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Policy of Renest Limited Liability Companywith regard to personal data processing

1. General provisions

1.1 This Renest Limited Liability Company Policy on Personal Data Processing (hereinafter - the Policy) is developed in compliance with the requirements of clause 2 of part 2. 2 ч. 1 of the Article 18.1 of the Federal Law of 27.07.2006 N 152-FZ "On Personal Data" (hereinafter - the Personal Data Law) in order to ensure the protection of human and civil rights and freedoms in the processing of 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 Renest Limited Liability Company (hereinafter the "Operator", "Renest" LLC).
1.3. The Policy applies to relations in the field of personal data processing which have arisen with the Operator both before and after approval of this Policy.
1.4 In accordance with the requirements of Part 2, Article 18.1 of the Personal Data Law, this Policy shall be published in free access on the information and telecommunications network of Internet on the website of the Operator.
1.5 Basic concepts used in the Policy:
personal data - any information relating to a directly or indirectly identified or identifiable individual (personal data subject);
personal data operator (operator) - a state body, municipal body, legal entity or individual, independently or together with other persons, arranging and (or) performing processing of personal data, as well as determining the purpose of personal data processing, composition of personal data to be processed, actions (operations) performed with personal data;
processing of personal data - any action (operation) or a set of actions (operations) with personal data, performed with or without the use of automation tools. Processing of personal data includes, but is not limited to:

• collection;
• entry;
• systematization;
• accumulation;
• storage;
• clarification (update, change);
• extraction;
• use;
• transmission (distribution, provision, access);
• depersonalization;
• blocking;
• removal;
• destruction;

automated processing of personal data - processing of personal data by means of computer equipment;
dissemination of personal data - actions aimed at disclosure of personal data to an indefinite number of persons;
provision of personal data - actions aimed at disclosure of personal data to a certain person or a certain circle of persons;
blocking of personal data - temporary termination of personal data processing (except for cases when processing is necessary to clarify personal data);
destruction of personal data - actions resulting in impossibility to restore content of personal data in information system of personal data and (or) resulting in destruction of tangible carriers of personal data;
depersonalization of personal data - actions, as a result of which it becomes impossible, without the use of additional information, to determine the identity of the personal data to a particular personal data subject;
personal data information system - means an aggregate of information technologies and technical means contained in personal data bases and ensuring personal data processing;
trans-border transfer of personal data - transfer of personal data to the territory of a foreign state to a foreign state authority, foreign individual or foreign legal entity.
1.6. Basic rights and obligations of the Operator.
1.6.1 The Operator has the right: имеет право:

• independently determine the composition and list of measures necessary and sufficient to ensure fulfillment of obligations provided by the Personal Data Law and regulatory legal acts adopted in accordance therewith, unless otherwise provided by the Personal Data Law or other federal laws;
• to assign processing of personal data to another person with the consent of the personal data subject, unless otherwise provided by the federal law, on the basis of the contract concluded with this person. The person processing personal data on behalf of the Operator shall comply with the principles and rules of personal data processing stipulated by the Personal Data Law;
• in case of revocation of personal data subject's consent to personal data processing, the Operator shall be entitled to continue processing of personal data without consent of the personal data subject on the grounds specified in the Personal Data Law.

1.6.2. The Operator shall:

• organize processing of personal data in accordance with the requirements of the Law on Personal Data;
• to respond to requests and inquiries of personal data subjects and their legal representatives in accordance with the requirements of the Law on Personal Data;
• to inform the authorized body for protection of the rights of subjects of personal data (Federal Service for Supervision of Communications, Information Technology and Mass Media (Roskomnadzor)) of the necessary information upon the request of this body within 30 days from the date of receipt of such request.

1.7 Basic rights of the subject of personal data. The subject of personal data has the right to

• receive information related to processing of his/her personal data, except for cases stipulated by federal laws. Information shall be provided to the subject of personal data by the Operator in an accessible form and shall not contain personal data relating to other subjects of personal data, except in cases where there are legitimate grounds for disclosure of such personal data. The list of information and the procedure for obtaining it is established by the Personal Data Law;
• require the operator to clarify his personal data, block or destroy it if the personal data is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing, as well as to take statutory measures to protect his rights;
• to condition prior consent when processing personal data for the purpose of promoting goods, works and services on the market;
• appeal to Roskomnadzor or to a court of law against unlawful actions or omissions of the Operator in processing his personal data.

1.8 Compliance with the requirements of this Policy shall be monitored by an authorized person responsible for organization of personal data processing at the Operator.
1.9 Responsibility for violation of requirements of the legislation of the Russian Federation and regulations of Renest LLC in the field of processing and protection of personal data is determined in accordance with the legislation of the Russian Federation.

2. Purposes of personal data collection

2.1 Processing of personal data shall be limited to achieving specific, predetermined and legitimate purposes. Processing of personal data that is incompatible with the purposes of personal data collection shall not be permitted.
2.2 Only personal data that meets the purposes of its processing shall be processed.
2.3 Processing of personal data by the Operator shall be carried out for the following purposes:

• ensuring compliance with the Constitution of the Russian Federation, federal laws and other regulatory legal acts of the Russian Federation;
• carrying out its activities in accordance with the Charter of Renest LLC;
• implementation of civil law relations;
• bookkeeping.

2.4 Processing of employees' personal data may be carried out solely for the purpose of ensuring compliance with laws and other regulations.

3. Legal basis of personal data processing

3.1 The legal basis for processing of personal data shall be a set of regulatory legal acts, pursuant to which and in accordance with which the Operator carries out processing of personal data, including:

• Constitution of the Russian Federation;
• Civil Code of the Russian Federation;
• Labour Code of the Russian Federation;
• Tax Code of the Russian Federation;
• Federal Law dated 08.02.1998 N 14-FZ "On Limited Liability Companies";
• Federal Law dated 06.12.2011 N 402-FZ "On Accounting";
• Federal Law dated 15.12.2001 N 167-FZ "On Compulsory Pension Insurance in the Russian Federation";
• other normative legal acts regulating relations connected with the Operator's activity.

3.2 The legal basis for processing personal data shall also be:

• the charter of Renest LLC;
• agreements concluded between the Operator and subjects of personal data;
• consent of personal data subjects to processing of their personal data.

4. Amount and categories of personal data processed, categories of subjects of personal data

4.1 The content and scope of processed personal data shall comply with the stated processing purposes provided for in Section 2 of this Policy. 2 of this Policy. Processed personal data shall not be redundant in relation to the stated purposes of its processing.
4.2 The Operator may process personal data of the following categories of personal data subjects.
4.2.1 Customers and counterparties of the Operator (individuals):

• last name, first name, middle name;
• date and place of birth;
• passport details;
• residence registration address;
• contact information;
• position to be filled;
• individual taxpayer number;
• account number;
• other personal data provided by customers and counterparties (individuals) required for conclusion and execution of contracts.

4.2.5. Representatives (employees) of the Operator's clients and counterparties (legal entities):

• last name, first name, middle name;
• passport details;
• contact information;
• position to be filled;
• other personal data provided by representatives (employees) of clients and counterparties necessary for conclusion and execution of contracts.

4.3 Processing of biometric personal data (information that characterizes the physiological and biological characteristics of a person, on the basis of which his identity can be established) by the Operator is carried out in accordance with the legislation of the Russian Federation.
4.4. The Operator shall not process special categories of personal data relating to race, ethnicity, political views, religious or philosophical beliefs, health status, intimate life, except in cases provided for by Russian law.

5. Procedure and conditions of personal data processing

5.1 Processing of personal data shall be carried out by the Operator in accordance with the requirements of the legislation of the Russian Federation.
5.2 Processing of personal data shall be carried out with the consent of personal data subjects for processing of their personal data, as well as without such consent in cases stipulated by the legislation of the Russian Federation.
5.3 The Operator carries out both automated and non-automated processing of personal data.
5.4 Employees of the Operator, whose job duties include personal data processing, shall be allowed to process personal data.
5.5. Обработка персональных данных осуществляется путем:

• receipt of personal data verbally and in writing directly from the subjects of personal data;
• obtaining personal data from publicly available sources;
• entering personal data into the Operator's registers, registers and information systems;
• use of other methods of personal data processing.

5.6 Disclosure to third parties and dissemination of personal data without consent of the personal data subject shall not be permitted, unless otherwise provided by the federal law. Consent for processing of personal data permitted by the personal data subject for dissemination shall be executed separately from other consents of the personal data subject for processing of his/her personal data.
Requirements for the content of consent to the processing of personal data allowed to the subject of personal data for distribution, approved by Order of Roskomnadzor from 24.02.2021 N 18.
5.7 Transfer of personal data to the bodies of inquiry and investigation, the Federal Tax Service, the Pension Fund of the Russian Federation, the Social Insurance Fund and other authorized executive authorities and organizations is carried out in accordance with the requirements of the legislation of the Russian Federation.
5.8. The Operator shall take necessary legal, organizational and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, distribution and other unauthorized actions, including:

• determines threats to the security of personal data in the course of its processing;
• adopts local regulatory acts and other documents regulating relations in the field of processing and protection of personal data;
• appoints persons responsible for ensuring security of personal data in structural subdivisions and information systems of the Operator;
• creates the necessary conditions for working with personal data;
• organizes accounting of documents containing personal data;
• organizes work with information systems in which personal data are processed;
• store personal data in a manner that ensures its security and prevents unauthorized access to it;
• arranges training for the Operator's employees engaged in processing of personal data.

5.9. The operator shall store personal data in a form that allows for identification of the personal data subject for no longer than the personal data processing purposes require, unless the personal data storage period is established by federal law or by contract.
5.10. When collecting personal data, including by means of the information and telecommunications network Internet, the Operator shall ensure recording, systematization, accumulation, storage, clarification (updating, modification), extraction of personal data of citizens of the Russian Federation using databases located in the Russian Federation, except in cases specified in the Law on Personal Data.

6. Updating, correction, deletion and destruction personal data, responses to subjects' requests to access personal data

6.1. Подтверждение факта обработки персональных данных Оператором, правовые основания и цели обработки персональных данных, а также иные сведения, указанные в ч. 7 ст. 14 Закона о персональных данных, предоставляются Оператором субъекту персональных данных или его представителю при обращении либо при получении запроса субъекта персональных данных или его представителя.
Personal data relating to other personal data subjects shall not be included in the information provided, unless there is a legitimate reason for disclosing such personal data.
The request must contain:

• number of the main document certifying identity of the subject of personal data or his/her representative, information on the date of issue of such document and the authority that issued it;
• information confirming participation of the personal data subject in relations with the Operator (contract number, contract conclusion date, conventional word mark and (or) other information), or information otherwise confirming the fact of personal data processing by the Operator;
• signature of the personal data subject or his/her representative.

The request may be sent in the form of an electronic document and signed by electronic signature in accordance with the laws of the Russian Federation.
If the personal data subject's application (request) does not reflect all the necessary information in accordance with the requirements of the Law on Personal Data, or if the subject does not have the rights to access the requested information, a reasoned refusal shall be sent.
The subject's right to access his personal data may be limited in accordance with Part 8 of Article 14 of the Law on Personal Data, including if the subject's access to his personal data violates the rights and legitimate interests of third parties.
6.2 In case of identification of inaccurate personal data upon request of the subject of personal data or his/her representative or at their request or at the request of Roskomnadzor, the Operator shall block personal data related to this subject of personal data from the moment of such request or receipt of such request for the verification period, if blocking of personal data does not violate rights and legitimate interests of the subject of personal data or third parties.
In case of confirmation of inaccuracy of personal data, the Operator shall clarify personal data within seven business days of submission of such information and remove blocking of personal data based on information submitted by the subject of personal data or his/her representative or Roskomnadzor or other necessary documents.
6.3 If unlawful processing of personal data is detected upon application (request) of the personal data subject or his/her representative or Roskomnadzor, the Operator shall block unlawfully processed personal data related to such personal data subject from the moment of such application or request receipt.
6.4 Upon achievement of the personal data processing objectives, as well as in case of withdrawal of consent to its processing by the personal data subject, the personal data shall be destroyed if:

• other than as provided in the contract to which the personal data subject is a party, beneficiary or guarantor;
• the operator shall not be entitled to carry out processing without the consent of the personal data subject on the grounds stipulated by the Personal Data Law or other federal laws;
• otherwise is not stipulated by another agreement between the Operator and the subject of personal data.

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