Privacy policy of «Info-Content» LLC

1. General provisions.

This Policy regarding the processing of personal data (hereinafter Policy) was developed in accordance with the requirements of the Federal Law of July 27, 2006 No. 152-FZ «Privacy policy» and defines the principles of processing and ensuring the security of personal data in «Info-Contentт» LLC (hereinafter also the Company).

Policy was developed taking into account requirements of the Council of Europe Convention on protection of individuals by automatic processing of personal data, the Constitution of the Russian Federation, international treaties of Russia, federal laws and other normative legal acts of the Russian Federation in field of personal data.

The purpose of this document is to inform the subjects of personal data and persons involved in processing of personal data about the observance in the Company of the fundamental principles of legality, fairness, non-redundancy, compliance of the content and volume of processed personal data with the stated purposes of processing.

Ensuring the protection of human rights and freedoms when processing their personal data, including the protection of rights to privacy, personal and family secrets, is one of the priority tasks of the Company.

Provisions of the Policy serve as the basis for elaboration of local legislation, regulating the processing of personal data of employees of the Company and other subjects of personal data.

This Policy applies to all processes of privacy policy of the Company, both with the use or not use of automatic tools, to all employees of the Company participating in such processes, as well as to the information systems of the Company used in the processing of personal data.

2. Terms and definitions.

Personal data – any information which relates directly or indirectly to a definite or identifiable individual (subject of personal data);

Personal data operator (operator)– a state authority, municipal authority, legal entity or individual, who independently or jointly organizes and (or) processes personal data with other persons, as well as determines the purposes of processing personal data, the composition of personal data, actions (operations) which are performed with personal data;

  • Personal data processing–it’s any action (operation) or a set of actions (operations) with personal data performed with use or without use of automatic tools. The processing of personal data includes:
     collection;
     recording;
     сsystematization;
     accumulation;
     storage;
     clarification (update, change);
     extraction;
     using;
     transmission (distribution, provision, access);
     depersonalization;
     blocking;
     deletion;
     destruction.

Automated processing of personal data–processing of personal data using computer technology;

Dissemination of personal data –actions directed at disclosure of personal data to an indefinite group of persons;

Provision of personal data – actions directed at disclosure of personal data to a certain person or a certain group of persons;

Blocking of personal data– temporary termination of processing of personal data (excepting cases when 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 material carriers of personal data are destroyed;

Depersonalization of personal data–actions, as a result of which it becomes impossible to determine if personal data belong to a definite subject without using additional information;

Personal data information system –set of personal data which contained in databases and ensure processing with use of information technologies and technical means that;

Cross-border transfer of personal data – transfer of personal data to the territory of a foreign state to its state authority, a foreign individual or legal entity.

Unauthorized access – is an access to information or actions in attitude to information that violate the rules for differentiation of access using standard means provided by personal data information systems.

3. Principles and purposes of processing personal data.

Company, as a personal data operator, processes personal data of company’s employees and other subjects of personal data who are not in labor relations with the Company.

Processing of personal data is carried out by the Company with regard to protect the rights and freedoms of the Company's employees and other subjects of personal data, including the protection of the right to privacy, personal and family secrets, on the basis of the following principles:

  • processing of personal data is realized in the Company on a basis of legality and fairness;
  • processing of personal data is limited to the achievement of specific, predetermined and legitimate purposes;
  • processing of personal data that is incompatible with the purposes of collecting personal data is not allowed;
  • combination of databases containing personal data, the processing of which is carried out for incompatible with each other purposes it is not allowed;
  • only personal data that meet the purposes of their processing are subject to processing;
  • content and volume of processed personal data corresponds to the stated purposes of processing. Redundancy of the processed personal data in relation to the stated purposes of their processing is not allowed;
  • accuracy of personal data is ensured when processing personal data, their sufficiency, and, if necessary, relevance in relation to the purposes of processing personal data. The company takes the necessary measures or ensures their adoption to delete or clarify incomplete or inaccurate personal data;
  • storage of personal data is carried out in a form that allows you to determine the subject of personal data, no longer than the purpose of processing personal data requires, if the personal data storage period is not established by federal law, an agreement where the party is the subject of personal data, beneficiary or guarantor;
  • processed personal data are destroyed or depersonalized after achievement of purposes or in case of no need to achieve these purposes, if nothing else is provided by federal law.

Privacy policy is processed by the Company in order to:

  • observe the Constitution of the Russian Federation, legislative and other regulatory legal acts of the Russian Federation, local regulatory acts of the Company;
  • perform functions, powers and duties imposed on the Company by the legislation of the Russian Federation, including the provision of personal data to state authorities, to the Pension Fund of the Russian Federation, to the Social Insurance Fund of the Russian Federation, to the Federal Fund of Compulsory Medical Insurance, as well as to other organs of government;
  • consider resumes and select candidates for vacant positions for further employment;
  • regulate labor relations with employees of the Company, including (training and promotion, ensuring personal safety, monitoring the quantity and quality of work performed, ensuring safety of property, assistance in obtaining benefits and compensations);
  • protect life, health or other vital interests of subjects of personal data;
  • prepare, conclude, execute and terminate contracts with counterparties;
  • ensure access and intra-facility modes at the company’s facilities;
  • form reference materials for the internal information support of the activities of the Company, its branches and representative offices, as well as subsidiaries and organizations of the company;
  • execute judicial acts, acts of other organs of government or officials who has the authority in accordance with the legislation of the Russian Federation concerning enforcement proceedings;
  • implement the rights and legal interests of the company in the framework of the activities provided by the Charter and other local regulations of the company, or third parties, or to achieve socially significant purposes;
  • fulfill obligations stipulated in contracts on the basis of which the Company is entrusted with processing of personal data;
  • keep records of clients, potential clients, their representatives (contacts) and / or other counterparties of their representatives, including potential ones.
  • 4. Legal basis for privacy policy.

Following regulations and documents are basis for the processing of personal data in the Company:

  • The Constitution of the Russian Federation;
  • Labor Code of the Russian Federation;
  • Tax Code of the Russian Federation;
  • Federal Law of April 1, 1998  № 27-FZ «On individual (personified) accounting in the compulsory pension insurance system»; Federal Law of December 6, 2001 №402-FZ «On Bookkeepin»;
  • Federal Law of December 15, 2001 № 166-FZ «On State Pension Provision in the Russian Federation»;
  • Federal Law of December 15, 2001 № 167-FZ «On Compulsory Pension Insurance in the Russian Federation»;
  • Federal Law of December 17, 2001 № 173-FZ «On Labor Pensions in the Russian Federation»;
  • Federal Law of July 24, 2009 № 212-FZ «On Insurance fees to the Pension Fund of the Russian Federation. Social Insurance Fund of the Russian Federation. Federal Compulsory Medical Insurance Fund »;
  • Contracts concluded between the Company and the subject of personal data;
  • Contracts concluded between the Company and personal data operators which contain instructions for the processing of personal data;
  • Agreements of personal data subjects to the processing of personal data.

In cases, which are not explicitly provided by the legislation of the Russian Federation, but which are corresponded to the powers of the Company, processing of personal data is carried out with consent of the subject of privacy policy.

Terms for processing personal data are determined by the Company, taking into account the established purposes, period of validity of the consent to processing of personal data, period of validity of contracts with the operators, as well as terms that are determined by Order of the Ministry of Culture of the Russian Federation of August 25, 2010 N 558.

5. Volume and categories of processed personal data, categories of privacy policy subjects

Content and volume of processed personal data must correspond to the stated processing objectives. The processed personal data should not be redundant in relation to the stated purposes.

The company processes biometric and other categories of personal data.

Biometric personal data are processed in order to ensure access and intra-facility regimes at the Company's facilities.

In accordance with the purposes of processing personal data specified in clause 3 of this Policy, the Company processes personal data of following categories of subjects:

  • employees, whose personal data is necessary in order to comply with the requirements of the labor legislation of the Russian Federation;
  • subjects who are not employees of the Company, to ensure the realization of the purposes of personal data processing referred to in paragraph 3 of the Policy;
  • applicants for vacancies;
  • individuals who leaved the Company;
  • representatives of counterparties and potential counterparties of the Company and individuals who are in agreed legal relations with the Company;
  • representatives of legal entities - clients of organizations to which the Company provides services;
  • individuals - clients and potential clients of organizations to which the Company provides services;
  • users of the https://www.voxys.ru/ website.

Privacy policy processed by the Company:

  • personal data, which are provided by an employee during employment, established by Article 65 of the Labor Code of the Russian Federation, as well as personal data received and created by the Company during the period of an employee's employment;
  • personal data received from an applicant for a vacancy;
  • personal data, which are obtained during the conclusion of civil law contracts;
  • personal data, which are obtained when issuing electronic passes to the territory of the Company;
  • personal data, which are obtained during the execution of contracts with organizations for the provision of contact center’s services;
  • technical data that is automatically transmitted by device with which the person uses our site, including the IP address, information which is stored in cookies (small data files that were sent to the user's device from the visited sites), information about browser (or other program with which site is accessed), the date and time of access to site, addresses of the requested pages and other similar information.
  • 6. Procedure and conditions for the processing of personal data.

The Company, when processing personal data, carries out the following actions with personal data: collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.

The processing of personal data is carried out in accordance with purposes predetermined and declared in the collection of personal data, as well as with powers of the Company determined by the current legislation of the Russian Federation and contractual relations with the Company.

The company processes personal data in presence of one or several following conditions:

  • processing is carried out only with the consent of the subject of personal data;
  • processing is necessary to achieve purposes provided for by law, for the implementation of functions, powers and duties assigned by the legislation of the Russian Federation to the Company;
  • processing is necessary for the conclusion, execution of a contract by a party or beneficiary, the guarantor of which is the subject of personal data, as well as processing is necessary for concluding an agreement on the initiative of the subject of personal data;
  • processing is necessary to exercise the rights and legitimate interests of the Company or third parties, as well as to achieve socially significant purposes, but the rights and freedoms of the subject of personal data should not be violated;
  • processing of personal data is carried out with request to access of the subject of personal data to an unlimited number of persons;
  • privacy policy is liable to publication or obligatory disclosure in accordance with federal law;
  • as well as it is liable to other conditions stipulated by Federal Law of July 27, 2006 № 152-FZ от 27.07.2006 «On Personal Data».

Terms for processing personal data are determined by the Company, taking into account the established processing purposes, the validity period of consent to the processing of personal data and / or agreements with operators who instructed the processing of subjects’ personal data, as well as terms that are determined by the Order of the Ministry of Culture of the Russian Federation of August 25, 2010. N 558.

Privacy policy is carried out in the following ways:

  • non-automated processing of personal data;
  • automated processing of personal data with or without transmission of the information received via information and telecommunication networks;
  • mixed processing of personal data.

The Company can carry out cross-border transfer of personal data, during its activities, but only in accordance with international treaties of the Russian Federation and Federal Law № 152-FZ of July 27, 2006 «On Personal Data».

Processing of special categories of personal data concerning race, nationality, political views, religious or philosophical beliefs, intimate life is not carried out by the Company.

Information that characterizes the physiological characteristics of a person and on the basis of these characteristics it is possible to establish his identity (biometric personal data) and information about the state of health can be processed only with the consent in written form of the subject of personal data or other grounds provided for by federal legislation.

Privacy policy of the subject can be obtained by the Company from a person who is not a subject of personal data, under terms of the Company is provided with confirmation of the existence of the reasons specified in the Federal Law № 152-FZ «On Personal Data» or other reasons provided for by federal legislation.

Employees of the Company have the right to access the privacy policy of personal data subjects in paper and electronic form in accordance with their job responsibilities.

The Company does not disclose and distribute personal data to third parties without the consent of the subject of personal data, unless otherwise provided by federal law.

The Company has the right to transfer personal data to the bodies of inquiry and investigation, also to other authorized bodies on the grounds provided for by the current legislation of the Russian Federation.

Company’s employees who have gained access to personal data, do not disclose distribute personal data to third parties without the consent of the subject of personal data, unless otherwise provided by federal law.

Info-Content LLC has the right to entrust the processing of personal data to another person with consent of subject of personal data on the basis of an agreement concluded with this person. The agreement must contain a list of actions (operations) with personal data that will be performed by the person processing personal data, purposes of processing, obligation of this person to maintain confidentiality of personal data and ensure security of personal data during their processing, as well as requirements for the protection of processed personal data in in accordance with Article 19 of the Federal Law «On Personal Data».

Conditions for termination of the processing of personal data are: achievement of the purposes of processing personal data, expiration of the consent period or withdrawal of the consent of the subject of personal data to the processing of his personal data, as well as identification of illegal processing of personal data.

Storage of personal data is carried out in a form that makes it possible to determine the subject of personal data no longer than the purpose of processing personal data requires, except for cases when storage period of personal data is not established by federal law, an agreement, in which the subject of personal data is a party, beneficiary or guarantor.

The Company undertakes to use databases located on the territory of the Russian Federation, while storing personal data, in accordance with Part 5 of Article 18 of the Federal Law "On Personal Data".

The Company creates publicly available sources of personal data, for the purpose of providing information. Information about the subject of personal data is excluded from publicly available sources of privacy policy at the request of the subject of personal data or by decision of a court or other authorized organs of government.

Following information is included in publicly available sources of personal data: Employees (full name, contact phone number, position, photo).

The Company has the right to instruct the processing of personal data to a third party with the consent of the subject of personal data and in other cases provided for by the current legislation of the Russian Federation, on the basis of an agreement concluded with this party (hereinafter the instruction). A third party processing personal data on behalf of the Company is obliged to comply with the principles and rules for processing personal data provided for by Federal Law № 152-FZ «On Personal Data»ensuring the confidentiality and security of personal data during their processing.

The processing of personal data contained in the personal data information system or extracted from such system is considered to be carried out without the use of automation tools (manual) if such actions with personal data as the use, clarification, distribution, destruction of personal data in relation to each of the subjects of personal data , are carried out with the direct participation of a person.

The Company does not make decisions on the basis of exclusively automated processing of personal data that give rise to legal consequences in relation to the subject of personal data or otherwise affect his rights and legitimate interests.

During processing, carried out without the use of automation tools, personal data are separated from other information, in particular by fixing them on separate material carriers of personal data (hereinafter the material carriers), in special sections or in the fields of forms.

When fixing personal data on the material carrier, it is not allowed to fix personal data on one tangible media, the processing purposes of which are obviously incompatible. For the processing of various categories of personal data, carried out without the use of automation tools, a separate material carrier is used for each category of personal data.

Persons who process personal data without using automated tools (including employees of the Company or persons who carry out such processing under an agreement with the Company) are informed about the fact of their privacy policy, the processing of which is carried out by the Company without using automation tools, categories of processed personal data, as well as on the features and rules for such processing established by the legislation of the Russian Federation, as well as by local legal acts of the Company.

Destruction or depersonalization of a part of personal data, if allowed by a material carrier, can be carried out in a way that excludes further processing of this personal data while preserving the possibility of processing other data recorded on a material carrier (deletion, blotting out). These rules also apply in case when it is necessary to provide separate processing of personal data recorded on one material carrier and information which is not personal data.

Clarification of personal data when processing them without using automation tools is carried out by updating or changing data on the material carrier, and if this is not allowed by the technical features of the material carrier, fixing method is used on the same material carrier information about the changes made to them or the way of making a new material carrier with clarified personal data.

The processing of personal data, 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 places where personal data (material carriers) are stored and establish a list of persons who process personal data or have access to them.

Separate storage of personal data (material carriers) is provided, the processing of which is carried out for various purposes.

During storing material carriers, conditions that ensure the safety of personal data and exclude unauthorized access to them are observed. The list of measures necessary to ensure such conditions, the procedure for their acceptance, as well as the list of persons responsible for the implementation of these measures, are established by the Company.

In some cases, the Company automatically collects certain types of information when visiting the site www.voxys.ru and / or filling out questionnaires. For these purposes, technologies such as web server logs to collect IP addresses and cookies and data for web analytics can be used.

Collection of such information enables us to improve the functional characteristics of the site, as well as evaluate the productivity of our marketing activities.

Cookies are files or pieces of information which can be stored on the device due to which persons who use our site for the first time are allowed us to recognize their data when they visit it again. Such information can be used by us to improve the content and functioning of the site, conduct marketing research, and collect statistical data.

Cookies, under any circumstances, neither personally identify the user in any way, nor do they constitute malicious software.

In many cases, web browsing software (web browser) allows cookies to be stored on the user's device by default. The user can disable cookies at any time or attune his web browser to alert you when such files are received. However, disabling cookies may limit access to some of the site's functions.

7. Updating, correcting, deleting and destroying personal data, responding to requests from subjects for access to personal data.

In case of confirmation of the fact of inaccuracy of personal data or the illegality of their processing, personal data must be updated by the Company, and processing must be stopped, correspondingly.

When purposes of processing personal data are reached, as well as in case when subject of personal data withdraws his consent, the processing shall be destroyed if:

  • otherwise is not provided for by the contract, the party of which, beneficiary or guarantor of which is the subject of personal data;
  • the Сompany has no rights to carry out processing without consent of the subject of personal data on the bases provided for by the Federal Law "On Personal Data" or other federal laws;
  • otherwise is not provided for by another agreement between the Company and the subject of personal data.

The Company is obliged to inform the subject of personal data or his representative about the processing of personal data of such a subject carried out by him at the request of the latter.

In due course, the company informs the subject of personal data or his representative information about the availability of personal data relating to relevant subject, and also provides an opportunity to familiarize himself with these personal data when the subject of personal data or his representative applies, or within thirty days from the date of receipt of subject’s or his representative’s request.

In case of refusal to provide information on the availability of personal data about the relevant subject or personal data to this subject or his representative when they apply for them or upon receipt of a request from the subject of personal data or his representative, the Company gives a reasoned response in writing form within a period not exceeding thirty days from the date of the request of the subject of personal data or his representative, or from the date of receipt of the request of the subject of personal data or his representative.

Free of charge the Company provides to the subject of personal data or his representative the opportunity to familiarize himself with the personal data relating to this subject. Within a period not exceeding seven working days from the date the subject of personal data or his representative provides information confirming that the personal data is incomplete, inaccurate or irrelevant, and the Company makes the necessary changes to them. Within a period not exceeding seven working days from the date the subject of personal data or his representative submits information confirming that such personal data is illegally obtained or is not necessary for the stated purpose of processing, and the Company destroys such personal data. The company notifies the subject of personal data or his representative about the changes made and the measures taken and takes reasonable measures to notify third parties to whom the personal data of this subject was transferred.

The Company informs authorized organ of government for the protection of the rights of subjects of personal data at the request of this organ for necessary information within thirty days from the date of receipt of such a request.

In case when unlawful processing of personal data is revealed when the subject of personal data or his representative contacts or at the request of the subject of personal data or his representative or an authorized body for the protection of the rights of subjects of personal data, the Company blocks unlawfully processed personal data relating to this subject of personal data, or provides blocking them (if processing of personal data is carried out by another person acting on behalf of the Company) from the moment of such an appeal or receipt of the specified request for the verification period. In case of revealing inaccurate personal data when the subject of personal data or his representative applies, 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 processing of personal data is carried out by another person acting on behalf of the Company) from the moment of such an appeal or receipt of the specified request for the verification period, if blocking of personal data does not violate the rights and legitimate interests of the subject of personal data or third parties.

In case of confirmation of fact of inaccuracy of personal data, the Company on the basis of information provided by the subject of personal data or his representative or the authorized body for the protection of the rights of subjects of personal data, or other necessary documents, clarifies personal data or provides their clarification (if processing of personal data is carried out by another person acting on behalf of the Company) within seven working days from the date of submission of such information, and removes blocking of personal data.

In case of revealing illegal 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 revealing, stops illegal processing of personal data or ensures the termination of the illegal 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 revealing of illegal processing of personal data, destroys such personal data or ensures their destruction. The Company notifies the subject of personal data or his representative about the elimination of violations or the destruction of personal data, and in case when appeal of the subject of personal data or his representative or the request of the authorized body for protection of rights of subjects of personal data were sent by the authorized body for the protection of the rights of subjects of personal data , the Company also notifies that specified body.

If the purpose of processing personal data 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) Of the Company) within a period not exceeding thirty days from the date of achieving the purpose of processing personal data, unless otherwise provided by an agreement to which the subject of personal data is a party, beneficiary or guarantor, another agreement between the Company and the subject of personal data, or if the Company is not entitled to carry out processing of personal data without consent of the subject of personal data on the bases provided for by the Federal Law «On Person confidential data»" or other federal laws.

If the subject of personal data withdraws consent to the processing of his personal data, the Company stops processing them or ensures that such processing is terminated (if 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 processing personal data, the Company destroys personal data or ensures their destruction (if 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 receipt of that revocation, unless otherwise provided by the contract, the party of which is the beneficiary or the guarantor under which is the subject of personal data, another agreement between the Company and the subject of personal data, or if the Company is not entitled to process personal data without the consent of the subject of personal data on the bases provided for by the Federal Law «On Person confidential data» or other federal laws.

If it is impossible to destroy personal data within the specified period, the Company blocks such personal data or ensures their blocking (if processing of personal data is carried out by another person acting on behalf of the Company) and ensures the destruction of personal data within a period of no more than six months, if another term is not established by federal laws.

8. Subjects’ rights of personal data

If personal data is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing, subject of this personal data has the right to demand clarification of his personal data from the Company, their blocking or destruction, also subject has the right to accept law measures to protect his rights.

Personal data subject has the right to receiving information as far as processing of his personal data is concerned, including following contents:

  • confirmation of fact of processing of personal data by the Company;
  • legal bases and purposes of personal data processing; the purposes and methods of processing personal data used by the Company;
  • name and location of the Company, information about persons (except 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 federal law;
  • processed personal data relating to the relevant subject of personal data, the source of their receipt, unless another procedure for submitting such data is provided for by federal law;
  • terms of processing personal data, including storage terms;
  • the procedure for the exercise by the subject of personal data of the rights provided for by the Federal Law of July 27, 2006 № 152-FZ «On Personal Data»;
  • information about performed or expected cross-border data transfer;
  • name or first name, middle name, last name and address of the person who processes personal data on behalf of the Company, if the processing is entrusted or will be entrusted to that person;
  • other information provided for by the Federal Law of July 27, 2006 № 152-FZ «On Personal Data» or other federal laws.
  • 9. Measures taken to ensure the security of personal data.

Company takes the necessary legal, organizational and technical measures or ensures their adoption to protect personal data from unauthorized or accidental access to them, destruction, alteration, blocking, copying, provision, distribution personal data, as well as from other illegal actions in relation to personal data.

Such measures include:

  • appointment of a person responsible for organizing processing of personal data;
  • providing control over compliance with the legislation of the Russian Federation on personal data, including requirements for the protection of personal data;
  • Company's employees’ familiarization with provisions of legislation of the Russian Federation on personal data, local acts on the processing of personal data, requirements for the protection of personal data;
  • publication of local acts concerning processing of personal data and local acts establishing procedures aimed at preventing and detecting violations of legislation of the Russian Federation;
  • revealing threats to the security of personal data and required level of security of personal data, when processing them in personal data information systems;
  • determination of the list of positions, upon replacement of which personal data processing is carried out;
  • training organization and conducting methodological work with the employees of the Company;
  • • application of organizational and technical measures to ensure the security of personal data during their processing in personal data information systems;
  • use of information security tools that have passed, in due course, the procedure for assessing accordance with the requirements of legislation of the Russian Federation in the field of information security;
  • • ensuring registration and accounting of actions performed with personal data;
  • accounting of material carriers of personal data and their circulation control;
  • keeping records of execution of requests from subjects of personal data;
  • privacy policy placement within the boundaries of the protected area, as well as organization of physical protection of carriers of personal data, places and means of their processing;
  • organization of access to the premises where the processing of personal data is, and / or storage of their material carriers;
  • detection of facts of unauthorized access to personal data and taking appropriate measures;
  • separation of personal data from other information processed without using automation tools, in particular by fixing them in special sections, on separate material carriers of personal data;
  • ensuring the separate storage of personal data and their material carriers, the processing of which is carried out for different purposes and which contain different categories of personal data;
  • prohibiting transfer of personal data through open communication channels, computer networks out of the controlled corporate data transmission network of the Company and the Internet without applying the measures established by the Company to ensure the security of personal data (with the exception of publicly available and (or) anonymized personal data);
  • Estimation of the effectiveness of measures applied to ensure the security of personal data.
  • 10. Final Provisions.

This Policy is an internal document of the Company, is publicly available and must be posted on the official website of the Company.

Current edition is on the page at: https: // www.voxys.ru/privacy/.

Control over the fulfillment of the requirements of this Policy is carried out by the person responsible for organizing processing of personal data.

Company's officials, who have access to personal data are responsible for failure to comply with the requirements of the rules governing the processing and protection of personal data. This responsibility is determined in accordance with the legislation of the Russian Federation and internal documents of the Company.

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