1. GENERAL PROVISIONS

1.1 This policy of personal data processing is drawn up in accordance with the requirements of the Federal Law dated 27.07.2006. No. 152-FZ “On Personal Data” (hereinafter – the Personal Data Law) and defines the procedure of personal data processing and measures to ensure personal data security taken by Dashboard Systems JSC (hereinafter – the Operator).

1.2 The Operator sets as its most important goal and condition of its activity the observance of human and citizen’s rights and freedoms in the processing of personal data, including the protection of the rights to privacy, personal and family secrecy.

1.3 This Operator’s policy on personal data processing (hereinafter – the Policy) is valid for both the Website and the Operator’s Services (regardless of the platform), and applies to all subjects whose personal data have been provided to the Operator in connection with: (1) using the Service/s, and/or (2) receiving or rendering services when using the Services and/or (3) entering into civil law and labor contracts and/or (4) other purposes for the achievement of which the processing of personal data is necessary.

1.4 Use of the Operator’s Services means that the User unconditionally agrees with this Policy and the terms of processing his/her personal information specified in it. In case of disagreement with these terms, the User refrains from using the Services.

2. BASIC DEFINITIONS USED IN THE POLICY

2.1 Automated processing of personal data means processing of personal data by means of computer equipment.

2.2 Blocking of personal data means temporary cessation of personal data processing (except for cases when processing is necessary to clarify personal data).

2.3 Website/Site means a set of graphic and informational materials, as well as computer programs and databases, ensuring their availability on the Internet at the network address https://boardmaps.ru.

2.4 Personal data information system means a set of personal data contained in databases and information technologies and technical means ensuring their processing.

2.5 Personal data depersonalization means actions, because of which it is impossible to determine without using additional information the belonging of personal data to a particular User or other subject of personal data.

2.6 Processing of personal data means any action (operation) or set of actions (operations) performed with or without the use of automation means with personal data, including collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.

2.7 Operator means a state authority, municipal authority, legal entity or natural person, independently or jointly with other entities organizing and/or carrying out processing of personal data, as well as determining the purposes of personal data processing, composition of personal data subject to processing, actions (operations) performed with personal data.

2.8 Personal Data means any information relating directly or indirectly to a specific or identifiable User.

2.9 Personal data authorized for dissemination by the subject of personal data means personal data, access to which is provided by the subject of personal data to an unlimited number of entities by giving consent to the processing of personal data authorized by the subject of personal data for dissemination in the manner prescribed by the Law on Personal Data (hereinafter – personal data authorized for dissemination).

2.10 User means a subject who has provided his/her personal data to the Operator in connection with: (1) using the Service/s, and/or (2) receiving or rendering services when using the Services and/or (3) entering into civil and labor contracts and/or (4) other purposes for which the processing of personal data is necessary.

2.11 Provision of personal data means actions aimed at disclosure of personal data to a certain person or a certain circle of entities.

2.12 Dissemination of personal data means any actions aimed at disclosure of personal data to an indefinite number of entities (transfer of personal data) or familiarization of personal data to an unlimited number of entities, including disclosure of personal data in mass media, placement in information and telecommunication networks or providing access to personal data in any other way.

2.13 Service/Services means all pages of the Website, as well as software (including mobile applications, regardless of the platform), sold under the trademark “BoardMaps” and managed by the Operator.

2.14 Cross-border transfer of personal data means transfer of personal data to the territory of a foreign country to a foreign government authority, a foreign individual, or a foreign legal entity.

2.15 Destruction of personal data means any actions, because of which personal data is irretrievably destroyed with the impossibility of further recovery of the content of personal data in the personal data information system and/or material carriers of personal data is destroyed.

3. BASIC RIGHTS AND OBLIGATIONS OF THE OPERATOR

3.1 The Operator has the right to:

– to receive reliable information and/or documents containing personal data from the subject of personal data;

– in case the personal data subject revokes his/her consent to personal data processing, as well as in case the personal data subject submits a request to stop personal data processing, the Operator has the right to continue personal data processing without consent of the personal data subject, if there are grounds specified in the Personal Data Law;

– independently determine the composition and the list of measures necessary and sufficient to ensure the fulfillment of obligations stipulated by the Law on personal data and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Law on personal data or other federal laws.

3.2 The Operator:

– provides the personal data subject, upon his/her request, with information regarding the processing of his/her personal data;

– organizes the processing of personal data in accordance with the procedure established by the current legislation of the Russian Federation;

– responds to appeals and requests of personal data subjects and their legal representatives in accordance with the requirements of the Law on personal data;

– informs the authorized body for the protection of the rights of personal data subjects, upon request of this body, of the necessary information within 10 days from the date of receipt of such request;

– publishes or otherwise provides unrestricted access to this Personal Data Processing Policy;

– takes legal, organizational, and technical measures for protection of personal data from unlawful or accidental access to them, destruction, modification, blocking, copying, provision, dissemination of personal data, as well as from other unlawful actions in relation to personal data;

– ceases transfer (dissemination, provision, access) of personal data, stop processing and destroy personal data in the manner and cases stipulated by the Personal Data Law;

– fulfills other obligations stipulated by the Personal Data Law.

4. BASIC RIGHTS AND OBLIGATIONS OF PERSONAL DATA SUBJECTS

4.1 Personal data subjects have the right:

– to receive information regarding the processing of his/her personal data, except in cases provided for by federal laws. Information is provided to the subject of personal data by the Operator in an accessible form and does not contain personal data relating to other subjects of personal data, except in cases where there are legal grounds for disclosure of such personal data. The list of information and the procedure for obtaining it is established by the Law on Personal Data;

– to demand from the operator to clarify his personal data, block or destroy it 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 measures provided for by law to protect his rights;

– to impose a condition of prior consent when processing personal data for the purpose of marketing goods, works and services;

– to withdraw consent for processing of personal data and to send a request to stop processing of personal data;

– to appeal to the authorized body for the protection of the rights of personal data subjects or in court against unlawful acts or omissions of the Operator in the processing of his/her personal data;

– to exercise other rights provided for by the legislation of the Russian Federation.

4.2 Personal data subjects are obliged to:

– provide the Operator with true data about himself;

– inform the Operator about the clarification (update, change) of his/her personal data.

4.3 Entities who have passed to the Operator false information about themselves, or information about another subject of personal data without the consent of the latter, are liable in accordance with the legislation of the Russian Federation.

5. PRINCIPLES OF PERSONAL DATA PROCESSING

5.1 The personal data is processed on a lawful and fair basis.

5.2 The processing of personal data is limited to the achievement of specific, predetermined, and legitimate purposes. Processing personal data in a manner that is incompatible with the purposes of personal data collection is not allowed.

5.3 It is not allowed to merge databases containing personal data processed for incompatible purposes.

5.4 Only personal data that is relevant for the purposes of processing are processed.

5.5 The content and scope of processed personal data correspond to the stated purposes of processing. Redundancy of processed personal data in relation to the stated purposes of their processing is not allowed.

5.6 When processing personal data, the accuracy of personal data, their sufficiency and, where necessary, relevance to the purposes of personal data processing is ensured. The Operator takes the necessary measures and/or ensures that they are taken to delete or clarify incomplete or inaccurate data.

5.7 Personal data is stored in a form that allows identification of the subject of personal data, no longer than required by the purposes of personal data processing, unless the period of personal data storage is established by federal law, contract to which the subject of personal data is a party, beneficiary or guarantor. Processed personal data is destroyed or depersonalized upon achievement of the purposes of processing or if it is not necessary to achieve these purposes, unless otherwise provided by federal law.

6. PURPOSES OF PROCESSING AND CATEGORIES OF PERSONAL DATA

7. CONDITIONS OF PERSONAL DATA PROCESSING

7.1 Personal data is processed according to consent of the personal data subject to the processing of his/her personal data.

7.2 Personal data is processed in cases when it is necessary to achieve the purposes stipulated by the international treaty of the Russian Federation or law, to fulfill the functions, powers and duties assigned to the Operator by the legislation.

7.3 Personal data is processed if it is necessary for the administration of justice, execution of a judicial act, act of another body or official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.

7.4 Personal data is processed if it is necessary for the execution of an agreement to which the personal data subject is a party or a beneficiary or guarantor, as well as for the conclusion of an agreement at the initiative of the personal data subject or an agreement under which the personal data subject is a beneficiary or guarantor.

7.5 Personal data is processed if it is necessary for observance of rights and legitimate interests of the Operator or third parties or for achievement of socially important purposes, provided that the rights and freedoms of the personal data subject are not violated.

7.6 The Operator also processes personal data to which an unlimited number of entities have access by the personal data subject or at his/her request (hereinafter referred to as publicly available personal data).

7.7 The Operator processes personal data subject to publication or mandatory disclosure in accordance with federal law.

8. PROCEDURE FOR PERSONAL DATA PROCESSING

8.1 Security of personal data processed by the Operator is ensured by implementing legal, organizational, and technical measures necessary for full compliance with the requirements of the applicable legislation in the field of personal data protection.

8.2 The Operator ensures safety of personal data and takes all measures to prevent unauthorized entities from accessing personal data.

8.3 The User’s personal data never, under no circumstances, is transferred to third parties, except in cases related to the execution of the current legislation or if the subject of personal data has given consent to the Operator to transfer the data to a third party for the fulfillment of obligations under a civil law contract.

8.4 In case of identification of inaccuracies in personal data, the User may update them independently by sending a notice to the Operator to the Operator’s e-mail address privacy@vdr.boardmaps.ru with the note “Personal Data Update”.

8.5 The term of personal data processing is determined by the achievement of the purposes for which the personal data were collected unless another term is provided by the contract or applicable law. The User may withdraw his/her consent to the processing of personal data at any time by sending a notice to the Operator by e-mail to the Operator’s e-mail address privacy@vdr.boardmaps.ru marked “Withdrawal of consent to the processing of personal data”.

8.6 All information that is collected by third-party services, including payment systems, means of communication and other service providers, is stored and processed by the specified entities (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data and/or the User is obliged to familiarize himself/herself with the said documents in a timely manner. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this clause.

8.7 The prohibitions established by the personal data subject on the transfer (other than granting access), as well as on the processing or conditions of processing (other than access) of personal data authorized for dissemination are not applicable in cases of processing personal data in the state, public and other public interest as defined by the legislation of the Russian Federation.

8.8 When processing personal data, the Operator ensures confidentiality of personal data.

8.9 The Operator stores personal data in a form that allows to identify the subject of personal data for no longer than required by the purposes of personal data processing, unless the period of personal data storage is established by federal law, contract to which the subject of personal data is a party, beneficiary or guarantor.

8.10 The condition for termination of personal data processing may be the achievement of the purposes of personal data processing, expiration of the personal data subject’s consent, withdrawal of consent by the personal data subject or the requirement to terminate personal data processing, as well as the detection of unlawful processing of personal data.

9. PROCESSING OF ELECTRONIC USER DATA

9.1 The Operator, for the purposes of personal data processing established by the Policy, may collect electronic user data on the Website automatically, without the need for the user to participate and perform any actions to send data.

9.2 The reliability of electronic data collected in this way is not checked by the Operator, the information is processed “as is” as it came from the client device.

9.3 Visitors and users of the Operator’s Website may be shown pop-up notices about the collection and processing of cookie data with a link to the Policy and buttons to accept the terms of processing or close the pop-up notice.

9.4 Such notifications mean that when visiting and using the Operator’s websites, information resources and web applications, information (e.g. cookie data) may be stored in the browser on the user’s device, which allows to further identify the user or device, remember the session or save some user settings and preferences specific to these sites. Such information, after being saved to the browser and before expiration of the set validity period or deletion from the device, is sent with each subsequent request to the site on behalf of which they were saved, together with this request for processing on the Operator’s side.

9.5 Processing of cookie data is necessary for the Operator for the correct operation of the Site, in particular, functions related to the access of registered users of the Operator’s software products, services, works and resources; personalization of users; improving the efficiency and convenience of the Site, as well as other purposes provided for in the Policy.

9.6 In addition to the processing of these cookies by the Operator’s Site, Users may be set cookies relating to third party sites, for example, where third party components and software are used on the Operator’s Site. The processing of such cookies is governed by the policies of the respective sites to which they relate and may change without notice to Operator Site Users. Such cases may include placement on the sites:

– visit counters, analytical and statistical services, such as Yandex.Metrica or Google Analytics to collect statistics on traffic to publicly accessible pages of websites.

– widgets of auxiliary services for collecting feedback, organizing chats and other types of communication with users.

– contextual advertising systems, banners, and other marketing networks.

– authorization buttons on websites using social media accounts.

– other third-party components used by the Operator on the Website.

9.7 Acceptance by the user of the terms of processing cookies or closing the pop-up notification in accordance with the Policy is considered as consent to the processing of cookie data on the Operator’s Site.

9.8 If the user does not agree to the processing of cookies, the user must accept the risk that the functions and features of the Site may not then be fully available and then follow one of the following options:

– independently set up your browser in accordance with the documentation or help for it so that it does not permanently allow receiving and sending cookie data for the Operator’s Site or the site of a third-party component.

– switch to the browser’s special “incognito” mode to use cookies before closing the browser window or before switching back to normal mode.

– leave the Site to avoid further processing of cookies.

9.9 The User may independently, through the browsers built-in cookie tools, manage stored data, including deleting or viewing details of cookies set by websites, including:

– addresses and paths to sites where cookies are sent.

– names and values of parameters stored in cookies.

– cookie expiration dates.

10. METHODS OF PERSONAL DATA PROCESSING

10.1 The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), extracts, uses, transfers (disseminates, provides, accesses), depersonalizes, blocks, deletes, and destroys personal data.

10.2 The Operator performs automated processing of personal data with or without receiving and/or transmitting the received information via information and telecommunication networks.

11. TRANS-BORDER TRANSFER OF PERSONAL DATA

11.1 Prior to starting trans-border transfer of personal data, the Operator notifies the authorized body for the protection of the rights of personal data subjects of its intention to carry out trans-border transfer of personal data (such notification is sent separately from the notification of intention to process personal data).

11.2 Before submitting the above notification, the Operator is obliged to obtain relevant information from the authorities of a foreign state, foreign entities, foreign legal entities to whom trans-border transfer of personal data is planned.

12. CONFIDENTIALITY OF PERSONAL DATA

12.1 The Operator and other entities who have access to personal data are obliged not to disclose to third parties and not to disseminate personal data without the consent of the subject of personal data, unless otherwise provided by federal law.

13. FINAL PROVISIONS

13.1 The User may obtain any clarifications on matters of interest regarding the processing of his/her personal data by contacting the Operator via e-mail at privacy@vdr.boardmaps.ru.

13.2 This document will reflect any changes to the Operator’s personal data processing policy. The Policy is valid indefinitely until it is replaced by a new version.

13.3 The current version of the Policy is available on the Internet at: https://virtualdataroom.boardmaps.ru/en/policy-en/.