The policy of SAFMAR Financial Investments PJSC in the field of personal data processing

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Privacy policy
In order to ensure the protection of the rights and freedoms of a person and a citizen in the processing of their personal data, as well as in order to comply with the laws of the Russian Federation in the field of personal data, Closed Joint-Stock Company “Europlan”, OGRN 1027700085380 (hereinafter referred to as “the Company”) has developed this document (hereinafter - "Politics").
1. General Provisions

1.1. The processing of personal data is carried out by the Company in accordance with the Constitution of the Russian Federation, international treaties of the Russian Federation, Federal Law No. 152 FZ dated July 27, 2006 “On Personal Data”, other federal laws defining cases and peculiarities of personal data processing, regulatory acts adopted on the basis and in pursuance of federal laws.

1.2. The company independently processes personal data as an operator. If necessary, the Company has the right to entrust the processing of personal data to another person in accordance with the requirements established by the legislation of the Russian Federation in the field of personal data.

1.3. The processing of personal data is carried out by the Company using automation equipment, as well as without the use of such tools. In this case, the automated processing of personal data means the processing of personal data using computer technology, but in any case, with the direct participation of a person.

2. Principles of personal data processing

2.1. The processing of personal data is carried out by the Company in accordance with the following principles:

2.1.1. The legitimacy of the goals and methods of processing personal data.

2.1.2. Compliance with the processing of personal data to the goals predetermined during the collection of personal data.

2.1.3. The correspondence of the volume and nature of the personal data processed to the purposes of personal data processing. The inadmissibility of the processing of personal data redundant in relation to the stated purposes of their processing.

2.1.4. Reliability and accuracy of personal data, their sufficiency, as well as relevance for the purposes of processing personal data.

2.1.5. Ensuring the confidentiality of personal data during their processing.

3. Purposes of personal data processing

3.1. The processing of personal data is carried out by the Company in order to:

3.1.1. implementation of the obligations and functions imposed on the Company by the legislation of the Russian Federation in accordance with the Tax Code of the Russian Federation, federal laws, in particular: "On financial leasing (leasing)", "On countering the legalization (laundering) of proceeds from crime and financing of terrorism" , "On Insolvency (Bankruptcy)", "On Personal Data", as well as other regulatory legal acts, local acts and internal procedures of the Company.

3.1.2. organizing accounting of Company employees to ensure compliance with laws and other regulatory legal acts, assisting employees in employment, training and promotion, ensuring personal safety of employees, monitoring the quantity and quality of work performed and ensuring the safety of property in accordance with the Labor Code of the Russian Federation, Tax Code Of the Russian Federation, federal laws, in particular: "On the individual (personified) accounting in the system of compulsory pension insurance "," On personal data ", as well as other regulatory legal acts, local acts and internal procedures of the Company.

3.1.3. other purposes not contrary to the legislation of the Russian Federation.

4. Actions (operations) performed with personal data

4.1. The Company can perform the following actions (operations) with personal data: collection, recording, systematization, accumulation, storage, refinement (update, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction .

5. Conditions for processing personal data

5.1. The processing of personal data is carried out with the consent of the subject of personal data for such processing, except in cases where, in accordance with the legislation of the Russian Federation, such consent is not required.

5.2. The company does not process the following personal data:

5.2.1. political views;

5.2.2. philosophical convictions;

5.2.3. religious beliefs;

5.2.4. criminal record.

5.3. The company takes the measures necessary and sufficient to ensure the fulfillment of obligations stipulated by the legislation on personal data. The company independently determines the composition and the list of measures necessary and sufficient to ensure the fulfillment of the obligations stipulated by the legislation of the Russian Federation on personal data.

5.4. In order to exercise internal control over the compliance of the Company and its employees with the legislation of the Russian Federation on personal data, the Company appoints persons responsible for organizing the processing of personal data.