Policy for processing of personal data

This Policy for processing of personal data (hereinafter the Policy) is developed in accordance with the Federal Law "On Personal Data" of July 27, 2006 N 152-FZ with respect to all information that the operator of personal data (hereinafter referred to as the Operator) can obtain about the subject of personal data (hereinafter the User) through the website www.adelphi-recruitment.com.

 

1. GENERAL PROVISIONS

1.1. This Policy defines the procedure for processing personal data and measures to ensure the security of personal data in LLC Adelphi Recruitment in order to protect the rights and freedoms of a person and citizen in processing his personal data, including protection of privacy rights, personal and family secrets.

1.2. Use of the Site by the User means acceptance of this Policy for processing of the User's personal data.

1.3. The following terms and definitions are used in this Policy:

Operator of personal data (Operator) - [LLC "Adelphi Recruitment, 109028, Moscow, Khokhlovskiy per., 16, building 1, 4 floor, room 1-5], independently or jointly with other persons organizing and (or) carrying out the processing of personal data, as well as defining the purposes of processing personal data, the composition of personal data to be processed, the actions (operations) performed with personal data;

Personal data - any information relating to a directly or indirectly defined or determined individual (subject of personal data);

Personal data processing - any action (operation) or a set of actions (operations) performed using automation tools or without using such tools with personal data, including collection, recording, systematization, accumulation, storage, updating (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data;

Automated processing of personal data - processing of personal data by means of computer facilities;

Confidentiality of personal data is a mandatory requirement for the Operator or other person who has access to a personal data to prevent their dissemination without the consent of the subject of personal data or other legal grounds.

The subject of personal data (User) is an individual who has access to the site through the Internet and uses the site.

Distribution of personal data - actions aimed at disclosing personal data to an indeterminate circle of persons (transfer of personal data) or for acquaintance with personal data of an unlimited number of persons, including promulgation of personal data in mass media, placement in information and telecommunication networks or provision of access to personal data in any other way;

Provision of personal data - actions aimed at disclosing personal data to a certain person or a certain circle of persons;

Blocking of personal data - temporary termination of processing of personal data (except for cases when processing is necessary for specification of personal data);

Destruction of personal data - actions, as a result of which it is impossible to restore the contents of personal data in the personal data information system and (or) the result of which material data carriers of personal data are destroyed;

Depersonalization of personal data is an action, as a result of which it is impossible to determine without the use of additional information the belonging of personal data to a specific subject of personal data;

Information system of personal data - a set of personal data contained in databases, and ensuring their processing of information technology and technical means;

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

1.4. The Policy applies to all personal data of entities processed by Adelphi Recruitment LLC with the use of automation tools and without the use of such means.

1.5. Any subject of personal data must have access to this Policy.

 

2. PRINCIPLES AND TERMS OF PERSONAL DATA PROCESSING

2.1. This Policy for processing of personal data establishes the Operator's obligation not to disclose and protect the privacy of personal data that the User provides to the Operator when interacting with the site, including filling out forms on the site, sending messages to the Operator through the site or e-mail.

2.2. The operator shall process the following personal data that may be provided by the User to the Operator on the Site:

  • last name, first name, patronymic of the User.
  • gender, date and place of birth of the User, marital status.
  • User's contact phone number.
  • e-mail address
  • address of the User.
  • User’s messages.
  • user data (location information, type and version of the OS, type and version of the browser, type of device and its screen resolution, the source from which the user came to the site, from which site or by which advertisement, OS and browser language, what pages are opened and what buttons are pressed by the user; ip-address.
  • other information that the User transfers to the Operator on his own initiative, including sending messages via the site, e-mail, filling in the appropriate fields or marking in the appropriate fields in the forms posted on the Site.

2.3. Information is provided by the User at his discretion.

2.4. The company processes personal data only if at least one of the following conditions exists:

  • processing of personal data is carried out with the consent of the subject of personal data to the processing of his personal data;
  • processing of personal data is necessary to achieve the objectives stipulated by law for the implementation of the functions, powers and duties imposed by the legislation of the Russian Federation on the operator;
  • processing of personal data subject to publication or mandatory disclosure in accordance with federal law.

2.5. LLC Adelphi Recruitment has the right to transfer the User's personal data to potential employers in order to facilitate the employment of the User.

2.6. The User agrees and accepts that Adelphi Recruitment LLC reserves the right to amend the existing information about the User and / or add information necessary to assist in the employment of the User, but only after verbal or written approval of this information with the User, including approvals received as a result of the interview.

2.7. Processing by the Company of special categories of personal data relating to race, nationality, political views, religious or philosophical beliefs, health status, intimate life is allowed in cases when:

  • the subject of personal data has agreed in writing to process his personal data;
  • personal data is made publicly available by the subject of personal data;
  • processing of personal data is carried out in accordance with the legislation of the Russian Federation on counteraction against terrorism, on counteraction against corruption, on enforcement proceedings, the criminal-executive legislation of the Russian Federation;

Processing of special categories of personal data must be immediately terminated if the reasons for their processing are eliminated, unless otherwise provided by federal law.

2.8. The processing of personal data containing criminal records can be carried out by LLC Adelphi Recruitment only in cases and in the order determined in accordance with federal laws.

2.9. Information that characterizes the physiological and biological characteristics of a person on the basis of which it is possible to establish his identity - biometric personal data - can be processed by Adelphi Recruitment LLC only with the written consent provided by the User.

2.10. Transboundary transfer of personal data to the territory of foreign countries may be carried out by Adelphi Recruitment LLC only if the personal data subject gives his consent to the processing of his personal data.

 

3. RIGHTS OF THE SUBJECT OF PERSONAL DATA

3.1. The subject of personal data decides to provide his personal data and agrees to their processing freely, on his will and in his interest. Consent to the processing of personal data can be given by the subject of personal data or his representative in any possible way, unless otherwise provided by federal law.

3.2. The subject of personal data has the right to receive information concerning the processing of his personal data, if such right is not restricted in accordance with federal laws. Personal data subject has the right to require the Company to clarify their personal data, their blocking or destruction in case personal data are incomplete, outdated, inaccurate, illegally obtained or are not necessary for the stated purpose of the processing, as well as take legal measures to protect his rights.

The company must immediately stop the processing of User’s personal data for the above purposes upon requirement of the User.

 

4. PURPOSE OF USER'S PERSONAL DATA COLLECTION

4.1. The site operator can use User’s personal data for the following purposes:

  • User identification.
  • Providing User on his consent with information about the products, services, promotions, special offers, pricing information, newsletters and other information on behalf of the company's website.
  • Use of personal data for the purpose of employment of the User if he expresses such a wish.
  • Organization of the work of the site, identifying the problems that have arisen on it and their elimination.

 

5. METHODS AND TERMS OF PERSONAL DATA PROCESSING

5.1. The consent to the processing of the User's personal data is given by the User for an indefinite period and is valid until the User recalls the consent for the processing of personal data.

5.2. The processing of the User's personal data is carried out by any lawful means, including information systems for personal data with the use of the means of automation or without such means.

5.3. The personal data of the User can be transferred to the authorized bodies of the government of the Russian Federation only on the grounds and in the order established by the legislation of the Russian Federation.

5.4. In case of the loss or disclosure of personal data, the site Operator informs the User about the loss or disclosure of personal data.

5.5. The site operator takes the necessary legal, organizational and technical measures to protect the User's personal information from unauthorized or accidental access, destruction, modification, blocking, copying, distribution, as well as from other illegal actions of third parties.

  

6. OTHER PROVISIONS

6.1. Other rights and obligations of the Company as an operator of personal data are determined by the legislation of the Russian Federation in the field of personal data.

6.2. The Operator has the right to amend this Policy for processing of personal data without the consent of the User.