Privacy Policy with regard to personal data processing in Keysystems LLC
CONFIRMED BY
CEO of Keysystems LLC
____________A.A. Matrosov
___________20__
PRIVACY POLICY
regarding the processing of personal data in Keysystems LLC
1. General provisions
1.1. Purpose of the Privacy Policy
1.1.1. This Policy regarding the processing of personal data in Keysystems LLC (hereinafter - the Policy) is developed in accordance with the Federal Law dated July, 27, 2006 No. 152-FZ «About Personal Data».
1.1.2. The Policy comes into force from the moment of its approval by General Director of Keysystems LLC.
1.1.3. The Policy is subject to revision in the course of periodic analysis by the management of Keysystems LLC (hereinafter referred to as the Company), as well as in cases of changes in the legislation of the Russian Federation in the field of personal data.
1.1.4. The policy is subject to publication on the official websites of the Company (https://www.keysystems.ru; https://ksbusiness.info).
1.2. Policy Objectives
1.2.1. The purpose of the Policy is to ensure the protection of the rights and freedoms of personal data subjects when their personal data is processed by the Company.
1.3. Basic concepts
1.3.1. For the purposes of the Policy, the following concepts are used:
personal data – any information relating to a directly or indirectly identified or identifiable individual (subject of personal data);
personal data permitted by the subject of personal data for distribution – personal data, access to which by an unlimited number of persons is provided by the subject of personal data by giving consent to the processing of personal data permitted by the subject of personal data for distribution in the manner prescribed by the Federal Law "About Personal Data";
subject of personal data – an individual who is directly or indirectly identified or identifiable using personal data;
operator – 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 subject to processing, actions (operations) performed with personal data;
processing of personal data – any action (operation) or 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, modification), extraction, use, transfer (distribution, provision, access), blocking, deletion, destruction of personal data;
automated processing of personal data – processing of personal data using computer means;
dissemination of personal data – actions aimed at disclosing personal data to an indefinite number of persons;
provision of personal data – actions aimed at disclosing personal data to a specific person or a specific group of persons;
blocking of personal data – temporary cessation 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 physical data media with personal data are destroyed;
personal data information system – a set of personal data contained in databases and information technologies and technical means that ensure their processing;
confidentiality of information – a mandatory requirement for a person who has gained access to certain information not to transfer such information to third parties without the consent of its owner;
cross-border transfer of personal data – transfer of personal data to the territory of a foreign state to a foreign government body, a foreign individual or a foreign legal entity;
threats to the security of personal data – a set of conditions and factors that create the danger of unauthorized, including accidental, access to personal data, which may result in the destruction, modification, blocking, copying, provision, distribution of personal data, as well as other illegal actions during their processing in the personal data information system;
the level of protection of personal data is a complex indicator characterizing the requirements, the fulfillment of which ensures the neutralization of certain threats to the security of personal data when they are processed in personal data information systems.
1.4. Scope of application
1.4.1. The provisions of the Policy apply to all relations related to the processing of personal data carried out by the Company:
– using automation tools, including in information and telecommunications networks, or without using such tools, if the processing of personal data without using such tools corresponds to the nature of the actions (operations) performed with personal data using automation tools, that is, it allows, in accordance with a specified algorithm, to search for personal data recorded on a physical medium and contained in card indexes or other systematized collections of personal data, and (or) access to such personal data;
– without the use of automation tools.
1.4.2. This Policy should be followed by all employees of the Company who process or have access to personal data.
2. Purposes of personal data processing
2.1. The processing of personal data is carried out by the Company for the following purposes:
– maintaining personnel and accounting records;
– ensuring compliance with the labor legislation of the Russian Federation;
– ensuring compliance with the tax legislation of the Russian Federation;
– ensuring compliance with pension legislation of the Russian Federation;
– ensuring compliance with the insurance legislation of the Russian Federation;
– organization of voluntary medical insurance;
– recruitment of personnel (applicants) for vacant operator positions;
– ensuring the passing of introductory, industrial or pre-graduate internship on the basis of an agreement with an educational institution;
– organization of preliminary and periodic medical examinations for employees;
– implementation of the loyalty program;
– provision of corporate cellular communication services;
– issuance and accounting of loans;
– conclusion of targeted training agreements;
– preparation, conclusion and execution of a civil law contract;
– ensuring access to the operator's territory;
– maintaining a corporate portal;
– software development and provision of services in the field of software supply; providing consulting support to software users; conducting training courses; fulfilling the terms of contracts and agreements; maintaining an official website; organizing access to information about the organization's activities posted on the Internet information and telecommunications network; providing access to information about employees' birthdays, posted on a video panel in the lobby of the building; implementation of other statutory tasks;
– organization of access to information about employees of Keysystems LLC, posted on the Internet information and telecommunications network;
– analysis of the behavioral characteristics of users on the site;
– organization of access to information about the partners of Keysystems LLC, posted on the Internet information and telecommunications network;
– organization of access to information about the employees of R.O.S.T.U. LLC, posted on the Internet information and telecommunications network;
– establishment of feedback with the User;
– organization of access to information about the speakers of the event;
– maintaining a self-service portal;
– registration in the app;
– organization of the activities of the Marketing Department.
3. Legal grounds for processing personal data
3.1. The following regulations and documents are the basis for the processing of personal data in the Company:
– the Tax Code of the Russian Federation;
– the Civil Code of the Russian Federation;
– The Labor Code of the Russian Federation;
– Federal Law No. 402-FZ dated December, 6, 2011 "About Accounting";
– Federal Law No. 53-FZ dated March, 28, 1998 "About Military Duty and Military Service";
– Federal Law No. 273-FZ dated December, 29, 2012 "About Education in the Russian Federation";
– Federal Law No. 173-FZ dated December, 17, 2001 "About Labor Pensions in the Russian Federation";
– Federal Law No. 255-FZ dated December, 29, 2006 "About Compulsory Social Insurance in case of Temporary Working Disability and in connection with Maternity";
– Federal Law No. 27-FZ dated April, 01, 1996 "About Individual (Personalized) Accounting in the Compulsory Pension Insurance System";
– Federal Law No. 165-FZ dated July, 16, 1999 "About the Fundamentals of Compulsory Social Insurance";
– Federal Law No. 181-FZ dated November, 24, 1995 "About Social Protection of Persons with Disabilities in the Russian Federation";
– Federal Law No. 44-FZ dated April, 05, 2013 "About the Contract System in the field of procurement of goods, Works, and Services for State and Municipal Needs";
– Federal Law No. 31-FZ dated February, 26, 1997 "About Mobilization Training and Mobilization in the Russian Federation;
– Federal Law No. 63-FZ dated April, 06, 2011 "About Electronic Signature";
– Federal Law No. 400-FZ dated December, 28, 2013 "About Insurance Pensions";
– Federal Law No. 326-FZ dated November, 29, 2010 "About Compulsory Medical Insurance in the Russian Federation";
– Federal Law No. 167-FZ dated December, 15, 2001 "About Compulsory Pension Insurance in the Russian Federation";
– Federal Law No. 125-FZ dated July, 24, 1998 "About Compulsory Social Insurance against industrial Accidents and occupational diseases";
– Federal Law No. 31-FZ dated February, 26, 1997 "About Mobilization Training and Mobilization in the Russian Federation;
– Federal Law No. 223-FZ dated July, 18, 2011 "About Procurement of Goods, Works, and Services by Certain Types of Legal Entities";
– Order of the Ministry of Health of the Russian Federation dated May, 30, 2023 No. 266n "About Approval of the Procedure and Periodicity of pre-shift, pre-trip, post-shift, post-trip medical examinations, medical examinations during the working day (shift) and the list of studies included in them";
– Rosarchive Order No. 236 dated December, 20, 2019 "About Approval of the List of Standard Administrative Archival Documents formed in the course of the activities of state bodies, local governments and organizations, indicating the terms of their storage";
– The Charter of Keysystems Limited Liability Company, approved by Protocol No. 50 of the general meeting of participants dated December, 25, 2015;
– contracts concluded between the operator and the subject of personal data;
– contracts for the assignment of personal data processing concluded with third parties;
– contracts under which the beneficiary or guarantor is the subject of personal data;
– consent of the personal data subject to the processing of personal data;
– consent to the processing of personal data authorized by the personal data subject for dissemination.
3.2. In cases not directly provided for by the legislation of the Russian Federation that do not comply with the Company's powers, personal data processing is carried out with the consent of the personal data subject to the processing of his/her personal data.
3.3. The processing of personal data is terminated upon the reorganization or liquidation of the Company.
4. Scope and categories of personal data processed, categories of personal data subjects
4.1. Information on the categories of subjects whose personal data is processed by the Company, the categories and list of personal data processed, the methods and timing of their processing and storage are provided in Appendix No. 1 to this Policy.
5. Procedure and conditions of personal data processing
5.1. Principles of personal data processing
Personal data processing is carried out by the Company in accordance with the following principles:
– personal data is processed on a lawful and fair basis;
– processing of personal data is limited to the achievement of specific, predetermined and legitimate purposes; processing of personal data incompatible with the purposes of personal data collection is not allowed;
– it is not allowed to combine databases containing personal data, the processing of which is carried out for purposes incompatible with each other;
– only personal data that meets the purposes of their processing is subject to processing;
– the content and volume of the personal data being processed correspond to the stated purposes of processing; the personal data being processed are not redundant in relation to the stated purposes of their processing;
– when processing personal data, the accuracy of personal data, its sufficiency, and, if necessary, its relevance to the purposes of personal data processing is ensured; the Company takes the necessary measures or ensures their adoption to delete or clarify incomplete or inaccurate data;
– personal data is stored in a form that makes it possible to identify 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, an agreement to which the personal data subject is a party, beneficiary or guarantor; the processed personal data is subject to destruction upon achievement of the purposes of processing or in case of loss of the need to achieve these goals, unless otherwise provided by the Federal Law.
5.2. Conditions of personal data processing
5.2.1. Conditions for processing special categories of personal data
The processing of special categories of personal data is carried out by the Company in compliance with the following conditions:
– personal data processing is carried out in accordance with the legislation on state social assistance, labor legislation, pension legislation of the Russian Federation;
– the processing of personal data is carried out in accordance with the legislation on compulsory types of insurance, with insurance legislation;
– the processing of personal data on criminal records may be carried out by state bodies or municipal bodies within the limits of the powers granted to them in accordance with the legislation of the Russian Federation, as well as by other persons in cases and in accordance with the procedure determined in accordance with Federal Laws;
– personal data is processed on behalf of another person.
5.2.2. Conditions for processing biometric personal data
Information characterizing the physiological and biological characteristics of a person, on the basis of which it is possible to establish his/her identity (biometric personal data) and which is used by the Company to establish the identity of the personal data subject, is not processed by the Company.
5.2.3. Conditions for processing other categories of personal data
The processing of other categories of personal data is carried out by the Company in compliance with the following conditions:
– processing of personal data is carried out with the consent of the personal data subject to the processing of his/her personal data;
– processing of personal data is necessary to achieve the goals stipulated by an international agreement of the Russian Federation or a Law, to perform and fulfill the functions, powers and duties assigned to the Company by the legislation of the Russian Federation;
– processing of personal data is required for the performance of a contract to which the personal data subject is a party or beneficiary or guarantor, as well as for the conclusion of a contract on the initiative of the personal data subject or an agreement under which the personal data subject will be the beneficiary or guarantor. An agreement concluded with a personal data subject may not contain provisions restricting the rights and freedoms of the personal data subject, establishing cases of processing personal data of minors, unless otherwise provided for by the legislation of the Russian Federation, as well as provisions allowing inaction of the personal data subject as a condition for concluding the agreement;
– processing of personal data is necessary for the exercise of the rights and legitimate interests of the Company or third parties, including in cases provided for by the Federal Law "About Protection of the Rights and Legitimate Interests of Individuals when Carrying out Activities to Repay Overdue Debts and about Amendments to the Federal Law "About Microfinance Activities and Microfinance Organizations", or to achieve socially significant purposes, provided that the rights and freedoms of the personal data subject are not violated;
– personal data is processed on behalf of another person;
– processing of personal data is carried out with consent to the processing of personal data authorized by the personal data subject for dissemination.
5.2.4. Assignment of personal data processing
5.2.4.1. The Company 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 an agreement concluded with this person, including a state or municipal contract, or by adopting a relevant act by a state or municipal body (hereinafter referred to as the entrusting).
5.2.4.2. The Company, if necessary, assigns the processing of personal data of personal data subjects. Information about the purpose of the processing order, the name and location of the persons to whom personal data is transferred, the amount of personal data transferred, and other information about the processing order are provided in Appendix No. 2 to this Policy.
5.2.4.3. The person who processes personal data on behalf of the Company adheres to the principles and rules of personal data processing provided for in this Policy, respects the confidentiality of personal data, and takes the necessary measures to ensure compliance with the obligations provided for by the Federal Law "About Personal Data". The Company's order defines the list of personal data, the list of actions (operations) with personal data to be performed by the person processing personal data, the methods and purposes of their processing, the obligation of such person to respect the confidentiality of personal data, the requirements provided for in part 5 of Article 18 and Article 18.1 of the Federal Law "About Personal Data", the obligation to provide documents and other information at the request of the Company during the period of validity of the Company's order, including before processing personal data, confirming the taking of measures and compliance with the requirements established in accordance with Part 3 of Article 6 of the Federal Law "About Personal Data" in order to fulfill the Company's entrustings to ensure the security of personal data during their processing, as well as the requirements for the protection of processed personal data, including the requirement to notify the Company of the cases provided for in Part 3.1 of the Article 21 of the Federal Law "About Personal Data".
5.2.4.4. When assigning the processing of personal data to another person, the Company is responsible to the personal data subject for the actions of the said person. The person who processes personal data on behalf of the Company is responsible to the Company.
5.2.4.5. If the Company entrusts the processing of personal data to a foreign individual or a foreign legal entity, the Company and the person processing personal data on behalf of the Company are responsible to the personal data subject for the actions of these persons.
5.2.5. Transfer of personal data
5.2.5.1. The Company has the right to transfer personal data to the bodies of inquiry and investigation and other authorized bodies on the grounds provided for by the current legislation of the Russian Federation.
5.3. Confidentiality of personal data
5.3.1. Employees of the Company who have received access to personal data do not disclose or distribute personal data to third parties without the consent of the personal data subject, unless otherwise provided by the Federal Law.
5.4. Publicly available sources of personal data
5.4.1. The Company does not create publicly available sources of personal data.
5.5. Consent of the personal data subject to the processing of his/her personal data
5.5.1. If it is necessary to ensure the conditions for processing the personal data of the subject, the consent of the personal data subject to the processing of his/her personal data may be provided.
5.5.2. The personal data subject decides on the provision of his/her personal data and agrees to their processing freely, voluntarily and in his/her own interest. Consent to the processing of personal data must be specific, substantive, informed, conscious and unambiguous. Consent to the processing of personal data may be given by the personal data subject or his/her representative in any form that allows confirming the fact of its receipt, unless otherwise established by the Federal Law. If consent to the processing of personal data is obtained from a representative of the personal data subject, the authority of this representative to give consent on behalf of the personal data subject is verified by the Company.
5.5.3. Consent to the processing of personal data may be revoked by the personal data subject. If the personal data subject withdraws consent to the processing of personal data, the Company has the right to continue processing personal data without the consent of the personal data subject if there are grounds specified in paragraphs 2-11 of part 1 of Article 6, paragraphs 2-10 of part 2 of Article 10 and part 2 of Article 11 of the Federal Law "About Personal Data".
5.5.4. The Company is responsible for providing proof of obtaining the consent of the personal data subject to the processing of his/her personal data or proof of the existence of the grounds specified in paragraphs 2-11 of part 1 of Article 6, paragraphs 2-10 of part 2 of Article 10 and Part 2 of Article 11 of the Federal Law "About Personal Data".
5.5.5. In cases stipulated by the Federal Law, personal data processing is carried out only with the written consent of the personal data subject. Consent in the form of an electronic document signed with an electronic signature in accordance with the Federal Law is considered equivalent to a written consent on paper containing a handwritten signature of the personal data subject. The written consent of the personal data subject to the processing of his/her personal data must include, in particular:
1) last name, first name, patronymic, address of the personal data subject, number of the main identity document, information about the date of issue of the specified document and the issuing authority;
2) last name, first name, patronymic, address of the representative of the personal data subject, number of the main identity document, information about the date of issue of the specified document and the issuing authority, details of a power of attorney or other document confirming the authority of this representative (upon receipt of consent from the representative of the personal data subject);
3) name or last name, first name, patronymic and address of the Company;
4) purpose of personal data processing;
5) list of personal data to be processed with the consent of the personal data subject;
6) name or last name, first name, patronymic and address of the person who processes personal data on behalf of the Company, if processing will be entrusted to such person;
7) a list of actions with personal data for which consent is given, a general description of the methods of personal data processing used by the Company;
8) period during which the consent of the personal data subject is valid, as well as the method of withdrawal, unless otherwise established by the Federal Law.;
9) signature of the personal data subject.
5.5.6. In case of incapacity of the personal data subject, consent to the processing of his personal data is given by the legal representative of the personal data subject.
5.5.7. In case of death of the personal data subject, consent to the processing of his personal data is given by the heirs of the personal data subject, if such consent was not given by the personal data subject during his lifetime.
5.5.8. Personal data may be obtained by the Company from a person who is not the subject of personal data, provided that the Company is provided with confirmation of the existence of the grounds specified in paragraphs 2-11 of Part 1 of Article 6, paragraphs 2-10 of Part 2 of Article 10 and Part 2 of Article 11 of the Federal Law "About Personal Data".
5.6. Cross-border transfer of personal data
5.6.1. The Company carries out cross-border transfer of personal data of personal data subjects. Information on the purpose of the cross-border transfer, the name and location of the persons to whom personal data is transferred, the amount of personal data transferred, and other information about the cross-border transfer are provided in Appendix No. 3 to this Policy.
5.7. Specifics of personal data processing authorized by the personal data subject for dissemination.
5.7.1. The processing of personal data authorized by the personal data subject for dissemination is carried out on the basis of the relevant consent of the personal data subject.
5.7.2. Consent to the processing of personal data authorized by the personal data subject for dissemination is issued separately from other consents of the personal data subject to the processing of his personal data.
5.7.3. The Consent contains a list of personal data for each category of personal data specified in the consent to the processing of personal data authorized by the personal data subject for dissemination.
5.7.4. Consent to the processing of personal data authorized by the personal data subject for dissemination is provided directly to the Company.
5.7.5. Silence or inaction of the personal data subject is not considered consent to the processing of personal data authorized by the personal data subject for dissemination.
5.7.6. In consent to the processing of personal data authorized by the personal data subject for dissemination, the personal data subject has the right to establish prohibitions on the transfer (other than granting access) of this personal data by the Company to an unlimited number of persons, as well as prohibitions on processing or conditions for processing (other than gaining access) of this personal data to an unlimited number of persons. The Company's refusal to establish prohibitions and conditions provided for in Article 10.1 of the Federal Law "About Personal Data" by the subject of personal data is not allowed.
5.7.7. The prohibitions established by the personal data subject on the transfer (other than granting access), as well as on the processing or conditions of processing (other than gaining access) of personal data authorized by the personal data subject for dissemination, do not apply to cases of personal data processing in the state, public and other public interests defined by the legislation of the Russian Federation.
5.7.8. The transfer (dissemination, provision, access) of personal data authorized by the personal data subject for dissemination must be terminated at any time at the request of the personal data subject. This requirement must include the last name, first name, patronymic (if any), contact information (phone number, e-mail address or postal address) of the personal data subject, as well as a list of personal data whose processing is subject to termination. The personal data specified in this requirement may be processed only by the Company.
5.7.9. The consent of the personal data subject to the processing of personal data authorized by the personal data subject for dissemination is terminated from the moment the Company receives the respective request.
5.7.10. The requirements specified above do not apply in the case of processing personal data for the purpose of fulfilling the functions, powers and duties assigned by the legislation of the Russian Federation to state bodies, municipal bodies, as well as to organizations subordinate to these bodies.
5.7.11. Based on written consent, the Company processes the following personal data authorized by the personal data subject for dissemination:
– full name, date of birth, photo, contact phone numbers, email address, position, structural unit, place of work, information about work activity, if the subject of personal data is an employee of Keysystems LLC;
– full name, if the subject of personal data is a representative of the partners;
– full name, photo, place of work, position, if the speaker of the event is the subject of personal data.
5.8. Processing of personal data carried out without the use of automation tools
5.8.1. General provisions
5.8.1.1. The processing of personal data contained in the personal data information system or extracted from such a system is considered to be carried out without the use of automation tools (non-automated) if such actions with personal data as the use, clarification, dissemination, destruction of personal data in relation to each of the subjects of personal data are carried out with the direct participation of a person.
5.8.2. Features of the organization of personal data processing carried out without the use of automation tools
5.8.2.1. Personal data, when processed without the use of automation tools, is separated from other information, in particular by recording them on separate tangible personal data carriers (hereinafter referred to as tangible media), in special sections or in the fields of forms (blanks).
5.8.2.2. When recording personal data on tangible media, it is not allowed to record personal data on one tangible medium, the purposes of processing which are obviously incompatible. For the processing of various categories of personal data carried out without the use of automation tools, a separate physical medium is used for each category of personal data.
5.8.2.3. Persons processing personal data without the use of automation tools (including employees of the Company or persons performing such processing under an agreement with the Company) are informed about the fact that they process personal data processed by the Company without the use of automation tools, the categories of personal data being processed, as well as the specifics and rules of such processing, established by the regulatory legal acts of the federal executive authorities, executive authorities of the subjects of the Russian Federation, and local legal acts of the Company.
5.8.2.4. When using standard forms of documents, the nature of the information in which presupposes or allows the inclusion of personal data in them (hereinafter referred to as the standard form), the following conditions are met:
a) the standard form or related documents (instructions for completing it, cards, registers and journals) contain information about the purpose of personal data processing carried out without the use of automation tools, the name(s) and address of the Company, last name, first name, patronymic and address of the personal data subject, the source of personal data, and the timing of personal data processing. a list of actions with personal data that will be performed during their processing, a general description of the methods of personal data processing used by the Company;
b) The standard form provides for a field in which the personal data subject can mark his consent to the processing of personal data carried out without the use of automation tools, if necessary, to obtain written consent to the processing of personal data;
c) The standard form is drawn up in such a way that each of the subjects of personal data contained in the document has the opportunity to get acquainted with their personal data contained in the document without violating the rights and legitimate interests of other subjects of personal data;
d) the standard form excludes combining fields intended for entering personal data, the purposes of processing which are obviously incompatible.
5.8.2.5. When maintaining journals (registers, books) containing personal data necessary for a single entry of a personal data subject into the territory where the Company is located or for other similar purposes, the following conditions are met:
a) the need to maintain such a journal (register, book) is provided for by an act of the Company containing information on the purpose of personal data processing carried out without the use of automation tools, methods of recording and composition of information requested from personal data subjects, a list of persons (by name or by position) who have access to material media and are responsible for maintaining and preserving the journal. (register, books), the terms of processing personal data, as well as information on the procedure for allowing a personal data subject to enter the territory where the Company is located, without confirming the authenticity of the personal data provided by the personal data subject;
b) copying of information contained in such journals (registers, books) is not allowed;
c) personal data of each personal data subject may be entered in such a journal (book, register) no more than once in each case of the personal data subject's admission to the territory where the Company is located.
5.8.2.6. If the purposes of processing personal data recorded on one physical medium are incompatible, if the physical medium does not allow processing personal data separately from other personal data recorded on the same medium, measures are taken to ensure separate processing of personal data, in particular:
a) if it is necessary to use or distribute certain personal data separately from other personal data located on the same physical medium, the personal data to be distributed or used is copied in a way that excludes simultaneous copying of personal data not subject to distribution and use, and a copy of the personal data is used (distributed);
b) if it is necessary to destroy or block part of the personal data, the material medium is destroyed or blocked with preliminary copying of information that is not subject to destruction or blocking, in a way that excludes simultaneous copying of personal data that is subject to destruction or blocking.
5.8.2.7. The destruction of a part of personal data, if permitted by a physical medium, may be carried out in a manner that excludes further processing of this personal data while preserving the possibility of processing other data recorded on a physical medium (deletion, erasure). These rules also apply if it is necessary to ensure separate processing of personal data recorded on the same physical medium and information that is not personal data.
5.8.2.8. Clarification of personal data during their processing without the use of automation tools is carried out by updating or changing data on a physical medium, and if this is not allowed by the technical features of the physical medium, by fixing information about changes made to them on the same physical medium or by manufacturing a new physical medium with updated personal data.
5.8.3. Measures to ensure the security of personal data during their processing, carried out without the use of automation tools
5.8.3.1. Personal data processing, carried out without the use of automation tools, is carried out in such a way that for each category of personal data, it is possible to determine the storage locations of personal data (physical media) and establish a list of persons who process personal data or have access to it.
5.8.3.2. Separate storage of personal data (physical media) is provided, the processing of which is carried out for various purposes.
5.8.3.3. When storing physical media, the conditions ensuring the safety of personal data and excluding unauthorized access to them are observed. The list of measures necessary to ensure such conditions, the procedure for their adoption, as well as the list of persons responsible for the implementation of these measures, are established by the Company.
5.9. Metric data processing
5.9.1. General provisions
5.9.1.1. Web analytics tools are used on the Company's websites (Table 1) in order to analyze the use of the Company's websites and improve its work.
Table 1. Web analytics tools
Website address Web analytics tools Name and address of the hosting organization owner
https://www.keysystems.ru Yandex.Metrica Rostelecom Public Joint Stock Company (Sinopskaya, 14A, ext.ter.of Smolninskoye municipal district, 191167, Saint Petersburg)
https://ksbusiness.info Yandex.Metrica Rostelecom Public Joint Stock Company (Sinopskaya, 14A, ext.ter.of Smolninskoye municipal district, 191167, Saint Petersburg)
5.9.1.2. The processing of cookies is carried out by the Company in a generalized form and is never correlated with the personal information of Users.
5.9.1.3. On the sites specified in clause 5.9.1.1, a warning is displayed informing users about the processing of metric data.
5.9.1.4. When visiting the sites specified in clause 5.9.1.1, the user consents to the Company to process the specified data using metric services to analyze the use, measure and improve the performance of the Company's website. The consent is valid from the moment it is provided and during the entire period of use of the site by User.
5.9.1.5. In case of refusal to process cookies, the User must stop using the Company's website or disable the use of cookies in the browser settings, while some functions of the Company's website may become unavailable.
5.9.1.6. The addresses of the websites are shown in Table 1.
6. Updating, correction, deletion and termination of personal data, responses to requests from subjects for access to personal data, rights of the personal data subject, duties of the operator
6.1. Rights of personal data subjects
6.1.1. The right of personal data subject to access his/her personal data
6.1.1.1. The personal data subject has the right to receive information (hereinafter referred to as the information requested by the subject) concerning the processing of his personal data, including the following:
1) confirmation of the fact of personal data processing by the Company;
2) legal grounds and purposes of personal data processing;
3) purposes and methods of personal data processing used by the Company;
4) name and location of the Company, information about persons (with the exception of employees of the Company) who have access to personal data or to whom personal data may be disclosed on the basis of an agreement with the Company or on the basis of the Federal Law;
5) processed personal data related to the respective personal data subject, the source of their receipt, unless another procedure for submitting such data is provided for by the Federal Law;
6) terms of personal data processing, including the terms of their storage;
7) the procedure for the exercise by a personal data subject of the rights provided for by the Federal Law "About Personal Data";
8) information about a cross-border data transfer that has been carried out or is expected to be carried out;
9) name or last name, first name, patronymic and address of the person who processes personal data on behalf of the Company, if the processing is or will be entrusted to such a person;
10) information on the ways in which the Company fulfills the obligations set forth in Article 18.1 of the Federal Law "About Personal Data";
11) other information provided by the Federal Law "About Personal Data" or other Federal Laws.
6.1.1.2. The personal data subject has the right to receive the information requested by the subject, except in the following cases:
– the processing of personal data, including personal data obtained as a result of operational search, counterintelligence and intelligence activities, is carried out for the purposes of national defense, state security and law enforcement;
– personal data is processed by the authorities that have detained the subject of personal data on suspicion of committing a crime or have charged the subject of personal data in a criminal case, or have applied a preventive measure to the subject of personal data prior to the indictment, except in cases provided for by the criminal procedure legislation of the Russian Federation when it is allowed to familiarize the suspect or accused with such personal data;
– personal data is processed in accordance with the legislation on countering the legalization (laundering) of proceeds from crime and financing of terrorism;
– the access of the personal data subject to his personal data violates the rights and legitimate interests of third parties;
– personal data is processed in cases stipulated by the legislation of the Russian Federation on transport security in order to ensure the stable and safe functioning of the transport complex, protect the interests of individuals, society and the state in the field of transport complex from acts of unlawful interference.
6.1.1.3. The personal data subject has the right to require the Company to clarify his personal data, block or destroy them if the personal data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated purpose of processing, as well as to take legally prescribed measures to protect his rights.
6.1.1.4. The information requested by the subject must be provided to the personal data subject by the Company in an accessible form, and it must not contain personal data related to other personal data subjects, except in cases where there are legitimate grounds for the disclosure of such personal data.
6.1.1.5. The requested information is provided to the personal data subject or his representative by the Company within ten working days from the date of the request or receipt by the Company of the request from the personal data subject or his representative. The specified period may be extended, but not for more than five working days, if the Company sends a reasoned notification to the personal data subject indicating the reasons for extending the deadline for providing the requested information. 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 personal data subject in relations with the Company (contract number, date of conclusion of the contract, conditional verbal designation and (or) other information), or information, otherwise confirming the fact of personal data processing by the Company, the signature of the personal data subject or his representative (hereinafter referred to as the information required for the request). 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. The Company provides the requested information to the personal data subject or his representative in the form in which the relevant request or request is sent, unless otherwise specified in the request or inquiry.
6.1.1.6. If the information requested by the subject, as well as the personal data being processed, has been provided to the personal data subject upon his request, the personal data subject has the right to contact the Company again or send a second request in order to receive the information requested by the subject and familiarize himself with such personal data no earlier than thirty days later (hereinafter referred to as – standardized request period) after the initial request or sending of the initial request, unless a shorter period is established by the Federal Law, a regulatory legal act adopted in accordance with it, or an agreement to which the personal data subject is a party or beneficiary or guarantor.
6.1.1.7. The personal data subject has the right to re-apply to the Company or send a repeat request in order to obtain the information requested by the subject, as well as to familiarize himself with the personal data being processed before the expiration of the normalized request period, if such information and (or) the personal data being processed have not been provided to him for review in full based on the results of the review the initial request. The repeated request, along with the information necessary for the request, must contain a justification for sending the repeated request.
6.1.1.8. The Company has the right to refuse to fulfill a repeated request to a personal data subject that does not comply with the terms of the repeated request. Such a refusal must be motivated. The obligation to provide evidence of the validity of the refusal to fulfill the repeated request lies with the Company.
6.1.2. The rights of personal data subjects when processing their personal data for the purpose of promoting goods, works, and services on the market, as well as for political campaigning purposes
6.1.2.1. The Company does not process personal data for the purpose of promoting goods, works, and services on the market through direct contacts with potential consumers via means of communication, as well as for political campaigning purposes.
6.1.3. The rights of personal data subjects when making decisions based solely on automated processing of their personal data
6.1.3.1. The Company does not make decisions based solely on automated processing of personal data that have legal consequences for the personal data subject or otherwise affect his rights and legitimate interests.
6.1.4. The right to appeal against the actions or inaction of the Company
6.1.4.1. If the personal data subject believes that the Company is processing his personal data in violation of the requirements of the Federal Law "About Personal Data" or otherwise violates his rights and freedoms, the personal data subject has the right to appeal the actions or inaction of the Company to the authorized body for the protection of the rights of personal data subjects or in court.
6.1.4.2. The personal data subject has the right to protect his rights and legitimate interests, including compensation for damages and (or) compensation for moral damage in court.
6.2. Obligations of the Company
6.2.1. Obligations of the Company in collection of personal data
6.2.1.1. When collecting personal data, the Company provides the personal data subject, upon his request, with the requested information regarding the processing of his personal data in accordance with Part 7 of Article 14 of the Federal Law "About Personal Data".
6.2.1.2. If, in accordance with the Federal Law, the provision of personal data and (or) the Company's consent to the processing of personal data is mandatory, the Company explains to the personal data subject the legal consequences of refusing to provide his personal data and (or) consent to their processing.
6.2.1.3. If personal data is not received from the personal data subject, the Company provides the following information to the personal data subject prior to the start of processing such personal data (hereinafter referred to as information provided upon receipt of personal data not from the personal data subject):
1) name or last name, first name, patronymic and address of the representative of the Company;
2) the purpose of personal data processing and its legal basis;
3) list of personal data;
4) intended users of personal data;
5) the rights of the personal data subject established by the Federal Law "About Personal Data";
6) the source of receiving personal data.
6.2.1.4. The Company does not provide the subject with information provided upon receipt of personal data not from the subject of personal data, in cases where:
1) the personal data subject has been notified about the processing of his/her personal data by the Company;
2) personal data was obtained by the Company on the basis of the Federal Law or in connection with the execution of a contract to which the personal data subject is a party or beneficiary or guarantor;
3) the processing of personal data authorized by the personal data subject for dissemination is carried out in compliance with the prohibitions and conditions provided for in Article 10.1 of the Federal Law "About Personal Data";
4) The Company processes personal data for statistical or other research purposes, for the professional activity of a journalist, or for scientific, literary or other creative activities, provided that the rights and legitimate interests of the personal data subject are not violated;
5) providing the personal data subject with information provided upon receipt of personal data not from the personal data subject violates the rights and legitimate interests of third parties.
6.2.1.5. When collecting personal data, including through the Internet information and telecommunications network, the Company 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.
6.2.1.6. The location of the data processing center(s) and information about the organization responsible for data storage are determined by the Company's internal documents.
6.2.2. Measures aimed at ensuring that the Company fulfills its obligations
6.2.2.1. The Company takes measures necessary and sufficient to ensure the fulfillment of its duties. The Company independently determines the composition and list of measures necessary and sufficient to ensure the fulfillment of duties, unless otherwise provided by the Federal Laws. Such measures include, in particular:
1) appointment of a person responsible for the organization of personal data processing;
2) the publication of Policies, local acts on the processing of personal data, as well as local acts establishing procedures aimed at preventing and detecting violations of the legislation of the Russian Federation and eliminating the consequences of such violations. Such documents and local acts may not contain provisions restricting the rights of personal data subjects, as well as imposing powers and obligations on the Company that are not provided for by the legislation of the Russian Federation;
3) application of legal, organizational and technical measures to ensure the security of personal data;
4) implementation of internal control and (or) audit of compliance of personal data processing with personal data protection requirements, Policies, and local acts of the Company;
5) assessment of the harm that may be caused to personal data subjects in case of violation of the Federal Law "About Personal Data", the ratio of this harm and the measures taken by the Company aimed at ensuring the fulfillment of obligations stipulated by the Federal Law "About Personal Data";
6) familiarization of the Company's employees who directly process personal data with the provisions of the legislation of the Russian Federation on personal data, including requirements for personal data protection, documents, Policies, local acts on personal data processing, and (or) training of these employees.
6.2.3. Measures to ensure the security of personal data during their processing
6.2.3.1. When processing personal data, the Company takes the necessary legal, organizational and technical measures or ensures their adoption to protect personal data from unlawful or accidental access to them, destruction, modification, blocking, copying, provision, dissemination of personal data, as well as from other unlawful actions in relation to personal data.
6.2.3.2. Ensuring the security of personal data is achieved, in particular:
1) identification of threats to the security of personal data during their processing in personal data information systems;
2) the application of organizational and technical measures to ensure the security of personal data during their processing in personal data information systems necessary to meet the requirements for personal data protection, the implementation of which ensures the levels of personal data security established by the Government of the Russian Federation;
3) the use of information security tools that have passed the compliance assessment procedure in accordance with the established procedure;
4) assessment of the effectiveness of measures taken to ensure the security of personal data prior to the commissioning of the personal data information system;
5) taking into account the machine storage of personal data;
6) detection of unauthorized access to personal data and taking measures;
7) recovery of personal data modified or destroyed due to unauthorized access to them;
8) establishing rules for access to personal data processed in the personal data information system, as well as ensuring registration and accounting of all actions performed with personal data in the personal data information system;
9) control over the measures taken to ensure the security of personal data and the level of security of personal data information systems.
6.2.3.3. The use and storage of biometric personal data outside of personal data information systems may be carried out only on such material media and with the use of such storage technology that ensures the protection of this data from unlawful or accidental access to them, their destruction, modification, blocking, copying, provision, dissemination.
6.2.4. The Company's obligations when contacting the personal data subject or when receiving a request from the personal data subject or his representative, as well as the authorized body for the protection of the rights of personal data subjects
6.2.4.1. In accordance with the established procedure, the Company informs the personal data subject or his representative about the availability of personal data related to the relevant personal data subject, and also provides an opportunity to get acquainted with these personal data when contacting the personal data subject or his representative, or within ten working days from the date of receipt of the request from the personal data subject or his representative. The specified period may be extended, but not for more than five working days if the Company sends a reasoned notification to the personal data subject indicating the reasons for extending the deadline for providing the requested information.
6.2.4.2. In case of refusal to provide information on the availability of personal data about the relevant personal data subject or personal data to the personal data subject or his representative, upon their request or upon receipt of a request from the personal data subject or his representative, the Company shall give a reasoned response in writing within a period not exceeding ten working days from the date of the personal data subject's request or his representative, or from the date of receipt of the request from the personal data subject or his representative. The specified period may be extended, but not for more than five working days if the Company sends a reasoned notification to the personal data subject indicating the reasons for extending the deadline for providing the requested information.
6.2.4.3. The Company provides free of charge to the personal data subject or his representative the opportunity to get acquainted with personal data related to this personal data subject. Within a period not exceeding seven business days from the date on which the personal data subject or his representative provides information confirming that the personal data is incomplete, inaccurate or outdated, the Company makes the necessary changes to them. Within a period not exceeding seven working days from the date of submission by the personal data subject or his representative of information confirming that such personal data was illegally obtained or is not necessary for the stated purpose of processing, the Company destroys such personal data. The Company notifies the personal data subject or his representative of the changes made and the measures taken, and takes reasonable measures to notify third parties to whom the personal data of this subject has been transferred.
6.2.4.4. Upon request of this body, the Company shall provide the necessary information to the authorized body for the protection of the rights of personal data subjects within ten working days from the date of receipt of such request. The specified period may be extended, but not for more than five working days, if the Company sends a reasoned notification to the authorized body for the protection of the rights of personal data subjects, indicating the reasons for extending the deadline for providing the requested information.
6.2.5. The Company's obligations to eliminate violations of the law committed during the processing of personal data, to clarify, block and destroy personal data
6.2.5.1. In case of detection of unlawful processing of personal data when contacting the personal data subject or his representative, or at the request of the personal data subject or his representative or the authorized body for the protection of the rights of personal data subjects, the Company blocks the unlawfully processed personal data related to this personal data subject, or ensures their blocking (if the processing of personal data is carried out by another person, acting on behalf of the Company) from the moment of such request or receipt of the specified request for the verification period. In case of detection of inaccurate personal data when contacting a personal data subject or his representative, or at their request or at the request of the authorized body for the protection of the rights of personal data subjects, the Company blocks personal data related to this personal data subject, or ensures their blocking (if the processing of personal data is carried out by another person acting on behalf of the Company) 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 personal data subject or third parties.
6.2.5.2. In case of confirmation of the inaccuracy of personal data, the Company, based on information provided by the personal data subject or his representative or the authorized body for the protection of the rights of personal data subjects, or other necessary documents, clarifies the personal data or ensures their clarification (if personal data is processed by another person acting on behalf of the Company) within seven working days. days from the date of submission of such information and removes the blocking of personal data.
6.2.5.3. In case of detection of unlawful processing of personal data carried out by the Company or a person acting on behalf of the Company, the Company, within a period not exceeding three working days from the date of this detection, stops the unlawful processing of personal data or ensures the termination of unlawful processing of personal data by a person acting on behalf of the Company. If it is impossible to ensure the legality of the processing of personal data, the Company, within a period not exceeding ten working days from the date of detection of the unlawful processing of personal data, destroys such personal data or ensures their destruction. The Company notifies the personal data subject or his representative about the elimination of violations or the destruction of personal data, and if the request of the personal data subject or his representative or the request of the authorized body for the protection of the rights of personal data subjects has been sent by the authorized body for the protection of the rights of personal data subjects, also the specified body.
6.2.5.4. If the fact of unlawful or accidental transfer (provision, dissemination, access) of personal data is established, which has resulted in a violation of the rights of personal data subjects, the Company, from the moment such incident is identified by the Company, the authorized body for the protection of the rights of personal data subjects or another interested person, notifies the authorized body for the protection of the rights of personal data subjects:
1) within twenty-four hours – about the incident, about the alleged causes that led to the violation of the rights of personal data subjects, and the alleged harm caused to the rights of personal data subjects, about the measures taken to eliminate the consequences of the relevant incident, as well as about the person authorized by the Company to interact with the authorized body for the protection of the rights of personal data subjects, on related to the identified incident;
2) within seventy-two hours – about the results of the internal investigation of the identified incident, as well as about the persons whose actions caused the identified incident (if any).
6.2.5.5. If the purpose of personal data processing is achieved, the Company stops processing personal data or ensures its termination (if the processing of personal data is carried out by another person acting on behalf of the Company) and destroys personal data or ensures their destruction (if the processing of personal data is carried out by another person acting on behalf of the Company) within a period not exceeding thirty days from the date of achievement of the purpose of personal data processing, unless otherwise provided by the contract to which the party, the beneficiary or guarantor of which is the personal data subject, by another agreement between the Company and the personal data subject, or if the Company is not entitled to process personal data without the consent of the personal data subject on the grounds provided for by the Federal Law "About Personal Data" or other Federal Laws.
6.2.5.6. If the personal data subject withdraws consent to the processing of his personal data, the Company stops processing them or ensures the termination of such processing (if the processing of personal data is carried out by another person acting on behalf of the Company) and if the storage of personal data is no longer required for the purposes of personal data processing, destroys the personal data or ensures their destruction (if personal data is processed by another person acting on behalf of the Company) on time, not exceeding thirty days from the date of receipt of the said withdrawal, unless otherwise provided by an agreement to which the personal data subject is a party, beneficiary or guarantor, or by another agreement between the Company and the personal data subject, or if the Company is not entitled to process personal data without the consent of the personal data subject on the grounds provided for by the Federal Law "About Personal Data " or other Federal Laws.
6.2.5.7. If a personal data subject requests the termination of personal data processing, the Company, within a period not exceeding ten working days from the date of receipt of the relevant request, terminates their processing or ensures the termination of such processing (if such processing is carried out by the person processing personal data), except for the cases provided for in paragraphs 2-11 of Part 1 Article 6, part 2 of Article 10 and Part 2 of Article 11 of the Federal Law "About Personal Data". The specified period may be extended, but not for more than five working days if the Company sends a reasoned notification to the personal data subject indicating the reasons for extending the deadline for providing the requested information.
6.2.5.8. If it is not possible to destroy personal data within the specified period, the Company blocks such personal data or ensures their blocking (if personal data is processed by another person acting on behalf of the Company) and ensures the destruction of personal data within no more than six months, unless another period is established by Federal Laws.
6.2.6. Notification of the processing (intention to process) of personal data
6.2.6.1. The Company, with the exception of cases stipulated by the Federal Law "About Personal Data", notifies the authorized body for the protection of the rights of personal data subjects of its intention to process personal data prior to the start of personal data processing.
6.2.6.2. The notification is sent in the form of a paper document or in the form of an electronic document and is signed by an authorized person. The notification contains the following information:
1) name (last name, first name, patronymic), Company address;
2) purpose of personal data processing;
3) description of measures, including information on the availability of encryption (cryptographic) tools and the names of these tools;
4) last name, first name, patronymic of the individual or name of the legal entity responsible for organizing the processing of personal data, and their contact phone numbers, postal addresses, and email addresses;
5) date of the beginning of personal data processing;
6) the term or condition of termination of personal data processing;
7) information about the presence or absence of cross-border transfer of personal data during their processing;
8) information about the location of the database of information containing personal data of citizens of the Russian Federation;
9) last name, first name, patronymic of an individual or the name of a legal entity that has access to and (or) processes personal data contained in state and municipal information systems on the basis of a contract;
10) information on ensuring the security of personal data in accordance with the requirements for the protection of personal data established by the Government of the Russian Federation.
6.2.6.3. In the event of a change in the specified information, the Company, no later than the 15th day of the month following the month in which such changes occurred, notifies the authorized body for the protection of the rights of personal data subjects of all changes that occurred during the specified period. In case of termination of personal data processing, the Company notifies the authorized body for the protection of the rights of personal data subjects within ten working days from the date of termination of personal data processing.
6.2.7. Notification of cross-border transfer of personal data
6.2.7.1. Prior to the start of cross-border transfer of personal data, the Company notifies the authorized body for the protection of the rights of personal data subjects of its intention to carry out cross-border transfer of personal data.
6.2.7.2. The notification of the cross-border transfer of personal data is sent separately from the notification of the processing (intention to process) of personal data provided for in Article 22 of the Federal Law "About Personal Data".
6.2.7.3. The notification is sent in the form of a paper document or in the form of an electronic document and is signed by an authorized person. The notification contains the following information:
1) name (last name, first name, patronymic), the Company's address, as well as the date and number of the notice of intent to process personal data previously sent by the Company in accordance with Article 22 of the Federal Law "About Personal Data";
2) name (last name, first name, patronymic) the person responsible for organizing the processing of personal data, contact phone numbers, postal addresses and email addresses;
3) the legal basis and purpose of the cross-border transfer of personal data and further processing of the transferred personal data;
4) categories and list of personal data to be transferred;
5) categories of subjects of personal data whose personal data is being transferred;
6) the list of foreign countries in territory of which the cross-border transfer of personal data is planned;
7) the date of the Company's assessment of compliance by authorities of foreign states, foreign individuals, and foreign legal entities to whom the cross-border transfer of personal data is planned, with the confidentiality of personal data and ensuring the security of personal data during their processing.
6.2.7.4. The assessment of compliance by authorities of foreign states, foreign individuals, and foreign legal entities to whom the cross-border transfer of personal data is planned with the confidentiality of personal data and ensuring the security of personal data during their processing is carried out by the Company on the basis of information requested in accordance with Part 5 of Article 12 of the Federal Law "About Personal Data".
7. Areas of responsibility
7.1. Persons responsible for the organization of personal data processing in organizations
7.1.1. The Company appoints a person responsible for the organization of personal data processing.
7.1.2. The person responsible for organizing the processing of personal data receives instructions directly from the executive body of the organization that is the operator and is accountable to it.
7.1.3. The Company provides the person responsible for organizing the processing of personal data with the necessary information.
7.1.4. The person responsible for the organization of personal data processing, in particular, performs the following functions:
1) performs internal control over compliance by the Company and the Company's employees with the legislation of the Russian Federation on personal data, including requirements for personal data protection;
2) informs the Company's employees of the provisions of the legislation of the Russian Federation on personal data, local acts on personal data processing and personal data protection requirements;
3) organizes the reception and processing of requests and requests from personal data subjects or their representatives and/or monitors the reception and processing of such requests and inquires.
7.2. Responsibility
7.2.1. Persons guilty of violating the requirements of the Federal Law "About Personal Data" are liable in accordance with the legislation of the Russian Federation.
7.2.2. Moral damage caused to a personal data subject as a result of violation of his rights, violation of the rules for processing personal data established by the Federal Law "About Personal Data", as well as requirements for the protection of personal data established in accordance with the Federal Law "About Personal Data", is subject to compensation in accordance with the legislation of the Russian Federation. Compensation for moral damage is carried out independently of compensation for property damage and losses incurred by the personal data subject.
8. Key results
When the goals are achieved, the following results are expected:
– ensuring the protection of the rights and freedoms of personal data subjects during the processing of their personal data by the Company;
– improving the overall level of information security of the Company;
– minimization of the Company's legal risks.
9. Coherent policies
There are no coherent policies.
APPENDIX No. 1
to Policy regarding the processing of personal data in Keysystems LLC
dated __ _________20__
Information about personal data processed by Keysystems LLC
List of processed personal data (PD)* PD processing methods PD processing period PD storage period
Purpose of PD processing:
maintaining personnel and accounting records
Employees of Keysystems LLC:
Other:
full name;
information about the name change;
TIN (INN);
IIAN (SNILS);
gender;
date of birth;
place of birth;
citizenship;
registration address;
date of registration at the place of residence;
residential address;
details of the identity document;
name of the authority that issued the identity document;
date of issue of the identity document;
contact phone numbers;
email address;
bank details;
validity period of the power of attorney;
information about education;
details of the education document;
qualification according to the document of education;
information about postgraduate professional education;
profession;
job title;
structural department;
place of work;
employee ID number;
details of the employment contract;
salary amount;
information about professional development;
information about professional retraining;
information contained in the orders;
information about employment and transfers to other positions;
information about foreign language proficiency;
information about annual leaves (vacations);
information about business trips;
employment record data;
information about work activity;
information about work experience;
sick leaves certificate data;
information about composition of the family;
marital status;
information about children;
information about social benefits;
information specified in the writ of execution;
information about income;
information about taxes;
information about insurance premiums;
direction of training or specialty according to the document of education;
relation to military duty and military rank;
information about awards (incentives), honorary titles;
information specified in the certificate of state registration of the civil status act;
driver's license details;
other information strictly necessary to achieve the purposes of personal data processing automated during the term of the employment contract in accordance with the regulations governing the storage of personal data
non-automated during the term of the employment contract in accordance with the regulations governing the storage of personal data
employees of organizations belonging to Keysystems Group of companies:
other:
full name;
information about the name change;
TIN (INN);
IIAN (SNILS);
date of birth;
email address;
place of birth;
gender;
citizenship;
registration address;
date of registration at the place of residence;
residential address;
contact phone numbers;
details of the identity document;
name of the authority that issued the identity document;
date of issue of the identity document;
bank details;
validity period of the power of attorney;
information about education;
education document details;
qualification according to the document of education;
information about postgraduate professional education;
profession;
job title;
structural department;
place of work;
employee ID number;
employment contract details;
salary amount;
information about professional development;
information about professional retraining;
information contained in the orders;
information about employment and transfers to other positions;
information about foreign language proficiency;
information about annual leaves (vacations);
information about business trips;
employment record data;
information about work activity;
information about work experience;
sick leaves certificate data;
information about composition of the family;
marital status;
information about children;
information about social benefits;
information specified in the writ of execution;
information about income;
information about taxes;
information about insurance premiums;
relation to military duty and military rank;
information about awards (incentives), honorary titles;
information specified in the certificate of state registration of the civil status act;
driver's license details;
other information strictly necessary to achieve the purposes of personal data processing automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
non-automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
close relatives of employees of Keysystems LLC:
other:
full name;
date of birth;
place of birth;
information specified in the certificate of state registration of a civil status act;
degree of kinship;
place of study;
year of study;
form of education;
field of study or specialty;
information specified in the writ of execution;
other information, strictly necessary to achieve the purposes of personal data processing automated during the term of the employee's employment contract in accordance with the regulations governing the storage of personal data
non-automated during the term of the employee's employment contract in accordance with the regulations governing the storage of personal data
close relatives of employees of organizations belonging to Keysystems Group of companies:
other:
full name;
date of birth;
place of birth;
information specified in the certificate of state registration of civil status act;
degree of kinship;
place of study;
year of study;
form of education;
field of study or specialty;
information specified in the writ of execution;
other information strictly necessary to achieve the purposes of personal data processing automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
non-automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
dismissed employees of Keysystems LLC:
other:
full name;
information about the name change;
TIN (INN);
IIAN (SNILS);
date of birth;
place of birth;
gender;
citizenship;
registration address;
date of registration at the place of residence;
email address;
residential address;
contact phone numbers;
details of the identity document;
name of the authority that issued the identity document;
date of issue of the identity document;
bank details;
validity period of the power of attorney;
information about education;
education document details;
qualification according to the document of education;
information about postgraduate professional education;
profession;
job title;
structural department;
place of work;
employee ID number;
employment contract details;
salary amount;
information about professional development;
information about professional retraining;
information contained in the orders;
information about employment and transfers to other positions;
information about foreign language proficiency;
information about annual leaves (vacation);
information about business trips;
employment record data;
information about employment;
work experience;
sick leaves certificate data;
the basis for termination of the employment contract (dismissal);
information about dismissal;
information about composition of the family;
marital status;
information about children;
information about social benefits;
information specified in the writ of execution;
information about income;
information about taxes;
information about insurance premiums;
date of dismissal;
direction of training or specialty according to the education document;
relation to military duty and military rank;
information about awards (incentives), honorary titles;
information specified in the certificate of state registration of civil status act;
driver's license details;
other information strictly necessary to achieve the purposes of personal data processing automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
non-automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
dismissed employees of organizations belonging to Keysystems Group of companies:
other:
full name;
information about the name change;
TIN (INN);
IIAN (SNILS);
Date of birth;
place of birth;
gender;
citizenship;
registration address;
date of registration at the place of residence;
email address;
residential address;
contact phone numbers;
identity document details;
name of the authority that issued the identity document;
date of issue of the identity document;
bank details;
validity period of the power of attorney;
information about education;
education document details;
qualification according to the education document;
information about postgraduate professional education;
profession;
job title;
structural department;
place of work;
employee ID number;
employment contract details;
salary amount;
information about professional development;
information about professional retraining;
information contained in the orders;
information about employment and transfers to other positions;
information about foreign language proficiency;
information about annual leaves (vacations);
information about business trips;
employment record data;
information about employment;
work experience;
sick leaves certificate data;
basis for termination of the employment contract (dismissal);
information about dismissal;
information about composition of the family;
marital status;
information about children;
information about social benefits;
information specified in the writ of execution;
information about income;
information about taxes;
information about insurance premiums;
date of dismissal;
direction of training or specialty according to the document of education;
relation to military duty and military rank;
information about awards (incentives), honorary titles;
information specified in the certificate of state registration of civil status act;
driver's license details;
other information strictly necessary to achieve the purposes of personal data processing automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
non-automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
close relatives of dismissed employees of Keysystems LLC:
other:
full name;
date of birth;
place of birth;
information specified in the certificate of state registration of civil status act;
degree of kinship;
place of study;
year of study;
education form;
field of study or specialty;
information specified in the writ of execution;
other information strictly necessary to achieve the purposes of personal data processing automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
non-automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
close relatives of dismissed employees of organizations belonging to Keysystems Group of companies:
other:
full name;
date of birth;
place of birth;
information specified in the certificate of state registration of civil status act;
degree of kinship;
place of study;
year of study;
education form;
field of study or specialty;
information specified in the writ of execution;
other information strictly necessary to achieve the purposes of personal data processing automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
non-automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
Purpose of PD processing:
ensuring compliance with the Labor Legislation of the Russian Federation
employees of Keysystems LLC:
special:
information about disability;
information about criminal record;
reason for working disability
other:
full name;
information about the name change;
TIN (INN);
IIAN (SNILS);
gender;
date of birth;
place of birth;
citizenship;
registration address;
date of registration at the place of residence;
residential address;
registration condition;
details of the identity document;
name of the authority that issued the identity document;
date of issue of the identity document;
contact phone numbers;
email address;
bank details;
details of the power of attorney;
validity period of the power of attorney;
information about education;
education document details;
qualification according to the document of education;
information about postgraduate professional education;
profession;
job title;
structural department;
place of work;
employee ID number;
nature, type of work;
employment contract details;
salary amount;
information about professional development;
information about professional retraining;
information contained in the orders;
information about employment and transfers to other positions;
information about foreign language proficiency;
annual leaves (vacations) data;
business trips data;
employment record data;
information about employment;
work experience;
sick leave certificate data;
information about family composition;
marital status;
information about children;
information about social benefits;
information specified in writs of execution;
information about income;
information about taxes;
information about insurance premiums;
direction of training or specialty according to educational document;
relation to military service and military rank;
information about awards (incentives), honorary titles;
information specified in the certificate of state registration of civil status act;
driver's license details;
other information strictly necessary to achieve the purposes of personal data processing automated during the term of the employment contract in accordance with the regulations governing the storage of personal data
non-automated during the term of the employment contract in accordance with the regulations governing the storage of personal data
employees of organizations belonging to Keysystems Group of companies:
special:
information about disability;
information about criminal record;
reason for working disability
other:
full name;
information about the name change;
TIN (INN);
IIAN (SNILS);
date of birth;
email address;
place of birth;
gender;
citizenship;
registration address;
date of registration at the place of residence;
residential address;
registration condition;
contact phone numbers;
details of the identity document;
name of the authority that issued the identity document;
date of issue of the identity document;
bank details;
details of the power of attorney;
validity period of the power of attorney;
education information;
education document details;
qualification according to the document of education;
information about postgraduate professional education;
profession;
job title;
structural department;
place of work;
employee ID number;
nature, type of work;
employment contract details;
salary amount;
information about professional development;
information about professional retraining;
information contained in the orders;
information about employment and transfers to other positions;
information about foreign language proficiency;
information about annual leaves (vacations);
information about business trips;
employment record data;
information about employment;
work experience;
sick leave certificate data;
information about composition of the family;
marital status;
information about children;
information about social benefits;
information specified in the writ of execution;
information about income;
information about taxes;
information about insurance premiums;
direction of training or specialty according to the document of education;
relation to military duty and military rank;
information about awards (incentives), honorary titles;
information specified in the certificate of state registration of civil status act;
driver’s license details;
other information strictly necessary to achieve the purposes of personal data processing automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
non-automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
close relatives of employees of Keysystems LLC:
other:
full name;
date of birth;
place of birth;
information specified in the certificate of state registration of civil status act;
degree of kinship;
place of study;
year of study;
form of education;
field of study or specialty;
information specified in the writ of execution;
other information strictly necessary to achieve the purposes of personal data processing
special:
disability information automated during the term of the employee’s employment contract in accordance with the regulations governing the storage of personal data
non-automated during the term of the employee’s employment contract in accordance with the regulations governing the storage of personal data
close relatives of employees of organizations belonging to Keysystems Group of companies:
other:
full name;
date of birth;
place of birth;
information specified in the certificate of state registration of civil status act;
degree of kinship;
place of study;
year of study;
form of education;
field of study or specialty;
information specified in the writ of execution;
other information strictly necessary to achieve the purposes of personal data processing
special:
disability information automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
non-automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
dismissed employees of Keysystems LLC:
special:
disability information;
information about criminal record;
reason for temporary disability
other:
full name;
information about changing the name;
TIN (INN);
IIAN (SNILS);
date of birth;
place of birth;
gender;
citizenship;
registration address;
date of registration at the place of residence;
email address;
residential address;
registration condition;
contact phone numbers;
details of the identity document;
name of the authority that issued the identity document;
date of issue of the identity document;
bank details;
details of the power of attorney;
validity period of the power of attorney;
education information;
education document details;
qualification according to the document of education;
information about postgraduate professional education;
profession;
job title;
structural department;
place of work;
employee ID number;
nature, type of work;
employment contract details;
salary amount;
information about professional development;
information about professional retraining;
information contained in the orders;
information about employment and transfers to other positions;
information about foreign language proficiency;
information about annual leaves (vacations);
information about business trips;
employment record data;
information about employment;
work experience;
sick leave certificate data;
basis for termination of the employment contract (dismissal);
information about dismissal;
information about composition of the family;
marital status;
information about children;
information about social benefits;
information specified in the writ of execution;
information about income;
information about taxes;
information about insurance premiums;
date of dismissal;
direction of training or specialty according to the document of education;
relation to military duty and military rank;
information about awards (incentives), honorary titles;
information specified in the certificate of state registration of civil status act;
driver’s license details;
other information strictly necessary to achieve the purposes of personal data processing automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
non-automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
dismissed employees of organizations belonging to Keysystems Group of companies:
special:
disability information;
information about criminal record;
reason for temporary disability
other:
full name;
information about changing the name;
TIN (INN);
IIAN (SNILS);
date of birth;
place of birth;
gender;
citizenship;
registration address;
date of registration at the place of residence;
email address;
residential address;
registration condition;
contact phone numbers;
details of the identity document;
name of the authority that issued the identity document;
date of issue of the identity document;
bank details;
details of the power of attorney;
validity period of the power of attorney;
education information;
education document details;
qualification according to the document of education;
information about postgraduate professional education;
profession;
job title;
structural department;
place of work;
employee ID number;
nature, type of work;
employment contract details;
salary amount;
information about professional development;
information about professional retraining;
information contained in the orders;
information about employment and transfers to other positions;
information about foreign language proficiency;
information about annual leaves (vacations);
information about business trips;
employment record data;
information about employment;
work experience;
sick leave certificate data;
basis for termination of the employment contract (dismissal);
information about dismissal;
information about composition of the family;
marital status;
information about children;
information about social benefits;
information specified in the writ of execution;
information about income;
information about taxes;
information about insurance premiums;
date of dismissal;
direction of training or specialty according to the document of education;
relation to military duty and military rank;
information about awards (incentives), honorary titles;
information specified in the certificate of state registration of civil status act;
driver’s license details;
other information strictly necessary to achieve the purposes of personal data processing automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
non-automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
close relatives of dismissed employees of Keysystems LLC:
other:
full name;
date of birth;
place of birth;
information specified in the certificate of state registration of civil status act;
degree of kinship;
place of study;
year of study;
form of education;
field of study or specialty;
information specified in the writ of execution;
other information strictly necessary to achieve the purposes of personal data processing
special:
disability information automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
non-automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
close relatives of dismissed employees of organizations belonging to Keysystems Group of companies:
other:
full name;
date of birth;
place of birth;
information specified in the certificate of state registration of civil status act;
degree of kinship;
place of study;
year of study;
form of education;
field of study or specialty;
information specified in the writ of execution;
other information strictly necessary to achieve the purposes of personal data processing
special:
disability information automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
non-automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
Purpose of PD processing:
ensuring compliance with the Tax Legislation of the Russian Federation
employees of Keysystems LLC:
other:
full name;
TIN (INN);
IIAN (SNILS);
gender;
date of birth;
place of birth;
citizenship;
registration address;
date of registration at the place of residence;
details of the identity document;
name of the authority that issued the identity document;
date of issue of the identity document;
information about income;
information about taxes;
information about insurance premiums;
information about deductions;
other information strictly necessary to achieve the purposes of personal data processing automated during the term of the employment contract in accordance with the regulations governing the storage of personal data
non-automated during the term of the employment contract in accordance with the regulations governing the storage of personal data
employees of organizations belonging to Keysystems Group of companies:
other:
full name;
TIN (INN);
IIAN (SNILS);
date of birth;
place of birth;
gender;
citizenship;
registration address;
date of registration at the place of residence;
details of the identity document;
name of the authority that issued the identity document;
date of issue of the identity document;
information about income;
information about taxes;
information about insurance premiums;
information about deductions;
other information strictly necessary to achieve the purposes of personal data processing automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
non-automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
close relatives of employees of Keysystems LLC:
other:
full name;
date of birth;
information specified in the certificate of state registration of civil status act;
degree of kinship;
other information strictly necessary to achieve the purposes of personal data processing automated during the term of the employee’s employment contract in accordance with the regulations governing the storage of personal data
non-automated during the term of the employee’s employment contract in accordance with the regulations governing the storage of personal data
close relatives of employees of organizations belonging to Keysystems Group of companies:
other:
full name;
date of birth;
information specified in the certificate of state registration of civil status act;
degree of kinship;
other information strictly necessary to achieve the purposes of personal data processing automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
non-automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
dismissed employees of Keysystems LLC:
other:
full name;
TIN (INN);
IIAN (SNILS);
date of birth;
place of birth;
gender;
citizenship;
registration address;
date of registration at the place of residence;
details of the identity document;
name of the authority that issued the identity document;
date of issue of the identity document;
information about income;
information about taxes;
information about insurance premiums;
information about deductions;
other information strictly necessary to achieve the purposes of personal data processing automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
non-automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
dismissed employees of organizations belonging to Keysystems Group of companies:
other:
full name;
TIN (INN);
IIAN (SNILS);
date of birth;
place of birth;
gender;
citizenship;
registration address;
date of registration at the place of residence;
details of the identity document;
name of the authority that issued the identity document;
date of issue of the identity document;
information about income;
information about taxes;
information about insurance premiums;
information about deductions;
other information strictly necessary to achieve the purposes of personal data processing automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
non-automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
close relatives of dismissed employees of Keysystems LLC:
other:
full name;
date of birth;
information specified in the certificate of state registration of civil status act;
degree of kinship;
other information strictly necessary to achieve the purposes of personal data processing automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
non-automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
close relatives of dismissed employees of organizations belonging to Keysystems Group of companies:
other:
full name;
date of birth;
information specified in the certificate of state registration of civil status act;
degree of kinship;
other information strictly necessary to achieve the purposes of personal data processing automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
non-automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
Purpose of PD processing:
ensuring compliance with Pension Legislation of the Russian Federation
employees of Keysystems LLC:
other:
full name;
IIAN (SNILS);
date of birth;
job title;
nature, type of work;
date of employment;
transfer date;
date of dismissal;
other information strictly necessary to achieve the purposes of personal data processing automated during the term of the employment contract in accordance with the regulations governing the storage of personal data
non-automated during the term of the employment contract in accordance with the regulations governing the storage of personal data
employees of organizations belonging to Keysystems Group of companies:
other:
full name;
IIAN (SNILS);
date of birth;
job title;
nature, type of work;
date of employment;
transfer date;
date of dismissal;
other information strictly necessary to achieve the purposes of personal data processing automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
non-automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
dismissed employees of Keysystems LLC:
other:
full name;
IIAN (SNILS);
date of birth;
job title;
nature, type of work;
date of employment;
transfer date;
date of dismissal;
other information strictly necessary to achieve the purposes of personal data processing automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
non-automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
dismissed employees of organizations belonging to Keysystems Group of companies:
other:
full name;
IIAN (SNILS);
date of birth;
job title;
nature, type of work;
date of employment;
transfer date;
date of dismissal;
other information strictly necessary to achieve the purposes of personal data processing automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
non-automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
Purpose of PD processing:
ensuring compliance with the Insurance Legislation of the Russian Federation
employees of Keysystems LLC:
other:
full name;
TIN (INN);
IIAN (SNILS);
date of birth;
details of the identity document;
name of the authority that issued the identity document;
date of issue of the identity document;
bank details;
work experience;
sick leave certificate data;
information specified in the certificate of state registration of civil status act;
banking details, date of issue of the certificate of state registration of civil status act;
banking details, date of issue of the certificate of state registration of civil status act;
other information strictly necessary to achieve the purposes of personal data processing
special:
reason for temporary disability automated during the term of the employment contract in accordance with the regulations governing the storage of personal data
non-automated during the term of the employment contract in accordance with the regulations governing the storage of personal data
employees of organizations belonging to Keysystems Group of companies:
other:
full name;
TIN (INN);
IIAN (SNILS);
date of birth;
details of the identity document;
name of the authority that issued the identity document;
date of issue of the identity document;
bank details;
work experience;
sick leave certificate data;
information specified in the certificate of state registration of civil status act;
banking details, date of issue of the certificate of state registration of civil status act;
banking details, date of issue of the certificate of state registration of civil status act;
other information strictly necessary to achieve the purposes of personal data processing
special:
reason for temporary disability automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
non-automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
close relatives of employees of Keysystems LLC:
other:
full name;
IIAN (SNILS);
date of birth;
information specified in the certificate of state registration of civil status act;
details of the identity document;
name of the authority that issued the identity document;
date of issue of the identity document;
place of work;
job title;
banking details, date of issue of the certificate of state registration of civil status act;
banking details, date of issue of the certificate of state registration of civil status act;
period of work at the current place of work;
other information strictly necessary to achieve the purposes of personal data processing automated during the term of the employee’s employment contract in accordance with the regulations governing the storage of personal data
non-automated during the term of the employee’s employment contract in accordance with the regulations governing the storage of personal data
close relatives of employees of organizations belonging to Keysystems Group of companies:
other:
full name;
IIAN (SNILS);
date of birth;
information specified in the certificate of state registration of civil status act;
details of the identity document;
name of the authority that issued the identity document;
date of issue of the identity document;
place of work;
job title;
banking details, date of issue of the certificate of state registration of civil status act;
banking details, date of issue of the certificate of state registration of civil status act;
period of work at the current place of work;
other information strictly necessary to achieve the purposes of personal data processing automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
non-automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
dismissed employees of Keysystems LLC:
other:
full name;
TIN (INN);
IIAN (SNILS);
date of birth;
details of the identity document;
name of the authority that issued the identity document;
date of issue of the identity document;
bank details;
work experience;
sick leave certificate data;
date of dismissal;
information specified in the certificate of state registration of civil status act;
banking details, date of issue of the certificate of state registration of civil status act;
banking details, date of issue of the certificate of state registration of civil status act;
other information strictly necessary to achieve the purposes of personal data processing
special:
reason for temporary disability automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
non-automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
dismissed employees of organizations belonging to Keysystems Group of companies:
other:
full name;
TIN (INN);
IIAN (SNILS);
date of birth;
details of the identity document;
name of the authority that issued the identity document;
date of issue of the identity document;
bank details;
work experience;
sick leave certificate data;
date of dismissal;
information specified in the certificate of state registration of civil status act;
banking details, date of issue of the certificate of state registration of civil status act;
banking details, date of issue of the certificate of state registration of civil status act;
other information strictly necessary to achieve the purposes of personal data processing
special:
reason for temporary disability automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
non-automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
close relatives of dismissed employees of Keysystems LLC:
other:
full name;
IIAN (SNILS);
date of birth;
information specified in the certificate of state registration of civil status act;
details of the identity document;
name of the authority that issued the identity document;
date of issue of the identity document;
place of work;
job title;
banking details, date of issue of the certificate of state registration of civil status act;
banking details, date of issue of the certificate of state registration of civil status act;
period of work at the current place of work;
other information strictly necessary to achieve the purposes of personal data processing automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
non-automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
close relatives of dismissed employees of organizations belonging to Keysystems Group of companies:
other:
full name;
IIAN (SNILS);
date of birth;
information specified in the certificate of state registration of civil status act;
details of the identity document;
name of the authority that issued the identity document;
date of issue of the identity document;
place of work;
job title;
banking details, date of issue of the certificate of state registration of civil status act;
banking details, date of issue of the certificate of state registration of civil status act;
period of work at the current place of work;
other information strictly necessary to achieve the purposes of personal data processing automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
non-automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
Purpose of PD processing:
organization of Voluntary Medical Insurance
employees of Keysystems LLC:
other:
full name;
date of birth;
registration address;
contact phone numbers;
job title;
place of work;
other information strictly necessary to achieve the purposes of personal data processing automated during the term of the employment contract in accordance with the regulations governing the storage of personal data
non-automated during the term of the employment contract in accordance with the regulations governing the storage of personal data
close relatives of employees of Keysystems LLC:
other:
full name;
date of birth;
information specified in the certificate of state registration of civil status act;
gender;
details of the identity document;
name of the authority that issued the identity document;
date of issue of the identity document;
residential address;
other information strictly necessary to achieve the purposes of personal data processing non-automated during the term of the employee’s employment contract in accordance with the regulations governing the storage of personal data
Purpose of PD processing:
recruitment of personnel (applicants) for vacant operator positions
individuals who are job candidates (applicants):
other:
full name;
photo;
date of birth;
gender;
information about foreign language proficiency;
education information;
residential address;
work experience;
marital status;
contact phone numbers;
email address;
place of work;
information about employment;
availability of a driver’s license;
driver’s license category;
citizenship;
other information strictly necessary to achieve the purposes of personal data processing automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
non-automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
Purpose of PD processing:
provision of introductory, industrial or pre-graduate internship on the basis of an agreement with an educational institution
students undergoing internship:
other:
full name;
TIN (INN);
IIAN (SNILS);
date of birth;
place of study;
year of study;
field of study or specialty;
details of the identity document;
name of the authority that issued the identity document;
date of issue of the identity document;
registration address;
date of registration at the place of residence;
residential address;
email address;
faculty;
dates of internship;
terms of internship;
information specified in the review of the head of the internship about the intern's work (at the end of the internship);
other information strictly necessary to achieve the purposes of personal data processing automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
non-automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
Purpose of PD processing:
organization of preliminary and periodic medical examinations for employees
employees of Keysystems LLC:
other:
full name;
gender;
date of birth;
profession;
job title;
structural department;
place of work;
medical examination report;
other information strictly necessary to achieve the purposes of personal data processing non-automated during the term of the employment contract in accordance with the regulations governing the storage of personal data
Purpose of PD processing:
implementation of the Loyalty Program
employees of Keysystems LLC:
other:
full name;
TIN (INN);
employee status;
details of the identity document;
name of the authority that issued the identity document;
date of issue of the identity document;
information about loyalty program bonus points;
job title;
employee ID number;
work experience;
date of employment;
international passport details;
name of the authority that issued the international passport;
date of issue of the international passport;
other information strictly necessary to achieve the purposes of personal data processing automated during the term of the employment contract in accordance with the regulations governing the storage of personal data
close relatives of employees of Keysystems LLC:
other:
full name;
information specified in the certificate of state registration of civil status act;
details of the identity document;
name of the authority that issued the identity document;
date of issue of the identity document;
international passport details;
name of the authority that issued the international passport;
date of issue of the international passport;
other information strictly necessary to achieve the purposes of personal data processing automated during the term of the employee’s employment contract in accordance with the regulations governing the storage of personal data
Purpose of PD processing:
provision of corporate mobile communication services
employees of Keysystems LLC:
other:
full name;
date of birth;
registration address;
details of the identity document;
name of the authority that issued the identity document;
date of issue of the identity document;
contact phone numbers;
other information strictly necessary to achieve the purposes of personal data processing automated during the term of the employment contract in accordance with the regulations governing the storage of personal data
non-automated during the term of the employment contract in accordance with the regulations governing the storage of personal data
Purpose of PD processing:
issuance and accounting of loans
employees of Keysystems LLC:
other:
full name;
TIN (INN);
IIAN (SNILS);
date of birth;
place of birth;
citizenship;
registration address;
details of the identity document;
name of the authority that issued the identity document;
date of issue of the identity document;
contact phone numbers;
bank details;
job title;
structural department;
place of work;
loan amount;
loan term;
loan interest rate;
information about loans;
information required to obtain a loan for the purchase of secondary housing and housing in a building under construction (in the case of obtaining a loan);
other information strictly necessary to achieve the purposes of personal data processing automated during the term of the loan agreement in accordance with the regulations governing the storage of personal data
non-automated during the term of the loan agreement in accordance with the regulations governing the storage of personal data
borrowers:
other:
full name;
TIN (INN);
IIAN (SNILS);
date of birth;
place of birth;
citizenship;
registration address;
contact phone numbers;
details of the identity document;
name of the authority that issued the identity document;
date of issue of the identity document;
bank details;
job title;
structural department;
place of work;
loan amount;
loan terms;
loan interest rate;
information about loans;
information required to obtain a loan for the purchase of secondary housing and housing in a building under construction (in the case of obtaining a loan);
other information strictly necessary to achieve the purposes of personal data processing automated during the term of the loan agreement in accordance with the regulations governing the storage of personal data
non-automated during the term of the loan agreement in accordance with the regulations governing the storage of personal data
Purpose of PD processing:
conclusion of targeted training contracts
individuals with whom a targeted training contract has been concluded:
other:
full name;
TIN (INN);
IIAN (SNILS);
details of the identity document;
name of the authority that issued the identity document;
date of issue of the identity document;
registration address;
residential address;
contact phone numbers;
email address;
bank account details;
place of study;
faculty;
field of study or specialty;
other information strictly necessary to achieve the purposes of personal data processing automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
non-automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
legal representatives of individuals with whom a targeted training agreement has been concluded:
other:
full name;
TIN (INN);
IIAN (SNILS);
details of the identity document;
name of the authority that issued the identity document;
date of issue of the identity document;
registration address;
residential address;
contact phone numbers;
email address;
other information strictly necessary to achieve the purposes of personal data processing automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
non-automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
Purpose of PD processing:
preparation, conclusion and execution of a civil law contract
persons who are in a civil and legal relationship with Keysystems LLC:
other:
full name;
TIN (INN);
IIAN (SNILS);
gender;
contact phone numbers;
date of birth;
email address;
place of birth;
citizenship;
registration address;
details of the identity document;
name of the authority that issued the identity document;
date of issue of the identity document;
bank details;
details of the civil law contract;
date of registration at the place of residence;
other information strictly necessary to achieve the purposes of personal data processing automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
non-automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
persons who have civil relations with organizations belonging to Keysystems Group of companies:
other:
full name;
TIN (INN);
IIAN (SNILS);
date of birth;
gender;
contact phone numbers;
place of birth;
email address;
citizenship;
registration address;
details of the identity document;
name of the authority that issued the identity document;
date of issue of the identity document;
bank details;
details of the civil law contract;
date of registration at the place of residence;
other information strictly necessary to achieve the purposes of personal data processing automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
non-automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
counterparties (representatives of counterparties and individual entrepreneurs):
other:
full name;
TIN (INN);
date of birth;
gender;
place of birth;
contact phone numbers;
email address;
bank details;
registration address;
details of the identity document;
name of the authority that issued the identity document;
date of issue of the identity document;
payment amount;
place of work;
job title;
other information strictly necessary to achieve the purposes of personal data processing automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
non-automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
Purpose of PD processing:
ensuring access to the operator's territory
employees of Keysystems LLC:
other:
full name;
photo;
job title;
employee ID number;
other information strictly necessary to achieve the purposes of personal data processing automated during the term of the employment contract in accordance with the regulations governing the storage of personal data
non-automated during the term of the employment contract in accordance with the regulations governing the storage of personal data
employees of organizations belonging to Keysystems Group of companies:
other:
full name;
photo;
job title;
employee ID number;
other information strictly necessary to achieve the purposes of personal data processing automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
non-automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
visitors:
other:
full name;
type of identity document;
other information strictly necessary to achieve the purposes of personal data processing non-automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
Purpose of PD processing:
maintaining a corporate portal
employees of Keysystems LLC:
other:
full name;
date of birth;
photo;
registration condition;
contact phone numbers;
email address;
job title;
structural department;
place of work;
employee ID number;
date of employment;
information about absences;
end term according to the registration condition;
other information strictly necessary to achieve the purposes of personal data processing automated during the term of the employment contract in accordance with the regulations governing the storage of personal data
employees of organizations belonging to Keysystems Group of companies:
other:
full name;
date of birth;
email address;
registration condition;
contact phone numbers;
photo;
job title;
structural department;
place of work;
employee ID number;
date of employment;
information about absences;
end term according to the registration condition;
other information strictly necessary to achieve the purposes of personal data processing automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
Purpose of PD processing:
software development and provision of services in the field of software supply; provision of consulting support to software users; conducting training courses; fulfilling the terms of contracts and agreements; maintaining an official website; organizing access to information about the organization's activities posted on the Internet information and telecommunications network; providing access to information about employees' birthdays posted on a video panel in the lobby of the building; implementing other statutory tasks
employees of Keysystems LLC:
other:
full name;
information about changing the name;
TIN (INN);
gender;
date of birth;
photo;
registration address;
date of employment;
details of orders;
residential address;
details of the identity document;
name of the authority that issued the identity document;
date of issue of the identity document;
contact phone numbers;
email address;
bank details;
details of the power of attorney;
validity period of the power of attorney;
education information;
job title;
structural department;
place of work;
employee ID number;
information about employment and transfers to other positions;
information about business trips;
information about employment;
other information strictly necessary to achieve the purposes of personal data processing automated during the term of the employment contract in accordance with the regulations governing the storage of personal data
employees of organizations belonging to Keysystems Group of companies:
other:
full name;
information about changing the name;
TIN (INN);
date of birth;
email address;
gender;
registration address;
details of orders;
residential address;
contact phone numbers;
details of the identity document;
name of the authority that issued the identity document;
date of issue of the identity document;
photo;
bank details;
details of the power of attorney;
validity period of the power of attorney;
education information;
job title;
structural department;
place of work;
employee ID number;
information about employment and transfers to other positions;
information about business trips;
other information strictly necessary to achieve the purposes of personal data processing automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
persons who are in a civil and legal relationship with Keysystems LLC:
other:
full name;
information about changing the name;
TIN (INN);
gender;
contact phone numbers;
date of birth;
email address;
place of work;
residential address;
structural department;
registration address;
job title;
details of the identity document;
name of the authority that issued the identity document;
date of issue of the identity document;
photo;
bank details;
details of the power of attorney;
validity period of the power of attorney;
other information strictly necessary to achieve the purposes of personal data processing automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
persons who have civil relations with organizations belonging to Keysystems Group of companies:
other:
full name;
information about changing the name;
TIN (INN);
date of birth;
gender;
contact phone numbers;
email address;
residential address;
place of work;
registration address;
structural department;
details of the identity document;
job title;
name of the authority that issued the identity document;
date of issue of the identity document;
photo;
bank details;
details of the power of attorney;
validity period of the power of attorney;
other information strictly necessary to achieve the purposes of personal data processing automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
counterparties (representatives of counterparties and individual entrepreneurs):
other:
full name;
information about changing the name;
TIN (INN);
date of birth;
gender;
place of birth;
essence of the appeal;
citizenship;
contact phone numbers;
email address;
bank details;
registration address;
details of the identity document;
name of the authority that issued the identity document;
date of issue of the identity document;
place of work;
structural department;
job title;
other information strictly necessary to achieve the purposes of personal data processing automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
non-automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
partners’ representatives:
other:
address;
full name;
information about changing the name;
TIN (INN);
date of birth;
gender;
place of birth;
citizenship;
contact phone numbers;
email address;
registration address;
details of the identity document;
name of the authority that issued the identity document;
date of issue of the identity document;
bank details;
place of work;
structural department;
job title;
other information strictly necessary to achieve the purposes of personal data processing automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
non-automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
persons to whom an electronic digital signature has been issued:
other:
full name;
TIN (INN);
IIAN (SNILS);
date of birth;
gender;
place of birth;
citizenship;
contact phone numbers;
email address;
registration address;
details of the identity document;
name of the authority that issued the identity document;
date of issue of the identity document;
place of work;
structural department;
job title;
bank details;
photo non-automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
students of the courses conducted by Keysystems LLC:
other:
full name;
contact phone numbers;
email address;
year of study;
field of study or specialty;
place of study;
other information strictly necessary to achieve the purposes of personal data processing automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
non-automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
persons taking advanced training courses:
other:
full name;
information about changing the name;
contact phone numbers;
email address;
place of work;
structural department;
job title;
education information;
other information strictly necessary to achieve the purposes of personal data processing automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
non-automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
persons who filled out the feedback form and (or) registered on the self-service portal of Keysystems website, forum users:
other:
full name;
contact phone numbers;
email address;
place of work;
structural department;
job title;
information contained in the message automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
website visitors:
other:
information collected through metric programs automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
mobile application users:
other:
full name;
photo;
contact phone numbers;
email address;
place of work;
job title automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
Purpose of PD processing:
organization of access to information about employees of Keysystems LLC, hosted in the Internet
employees of Keysystems LLC:
other:
full name;
photo;
contact phone numbers;
email address;
job title;
structural department;
place of work;
information about work experience automated during the term of the employment contract in accordance with the regulations governing the storage of personal data
Purpose of PD processing:
analysis of the behavioral characteristics of users on the website
website visitors:
other:
information collected through metric programs automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
Purpose of PD processing:
organization of access to information about the partners of Keysystems LLC, posted on the Internet
partners’ representatives:
other:
full name automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
Purpose of PD processing:
organization of access to information about employees of R.O.S.T.U. LLC, posted on the Internet
employees of R.O.S.T.U. LLC:
other:
full name;
photo;
contact phone numbers;
email address;
place of work;
job title automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
Purpose of PD processing:
establishing of feedback with User
persons who filled out the feedback form:
other:
full name;
contact phone numbers;
email address;
place of work;
job title;
region;
country;
other information contained in the request automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
Purpose of PD processing:
organization of access to information about the event speakers
Event speakers:
other:
full name;
photo;
place of work;
job title automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
Purpose of PD processing:
maintaining the self-service portal
event speakers:
other:
full name automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
users of the self-service portal:
other:
full name;
contact phone numbers;
place of work;
job title;
region automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
persons who left the appeal:
other:
last name, first name, patronymic;
region;
other information contained in the appeal automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
Purpose of PD processing:
registration in the application
mobile application users:
other:
full name;
date of birth;
city/region;
contact phone numbers;
email address;
place of work;
job title;
other information strictly necessary to achieve the purposes of personal data processing automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
Purpose of PD processing:
organization of the Marketing Department's activities
employees of Keysystems LLC:
other:
full name;
contact phone numbers;
email address;
job title;
structural department automated during the term of the employment contract in accordance with the regulations governing the storage of personal data
counterparties (representatives of counterparties and individual entrepreneurs):
other:
full name;
TIN (INN);
contact phone numbers;
email address;
place of work;
job title automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
event participants:
other:
full name;
contact phone numbers;
email address;
place of work;
job title automated in accordance with the regulatory legal acts governing the processing of personal data in accordance with the regulations governing the storage of personal data
*PD – personal data
APPENDIX No. 2
to Policy regarding the processing of personal data in Keysystems LLC
dated __ _________20__
Information about the order for the processing of personal data carried out by Keysystems LLC
Name and location of the person to whom the PD are transferred * List of PD
Purpose of receiving PD processing:
issuance of a bank card, payroll and other payments
Sberbank of Russia PJSC (Vavilova Str., 19, 117312, Moscow) employees of Keysystems LLC:
other categories of PD:
full name; date of birth; details of the identity document; name of the authority that issued the identity document; date of issue of the identity document; registration address; bank details; payment amount
Gazprombank JSC (Nametkina Str., 16, build. 1, 117420, Moscow) employees of Keysystems LLC:
other categories of PD:
full name; date of birth; details of the identity document; name of the authority that issued the identity document; date of issue of the identity document; registration address; bank details; payment amount
VTB bank JSC (Degtyarnyy Lane, 11А, 191144, Saint Petersburg) employees of Keysystems LLC:
other categories of PD:
full name; date of birth; details of the identity document; name of the authority that issued the identity document; date of issue of the identity document; registration address; bank details; payment amount
Purpose of receiving PD processing:
implementation of the voluntary health insurance program
ENERGOGARANT Insurance Joint Stock Company (Sadovnicheskaya Embankment, 23, 115035, Moscow) employees of Keysystems LLC:
other categories of PD:
full name; date of birth; place of work; details of the identity document; name of the authority that issued the identity document; date of issue of the identity document; job title; registration address; contact phone numbers
employees of organizations belonging to Keysystmes Group of companies:
other categories of PD:
full name; date of birth; details of the identity document; name of the authority that issued the identity document; date of issue of the identity document; registration address; contact phone numbers; place of work; job title
AlfaStrakhovanie JSC (Nizhegorodskaya Str., 4, office 13, 428000, Cheboksary, the Chuvash Republic) employees of Keysystems LLC:
other categories of PD:
full name; date of birth; address; contact phone numbers
Purpose of receiving PD processing:
provision of corporate mobile communication services
VimpelCom PJSC (8th of March Str., 10, build. 14, 127083, Moscow) employees of Keysystems LLC:
other categories of PD:
full name; date of birth; details of the identity document; name of the authority that issued the identity document; date of issue of the identity document; job title; registration address; contact phone numbers; IIAN (SNILS)
Purpose of receiving PD processing:
conducting preliminary and periodic medical examinations
Budgetary institution of the Chuvash Republic called Republican Narcological Dispensary of the Ministry of Health of the Chuvash Republic (Pirogova Str., 6, 428015, Cheboksary, the Chuvash Republic) employees of Keysystems LLC:
other categories of PD:
full name; date of birth; place of work; structural department; job title; gender
Budgetary institution of the Chuvash Republic called Republican Psychiatric Hospital of the Ministry of Health of the Chuvash Republic (Pirogova Str., 6, 428015, Cheboksary, the Chuvash Republic) employees of Keysystems LLC:
other categories of PD:
full name; date of birth; place of work; structural department; job title; gender
Budgetary institution of the Chuvash Republic called City Clinical Hospital No. 1 of the Ministry of Health of the Chuvash Republic (Traktotostroiteley Ave., 46, 428028, Cheboksary, the Chuvash Republic) employees of Keysystems LLC:
other categories of PD:
full name; date of birth; place of work; structural department; job title; gender
Primary trade union organization of the budgetary institution of the Chuvash Republic called First Cheboksary City Hospital named after Petr N. Osipov, Honored Doctor of the RSFSR of the Ministry of Health of the Chuvash Republic (K. Ivanova Str., 14, 428018, Cheboksary, the Chuvash Republic) employees of Keysystems LLC:
other categories of PD:
full name; date of birth; place of work; structural department; job title; gender
Purpose of receiving PD processing:
fulfillment of the terms of the loan contract
Sberbank of Russia PJSC (Vavilova Str., 19, 117312, Moscow) employees of Keysystems LLC:
other categories of PD:
full name; date of birth; details of the identity document; name of the authority that issued the identity document; date of issue of the identity document; TIN (INN); place of birth; registration address; IIAN (SNILS); bank details; loan amount
borrowers:
other categories of PD:
full name; date of birth; details of the identity document; name of the authority that issued the identity document; date of issue of the identity document; TIN (INN); place of birth; registration address; IIAN (SNILS); loan amount
Gazprombank JSC (Nametkina Str., 16, build. 1, 117420, Moscow) employees of Keysystems LLC:
other categories of PD:
full name; date of birth; details of the identity document; name of the authority that issued the identity document; date of issue of the identity document; TIN (INN); place of birth; registration address; IIAN (SNILS); bank details; loan amount
borrowers:
other categories of PD:
full name; date of birth; details of the identity document; name of the authority that issued the identity document; date of issue of the identity document; TIN (INN); place of birth; registration address; IIAN (SNILS); bank details; loan amount
VTB bank JSC (Degtyarnyy Lane, 11A, 191144, Saint Petersburg) employees of Keysystems LLC:
other categories of PD:
full name; date of birth; details of the identity document; name of the authority that issued the identity document; date of issue of the identity document; TIN (INN); place of birth; registration address; IIAN (SNILS); bank details; loan amount
borrowers:
other categories of PD:
full name; TIN (INN); IIAN (SNILS); date of birth; place of birth; details of the identity document; name of the authority that issued the identity document; date of issue of the identity document; registration address; bank details; loan amount
Purpose of receiving PD processing:
printing business cards
NN Press Printing House LLC (Mashinostroiteley driveway, 1, build. С, 428022, Cheboksary, the Chuvash Republic) employees of Keysystems LLC:
other categories of PD:
full name; contact phone numbers; email address; place of work; structural department; job title
Purpose of receiving PD processing:
booking/purchase of hotel rooms and transportation tickets for business trips
Keysystems Tour LLC (M. Gorky Ave., 18b, 428000, Cheboksary, the Chuvash Republic) employees of Keysystems LLC:
other categories of PD:
full name; gender; date of birth; details of the identity document; contact phone numbers; email address
Purpose of receiving PD processing:
administration of the official website
Rostelecom PJSC (Sinopskaya Embankment, 14A, 191167, intracity territory of a federal city of Smolninskoye Municipal District, Saint Petersburg) employees of Keysystems LLC:
other categories of PD:
full name; photo; contact phone numbers; email address; place of work; structural department; job title; information about employment record
partners’ representatives:
other categories of PD:
full name
website visitors:
other categories of PD:
information collected through metric programs
persons who filled out the feedback form:
other categories of PD:
full name; contact phone numbers; email address; place of work; job title; country; region
Purpose of receiving PD processing:
reporting to regulatory authorities
SKB Kontur Production Company JSC (Narodnaya Volya Str., 19A, 620144, Ekaterinburg, Sverdlovsk region) employees of Keysystems LLC:
other categories of PD:
full name; TIN (INN); IIAN (SNILS); gender; date of birth; citizenship; details of the identity document; name of the authority that issued the identity document; date of issue of the identity document; structural department; job title; date of employment; transfer date; date of dismissal; details of orders; information specified in the certificate of state registration of civil status act; information about income; information about taxes; information about insurance premiums; information about deductions
persons who have civil relations with Keysystems LLC:
other categories of PD:
full name; TIN (INN); IIAN (SNILS); gender; date of birth; citizenship; details of the identity document; name of the authority that issued the identity document; date of issue of the identity document
Purpose of receiving PD processing:
transfer of commission for work performed (services rendered)
Sberbank of Russia PJSC (Vavilova Str., 19, 117312, Moscow) persons who have civil relations with Keysystems LLC:
other categories of PD:
full name; bank details; payment amount
Gazprombank JSC (Nametkina Str., 16, build. 1, 117420, Moscow) persons who have civil relations with Keysystems LLC:
other categories of PD:
full name; bank details; payment amount
VTB bank JSC (Degtyarnyy Lane, 11A, 191144, Saint Petersburg) persons who have civil relations with Keysystems LLC:
other categories of PD:
full name; bank details; payment amount
Purpose of receiving PD processing:
transfer of the scholarship
Sberbank of Russia PJSC (Vavilova Str., 19, 117312, Moscow) individuals with whom a targeted training contract has been concluded:
other categories of PD:
full name; bank details; payment amount
Gazprombank JSC (Nametkina Str., 16, build. 1, 117420, Moscow) individuals with whom a targeted training contract has been concluded:
other categories of PD:
full name; bank details; payment amount
VTB bank JSC (Degtyarnyy Lane, 11A, 191144, Saint Petersburg) individuals with whom a targeted training contract has been concluded:
other categories of PD:
full name; bank details; payment amount
*PD – personal data.
APPENDIX No. 3
to Policy regarding the processing of personal data in Keysystems LLC
dated __ _________20__
Information about the cross-border transfer of personal data carried out by Keysystems LLC
Name and location of the person to whom the personal data are transferred* List of PD transferred Legal basis of cross-border transfer Methods of PD processing Actions for PD processing
Purpose of cross-border transfer of PD:
organization of business trips for employees of the Organization
Somon Air LLC (Mirzo Mastongulova Str., 40, Tajikistan, 734012, г. Dushanbe) employees of Keysystems LLC:
other categories of PD:
full name; gender; date of birth; citizenship; details of the identity document; contact phone numbers; email address; structural department; job title; international passport details - presence of consent of the subject of personal data to the processing of his/her personal data (consent of the subject of personal data to the processing of personal data) automated and
non-automated Collection, Recording, Systematization, Accumulation, Storage, Clarification (updating, changing), Extraction, Use, Transfer (provision, access), Blocking, Deletion, Termination
Nebuchadnezzar FZ LLC (103104, 103&104, First Floor, Building 14, Dubai Internet City, Dubai, United Arab Emirates) employees of Keysystems LLC:
other categories of PD:
full name; gender; date of birth; citizenship; details of the identity document; passport details; information specified in the certificate of state registration of civil status act; contact phone numbers; email address - presence of consent of the subject of personal data to the processing of his/her personal data (consent of the subject of personal data to the processing of personal data) automated and
non-automated Collection, Recording, Systematization, Accumulation, Storage, Clarification (updating, changing), Extraction, Use, Transfer (provision, access), Blocking, Deletion, Termination
Belavia JSC (Nemiga Str., 14A, 220004, Minsk, Belarus) employees of Keysystems LLC:
other categories of PD:
full name; gender; date of birth; citizenship; details of the identity document; contact phone numbers; email address; passport details; information specified in the certificate of state registration of the civil status act - presence of consent of the subject of personal data to the processing of his/her personal data (consent of the subject of personal data to the processing of personal data) automated and
non-automated Collection, Recording, Systematization, Accumulation, Storage, Clarification (updating, changing), Extraction, Use, Transfer (provision, access), Blocking, Deletion, Termination
Purpose of cross-border transfer of PD:
Organization's participation in procurement
Republican Unitary Enterprise called Information and Computing Center of the Ministry of Finance of the Republic of Belarus (Kalvaryiskaya Str., 17, 220004, Minsk, Belarus) employees of Keysystems LLC:
other categories of PD:
full name; profession; place of work; job title; education information; professional experience; other information necessary to achieve the purpose of personal data processing - presence of consent of the subject of personal data to the processing of his/her personal data (consent of the subject of personal data to the processing of personal data) automated and
non-automated Collection, Recording, Systematization, Accumulation, Storage, Clarification (updating, changing), Extraction, Use, Transfer (provision, access), Blocking, Deletion, Termination
Purpose of cross-border transfer of PD:
Organization's participation in the international investment conference
Ministry of industry and Advanced Technology (000000, Muhaisnah, Muhaisanah 2, Dubai, United Arab Emirates) employees of Keysystems LLC:
other categories of PD:
full name; contact phone numbers; email address; place of work; job title; country; photo; details of the identity document
special categories of PD:
nationality - presence of consent of the subject of personal data to the processing of his/her personal data (consent of the subject of personal data to the processing of personal data) automated and
non-automated Collection, Recording, Systematization, Accumulation, Storage, Clarification (updating, changing), Extraction, Use, Transfer (provision, access), Blocking, Deletion, Termination
*PD – personal data.
INTRODUCTION PAGE
with the Policy regarding the processing of personal data in Keysystems LLC
No. Full name Job title Date Signature