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1. General Provisions

Policy of Limited Liability Company "Managing Company 'Proekt'" Regarding the Processing of Personal Data and Cookie Files

1.1. This Policy of Limited Liability Company "Managing Company 'Proekt'" Regarding the Processing of Personal Data and Cookie Files (hereinafter - the "Policy") is developed in fulfillment of the requirements of Clause 2, Part 1, Article 18.1 of Federal Law No. 152-FZ dated July 27, 2006, "On Personal Data" (hereinafter - the "Personal Data Law") to ensure the protection of human and civil rights and freedoms during the processing of their personal data, including the protection of the rights to privacy, personal and family secrets.
1.2. The Policy applies to all personal data processed by Limited Liability Company "Managing Company 'Proekt'" (hereinafter - the "Operator", LLC "UK 'Proekt'").
1.3. The Policy governs relations in the field of personal data processing that arose for the Operator both before and after the approval of this Policy.
1.4. In fulfillment of the requirements of Part 2, Article 18.1 of the Personal Data Law, this Policy is published in free access on the Internet on the Operator's website.
1.5. Key terms used in the Policy:
* Personal Data - Any information relating to a directly or indirectly identified or identifiable natural person (personal data subject);
* Personal Data Operator (Operator) - A state body, municipal body, legal entity, or individual that independently or jointly with other persons organizes and/or carries out the processing of personal data, as well as determines the purposes of personal data processing, the composition of personal data to be processed, and the actions (operations) performed with personal data;
* Processing of Personal Data - Any action (operation) or set of actions (operations) performed with personal data, using automation tools or without their use. Processing of personal data includes, inter alia:
* Collection;
* Recording;
* Systematization;
* Accumulation;
* Storage;
* Clarification (updating, modification);
* Retrieval;
* Use;
* Transfer (distribution, provision, access);
* Anonymization;
* Blocking;
* Deletion;
* Destruction;
* Automated Processing of Personal Data - Processing of personal data using computer technology;
* Distribution of Personal Data - Actions aimed at disclosing personal data to an indefinite number of persons;
* Provision of Personal Data - Actions aimed at disclosing personal data to a specific person or a specific circle of persons;
* Blocking of Personal Data - Temporary cessation of the processing of personal data (except where processing is necessary to clarify personal data);
* 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 the material carriers of personal data are destroyed;
* Anonymization of Personal Data - Actions as a result of which it becomes impossible, without the use of additional information, to determine the affiliation of personal data to a specific personal data subject;
* Personal Data Information System - A set of personal data contained in databases and the information technologies and technical means ensuring their processing;
* Cookies – A text file placed by the website on the computer or other device of the personal data subject when the subject visits certain sections of the Operator's website and/or uses certain functions of the Operator's website.
1.6. Key Rights and Obligations of the Operator.
1.6.1. The Operator has the right to:
* Independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations stipulated by the Personal Data Law and the regulatory legal acts adopted in accordance therewith, unless otherwise provided by the Personal Data Law or other federal laws;
* Entrust the processing of personal data to another person with the consent of the personal data subject, unless otherwise provided by federal law, based on an agreement concluded with that person. The person processing personal data on behalf of the Operator is obliged to comply with the principles and rules of personal data processing provided for by the Personal Data Law, maintain the confidentiality of personal data, and take necessary measures aimed at ensuring the fulfillment of obligations stipulated by the Personal Data Law;
* In case of withdrawal of consent to the processing of personal data by the personal data subject, continue processing personal data without the subject's consent if grounds specified in the Personal Data Law exist.
1.6.2. The Operator is obliged to:
* Organize the processing of personal data in accordance with the requirements of the Personal Data Law;
* Respond to applications and requests from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
* Provide, upon request, the necessary information to the authorized body for the protection of the rights of personal data subjects (Federal Service for Supervision of Communications, Information Technology and Mass Media (Roskomnadzor)) within 10 working days from the date of receipt of such request. This period may be extended, but for no more than five working days. To do this, the Operator must send Roskomnadzor a reasoned notification indicating the reasons for extending the period for providing the requested information;
* Ensure interaction with the state system for detecting, preventing, and eliminating the consequences of computer attacks on the information resources of the Russian Federation, including informing it about computer incidents that resulted in the unlawful transfer (provision, distribution, access) of personal data, in the manner determined by the federal executive body authorized in the field of security.
1.7. Key Rights of the Personal Data Subject. The personal data subject has the right to:
* Receive information concerning the processing of their personal data, except in cases provided for by federal laws. Information is provided to the personal data subject by the Operator in an accessible form and shall not contain personal data relating to other personal data subjects, unless there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
* Demand that the Operator clarify their personal data, block or destroy them if the personal data are incomplete, outdated, inaccurate, unlawfully obtained, or are not necessary for the stated purpose of processing, as well as take measures provided by law to protect their rights;
* Give prior consent to the processing of personal data for the purpose of promoting goods, works, and services on the market;
* Appeal unlawful actions or inaction of the Operator in processing their personal data to Roskomnadzor or in court.
1.8. Control over compliance with the requirements of this Policy is carried out by the authorized person responsible for organizing the processing of personal data at the Operator.
1.9. Liability for violation of the requirements of the legislation of the Russian Federation and the regulatory acts of Limited Liability Company "Managing Company 'Proekt'" in the field of processing and protection of personal data is determined in accordance with the legislation of the Russian Federation.

2.1. The processing of personal data is limited to the achievement of specific, predetermined, and legitimate purposes. Processing of personal data incompatible with the purposes of collecting personal data is not permitted.
2.2. Only personal data that meet the purposes of their processing are subject to processing.
2.3. The Operator processes personal data for the following purposes:
* Conducting its activities in accordance with the charter of Limited Liability Company "Managing Company 'Proekt'", including concluding and executing contracts with counterparties;
* Compliance with labor legislation within the framework of labor and other directly related relations, including: assisting employees in employment, education, and career advancement; attracting and selecting candidates for employment with the Operator; ensuring the personal safety of employees; monitoring the quantity and quality of work performed; ensuring the safety of property; maintaining personnel and accounting records; filling out and submitting required reporting forms to authorized bodies; organizing the registration of employees for individual (personalized) accounting in the systems of compulsory pension insurance and compulsory social insurance.
2.4. The processing of employees' personal data may be carried out solely for the purpose of ensuring compliance with laws and other regulatory legal acts.

2. Purposes of Personal Data Processing

3. Legal Grounds for Processing Personal Data

3.1. The legal grounds for processing personal data are the set of regulatory legal acts, in fulfillment of and in accordance with which the Operator processes personal data, including:
* The Constitution of the Russian Federation;
* The Civil Code of the Russian Federation;
* The Labor Code of the Russian Federation;
* The Tax Code of the Russian Federation;
* Federal Law No. 14-FZ dated February 8, 1998, "On Limited Liability Companies";
* Federal Law No. 402-FZ dated December 6, 2011, "On Accounting";
* Federal Law No. 167-FZ dated December 15, 2001, "On Compulsory Pension Insurance in the Russian Federation";
* Other regulatory legal acts regulating relations related to the Operator's activities.
3.2. The legal grounds for processing personal data also include:
* The charter of Limited Liability Company "Managing Company 'Proekt'";
* Contracts concluded between the Operator and personal data subjects;

• * Consent of personal data subjects to the processing of their personal data

7.1. Use of Cookies. The Operator's Website uses Cookie files. When visiting the Website, the Internet browser of the Personal Data Subject transmits certain information to the Operator's server: (1) date and time of visit, (2) browser type, (3) language settings, (4) operating system. This information is stored in connection logs for a limited time (from the session duration up to one year) to ensure security and proper operation of the Website, as well as to collect statistical information.
7.2. Functions of Cookies. Various groups of Cookies are used on the Website. The first group is functional and technical Cookies. The function of such files is to allow the Website server to obtain information about the Personal Data Subject's session, language used, browser, and other information, and to ensure the full functionality of the Website. These files are needed to recognize the Personal Data Subject when they revisit the Website. This allows the Operator to personalize the Website content according to the needs of the Personal Data Subject and remember their preferences. The second group is analytical Cookies; they allow the Operator to evaluate and count the number of visitors and understand how they navigate the Website while using it. This allows the Operator to make improvements to the Website's operation, for example, by optimizing the search for needed sections, making it simple and efficient. The Personal Data Subject has the right to refuse the use of analytical Cookies by applying the appropriate settings in their web browser.
7.3. Cookie Storage Period. Based on storage time on users' devices, Cookies are divided into Persistent and Session Cookies: "Session Cookies" are files that are stored on the Personal Data Subject's device until the subject closes the browser. "Persistent Cookies" are stored on the Personal Data Subject's device until their expiration date or until the Personal Data Subject deletes the Persistent Cookies.
7.4. Disabling Cookies. The Personal Data Subject has the ability to accept or reject all Cookies on all websites they visit by changing the settings in their web browser. For example, when the Personal Data Subject uses Internet Explorer browser version 11.0, they should do the following: (1) select "Settings", then "Internet Options", (2) go to the "Privacy" tab, (3) using the mouse, select the preferred settings. Each browser requires its own specific settings to change and delete Cookies. Certain functional features of the Website may become unavailable if Cookies are disabled. To learn more about how to adjust or change your browser settings, refer to your browser's instructions or visit www.aboutcookies.org or www.allaboutcookies.org. If the Personal Data Subject uses different devices to access the Website (smartphone, tablet, computer, etc.), they have the right to configure each browser on each device according to their preferences regarding Cookie files.

"Consent to the Processing of Personal Data - https://myfutureproof.ru/eng/consent-processing-personal-data"

7. Cookie Files

6.1. Confirmation of the fact of processing of personal data by the Operator, the legal grounds and purposes of processing personal data, as well as other information specified in Part 7, Article 14 of the Personal Data Law, shall be provided by the Operator to the personal data subject or their representative within 10 working days from the moment of application or receipt of the request from the personal data subject or their representative. This period may be extended, but for no more than five working days. To do this, the Operator must send the personal data subject a reasoned notification indicating the reasons for extending the period for providing the requested information.
The information provided shall not include personal data relating to other personal data subjects, unless there are legal grounds for disclosing such personal data.
The request must contain:
* The number of the primary identity document of the personal data subject or their representative, information on the date of issue of the said document and the issuing authority;
* Information confirming the participation of the personal data subject in relations with the Operator (contract number, contract date, conditional verbal designation and/or other information), or information otherwise confirming the fact of processing of personal data by the Operator;
* Signature of the personal data subject or their representative.
The request may be sent in the form of an electronic document and signed with an electronic signature in accordance with the legislation of the Russian Federation.
The Operator provides the information specified in Part 7, Article 14 of the Personal Data Law to the personal data subject or their representative in the form in which the corresponding application or request was sent, unless otherwise stated in the application or request.
If the application (request) of the personal data subject does not contain all necessary information in accordance with the requirements of the Personal Data Law, or the subject does not have the right to access the requested information, a reasoned refusal shall be sent to them.
The right of the personal data subject to access their personal data may be restricted in accordance with Part 8, Article 14 of the Personal Data Law, including if the access of the personal data subject to their personal data violates the rights and legitimate interests of third parties.
6.2. In case inaccurate personal data are identified upon application by the personal data subject or their representative, or upon their request or upon request from Roskomnadzor, the Operator blocks the personal data relating to this personal data subject from the moment of such application or receipt of the specified request for the period of verification, provided that blocking the personal data does not violate the rights and legitimate interests of the personal data subject or third parties.
If the inaccuracy of the personal data is confirmed, the Operator clarifies the personal data within seven working days from the date of submission of such information based on information provided by the personal data subject or their representative or Roskomnadzor, or other necessary documents, and removes the blocking of the personal data.
6.3. In case unlawful processing of personal data is identified upon application (request) by the personal data subject or their representative or Roskomnadzor, the Operator blocks the unlawfully processed personal data relating to this personal data subject from the moment of such application or receipt of the request.
6.4. If the Operator, Roskomnadzor, or another interested party identifies a fact of unlawful or accidental transfer (provision, distribution) of personal data (access to personal data) that resulted in a violation of the rights of personal data subjects, the Operator:
* Within 24 hours - notifies Roskomnadzor of the incident that occurred, the presumed causes that led to the violation of the rights of personal data subjects, the presumed harm caused to the rights of personal data subjects, and the measures taken to eliminate the consequences of the incident, and provides information about the person authorized by the Operator to interact with Roskomnadzor on issues related to the incident;
* Within 72 hours - notifies Roskomnadzor of the results of the internal investigation of the identified incident and provides information about the persons whose actions caused it (if any).
6.5. Procedure for Destruction of Personal Data by the Operator.
6.5.1. Conditions and Terms for Destruction of Personal Data by the Operator:
* Achievement of the purpose of processing personal data or loss of the need to achieve this purpose - within 30 days;
* Achievement of the maximum storage periods for documents containing personal data - within 30 days;
* Provision by the personal data subject (their representative) of confirmation that the personal data were obtained unlawfully or are not necessary for the stated purpose of processing - within seven working days;
* Withdrawal of consent to the processing of their personal data by the personal data subject, if their retention for the purpose of their processing is no longer required - within 30 days.
6.5.2. Upon achieving the purpose of processing personal data, as well as in case of withdrawal of consent to their processing by the personal data subject, the personal data shall be destroyed, unless:
* Otherwise provided by a contract to which the personal data subject is a party, beneficiary, or guarantor;
* The Operator is not entitled to process without the consent of the personal data subject on the grounds provided for by the Personal Data Law or other federal laws;
* Otherwise provided by another agreement between the Operator and the personal data subject.
6.5.3. The destruction of personal data is carried out by a commission established by order of the General Director of Limited Liability Company "Managing Company 'Proekt'".
6.5.4. Methods for destroying personal data are established in the Operator's local regulations.

6. Updating, Correction, Deletion, Destruction of Personal Data, Responses to Subjects' Requests for Access to Personal Data

5.1. The processing of personal data is carried out by the Operator in accordance with the requirements of the legislation of the Russian Federation.
5.2. The processing of personal data is carried out with the consent of the personal data subjects to the processing of their personal data, as well as without such consent in cases provided for by the legislation of the Russian Federation.
5.3. The Operator processes personal data for each purpose of their processing using the following methods:
* Non-automated processing of personal data;
* Automated processing of personal data with or without transmission of the obtained information via information and telecommunication networks;
* Mixed processing of personal data.
5.4. Only employees of the Operator whose job responsibilities include processing personal data are permitted to process personal data.
5.5. The processing of personal data for each processing purpose specified in Clause 2.3 of the Policy is carried out by:
* Receiving personal data orally and in writing directly from personal data subjects;
* Entering personal data into the Operator's journals, registers, and information systems;
* Using other methods of processing personal data.
5.6. Disclosure to third parties and distribution of personal data without the consent of the personal data subject is not permitted, unless otherwise provided by federal law. Consent to the processing of personal data permitted by the personal data subject for distribution is executed separately from other consents of the personal data subject to the processing of their personal data.
The requirements for the content of consent to the processing of personal data permitted by the personal data subject for distribution are approved by Order of Roskomnadzor No. 18 dated February 24, 2021.
5.7. The transfer of personal data to inquiry and investigation bodies, the Federal Tax Service, the Social Fund of Russia, and other authorized executive bodies and organizations is carried out in accordance with the requirements of the legislation of the Russian Federation.
5.8. The Operator takes necessary legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, alteration, blocking, distribution, and other unauthorized actions, including:
* Identifying threats to the security of personal data during their processing;
* Adopting local regulations and other documents governing relations in the field of processing and protection of personal data;
* Appointing persons responsible for ensuring the security of personal data in the Operator's structural subdivisions and information systems;
* Creating necessary conditions for working with personal data;
* Organizing the accounting of documents containing personal data;
* Organizing work with information systems in which personal data are processed;
* Storing personal data under conditions ensuring their safety and preventing unauthorized access;
* Organizing training for the Operator's employees processing personal data.
5.9. The Operator stores personal data in a form that allows identification of the personal data subject for no longer than required by each purpose of personal data processing, unless the storage period is established by federal law or contract.
5.9.1. Personal data on paper carriers are stored at Limited Liability Company "Managing Company 'Proekt'" for the storage periods of documents established by the legislation on archiving in the Russian Federation (Federal Law No. 125-FZ dated October 22, 2004, "On Archiving in the Russian Federation", List of Standard Management Archival Documents Generated in the Activities of State Bodies, Local Self-Government Bodies and Organizations, Indicating Storage Periods (approved by Order of Rosarkhiv No. 236 dated December 20, 2019)).
5.9.2. The storage period for personal data processed in personal data information systems corresponds to the storage period for personal data on paper carriers.
5.10. The Operator ceases processing personal data in the following cases:
* Unlawful processing is identified. Deadline - within three working days from the date of identification;
* The purpose of their processing is achieved;
* The term of validity expires or the consent of the personal data subject to the processing of the specified data is withdrawn, when, under the Personal Data Law, processing of this data is permitted only with consent.
5.11. Upon achieving the purposes of processing personal data, as well as in case of withdrawal of consent to their processing by the personal data subject, the Operator ceases processing these data, unless:
* Otherwise provided by a contract to which the personal data subject is a party, beneficiary, or guarantor;
* The Operator is not entitled to process without the consent of the personal data subject on the grounds provided for by the Personal Data Law or other federal laws;
* Otherwise provided by another agreement between the Operator and the personal data subject.
5.12. When a personal data subject contacts the Operator with a request to cease processing personal data, the processing of personal data shall be terminated within a period not exceeding 10 working days from the date the Operator receives the relevant request, except in cases provided for by the Personal Data Law. The specified period may be extended, but for no more than five working days. To do this, the Operator must send the personal data subject a reasoned notification indicating the reasons for extending the period.
5.13. When collecting personal data, including via the Internet, the Operator ensures the recording, systematization, accumulation, storage, clarification (updating, modification), and retrieval of personal data of citizens of the Russian Federation using databases located on the territory of the Russian Federation, except in cases specified in the Personal Data Law.

5. Procedure and Conditions for Processing Personal Data

4.1. The content and scope of the processed personal data must correspond to the stated processing purposes specified in Section 2 of this Policy. The processed personal data must not be excessive in relation to the stated purposes of their processing.
4.2. The Operator may process personal data of the following categories of personal data subjects.
4.2.1. Candidates for Employment with the Operator - For the purposes of compliance with labor legislation within the framework of labor and other directly related relations:
* Surname, Name, Patronymic;
* Gender;
* Citizenship;
* Date and Place of Birth;
* Contact Details;
* Information on Education, Work Experience, Qualifications;
* Other personal data provided by candidates in resumes and cover letters.
4.2.2. Current and Former Employees of the Operator - For the purposes of compliance with labor legislation within the framework of labor and other directly related relations:
* Surname, Name, Patronymic;
* Gender;
* Citizenship;
* Date and Place of Birth;
* Image (Photograph);
* Passport Details;
* Residential Registration Address;
* Actual Residential Address;
* Contact Details;
* Taxpayer Identification Number (INN);
* Individual Insurance Account Number (SNILS);
* Information on Education, Qualifications, Vocational Training, and Professional Development;
* Marital Status, Presence of Children, Family Relations;
* Information on Employment History, including Awards, Honors, and/or Disciplinary Penalties;
* Marriage Registration Data;
* Military Registration Information;
* Disability Information;
* Information on Alimony Withholdings;
* Information on Income from Previous Place of Employment;
* Other personal data provided by employees in accordance with labor legislation requirements.
4.2.3. Family Members of the Operator's Employees - For the purposes of compliance with labor legislation within the framework of labor and other directly related relations:
* Surname, Name, Patronymic;
* Degree of Kinship;
* Year of Birth;
* Other personal data provided by employees in accordance with labor legislation requirements.
4.2.4. Clients and Counterparties of the Operator (Individuals) - For the purposes of conducting its activities in accordance with the charter of Limited Liability Company "Managing Company 'Proekt'":
* Surname, Name, Patronymic;
* Date and Place of Birth;
* Passport Details;
* Residential Registration Address;
* Contact Details;
* Position Held;
* Taxpayer Identification Number (INN);
* Bank Account Number;
* Other personal data provided by clients and counterparties (individuals), necessary for concluding and executing contracts.
4.2.5. Representatives (Employees) of the Operator's Clients and Counterparties (Legal Entities) - For the purposes of conducting its activities in accordance with the charter of Limited Liability Company "Managing Company 'Proekt'", implementing access control:
* Surname, Name, Patronymic;
* Passport Details;
* Contact Details;
* Position Held;
* Other personal data provided by representatives (employees) of clients and counterparties, necessary for concluding and executing contracts.
4.3. The Operator's processing of biometric personal data (information characterizing the physiological and biological characteristics of a person, on the basis of which his/her identity can be established) is carried out in accordance with the legislation of the Russian Federation.
4.4. The Operator does not process special categories of personal data concerning race, nationality, political views, religious or philosophical beliefs, health status, or intimate life, except in cases provided for by the legislation of the Russian Federation.

4. Scope and Categories of Processed Personal Data, Categories of Personal Data Subjects

Privacy policy

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Office in Russia

Office in Germany

Оffice in Kazakhstan

LLC "UK "PROEKT"
INN: 5032331935
OGRN: 1215000082956
Legal address: 143003, Moscow Region, Odintsovo, 62a Severnaya St., Office 26

Phone: +7 800 777 69 22

Schönhauser Allee 163, 10435 Berlin

District Court of Charlottenburg (Berlin) HRB 245056 B


Phone: +49 157 3875 2884

ТОО "Not Space" ("нот спейс")

BIN: 220840042366

Legal address: Kazakhstan, Altai, st. Frunze, 52, apt. 69


Postal code: 070800