The Privacy Policy and
the Policy of personal data processing

1. GENERAL PROVISIONS

The Personal Data Processing Policy (hereinafter referred to as the Policy) has been developed in accordance with Federal Law No. 152-FZ dated 07/27/2006 "On Personal Data" (hereinafter referred to as FZ-152). This Policy defines the procedure for processing personal data and measures to ensure the security of personal data in TELESTOR LTD (hereinafter referred to as the Operator) in order to protect the rights and freedoms of a person and a citizen when processing his personal data, including the protection of the rights to privacy, personal and family secrets.

The following basic concepts are used in the Policy:
• automated processing of personal data – processing of personal data using computer technology;
• blocking of personal data – temporary termination of the processing of personal data (except in cases where processing is necessary to clarify personal data);
• personal data information system – a set of personal data contained in databases, and information technologies and technical means that ensure their processing;
• depersonalization of personal data – actions as a result of which it is impossible to determine, without using additional information, the identity of personal data to a specific personal data subject;
• personal data processing is any action (operation) or a set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data;
• operator – a state body, municipal body, legal entity or individual, independently or jointly with other persons organizing and (or) processing personal data, as well as determining the purposes of processing personal data, the composition of personal data to be processed, actions (operations) performed with personal data;
• personal data – any information related directly or indirectly to a specific or identifiable individual (subject of personal data);
• provision of personal data – actions aimed at disclosing personal data to a certain person or a certain circle of persons;
• dissemination of personal data – actions "27" aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or at familiarizing with personal data of an unlimited number of persons, including the publication of personal data in the media, posting in information and telecommunications networks or providing access to personal data in any other way;
• cross–border transfer of personal data - transfer of personal data to the territory of a foreign state to an authority of a foreign state, a foreign individual or a foreign legal entity;
• destruction of personal data – actions as a result of which it is 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.

The Company is obliged to publish or otherwise provide unrestricted access to this Personal Data Processing Policy in accordance with Part 2 of Article 18.1 of the Federal Law 152.

2. PRINCIPLES AND CONDITIONS OF PERSONAL DATA PROCESSING

2.1. Principles of personal data processing

The processing of personal data by the Operator is carried out on the basis of the following principles:
• legality and a 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 collecting personal data;
• preventing the consolidation of databases containing personal data, the processing of which is carried out for purposes incompatible with each other;
• processing only those personal data that meet the purposes of their processing;
• compliance of the content and volume of the processed personal data with the stated purposes of processing;
• preventing the processing of personal data that is excessive 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 the inability of the Operator to eliminate violations of personal data, unless otherwise provided by federal law.

2.2. Terms of personal data processing

The operator processes personal data in the presence of at least one of the following conditions:
• the processing of personal data is carried out with the consent of the personal data subject to the processing of his personal data;
• the processing of personal data is necessary to achieve the goals provided for by an international treaty of the Russian Federation or a law, to carry out and fulfill the functions, powers and duties assigned to the operator by the legislation of the Russian Federation;
• the processing of personal data is necessary for the administration of justice, the execution of a judicial act, an act of another body or official to be executed in accordance with the legislation of the Russian Federation on enforcement proceedings;
• the processing of personal data is necessary for the execution of an agreement to which the personal data subject is a party or beneficiary or guarantor, as well as for the conclusion of an agreement on the initiative of the personal data subject or an agreement under which the personal data subject will be the beneficiary or guarantor;
• the processing of personal data is necessary to exercise the rights and legitimate interests of the operator or third parties or to achieve socially significant goals, provided that the rights and freedoms of the personal data subject are not violated;
• the processing of personal data is carried out, access of an unlimited number of persons to which is provided by the subject of personal data or at his request (hereinafter referred to as publicly available personal data);
• the processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.

2.3. Confidentiality of personal data

The operator and other persons who have gained access to personal data are obliged not to disclose or distribute personal data to third parties without the consent of the personal data subject, unless otherwise provided by federal law.

2.4. Publicly available sources of personal data

For information support purposes, the Operator may create publicly available sources of personal data of subjects, including reference books and address books. With the written consent of the subject, publicly available sources of personal data may include his last name, first name, patronymic, date and place of birth, position, contact numbers, phone numbers, e-mail address and other personal data provided by the personal data subject.

Information about the subject must be excluded from publicly available sources of personal data at any time at the request of the subject or by a court decision or other authorized state bodies.

2.5. Special categories of personal data

The processing by the Operator of special categories of personal data relating to race, nationality, political views, religious or philosophical beliefs, health status, and intimate life is allowed in cases where:
• the subject of personal data has given written consent to the processing of his personal data;
• personal data is made publicly available by the subject of personal data;
• the processing of personal data is carried out in accordance with the legislation on state social assistance, labor legislation, the legislation of the Russian Federation on pensions for state pension provision, on labor pensions;
• the processing of personal data is necessary to protect the life, health or other vital interests of the personal data subject or the life, health or other vital interests of other persons and it is impossible to obtain the consent of the personal data subject;
• the processing of personal data is carried out for medical and preventive purposes, in order to establish a medical diagnosis, provide medical and medical and social services, provided that the processing of personal data is carried out by a person professionally engaged in medical activities and is obliged, in accordance with the legislation of the Russian Federation, to maintain medical secrecy;
• the processing of personal data is necessary to establish or exercise the rights of the personal data subject or third parties, as well as in connection with the administration of justice;
• the processing of personal data is carried out in accordance with the legislation on compulsory types of insurance, with the insurance legislation.

The processing of special categories of personal data must be stopped immediately if the reasons for their processing have been eliminated, unless otherwise established by federal law.

The processing of personal data on criminal record can be carried out by the Operator only in cases and in accordance with the procedure determined in accordance with federal laws.

2.6. Biometric personal data

Information that characterizes the physiological and biological characteristics of a person, on the basis of which his identity can be established - biometric personal data - can be processed by the operator only with the written consent of the subject.

2.7. Assigning the processing of personal data to another person

The operator 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 an agreement concluded with this 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 FZ-152.

2.8. Cross-border transfer of personal data

The operator is obliged to ensure that the foreign State to whose territory the transfer of personal data is supposed to be carried out ensures adequate protection of the rights of personal data subjects before such transfer begins.

Cross-border transfer of personal data on the territory of foreign states that do not adequately protect the rights of personal data subjects may be carried out in the following cases:
• he written consent of the personal data subject to the cross-border transfer of his personal data;
• execution of an agreement to which the subject of personal data is a party.

3. RIGHTS OF THE PERSONAL DATA SUBJECT

3.1. Consent of the personal data subject to the processing of his personal data

The subject of personal data decides on the provision of his personal data and consents to their processing freely, of his own free will 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 confirming the fact of its receipt, unless otherwise established by federal law.

The obligation to provide proof of obtaining the consent of the personal data subject to the processing of his personal data or proof of the existence of the grounds specified in FZ-152 is assigned to the Operator.

3.2. Rights of the personal data subject

The subject of personal data has the right to receive from the Operator information related to the processing of his personal data, unless such right is limited in accordance with federal laws. The subject of personal data has the right to require the Operator to clarify his personal data, block or destroy them if the personal data is incomplete, outdated, inaccurate, illegally obtained or are not necessary for the stated purpose of processing, as well as to take measures provided for by law to protect their rights.

The processing of personal data for the purpose of promoting goods, works, and services on the market by making direct contacts with a potential consumer using means of communication, as well as for the purpose of political campaigning, is allowed only with the prior consent of the personal data subject. The specified processing of personal data is recognized as carried out without the prior consent of the personal data subject, unless the Company proves that such consent has been obtained. The operator is obliged to immediately terminate, at the request of the personal data subject, the processing of his personal data for the above purposes.

It is prohibited to make decisions based solely on automated processing of personal data that generate legal consequences for the subject of personal data or otherwise affect his rights and legitimate interests, except in cases provided for by federal laws, or with the written consent of the subject of personal data.

If the personal data subject believes that the Operator is processing his personal data in violation of the requirements of FZ-152 or otherwise violates his rights and freedoms, the personal data subject has the right to appeal the actions or omissions of the Operator to the Authorized Body for the Protection of the Rights of personal data subjects or in court.

The subject of personal data has the right to protect his rights and legitimate interests, including compensation for damages and (or) compensation for moral damage in court.

4. ENSURING THE SECURITY OF PERSONAL DATA

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

To prevent unauthorized access to personal data by the Operator, the following organizational and technical measures are applied:
• appointment of officials responsible for organizing the processing and protection of personal data;
• limitation of the number of persons who have access to personal data;
• familiarization of subjects with the requirements of federal legislation and regulatory documents of the Operator for the processing and protection of personal data;
• organization of accounting, storage and circulation of media;
• identification of threats to the security of personal data during their processing, formation of threat models based on them;
• development of a personal data protection system based on a threat model;
• checking the readiness and effectiveness of the use of information security tools;
• differentiation of user access to information resources and hardware and software for information processing;
• registration and accounting of actions of users of personal data information systems;
• the use of anti-virus tools and personal data protection system recovery tools;
• the use of means of inter-network shielding, if necessary, intrusion detection, security analysis and cryptographic protection of information;
• organization of access control to the Operator's territory, protection of premises with technical means of processing personal data.

5. FINAL PROVISIONS

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

Officials of the Operator who are guilty of violating the norms governing the processing and protection of personal data bear material, disciplinary, administrative, civil or criminal liability in accordance with the procedure established by federal laws.