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Protection of Personal Data Policy

  

APPROVED

By Order of the General Director of ALFA ENGINEERING and CONSTRUCTION LLC No.48 dated 01.08.2022.

 

Policy regarding the processing of personal data of Alfa Engineering and Construction LLC

 

1.     GENERAL PROVISIONS

1.1.      This Personal Data Processing Policy (hereinafter referred to as the "Policy") has been developed and applied by ALFA ENGINEERING and CONSTRUCTION LLC (hereinafter referred to as the "Operator") in accordance with Federal Law No. 152 – FZ of 27.07.2006 "On Personal Data" and other regulatory acts in the field of personal data protection in force on the territory of the Russian Federation. territories of the Russian Federation.

1.2.     This Policy applies to all personal data that may be collected from individuals who visit the site www.alfaengineering.ru (hereinafter referred to as the "Personal Data Subject", "Subject") by the Operator and which can be unambiguously associated with a specific individual.

1.3.   The Regulation is a publicly available document and provides for the possibility of familiarizing any person with it. The Policy text is available to Users on the Internet at http://www.alfaengineering.ru/en/protection-of-personal-data-policy.aspx

1.4.   Thisая ПолPolicy comes into force on September 01, 2022. The policy is valid indefinitely. The Company has the right to make changes (additions) to the Policy at any time at its sole discretion, bringing such changes (additions) to the User's attention on the Site. The new version of the Policy comes into force from the moment it is posted in the corresponding section of Sitea. Continued use of the Site after the publication of the new version of the Policy means acceptance of the Policy and its terms by the User.

 

2.     TERMS AND DEFINITIONS

 

Company (Operator)

ALFA ENGINEERING and CONSTRUCTION LLC, 91 Vavilova str., Moscow, 117335, building 2, floor 2, room I II, room 1-10

Website of the Company

Internet-sait, located at www.alfaengineering.ru

User

A specific or identifiable individual who accesses the Site

Personal Data (hereinafter referred to as PD)

ЛFalse information related directly or indirectly to the User

Processing Personal data processing

Any action (operation) or a set of actions (operations) performed with or without the use of automation tools with personal data, including the collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, storage of personal data, processing of personal data directly or indirectly to the User. transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personaldata.

Provision of personal

Data Actions aimed at disclosing personal data to a certain person or a certain group of persons.

Distribution of personal

Data Actions aimed at disclosing personal data to an indefinite group of persons (transfer of personaldata) or at making personal data available to an unlimited number of persons, including publishing personal data in the mass media, posting it in information and telecommunications networks, or providing access to personal data in any other way.

 

CookiesCookies

 

are data that is automatically transmitted to the Operator during the use of the Site using the software installed on the User's device, including the IP address, geographical location, information about the browser and the type of operating system of the User's device, technical characteristics of the hardware and software used by the User, date and time of access to the Site

Deal

A civil contract between a Company and a legal entity or individual entrepreneur in whose interests the User acts, or an employment contract between the Company and the User

 

 

3.     LEGAL GROUNDS AND PURPOSES OF PERSONAL DATA PROCESSING

 

3.1. The legal basis for processing personal data of ALFA ENGINEERING and CONSTRUCTION LLC is:  

-     The Constitution of the Russian Federation;

-     The Civil Code of the Russian Federation;

-     Federal Law No. 152-FZ of 27.07.2006 "On Personal Data";

-     Federal Law of the Russian Federation No. 149-FZ of 27.07.2006 "On Information, Information Technologies and Information Protection";

-     Decree of the Government of the Russian Federation No. 1119 of 01.11.2012 "On Approval of Requirements for the Protection of Personal Data when Processing them in Personal Data Information systems";

-     Decree of the Government of the Russian Federation No. 687 of 15.09.2008 "On approval of the Regulation on the specifics of processing personal data performed without the use of automation tools";

-     FSTEC Order No. 21 of 18.02.2013 "On Approval of the Composition and Content of Organizational and technical measures to ensure the security of personal data when Processing them in Personal Data Information systems";

-     Local legal acts of the Operator.

-     Withtheconsent to the processing of personal dataprovidedby the User;

-     For personal data of citizens of the European Union (EU) using the Operator's services, as well as for personal data of citizens of other states temporarily or permanently residing in the territory of EU countries using the Operator's services in the territory of the EU, it is determined in accordance with the General Data Protection Regulation (Regulation (EU) 2016/679) of April 27, 2016 year.

3.2.      ALFA ENGINEERING and CONSTRUCTION LLC processes the User's Personal Data exclusively for the following purposes:

-     Identification of theUser on the Site, providing the User with the opportunity to fully use the Site;

-     Consideration of candidates and making a decision on the employment of applicants in ALFA ENGINEERING and CONSTRUCTION LLC;

-     Establishing and maintaining communication between the User and ALFA ENGINEERING and CONSTRUCTION LLC to obtain information about the activities of ALFA ENGINEERING and CONSTRUCTION LLC and the User for the purpose of concluding a Transaction;

-     Sending of ALFA ENGINEERING and CONSTRUCTION LLC messages to the User based on the results of the received information about the User, newsletters about the activities of ALFA ENGINEERING and CONSTRUCTION LLC, vacancies, special offers to the User's email address, by the User's phone number (User name) in the messengers "WhatsApp", "Viber", "Telegram", by means ofmailing lists, SMS-messages, as well as communication of such information to the User in oral format by phone;

-     Conclusion Of Transactions;

-     Statistical and other research based on depersonalized information provided by the User;  

3.3.         The specific amount of personal data processed for the purposes specified in clause 3.2 of the Policy is defined in section 5 of the Policy.

4.     CONDITIONS AND PROCEDURE FOR GRANTING CONSENT TO THE PROCESSING OF PERSONAL DATA BY SKILBOX

4.1.    ALFA ENGINEERING and CONSTRUCTION LLC does not check the personal data provided by the User. In this regard, ALFA ENGINEERING and CONSTRUCTION LLC assumes that when providing personal data to the Site, the User must:

-     Is a legally capable person. In case of incapacity of the person using the Site, consent to the processing of personal data is provided by the User's legal representative, who has read and accepted the conditions for processing personaldata specified in this Policy.

-     Indicates reliable information about yourself or the represented incapacitated person to the extent necessary to use the Sitea.

4.2.   The User accepts the terms of the Policy and gives ALFA ENGINEERING and CONSTRUCTION LLC informed and informed consent to the processing of their personal data under the conditions stipulated by the Policy and the Law:

4.2.1.    When entering personal data in the Application Form for employment on the Website in the "Career", sectionрасположенной, located on the Internet at the following addressу: http://www.alfaengineering.ru/ru/human-resources.aspx. The user is considered to have given consent to the processing of their personal data at the time of clicking the buttonconfirming the sending of Personal Data.

4.2.2.    When filling out the feedback form on the Site in the "Career" section, located on the Internet at http://www.alfaengineering.ru/ru/contact.aspx. The user is considered to have given consent to the processing of their personaldata entered in the fields of the feedback form, at the time of clicking the button confirming the submission of the form.

4.2.3.    Upon any visit/use of Sitea -for personaldata, which are automatically transmitted to ALFA ENGINEERING and CONSTRUCTION LLC during the use of the Sites using the software installed on the User's device (Файлы cookies). The User is considered to have given consent to the processing of their personal data at the time when they start using Sitea.

4.2.4.    When subscribing to receive informational materials from ALFA ENGINEERING and CONSTRUCTIONLLC — for personaldata, which the User provides when filling out the feedback form on the Internet to the SiteE. The user is considered to have given consent to the processing of their personaldata entered in the fields of the feedback form in order to receive information materials from ALFA ENGINEERING and CONSTRUCTION LLC at the time of clicking the button confirming the submission of the feedback form.

4.3.     By performing the actions specified in clause 4.2 of this Policy, the User gives ALFA ENGINEERING and CONSTRUCTION LLC consent to process the relevant personaldata, the list of which is specified in Section 5 of this Policy, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (provision to third parties access), depersonalization, blocking, deletion, destruction of personal data with or without the use of automation tools in accordance with the purposes specified in section 3 of this Policy.

4.4.         The consent to the processing of personal data provided by the User in accordance with this Policy ПДнis valid from the date of providing such consent and for the period necessary to achieve the purposes of processing personal data or until the User revokes this consent, unless otherwise provided for by the current legislation of the Russian Federation.

4.5.    The User's consent to the processing of personal data provided by the User in accordance with this Policy ПДнmay be revoked at any time by the User. The User can revoke the consent to the processing of personal data previously provided by ALFA ENGINEERING and CONSTRUCTION LLC согласие на обработку ПДнin one of the following ways:

-     by sending a corresponding application by mail to the address: 91 Vavilova str., building 2, floor 2, rooms I, II, room 1-10, 117335, Moscow;

-     by sending the corresponding application in the form of an electronic document to the e-mail address moscow@alfaengineering.ru@alfaengineering.ru.

4.6.       Ignorance of the terms and conditions set forth in this Policy does not constitute grounds for the User to make any claims against the Operator.

4.7.      In case of disagreement with the terms of the Policy, the User must immediately stop any use of the Site.

 

5.     VOLUME PROCESSEDX PERSONAL DATA 

 

Purpose of using personal data Volume of processed personal

data Volume of processed personaldata, including special categories of personal data:

 

Filling out the Application Form for the purposes ofreviewing candidates and making a decision on the employment of applicants on the Website in the "Career" section (clause 4.2.1)

-      Full: surname, First name, Patronymic;

-      passport or other identity card (series, number, division code, date of issue, issued by whom, date and place of birth);

-      place of birth;

-      gender;

-      date of birth;

-      citizenship;

-      marital status;

-      profession;

-      position;

-      military service;

-      criminal record;

-      driver's license;

-      information about trips abroad (countries, purpose of travel);

-      permanent registration address;

-      actual residence address;

-      phone number (home and mobile);

-      email address;

-      information about the level of education and educational institutions. institutions (if necessary for the fulfillment of obligations)

-      work experience, positions held (if necessary to fulfill obligations)

-      стаж work experience (if necessary for the performance of obligations), including the name of the previous Employer, the period of work with him, position, reasons for dismissal from the previous place of work, recommendations;

-      salary (if necessary for the performance of obligations);

-      bank details (if necessary for the performance of obligations);

-      computer skills (languages and level

-      health status;

-      photo

Filling out the feedback form on the Site in the "Career" section4.2.2)

-      Last name, First name, Patronymic;

-      phone number (home and mobile);

-      email address;

Subscription to receive information materials from ALFA ENGINEERING and CONSTRUCTION LLC»

-      Last name, First name, Patronymic;

-      phone number (home and mobile);

-      e-mail address;

Conclusion of Transactions

-      Last name, First name,Patronymic;

-      passport or other identity card (series, number, division code, date of issue, issued by whom, date and place of birth);

-      place of birth;

-      gender;

-      date of birth;

-      citizenship;

-      marital status;

-      profession;

-      position;

-      military service;

-      criminal record;

-      driver's license;

-      information about trips abroad (countries, purpose of travel);

-      permanent registration address;

-      address of actual residence;

-      phone number (home and mobile);

-      email address;

-      information about the level of education and educational institutions (if necessary for fulfillment of obligations)

-      work experience, positions held (if necessary to fulfill obligations)

-      стаж work experience (if necessary for the performance of obligations), including the name of the previous Employer, the period of work with him, position, reasons for dismissal from the previous place of work, recommendations;

-      salary (if necessary for the performance of obligations);

-      bank details (if necessary for the performance of obligations);

-      computer skills (languages and level knowledge);

-      health status;

-      photo

At any visit/use of the Site forstatistical and other research based on depersonalized information

cookiescookie

 

6.     PROCESSING OF PERSONAL DATA

6.1.         ALFA ENGINEERING and CONSTRUCTION LLC processes personal data based on the following principles:

-     legality and fair basis;

-     restrictions on the processing of personal data to achieve specific, pre-defined and legitimate goals.

-     prevent the processing of personaldata that is incompatible with the purposes of collecting personaldata.

-     avoid combining databases containing personaldata that are processed for purposes that are incompatible with each other.

-     processing only those personaldata that meet the purposes of their processing.

-     compliance of the content and volume of processed personal data with the declared processing purposes;

-     preventing the processing of personaldata that is excessive in relation to the stated purposes of their processing;

-     ensuring the accuracy, sufficiency and relevance of personal data in relation to the purposes of processing personaldata;

-     destruction or depersonalization of personal data after achieving the goals of their processing or in case of loss of the need to achieve these goals, receiving a request from Users to destroy personaldata, or receiving a revocation of consent to the processing of personaldata from the User.

6.2.    ALFA ENGINEERING and CONSTRUCTION LLC independently organizes and processes Users ' personal data, as well as determines the purposes of processing, the composition of personal datato be processed, and actions (operations) performed with personal data.

6.3.     ALFA ENGINEERING and CONSTRUCTION LLC processes Users ' personal data using databases located in the Russian Federation.

6.4.         Обработка ПДнUsers ' personal data is processed with or without automated tools.

6.5.      ALFA ENGINEERING and CONSTRUCTION LLC and other persons who have obtained access to personal data are required not to disclose or distribute personal data to third parties without the consent of the personal data subject, unless otherwise provided by federal law.

6.6.         Processing a User's personal data includes performing the following actions:: collection, recording, systematization, accumulation, storage, refinement (updating, modification), extraction, use, transfer (provision to third parties, access), depersonalization, blocking, deletion, destruction

6.7.         Storage of personal data is carried out in a form that allows you to determine the subject of personal data, no longer than the purposes of processing personal data require.

6.8.         ALFA ENGINEERING and CONSTRUCTION LLC has the right to transfer personal data in accordance with the requirements of the legislation of the Russian Federation or with the consent of the subject of PD processing to third parties solely for the purpose of issuing passes to enter the territory of ALFA ENGINEERING and CONSTRUCTION LLC or places of construction production (construction sites) for conducting interviews to fill a vacant position;  supplies of materials/equipment; to conclude Transactions and fulfill obligations under them.

6.9.    The transfer of personal data to third parties specified in clause 6.88 of the Policy is subject to the following conditions:

-     A third party processes personal data using databases on the territory of the Russian Federation;

-     A third party ensures the confidentiality of personal data when processing and using them; undertakes not to disclose or distribute ПДнUsers ' Personal Data to other persons without their consent;

-     A third party guarantees compliance with the following measures to ensure the security of personal data when processing them: use of information security tools; detection and recording of unauthorized access to personal data and taking measures to restore personaldata; restriction of access to personal data; registration and recording of actions with personal data; monitoring and evaluating the effectiveness of applied measures to ensure the security of personaldata.

-     The list of permitted methods of processing personaldata: collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (provision, access), depersonalization, blocking, deletion, destruction. Third parties are prohibited from transmitting and distributing personaldata.

 

7.     MEASURES TAKEN TO PROTECT PERSONAL DATA

 

7.1.    ALFA ENGINEERING and CONSTRUCTION LLC takesall measures necessary and sufficient to ensure that the Company fulfills the operator's obligations stipulatedby the legislation of the Russian Federation in the field of personal data, which include:

-     assign a person responsible for processing personaldata.

-     development of rules for access to personaldata, ensuring registration and accounting of all actions performed with personaldata, restricting access to personal data only for a strictly defined group of employees;

-     оestablishing internal control over compliance with the legislation of the Russian Federation and local regulations in the field of personaldata;

-     organization ofaccounting for documents containing personal data, determination of storage locations for personal data;

-     control of the facts of unauthorized access to personal data and taking measures to prevent such incidents in the future;

-     control over the measures taken to ensure the security of personal data and the level of security of personal data information systems;

-     информирование получателей informing PD recipients about the need for confidentiality;

 

8.     USER RIGHTS

8.1.         The User decides to provide their personal data and consents to their processing freely, voluntarily and in their own interest. The User agrees to the processing of personal data in accordance with the procedure specified in clause 4.2 of this Policy.

8.2.   The User has the right to receive information from ALFA ENGINEERING and CONSTRUCTION LLC regarding the processing of their personal data.

8.3.         The User has the right to send ООО «АЛЬФА ИНЖЕНЕРИНГ и КОНСТРАКШН» their requests and demands to ALFA ENGINEERING and CONSTRUCTION LLC (hereinafter referred to as the Request), including regarding the use of their personal data, as well as revoking consent to the processing of personal data. A request can be sent in the following ways:

-      by mail to the address: 91 Vavilova str., building 2, floor 2, rooms I, II, room 1-10, 117335, Moscow;

-      in the form of an electronic document to the e-mail address moscow@alfaengineering.ru. The document must be sent from the User's email address specified during registration/filling out the Questionnaire or feedback form on the Site.

 

9.     UPDATING, CORRECTING, DELETING, AND DESTROYING PERSONAL DATA

9.1.         ALFA ENGINEERING and CONSTRUCTION LLC undertakes to inform the User or his representative in accordance with the procedure provided for in Article 14 of Federal Law No. 152, information about the availability of personal data related to this User, as well as provide an opportunity to get acquainted with these personal Data when the User or his representative applies within 10 (ten) business days from the date of receipt of the User's request or its representative.

9.2.         ALFA ENGINEERING and CONSTRUCTION LLC undertakes to provide the User or his representative with the opportunity to get acquainted with the personal data related to this User free of charge.

9.3.         In case of detection of illegal processing of personal data, ALFA ENGINEERING and CONSTRUCTION LLC is obligedо to block (or ensure blocking) illegally processed personaldata related to the User and stop illegal processing of personal data within a period not exceeding three working days from the date of this detection.

9.4.  In case of detection of inaccurate personal data, ALFA ENGINEERING and CONSTRUCTION LLC is obligatedо to block (or ensure blocking)it. Personaldata related to the User, if blocking the Personal Data does not violate the rights and legitimate interests of the User or third parties. If the fact of inaccuracy of the personal data is confirmed, ALFA ENGINEERING and CONSTRUCTION LLC is obliged to clarify the personal Data within 7 (seven) business days from the date of submission of such information and remove the blocking of personal data.

9.5.        Within a period not exceeding 7 (seven) business days from the date of submission by the User or his representative of information confirming that such personal data are illegally obtained or are not necessary for the stated purpose of processing, ALFA ENGINEERING and CONSTRUCTION LLC is obliged to destroy such personal data.

9.6.   If the fact of illegal or accidental transfer (provision, distribution, access) of personal data that resulted in a violation of the rights of personal data subjects is established, the employer is obliged to notify the authorized body for the protection of the rights of personal data subjects from the moment of detection of such an incident:

-      within twenty-four hours about the incident that occurred, 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 provide information about the person authorized by the operator to interact with the authorized body for the protection of the rights of personal data subjects, on issues related to the identified incident;

-      report the results of the internal investigation of the identified incident within seventy-two hours, as well as provide information about the persons whose actions caused the identified incident (if any).

9.7.        A condition for terminating the processing of personal data may include:

-     sending a request by the personal data subject to terminate the processing of personal data;

-     achieving the purposes of personal data processing;

-     expiration of the personal data subject's consent to the processing of their personal data;

-     revocation of the personal data subject's consent to the processing of their personal data;

-     identification of illegal processing of personal data;

9.8.       If the User applies to ALFA ENGINEERING and CONSTRUCTION LLC with a request to stop processing personaldata, the latter is obliged to stop processing them or ensure the termination of such processing within a period not exceeding ten working days from the date of receipt of the relevant request, except for the cases provided forby Federal Lawом No. 152-FZ of 27.07.2006 "About personal data".

9.9.         Unless otherwise provided by the legislation of the Russian Federation:

-     if the purpose of processing personal data is achieved, ALFA ENGINEERING and CONSTRUCTION LLC is obligedto stop processing personal data or ensure its termination and destroy personal data or ensure their destruction, within a period not exceeding thirty days from the date of achieving the purpose of processing personal dataПДн;

-     if the User withdraws consent to the processing of their personal Data, ALFA ENGINEERING and CONSTRUCTION LLC is obligedto terminate the processing of personal Data or ensure its termination and destroy the Personal Data or ensure their destruction within a period not exceeding thirty days from the date of receipt of the specified revocation.

9.10.      If it is not possible to destroy personal data within the above-mentioned period, ALFA ENGINEERING and CONSTRUCTION LLC blocks such personal data or ensures their blocking and ensures the destruction of personal data within a period of no more than six months, unless another period is established by federal laws.

 

10.  CONTACT DETAILS.

 

10.1.   If you have any questions about this Policy, please send them to the following email address: moscow@alfaengineering.ru@alfaengineering.ru

10.2.    For all questions related to the processing of their personaldata, the User can contact the Company's contact email address moscow@alfaengineering.ru@alfaengineering.ru.

10.3.   The term of consideration of the request is 10 (ten) business days from the date of its receipt by the Company.

 

11.  INFORMATION ABOUT ALFA ENGINEERING AND CONSTRUCTION LLC

 

ALFA ENGINEERING AND CONSTRUCTION LLC

91 Vavilova str., bldg. 2, floor 2, pom. 117335, Moscow. I, II, com.1-10

TIN 7725616015 KPP 773601001 OGRN 1077759580799

Address: 40702810014000000911 in PJSC JSCBMetallinvestbank» , Moscow

K / s: 30101810300000000176 BIC: 044525176

OKPO 82522337

Phone / Fax: 8 (495) 797 67 62

 

 

 

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