations of Optima Log LLC in the field of personal data, including the requirements for the protection of personal data, is carried out in order to verify the compliance of the processing of personal data in the structural divisions of the administration LLC Optima Log, the legislation of the Russian Federation and local regulations of LLC Optima Log in the field of personal data, including the requirements for the protection of personal data, as well as the measures taken to prevent and detect violations of the legislation of the Russian Federation in the field of personal data , identifying possible channels of leakage and unauthorized access to personal data, and eliminating the consequences of such violations.
12.2. Internal control over compliance by the structural divisions of the administration of Optima Log LLC with the legislation of the Russian Federation and local regulations of Optima Log LLC in the field of personal data, including the requirements for the protection of personal data, is carried out by the person responsible for organizing the processing of personal data in LLC Optima Log.
12.3. Personal responsibility for compliance with the requirements of the legislation of the Russian Federation and local regulations of LLC Optima Log in the field of personal data in the structural division of the administration of LLC Optima Log, as well as for ensuring the confidentiality and security of personal data in these divisions of LLC Optima Log rests with their leaders.