PERSONAL DATA PROCESSING POLICY

1. General Provisions

1. This Personal Data Processing Policy (hereinafter — Policy) is developed and adopted in accordance with the requirements of Federal Law No. 152-FZ of July 27, 2006 "On Personal Data" (hereinafter — Personal Data Law) and defines the procedure for processing personal data and measures to ensure their security at LLC "Narpromservice" (hereinafter — Operator, Company).
2. The Operator sets as its most important goal and condition for carrying out its activities the observance of human and civil rights and freedoms when processing their personal data, including the protection of rights to privacy, personal and family secrets.
3. This Policy applies to all information that the Operator may obtain about visitors to the website http://narpromservice.ru.
4. The Policy is valid indefinitely until replaced by a new version.
5. The current version of the Policy is posted on the Internet at: http://narpromservice.ru/policy.

2. Basic Concepts Used in the Policy

1. Blocking of personal data — temporary cessation of processing of personal data (except for cases where processing is necessary to clarify personal data).
2. Website — a set of graphic and information materials, as well as computer programs and databases that ensure their availability on the Internet at the network address http://narpromservice.ru.
3. Personal data information system — a set of personal data contained in databases and information technologies and technical means that ensure their processing.
4. Processing of personal data — any action (operation) or set of actions (operations) performed with personal data using automation tools or without using such tools, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, blocking, deletion, destruction of personal data.
5. Personal data — any information relating to a directly or indirectly identified or identifiable natural person (personal data subject).
6. Consent of the personal data subject to the processing of personal data — voluntary, specific, informed and conscious expression of will by the personal data subject, by which he expresses his consent to the processing of personal data relating to him.
7. Personal data subject — a natural person to whom personal data relates.
8. User — any visitor to the website http://narpromservice.ru.
9. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific circle of persons.
10. Dissemination of personal data — actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or familiarization with personal data of an unlimited circle of persons, including publication of personal data in the media, placement in information and telecommunication networks or providing access to personal data in any other way.
11. Cross-border transfer of personal data — transfer of personal data to the territory of a foreign state to an authority of a foreign state, a foreign natural or foreign legal person.
12. Destruction of personal data — actions as a result of which personal data are destroyed irrevocably with the impossibility of further restoration of the content of personal data in the personal data information system and (or) material carriers of personal data are destroyed.

3. Categories of Personal Data and Purposes of Their Processing

4. Principles of Personal Data Processing

1. Processing of personal data is carried out on a lawful and fair basis.
2. Processing of personal data is limited to achieving specific, predetermined and lawful purposes. Processing of personal data incompatible with the purposes of collecting personal data is not allowed.
3. Combining databases containing personal data, the processing of which is carried out for incompatible purposes, is not allowed.
4. Only personal data that meets the purposes of their processing is subject to processing.
5. The content and volume of processed personal data correspond to the stated purposes of processing. Redundancy of processed personal data in relation to the stated purposes of their processing is not allowed.
6. When processing personal data, the accuracy of personal data, their sufficiency, and, if necessary, relevance in relation to the purposes of processing personal data is ensured. The Operator takes the necessary measures and (or) ensures their adoption to remove or clarify incomplete or inaccurate data.
7. Storage of personal data is carried out in a form that allows identifying the personal data subject, no longer than required by the purposes of processing personal data, if the storage period of personal data is not established by federal law, contract, party to which, beneficiary or guarantor for which is the personal data subject.

5. Rights and Obligations of the Operator

5.1. The Operator has the right to:

• receive from the personal data subject reliable information and (or) documents containing personal data;
• in case of withdrawal by the personal data subject of consent to the processing of personal data, as well as sending an appeal with a requirement to stop processing personal data, the Operator has the right to continue processing personal data without the consent of the personal data subject if there are grounds specified in the Personal Data Law;
• independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations provided for by the Personal Data Law and regulatory legal acts adopted in accordance with it.

5.2. The Operator is obliged to:

• provide the personal data subject with information regarding the processing of his personal data at his request;
• organize the processing of personal data in the manner established by the current legislation of the Russian Federation;
• respond to appeals and requests of personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
• report to the authorized body for the protection of the rights of personal data subjects at the request of this body the necessary information within 10 working days from the date of receipt of such a request;
• publish or otherwise ensure unlimited access to this Personal Data Processing Policy;
• take legal, organizational and technical measures to protect personal data from unlawful or accidental access to them, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other unlawful actions in relation to personal data;
• stop the transfer (distribution, provision, access) of personal data, stop processing and destroy personal data in the manner and cases provided for by the Personal Data Law;
• fulfill other obligations provided for by the Personal Data Law.

6. Rights of Personal Data Subjects

6.1. Personal data subjects have the right to:

• receive information regarding the processing of his personal data, except for cases provided for by federal laws;
• require the operator 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;
• withdraw consent to the processing of personal data;
• appeal to the authorized body for the protection of the rights of personal data subjects or in court against unlawful actions or inaction of the Operator when processing his personal data;
• exercise other rights provided for by the legislation of the Russian Federation.

6.2. To exercise their rights, the personal data subject can send an appeal to the Operator:

• by email: maletskii@elinar.ru
• by phone: +7 (495) 509-03-16
• by mail: 143322, Moscow Region, Naro-Fominsk, Atepcevo village, Kupca Alesina square, building 1, office 202

7. Conditions for Processing Personal Data

1. Processing of personal data is carried out on the basis of consent of the personal data subject to the processing of his personal data.
2. Consent to the processing of personal data is given by the personal data subject by performing conclusive actions — filling out and sending the feedback form on the website with preliminary marking in a special field of the form confirming consent to the terms of this Policy.
3. The Operator stops processing personal data in case of:
   • achieving the processing purposes;
   • expiration of the personal data subject's consent;
   • withdrawal of consent by the personal data subject;
   • detection of unlawful processing of personal data.

8. Procedure for Processing and Ensuring Security of Personal Data

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

1. The Operator ensures the safety of personal data and takes all possible measures to exclude access to personal data by unauthorized persons.
2. Only persons authorized by the Operator and familiar with this Policy and local acts on personal data processing issues are allowed to process personal data.
3. Personal data is not transferred to third parties, except for cases directly provided for by this Policy or in the presence of consent of the personal data subject.
4. When storing personal data, the Operator uses databases located on the territory of the Russian Federation.

9. Transfer of Personal Data

1. Personal data of subjects is not sold, exchanged, transferred, or provided to third parties free of charge.
2. Transfer of personal data to third parties is carried out only in cases established by the legislation of the Russian Federation, or in the presence of written consent of the personal data subject.
3. Transfer of personal data at the request of judicial and law enforcement agencies is possible in cases established by federal legislation.

10. Processing of Cookie Files and Internet Statistics

1. The Operator's website uses cookie files and similar technologies for:
   • analyzing website usage and its traffic;
   • improving website usability;
   • forming statistical reports.
2. The user can control the use of cookie files by changing their browser settings. However, some website functions may become unavailable.
3. When first visiting the website, the user is shown a notification about the use of cookie files with the ability to give or not give consent to their use.

11. Cross-border Transfer of Personal Data

1. The Operator does not carry out cross-border transfer of personal data without the consent of personal data subjects.
2. Before starting cross-border transfer of personal data, the Operator ensures compliance with the requirements of the legislation of the Russian Federation in this area.

12. Final Provisions

1. The user can get any clarifications on issues of interest regarding the processing of his personal data by contacting the Operator via email maletskii@elinar.ru.
2. Any changes to the Operator's personal data processing policy will be reflected in this document. The Policy is valid indefinitely until replaced by a new version.
3. When updating the Policy, the date of the last update will be indicated in the text. The new version of the Policy comes into force from the moment it is posted on the website, unless otherwise provided by the new version of the Policy.
4. The current version of the Policy is always available on the page at http://narpromservice.ru/policy.
5. We recommend that users regularly check the terms of this Policy for changes. Continued use of the website after making changes to this Policy means acceptance of these changes.