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Agreement on the processing of personal data

1. General provisions

1.1 This Policy defines the procedure for processing personal data and measures to ensure the security of personal data at Web Park LLC (hereinafter referred to as the Company) in order to protect human and civil rights and freedoms when processing personal data.

1.2 This Policy is a public document reflecting the Company’s system of views on the processing of information containing personal data of citizens.

1.3 The Policy is mandatory for all employees of the Company who have access to information containing personal data, as well as persons working with information belonging to the Company within the framework of concluded agreements and contracts.

1.4 The Policy applies to all personal data of subjects processed in the Company’s information system using automation tools.

1.5 The Company and other persons who have obtained access to personal data are obliged to comply with the confidentiality conditions regarding them, namely, not to disclose (provide) to third parties and not to distribute personal data without the consent of the personal data subject, unless otherwise provided by federal law.

2. Principles and conditions of personal data processing

2.1 The processing of personal data in the Company is based on the following principles:
- Legality and fair basis;
- restrictions on the processing of personal data to achieve specific, predetermined and legitimate goals;
- preventing the processing of personal data that is incompatible with the purposes of personal data collection.
- preventing the merging of databases containing personal data that are processed for purposes that are incompatible with each other;
- processing only those personal data that meet the purposes of their processing;
- compliance of the content and volume of personal data processed with the stated purposes of processing;
- preventing the processing of excessive personal data in relation to the stated purposes of their processing;
- ensuring the accuracy, sufficiency and relevance of personal data in relation to the purposes of personal data processing;
- destruction or depersonalization of personal data upon achievement of the purposes of their processing or in case of loss of the need to achieve these goals, if it is impossible for the Company to eliminate violations of personal data, unless otherwise provided by federal law.

2.2 The Company processes personal data only with the consent of the personal data subject to the processing of his personal data;

2.3 The Company does not process special categories of personal data related to race, nationality, political views, religious or philosophical beliefs, health status, or intimate life.

2.4 The Company has the right to entrust the processing of personal data to another person with the consent of the personal data subject, unless otherwise provided by federal law, on the basis of a contract concluded with this person. The person who processes personal data on behalf of the Company is obliged to comply with the principles and rules of personal data processing.

3. Rights of the personal data subject

3.1 The personal data subject decides on the provision of his personal data and agrees to their processing freely, voluntarily and in his own interest. Consent to the processing of personal data may be given by the personal data subject or his representative in any form that allows to confirm the fact of its receipt, unless otherwise established by federal law.

3.2 A personal data subject has the right to receive information regarding the processing of his/her personal data, unless such right is restricted in accordance with federal laws. The personal data subject has the right to require the Company to clarify his personal data, block or destroy them if the personal data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated purpose of processing, as well as to take legal measures to protect their rights.

3.3 The processing of personal data for the purpose of promoting goods, works, and services on the market through direct contacts with potential consumers via means of communication, as well as for political campaigning purposes, is permitted only with the prior consent of the personal data subject. The specified processing of personal data is considered to be carried out without the prior consent of the personal data subject, unless the Company proves that such consent has been obtained.

3.4 The Company is obliged to immediately stop processing his personal data for the above purposes at the request of the personal data subject.

4. Ensuring the security of personal data

4.1 The objectives of information security are to minimize the damage caused by the implementation of information security threats and to improve the business reputation and corporate culture of the Company.

4.2 Information is an important asset of the Company and its protection is the responsibility of every employee authorized to process it.

4.3 Ensuring the protection of information containing personal data is understood as maintaining its confidentiality, integrity and accessibility.

4.4 The security of personal data processed by the Company is ensured by the implementation of legal, organizational, technical and programmatic measures necessary and sufficient to meet the requirements of federal legislation in the field of personal data protection.

4.5 Access to information containing personal data is provided only to persons who need it to fulfill their official or contractual obligations to the minimum extent necessary.

4.6 For each information resource, a responsible person is identified who is responsible for providing access to it and the effective functioning of information security measures.

4.7 The Company has developed and approved a package of documents on personal data protection.

4.8 The Company annually analyzes the measures taken to protect personal data.

5. Final provisions

5.1 Other rights and obligations of the Company, as the operator of personal data, are determined by the legislation in the field of personal data.

5.2 Company officials guilty of violating the rules governing the processing and protection of personal data are personally liable in accordance with the procedure established by federal laws.

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