PERSONAL DATA PROCESSING POLICY

1. General Provisions

This Personal Data Processing Policy has been prepared in accordance with the requirements of Federal Law No. 152-FZ dated July 27, 2006, “On Personal Data” (hereinafter referred to as the “Personal Data Law”) and defines the procedure for processing personal data and the measures taken by RED LLC (hereinafter referred to as the “Operator”) to ensure the security of personal data.

1.1. The Operator considers the observance of human and civil rights and freedoms in the processing of personal data, including the protection of the rights to privacy, personal and family confidentiality, to be one of the most important goals and conditions of its activities.

1.2. This Personal Data Processing Policy of the Operator (hereinafter referred to as the “Policy”) applies to all information that the Operator may obtain about visitors to the website https://redhr.tech.

2. Key Terms Used in the Policy

2.1. Automated processing of personal data means the processing of personal data using computer technology.

2.2. Blocking of personal data means the temporary suspension of personal data processing, except where processing is required to clarify personal data.

2.3. Website means a collection of graphic and informational materials, as well as computer programs and databases, that make such materials available on the Internet at https://redhr.tech.

2.4. Personal data information system means a set of personal data contained in databases, together with the information technologies and technical means used to process such data.

2.5. Anonymization of personal data means actions that make it impossible, without the use of additional information, to determine whether personal data belongs to a particular User or another personal data subject.

2.6. Processing of personal data means any action or operation, or a set of actions or operations, performed with personal data using automation tools or without the use of such tools, including collection, recording, organization, accumulation, storage, clarification (updating or modification), retrieval, use, transfer (distribution, provision or access), anonymization, blocking, deletion and destruction of personal data.

2.7. Operator means a government authority, municipal authority, legal entity or individual that independently or jointly with other persons organizes and/or carries out the processing of personal data and determines the purposes of personal data processing, the scope of personal data to be processed and the actions or operations performed with personal data.

2.8. Personal data means any information relating directly or indirectly to an identified or identifiable User of the website https://redhr.tech.

2.9. Personal data authorized by the personal data subject for distribution means personal data to which access by an unlimited number of persons has been granted by the personal data subject by providing consent to the processing of personal data authorized for distribution in accordance with the procedure established by the Personal Data Law (hereinafter referred to as “personal data authorized for distribution”).

2.10. User means any visitor to the website https://redhr.tech.

2.11. Provision of personal data means actions aimed at disclosing personal data to a specific person or a specific group of persons.

2.12. Distribution of personal data means any actions aimed at disclosing personal data to an indefinite group of persons or making personal data available to an unlimited number of persons, including publication of personal data in mass media, posting in information and telecommunications networks or providing access to personal data by any other means.

2.13. Cross-border transfer of personal data means the transfer of personal data to the territory of a foreign state, to a foreign public authority, a foreign individual or a foreign legal entity.

2.14. Destruction of personal data means any actions resulting in the irreversible destruction of personal data, making it impossible to restore the contents of personal data in a personal data information system, and/or resulting in the destruction of physical media containing personal data.

3. Main Rights and Obligations of the Operator

3.1. The Operator has the right to:

— obtain accurate information and/or documents containing personal data from the personal data subject;

— where the personal data subject withdraws consent to the processing of personal data or submits a request to stop the processing of personal data, continue processing personal data without the subject’s consent where grounds specified by the Personal Data Law are present;

— independently determine the composition and list of measures necessary and sufficient to ensure compliance with the obligations established by the Personal Data Law and regulations adopted pursuant thereto, unless otherwise provided by the Personal Data Law or other federal laws.

3.2. The Operator shall:

— provide the personal data subject, upon request, with information concerning the processing of their personal data;

— organize personal data processing in accordance with the applicable laws of the Russian Federation;

— respond to requests and inquiries from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;

— provide the authority responsible for protecting the rights of personal data subjects, upon request, with the required information within 10 days from the date such request is received;

— publish this Personal Data Processing Policy or otherwise ensure unrestricted access to it;

— take legal, organizational and technical measures to protect personal data against unlawful or accidental access, destruction, alteration, blocking, copying, provision or distribution, as well as against other unlawful actions involving personal data;

— stop the transfer, distribution, provision or granting of access to personal data, stop processing and destroy personal data in the manner and cases provided for by the Personal Data Law;

— perform other obligations stipulated by the Personal Data Law.

4. Main Rights and Obligations of Personal Data Subjects

4.1. Personal data subjects have the right to:

— receive information concerning the processing of their personal data, except in cases provided for by federal laws. Such information shall be provided by the Operator in an accessible form and shall not contain personal data relating to other personal data subjects, except where there are lawful grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;

— require the Operator to clarify, block or destroy their personal data if the data is incomplete, outdated, inaccurate, unlawfully obtained or unnecessary for the stated purpose of processing, and to take measures provided by law to protect their rights;

— require prior consent for the processing of personal data for the purpose of promoting goods, works and services in the market;

— withdraw consent to the processing of personal data and submit a request to stop the processing of personal data;

— challenge unlawful actions or omissions of the Operator in connection with the processing of personal data before the authority responsible for protecting the rights of personal data subjects or in court;

— exercise other rights provided for by the laws of the Russian Federation.

4.2. Personal data subjects shall:

— provide the Operator with accurate information about themselves;

— notify the Operator of any clarification, update or change to their personal data.

4.3. Persons who provide the Operator with inaccurate information about themselves or information about another personal data subject without that subject’s consent shall be liable in accordance with the laws of the Russian Federation.

5. Principles of Personal Data Processing

5.1. Personal data shall be processed lawfully and fairly.

5.2. Personal data processing shall be limited to the achievement of specific, predetermined and lawful purposes. Processing that is incompatible with the purposes for which personal data was collected is not permitted.

5.3. Databases containing personal data processed for mutually incompatible purposes shall not be combined.

5.4. Only personal data that is relevant to the purposes of processing shall be processed.

5.5. The content and scope of the personal data processed shall correspond to the stated purposes of processing. Excessive personal data processing in relation to the stated purposes is not permitted.

5.6. The accuracy, sufficiency and, where necessary, relevance of personal data in relation to the purposes of processing shall be ensured. The Operator shall take, or ensure that others take, the necessary measures to delete or clarify incomplete or inaccurate data.

5.7. Personal data shall be stored in a form that allows the personal data subject to be identified for no longer than required by the purposes of processing, unless the storage period is established by federal law or by an agreement to which the personal data subject is a party, beneficiary or guarantor. Personal data being processed shall be destroyed or anonymized once the purposes of processing have been achieved or where the need to achieve such purposes no longer exists, unless otherwise provided by federal law.

6. Purposes of Personal Data Processing

Purpose of processing:

Providing information to the User by sending emails.

Personal data processed:

— surname, first name and patronymic;

— email address;

— telephone numbers;

— Telegram account.

Legal grounds:

Agreements entered into between the Operator and the personal data subject.

Types of personal data processing:

— collection, recording, organization, accumulation, storage, destruction and anonymization of personal data;

— sending informational messages to an email address.

7. Conditions for Personal Data Processing

7.1. Personal data shall be processed with the consent of the personal data subject.

7.2. Personal data processing is necessary to achieve purposes stipulated by an international treaty of the Russian Federation or by law, or to exercise the functions, powers and duties assigned to the Operator by the laws of the Russian Federation.

7.3. Personal data processing is necessary for the administration of justice or the enforcement of a judicial act, an act of another authority or an official that is enforceable in accordance with the laws of the Russian Federation on enforcement proceedings.

7.4. Personal data processing is necessary for the performance of an agreement to which the personal data subject is a party, beneficiary or guarantor, as well as for entering into an agreement at the initiative of the personal data subject or an agreement under which the personal data subject will be a beneficiary or guarantor.

7.5. Personal data processing is necessary to exercise the rights and legitimate interests of the Operator or third parties, or to achieve socially significant purposes, provided that the rights and freedoms of the personal data subject are not thereby violated.

7.6. Personal data to which access by an unlimited number of persons has been granted by the personal data subject or at the subject’s request shall be processed (hereinafter referred to as “publicly available personal data”).

7.7. Personal data subject to publication or mandatory disclosure in accordance with federal law shall be processed.

8. Procedure for the Collection, Storage, Transfer and Other Processing of Personal Data

The security of personal data processed by the Operator shall be ensured through the implementation of legal, organizational and technical measures necessary to fully comply with applicable personal data protection laws.

8.1. The Operator shall ensure the security of personal data and take all possible measures to prevent unauthorized persons from accessing personal data.

8.2. Under no circumstances shall the User’s personal data be transferred to third parties, except where such transfer is required to comply with applicable law or where the personal data subject has consented to the transfer of data by the Operator to a third party for the performance of obligations under a civil-law agreement.

8.3. If inaccuracies are identified in personal data, the User may update the data by sending a notice to the Operator at tech@redhr.ru with the subject line “Personal Data Update.”

8.4. The personal data processing period shall be determined by the achievement of the purposes for which the personal data was collected, unless another period is provided for by an agreement or applicable law.

The User may withdraw consent to the processing of personal data at any time by sending a notice to the Operator at tech@redhr.ru with the subject line “Withdrawal of Consent to Personal Data Processing.”

8.5. All information collected by third-party services, including payment systems, communications providers and other service providers, shall be stored and processed by such persons (operators) in accordance with their respective user agreements and privacy policies. The personal data subject shall familiarize themselves with the relevant documents. The Operator shall not be liable for the actions of third parties, including the service providers referred to in this clause.

8.6. Restrictions imposed by the personal data subject on the transfer of personal data, except for the provision of access, as well as restrictions on processing or conditions of processing, except for obtaining access, of personal data authorized for distribution shall not apply where personal data is processed in state, public or other public interests defined by the laws of the Russian Federation.

8.7. When processing personal data, the Operator shall ensure the confidentiality of such data.

8.8. The Operator shall store personal data in a form that allows the personal data subject to be identified for no longer than required by the purposes of processing, unless the storage period is established by federal law or by an agreement to which the personal data subject is a party, beneficiary or guarantor.

8.9. Grounds for terminating personal data processing may include achievement of the purposes of processing, expiration of the personal data subject’s consent, withdrawal of consent by the personal data subject, a request to stop processing personal data, or identification of unlawful personal data processing.

9. Actions Performed by the Operator with Personal Data Received

9.1. The Operator shall collect, record, organize, accumulate, store, clarify (update or modify), retrieve, use, transfer (distribute, provide or grant access), anonymize, block, delete and destroy personal data.

9.2. The Operator shall carry out automated processing of personal data, with or without the receipt and/or transfer of the information obtained through information and telecommunications networks.

10. Cross-Border Transfer of Personal Data

10.1. Before commencing any activity involving the cross-border transfer of personal data, the Operator shall notify the authority responsible for protecting the rights of personal data subjects of its intention to carry out cross-border transfers of personal data. Such notification shall be submitted separately from the notification of intent to process personal data.

10.2. Before submitting the above notification, the Operator shall obtain the relevant information from the authorities of the foreign state, foreign individuals or foreign legal entities to which the personal data is intended to be transferred.

11. Confidentiality of Personal Data

The Operator and other persons who have obtained access to personal data shall not disclose personal data to third parties or distribute it without the consent of the personal data subject, unless otherwise provided by federal law.

12. Final Provisions

12.1. The User may obtain clarification on any matters concerning the processing of personal data by contacting the Operator by email at tech@redhr.ru.

12.2. Any amendments to the Operator’s Personal Data Processing Policy shall be reflected in this document. This Policy shall remain in effect indefinitely until replaced by a new version.

12.3. The current version of the Policy is publicly available on the Internet at https://redhr.tech/policy.