PRIVACY POLICY

CEO of Brand Group LLC
Romanenko Natalya Alexandrovna

Saint Petersburg
The edition is valid from "07" October 2022.

GENERAL PROVISIONS

This Regulation on the processing of personal data (hereinafter referred to as the Regulation, this Regulation) was developed by Brand Group LLC (hereinafter referred to as the Operator) and is applied in accordance with paragraph 2 of part 1 of Art. 18.1. Federal Law of July 27, 2006 No. 152-FZ "On Personal Data". This Regulation defines the Operator's policy regarding the processing of personal data. All issues related to the processing of personal data not regulated by this Regulation are resolved in accordance with the current legislation of the Russian Federation in the field of personal data. These Regulations and amendments to it are approved by the head of the Operator and introduced by the order of the Operator.

In accordance with paragraph 1 of Art. 3 of the Federal Law of July 27, 2006 No. 152-FZ "On Personal Data", personal data of clients, individuals means any information related to a client, individual directly or indirectly identified or determined on the basis of such information (hereinafter referred to as personal data).
Brand Group LLC is the operator organizing and (or) carrying out the processing of personal data, as well as determining the purposes and content of the processing of personal data.

The purpose of personal data processing is:

- ensuring the protection of the rights and freedoms of a person and citizen in the processing of his personal data, including the protection of the rights to privacy, personal and family secrets;
- provision by the Operator to individuals and legal entities of services related to the economic activities of the Operator, including the Operator's contacts with such persons, including by e-mail, by phone, at the address provided by the relevant person;
- sending consultations, answers to the persons who applied using the means of communication and the contract data indicated by them;
- promotion of goods, works, services of the Operator on the market by making direct contacts with a potential consumer using means of communication (allowed only with the prior consent of the subject of personal data)

Processing is organized by the Operator on the principles of:
- legitimacy of the purposes and methods of processing personal data, good faith and fairness in the activities of the Operator;
- the reliability of personal data, their sufficiency for the purposes of processing, the inadmissibility of processing personal data that is excessive in relation to the purposes stated when collecting personal data;
processing only personal data that meet the purposes of their processing;
- compliance of the content and scope of the processed personal data with the stated purposes of processing. The processed personal data should not be excessive in relation to the stated purposes of their processing;
- the inadmissibility of combining databases containing personal data, the processing of which is carried out for purposes that are incompatible with each other;
- ensuring the accuracy of personal data, their sufficiency, and, if necessary, relevance in relation to the purposes of processing personal data. The operator takes the necessary measures or ensures their adoption to remove or clarify incomplete or inaccurate data;
- storage of personal data in a form that allows you to determine the subject of personal data, no longer than required by the purposes of processing personal data.

The processing of personal data is carried out in compliance with the principles and rules provided for by the Federal Law of July 27, 2006 No. 152-FZ "On Personal Data" and this Regulation.

Personal data is processed with and without the use of automation tools.
In accordance with the goals and objectives set, the Operator, prior to the processing of personal data, appoints a person responsible for organizing the processing of personal data.

1. The person responsible for organizing the processing of personal data receives instructions directly from the executive body of the Operator and is accountable to him.

2. The person responsible for organizing the processing of personal data has the right to draw up and sign a notice provided for in Parts 1 and 3 of Art. 22 of the Federal Law of July 27, 2006 No. 152-FZ "On Personal Data".

The Operator's employees directly involved in the processing of personal data must be familiarized with the provisions of the legislation of the Russian Federation on personal data, including the requirements for the protection of personal data, documents defining the Operator's policy regarding the processing of personal data, local acts on processing issues, before starting work. personal data, with this Regulation and amendments thereto.

When processing personal data, the Operator applies legal, organizational and technical measures to ensure the security of personal data in accordance with Art. 19 of the Federal Law of July 27, 2006 No. 152-FZ "On Personal Data".

When collecting personal data using information and telecommunication networks, the Operator is obliged to publishpublish in the relevant information and telecommunications network a document that defines its policy regarding the processing of personal data and information on the requirements for the protection of personal data being implemented, as well as provide access to the specified document using the means of the corresponding information and telecommunications network.

Conditions for the processing of personal data by the Operator. The processing of personal data is allowed in the following cases:

- the processing of personal data is carried out with the consent of the subject of personal data to the processing of his personal data;
- the processing of personal data is necessary to achieve the goals stipulated by an international treaty of the Russian Federation or the law, to exercise and fulfill the functions, powers and duties assigned to the Operator by the legislation of the Russian Federation;
- processing of personal data is necessary for the performance of an agreement to which the subject of personal data is a party or beneficiary or guarantor, including if the Operator exercises its right to assign rights (claims) under such an agreement, as well as to conclude an agreement on the initiative of the subject of personal data or an agreement under which the subject of personal data will be the beneficiary or guarantor;
- the processing of personal data is necessary to protect the life, health or other vital interests of the subject of personal data, if obtaining the consent of the subject of personal data is impossible;
- 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 subject of personal data are not violated;
- the processing of personal data is carried out for statistical or other research purposes, with the exception of the purposes specified in Art. 15 of the Federal Law of July 27, 2006 No. 152-FZ "On Personal Data", subject to the mandatory depersonalization of personal data;
- processing of personal data is carried out, access of an unlimited circle of persons to which is provided by the subject of personal data or at his request;
- processing of personal data subject to publication or mandatory disclosure in accordance with federal law.
The storage of personal data should be carried out in a form that allows determining the subject of personal data, no longer than required by the purposes of their processing, and they are subject to destruction upon achievement of the purposes of processing or in case of loss of the need to achieve them in the manner prescribed by the Regulations on the storage of personal data Operator.

Personal data that is processed in information systems is subject to protection against unauthorized access and copying. The security of personal data during their processing in information systems is ensured by means of a personal data protection system, which includes organizational measures and means of protecting information. Hardware and software must meet the requirements established in accordance with the legislation of the Russian Federation, ensuring the protection of information.

Interaction with federal executive authorities on the processing and protection of personal data of subjects whose personal data is processed by the Operator is carried out within the framework of the legislation of the Russian Federation.

PROVISION BY THE OPERATOR OF THE RIGHTS OF THE SUBJECT OF PERSONAL DATA

Subjects of personal data or their representatives have the rights provided for by the Federal Law of July 27, 2006 No. 152-FZ "On Personal Data" and other regulatory legal acts regulating the processing of personal data.

The operator ensures the rights of personal data subjects in the manner prescribed by chapters 3 and 4 of the Federal Law of July 27, 2006 No. 152-FZ "On Personal Data".

The Operator is obliged to provide free of charge to the subject of personal data or his representative the opportunity to get acquainted with the personal data relating to this subject of personal data at the location of the Operator during the working hours of the Operator.

The right of the subject of personal data to access his personal data may be limited in accordance with federal laws.

In the case of representing the interests of the subject of personal data by a representative, the representative's powers are confirmed by a power of attorney drawn up in the prescribed manner.
In cases where the personal data subject provides written consent to the use of personal data, a simple written form is sufficient for such consent.

The operator guarantees the security and confidentiality of the personal data used.
The processing of personal data in order to promote goods, works, services on the market by making direct contacts with a potential consumer using means of communication is allowed only with the prior consent of the subject of personal data.

RECEIVING, PROCESSING, STORAGENAL DATA

The Operator establishes the following procedure for obtaining personal data:

1. When applying for the services of the Operator, the client indicates the data specified in the relevant forms.
2. The operator does not receive and does not process the client's personal data about his race, political views, religious and philosophical beliefs, health status, intimate life, unless otherwise provided by law.
3. In cases directly related to issues of labor relations, in accordance with Art. 24 of the Constitution of the Russian Federation, the Organization has the right to receive and process data about the private life of the client only with his written consent.

If the client accepts the offer posted on the Operator's website, or concludes another agreement with the Operator, the processing of the client's personal data is carried out for the execution of the relevant agreement, which entered into force as a result of the acceptance of the terms of the offer by the client or the conclusion of another agreement, respectively.

Also, the Operator has the right to process personal data of customers who have applied to the Operator of individuals only with their consent to the use of personal data.

The client's consent to the processing of personal data is not required in the following cases:

- personal data is publicly available;
- the processing of personal data is carried out on the basis of a federal law that establishes its purpose, the conditions for obtaining personal data and the circle of subjects whose personal data is subject to processing, as well as certain powers of the Organization;
- at the request of authorized state bodies - in cases provided for by federal law;
- processing of personal data in order to fulfill the contract concluded with the Operator;
- the processing of personal data is carried out for statistical or other scientific purposes, subject to the mandatory depersonalization of personal data;
- the processing of personal data is necessary to protect the life, health or other vital interests of the client, if obtaining his consent is impossible.

The operator ensures the safe storage of personal data, including:

1. Storage, compilation, accounting and use of documents containing personal data is organized in the form of a separate archive of the Operator.
2. Storage of personal data should be carried out in a form that allows to determine the subject of personal data, no longer than required by the purposes of processing personal data, if the period of storage of personal data is not established by federal law, an agreement to which the subject of personal data is a party, beneficiary or guarantor data. The processed personal data is subject to destruction or depersonalization upon reaching the goals of processing or in case of loss of the need to achieve these goals, unless otherwise provided by federal law.

TRANSFER OF PERSONAL DATA

Personal data is transferred subject to the following requirements:
- it is forbidden to disclose personal data to a third party without the written consent of the client, except when it is necessary in order to prevent a threat to the life, health of the client, as well as in other cases provided for by law;
- not to disclose personal data for commercial purposes without the written consent of the subject of such data;
- to warn persons receiving personal data that this data can only be used for the purposes for which it is communicated, and require these persons to confirm that this rule has been observed;
- allow access to personal data only to specially authorized persons, while these persons should have the right to receive only those personal data that are necessary to perform specific functions;
- not to request information about the client's health status, with the exception of information that relates to the issue of the client's ability to fulfill obligations under an agreement with the Operator;
- transfer the personal data of the client to his representatives in the manner prescribed by the Federal Law of July 27, 2006 No. 152-ФЗ "On Personal Data".

ACCESS TO PERSONAL DATA

The following persons have the right to access personal data:
- the head of the Operator;
- employees of the Operator working with a particular client;
- accounting staff;
- employees providing technical support for the Operator's activities.

Clients, in order to ensure the protection of personal data, have the following rights:

- full information about their personal data and the processing of this data;
- free access to their personal data, including the right to receive copies of any record containing personal data, except as otherwise provided by federal law;
- to determine their representatives to protect their personal data;
- to the requirement to exclude or correct incorrect or incomplete personal data, as well as data processed in violation of the requirements of the Federal Law of July 27, 2006 No. 152-FZ "On Personal Data".

Copying and making extracts of personal data is allowed only in the servicefor private purposes with the permission of the head.

LIABILITY FOR VIOLATION OF REGULATIONS GOVERNING THE PROCESSING OF PERSONAL DATA

Persons guilty of violating the procedure for handling personal data bear disciplinary, administrative, civil or criminal liability in accordance with federal laws.

The heads of the structural divisions of the Operator are personally responsible for the performance of duties by their subordinates.

CONTACTS

Limited Liability Company "Brand Group"
TIN: 7842123711
Gearbox: 784201001
PSRN: 1167847476752

Legal address: 191036, St. Petersburg, 7th Sovetskaya st., 22 letter a, room. 8-n 106

+7 (812) 456-78-44
office@myeventgroup.ru