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POLICY REGARDING THE PROCESSING OF PERSONAL DATA AT IBF PKF "Akryl"

1 General Provisions
1.1 This document defines the policy of the Limited Liability Company Production and Commercial Firm "Akril" (hereinafter — the Operator) regarding the processing of personal data (hereinafter — the Policy).

1.1.1. This Policy applies to all information that the legal entity OOO PKF "Akril" (Primary State Registration Number (OGRN): 1023601312987; Taxpayer Identification Number (INN): 3628007099; registered address: 396950, Voronezh Region, Semilukskiy District, settlement of Latnaya, Komsomolskaya Street, 1) and/or its affiliates may receive about a user during their use of the site http://7color.ru/.

1.1.2. The use of the site http://7color.ru/ by a personal-data subject constitutes the unconditional consent of the personal-data subject to this Policy and to the conditions for processing their personal data set out in it; in case of disagreement with these conditions, the personal-data subject must refrain from using this resource.

1.1.3. This Policy applies only to the site http://7color.ru/. The Operator does not control and is not responsible for third-party sites to which the personal-data subject may proceed via links available on the site http://7color.ru/. On such sites, other personal information may be collected or requested from the user, and other actions may be carried out.

1.2 This Policy has been developed in accordance with the current legislation of the Russian Federation on personal data.

1.3 This Policy applies to all processes of collecting, recording, systematizing, accumulating, storing, clarifying, retrieving, using, transferring (distributing, providing, granting access to), anonymizing, blocking, deleting and destroying personal data, performed both with and without the use of automation tools.

1.4 The Policy contains information subject to disclosure in accordance with Part 1 of Article 14 of the Federal Law "On Personal Data" and is a publicly available document.

1.5 The Operator conducts its activities at the address: 396950, Voronezh Region, Semilukskiy District, settlement of Latnaya, Komsomolskaya Street, 1.

1.6 Zaytsev Oleg Anatolyevich (telephone +7 (47372) 2-27-21, e-mail: akril2010@yandex.ru) has been appointed as the person responsible for organizing the processing of personal data.
2. Key terms used in the Policy
2.1 Personal data — any information relating directly or indirectly to a defined or identifiable natural person (personal-data subject).

2.2 Operator — a state body, municipal body, legal entity or natural person who, independently or jointly with others, organizes and/or performs the processing of personal data, and who also determines the purposes of processing the personal data, the composition of personal data to be processed, and the actions (operations) performed on the personal data.

2.3 Processing of personal data — any action (operation) or set of actions (operations) performed on personal data, with or without the use of automation tools, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, granting of access), anonymization, blocking, deletion, and destruction of personal data.

2.4 Provision of personal data — actions aimed at disclosing personal data to a specific person or to a specific group of persons.

2.5 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.

2.6 Blocking of personal data — temporary cessation of personal-data processing (except in cases where processing is necessary to clarify the personal data).
3. Purposes of personal-data processing
3.1 The Operator carries out personal-data processing for the following purposes:

3.1.1 in order to perform a contract to which the personal-data subject is a party, beneficiary, or guarantor;

3.1.2 in order to conclude a contract initiated by the personal-data subject or a contract under which the personal-data subject will be a beneficiary or guarantor;

3.1.3 in order to process incoming requests from natural persons for the provision of information services;

3.1.4 in order to achieve purposes provided for by an international treaty of the Russian Federation or by law, to perform and discharge the functions, powers and duties assigned to the Operator under the legislation of the Russian Federation;

3.1.5 in order to promote the Operator's goods, work and services on the market through direct contacts with the personal-data subject by means of communication.
4. Legal grounds for the processing of personal data
4.1 The legal grounds for processing personal data are:

4.1.1 The legislation of the Russian Federation in the field of personal data, based on the Constitution of the Russian Federation and international treaties of the Russian Federation, and consisting of Federal Law No. 152-FZ of 27 July 2006 "On Personal Data" and other federal laws defining the cases and specifics of personal-data processing;

4.1.2 Consent to the processing of personal data, the terms of which are confirmed by the personal-data subject when working with the feedback form on the Operator's website;

4.1.3 Civil-law contracts that the Operator concludes with counterparties, and addenda to those contracts.
5. Categories of personal-data subjects
5.1 The categories of personal-data subjects whose personal data are processed by the Operator include:

5.1.1 Natural persons in labor or civil-law relations with the Operator;

5.1.2 Natural persons in labor or civil-law relations with the Operator's counterparties;

5.1.3 Personal-data subjects using the feedback form on the Operator's internet site http://7color.ru/.

5.2 For all categories of personal-data subjects, personal data are processed by the Operator within the framework of legal relations with the Operator governed by Part Two of the Civil Code of the Russian Federation.

5.3 For all categories of personal-data subjects, personal data are processed by the Operator with the consent of the personal-data subjects, given either in written form or through implicit (conclusive) actions on the Operator's internet site http://7color.ru/.

5.4 The Operator processes the following personal data of personal-data subjects:

5.4.1 Last name, first name, patronymic;
5.4.2 Type, series and number of the identity document;
5.4.3 Date of issue of the identity document and information about the issuing authority;
5.4.4 Year of birth;
5.4.5 Month of birth;
5.4.6 Date of birth;
5.4.7 Place of birth;
5.4.8 Address;
5.4.9 Contact telephone number;
5.4.10 Email address;
5.4.11 Taxpayer Identification Number (INN);
5.4.12 Insurance number of the individual personal account in the state pension insurance system (SNILS);
5.4.13 Position;
5.4.14 Location;
5.4.15 IP address.

5.5 The Operator may also process other personal data directly necessary to fulfill the purposes of personal-data processing.
6. Periods of processing and storing personal data
6.1 The Operator processes and stores personal data until the purposes of personal-data processing have been achieved or until the need to achieve those purposes has been lost.
7. Transfer of personal data to third parties
7.1 To achieve the purposes of personal-data processing and with the consent of personal-data subjects, the Operator provides personal data, or entrusts their processing, to the following persons:

7.1.1 state authorities;
7.1.2 natural persons in labor or civil-law relations with the Operator's counterparties;
7.1.3 natural persons in labor or civil-law relations with the Operator.

7.2 In order to fulfill contractual obligations or the requirements of federal legislation, the Operator receives personal data from the following third parties:

7.2.1 Partners or other persons, in accordance with a civil-law contract.
8. Principles of personal-data processing
8.1 Personal-data processing is carried out on the basis of the following principles:

- Personal-data processing is carried out on a lawful and fair basis;
- Personal-data processing is limited to the achievement of specific, predefined and lawful purposes. Processing of personal data incompatible with the purposes of collection is not permitted;
- The merging of databases containing personal data whose processing is carried out for purposes incompatible with each other is not permitted;
- Only such personal data as meet the purposes of their processing are subject to processing;
- The content and volume of personal data processed correspond to the stated purposes of processing. The personal data processed are not excessive in relation to the stated purposes;
- When processing personal data, the accuracy of the personal data, their sufficiency and, where necessary, their up-to-date character in relation to the stated purposes of processing, are ensured;
- Personal data are stored in a form which permits identification of the personal-data subject no longer than is required by the purposes of personal-data processing, unless the storage period for the personal data is established by federal law or by a contract to which the personal-data subject is a party, beneficiary or guarantor. The personal data processed are subject to destruction or anonymization once the purposes of processing have been achieved or in the event of loss of the need to achieve those purposes, unless federal law provides otherwise.
9. Conditions for the processing of personal data
9.1 The processing of personal data is performed in compliance with the principles and rules established by the Federal Law "On Personal Data". The processing of personal data is permitted in the following cases:

- Processing of personal data is carried out with the consent of the personal-data subject to the processing of their personal data;
- Processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, to discharge the functions, powers and duties imposed on the Operator by the legislation of the Russian Federation;
- Processing of personal data is necessary for the administration of justice or the execution of a judicial act, or an act of another body or official, subject to enforcement in accordance with the legislation of the Russian Federation on enforcement proceedings;
- Processing of personal data is necessary to perform a contract to which the personal-data subject is a party, beneficiary or guarantor, and also to conclude a contract on the initiative of the personal-data subject or a contract under which the personal-data subject will be a beneficiary or guarantor;
- Processing of personal data is necessary to protect the life, health or other vital interests of the personal-data subject, where obtaining the consent of the personal-data subject is impossible;
- Processing of personal data is necessary for the exercise of the rights and legitimate interests of the Operator or of third parties, or to achieve socially significant purposes, provided that the rights and freedoms of the personal-data subject are not thereby violated;
- Processing of personal data is carried out for statistical or other research purposes, provided that the personal data are necessarily anonymized. An exception is the processing of personal data for the purposes of promoting goods, work and services on the market through direct contacts with potential consumers by means of communication, and for purposes of political agitation;
- Processing is carried out of personal data to which access has been granted to an unlimited circle of persons by the personal-data subject or at their request (hereinafter — personal data made publicly available by the personal-data subject);
- Processing is carried out of personal data subject to publication or to mandatory disclosure in accordance with federal law.

9.2 The Operator may include personal data of subjects in publicly accessible sources of personal data, in which case the Operator obtains the subject's written consent to the processing of their personal data.

9.3 The Operator may carry out the processing of special categories of personal data relating to race, nationality and state of health; in such cases, the Operator undertakes to obtain the subject's written consent to the processing of their personal data.

9.4 Biometric personal data (information that characterizes a person's physiological and biological features, on the basis of which their identity may be established, and which is used by the operator to establish the identity of the personal-data subject) are not processed by the Operator.

9.5 The Operator does not carry out any cross-border transfer of personal data.

9.6 Decisions producing legal consequences for the personal-data subject, or otherwise affecting their rights and legitimate interests, taken solely on the basis of automated processing of personal data, are not carried out.

9.7 In the conditions governing the Operator's activities there is no prohibition on the transfer of personal data to third parties without the written consent of the personal-data subject.

9.8 Where written consent of the subject to the processing of their personal data is not required, consent may be given by the personal-data subject or their representative in any form which makes it possible to establish the fact of its receipt.

9.9 The Operator has the right to entrust the processing of personal data to another person with the consent of the personal-data subject, unless otherwise provided for by federal law, on the basis of a contract concluded with that person (hereinafter — the Operator's mandate). The Operator, in the contract, requires the person processing personal data on the Operator's behalf to comply with the principles and rules of personal-data processing established by the said Federal Law.

9.10 In the event that the Operator entrusts the processing of personal data to another person, the Operator bears responsibility before the personal-data subject for the actions of the said person. The person processing personal data on the Operator's behalf is liable to the Operator.

9.11 The Operator undertakes, and requires other persons who have obtained access to personal data, not to disclose personal data to third parties and not to distribute personal data without the consent of the personal-data subject, unless otherwise provided for by federal law.

9.12 Databases of information containing personal data of citizens of the Russian Federation are located on the territory of the Russian Federation.

10. Information on safeguarding the security of personal data
10.1 The Operator appoints a person responsible for organizing personal-data processing to carry out the duties provided for by the Federal Law "On Personal Data" and by regulatory legal acts adopted pursuant thereto.

10.2 The Operator applies a complex of legal, organizational and technical measures to ensure the security of personal data, in order to ensure the confidentiality of personal data and to protect them against unlawful actions:

10.2.1 ensures unrestricted access to the Policy, a copy of which is posted on the Operator's site at http://7color.ru/;

10.2.2 grants employees access to personal data processed in the Operator's information system, as well as to the corresponding material carriers, only for the performance of their work duties;

10.2.3 establishes rules for access to personal data processed in the Operator's information system and also ensures the registration and recording of all actions performed on them;

10.2.4 assesses the harm that may be caused to personal-data subjects in the event of a violation of the Federal Law "On Personal Data";

10.2.5 identifies threats to the security of personal data during their processing in the Operator's information system;

10.2.6 applies organizational and technical measures and uses information-security tools necessary to achieve the established level of protection of personal data;

10.2.7 detects facts of unauthorized access to personal data and takes response measures, including restoration of personal data modified or destroyed as a result of unauthorized access;

10.2.8 evaluates the effectiveness of the measures taken to ensure the security of personal data prior to commissioning the Operator's information system;

10.2.9 carries out internal control over the compliance of personal-data processing with the Federal Law "On Personal Data", with the regulatory legal acts adopted pursuant thereto, with the requirements for personal-data protection, with the Policy, with the Regulations and with other local acts, including control over the measures taken to ensure the security of personal data and their level of protection during processing in the Operator's information system.

11. Rights of personal-data subjects
11.1 The personal-data subject has the right:

11.1.1 to obtain the personal data relating to that subject and information concerning their processing;

11.1.2 to demand clarification, blocking or destruction of their personal data in the event that they are incomplete, outdated, inaccurate, unlawfully obtained, or are not necessary for the stated purpose of processing;

11.1.3 to withdraw the consent given by them to the processing of personal data — to protect their rights and legitimate interests, including to receive compensation for damages and compensation for moral harm in a court of law;

11.1.4 to appeal against the actions or inactions of the Operator to the authorized body for the protection of the rights of personal-data subjects, or in a court of law.

11.2 In order to exercise their rights and legitimate interests, personal-data subjects have the right to apply to the Operator in person or through a representative.

11.3 The request must contain the information specified in Part 3 of Article 14 of the Federal Law "On Personal Data" and must be sent to the address specified in clause 1.5 of the Policy.
12. Concluding provisions
12.1 This Policy regarding the processing of personal data may be amended unilaterally by the Operator by posting the new version on the Internet at http://7color.ru/.

12.2 In case of any discrepancy between the terms of the Policy and the provisions of a contract, the provisions of the contract shall prevail.
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