COMPANY POLICY ON PERSONAL DATA PROCESSING

I. GENERAL PROVISIONS

The Personal Data Processing Policy (hereinafter – the Policy) is developed in accordance with the Federal Law No. 152-FZ dated 27.07.2006 "On Personal Data" (hereinafter – FZ-152).
This Policy determines the procedure for processing personal data and measures to ensure the security of personal data in IQ TECHNOLOGY LLC (hereinafter – the Operator) in order to protect human and civil rights and freedoms during the processing of their 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 by means of computer technology;
• blocking of personal data – temporary cessation of personal data processing (except for cases where processing is necessary to clarify personal data);
• personal data information system – an aggregate of personal data contained in databases and information technologies and technical means ensuring their processing;
• depersonalization of personal data – actions as a result of which it is impossible to determine, without using additional information, the belonging of personal data to a specific personal data subject;
• processing of personal data – any action (operation) or 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) carrying out the processing of personal data, as well as determining the purposes of personal data processing, the composition of personal data to be processed, actions (operations) performed with personal data;
• personal data – any information relating to a directly or indirectly identified or identifiable natural person (personal data subject);
• provision of personal data – actions aimed at disclosing personal data to a specific person or a specific circle of persons;
• dissemination of personal data – actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or at making personal data familiar to an unlimited circle of persons, including the publication of personal data in the mass media, placement in information and telecommunication 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 a foreign state authority, 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, Article 18.1 of FZ-152.

II. PRINCIPLES AND CONDITIONS OF PERSONAL DATA PROCESSING

II.I Principles of Personal Data Processing
The processing of personal data by the Operator is carried out based on the following principles:

• lawfulness and fairness;
• limiting the processing of personal data to the achievement of specific, predetermined and lawful purposes;
• preventing the processing of personal data incompatible with the purposes of collecting personal data;
• preventing the merging 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;
• correspondence of the content and volume of processed personal data to the stated purposes of processing;
• preventing the processing of personal data excessive in relation to the stated purposes of their processing;
• ensuring the accuracy, adequacy and relevance of personal data in relation to the purposes of personal data processing;
• destruction or depersonalization of personal data upon achieving the purposes of their processing or in case of loss of necessity to achieve these purposes, if it is impossible for the Operator to eliminate violations of personal data, unless otherwise provided by federal law.

II.II Conditions for Personal Data Processing
The Operator processes personal data if at least one of the following conditions exists:

• the processing of personal data is carried out with the consent of the personal data subject to the processing of his/her personal data;
• the processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, for the implementation and performance of the functions, powers and duties imposed on 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 subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings;
• the processing of personal data is necessary for the execution of a contract to which the personal data subject is a party, a beneficiary or a guarantor, as well as for concluding a contract on the initiative of the personal data subject or a contract under which the personal data subject will be a beneficiary or a guarantor;
• the processing of personal data is necessary for the exercise of the rights and legitimate interests of the operator or third parties or for achieving socially significant purposes, provided that the rights and freedoms of the personal data subject are not violated;
• the processing of personal data is carried out, access to which is provided to an unlimited number of persons by the personal data subject or at his/her request (hereinafter – publicly available personal data);
• the processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.

II.III Confidentiality of Personal Data
The Operator and other persons who have gained access to personal data are obliged not to disclose to third parties and not to distribute personal data without the consent of the personal data subject, unless otherwise provided by federal law.

II.IV Publicly Available Sources of Personal Data
For information purposes, the Operator may create publicly available sources of personal data of subjects, including directories and address books. With the written consent of the subject, his/her last name, first name, patronymic, date and place of birth, position, contact phone numbers, email address and other personal data communicated by the personal data subject may be included in publicly available sources of personal data.
Information about the subject must be excluded from publicly available sources of personal data at any time upon the request of the subject or by decision of a court or other authorized state bodies.

II.V Special Categories of Personal Data
The processing by the Operator of special categories of personal data concerning race, nationality, political views, religious or philosophical beliefs, health status, intimate life is permitted in cases where:

• the personal data subject has given written consent to the processing of his/her personal data;
• the personal data has been made publicly available by the personal data subject;
• 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 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 obtaining the consent of the personal data subject is impossible;
• the processing of personal data is carried out for medical and preventive purposes, for the purpose of establishing a medical diagnosis, providing medical and medico-social services, provided that the processing of personal data is carried out by a person professionally engaged in medical activities and obliged in accordance with the legislation of the Russian Federation to maintain medical confidentiality;
• the processing of personal data is necessary for the establishment or exercise of 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 mandatory types of insurance, insurance legislation.

The processing of special categories of personal data must be immediately terminated if the reasons for which they were processed are eliminated, unless otherwise established by federal law.

The processing of personal data on criminal records may be carried out by the Operator only in cases and in the manner determined in accordance with federal laws.

II.VI Biometric Personal Data
Information that characterizes the physiological and biological characteristics of a person, on the basis of which his/her identity can be established – biometric personal data – may be processed by the Operator only with the written consent of the subject.

II.VII Entrusting 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.

II.VIII 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 intended ensures adequate protection of the rights of personal data subjects, before starting such transfer.
Cross-border transfer of personal data to the territories of foreign states that do not ensure adequate protection of the rights of personal data subjects may be carried out in cases of:

• availability of written consent of the personal data subject to the cross-border transfer of his/her personal data;
• performance of a contract to which the personal data subject is a party.

III. RIGHTS OF THE PERSONAL DATA SUBJECT

III.I Consent of the Personal Data Subject to the Processing of His/Her Personal Data
The personal data subject makes a decision on providing his/her personal data and gives consent to their processing freely, by his/her own will and in his/her interest. Consent to the processing of personal data may be given by the personal data subject or his/her 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/her personal data or proof of the existence of grounds specified in FZ-152 is imposed on the Operator.

III.II Rights of the Personal Data Subject
The personal data subject has the right to receive information from the Operator regarding the processing of his/her personal data, unless such right is limited in accordance with federal laws. The personal data subject has the right to demand from the Operator clarification of his/her personal data, their blocking or destruction if the personal data are incomplete, outdated, inaccurate, illegally obtained or are not necessary for the stated purpose of processing, as well as to take measures provided by law to protect his/her rights.

The processing of personal data for the purpose of promoting goods, works, services on the market by means of direct contact with a potential consumer via communication means, as well as for the purpose of political campaigning, is allowed only with the prior consent of the personal data subject. The said processing of personal data is deemed to be carried out without the prior consent of the personal data subject if the Company does not prove that such consent was obtained.
The Operator is obliged to immediately terminate, at the request of the personal data subject, the processing of his/her personal data for the above purposes.

It is prohibited to make decisions based solely on automated processing of personal data that give rise to legal consequences for the personal data subject or otherwise affect his/her rights and legitimate interests, except for cases provided for by federal laws, or with the written consent of the personal data subject.
If the personal data subject believes that the Operator processes his/her personal data in violation of the requirements of FZ-152 or otherwise violates his/her rights and freedoms, the personal data subject has the right to appeal against the actions or inaction of the Operator to the Authorized Body for the Protection of the Rights of Personal Data Subjects or in court.

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

IV. 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, the Operator applies the following organizational and technical measures:

• appointment of officials responsible for organizing the processing and protection of personal data;
• limitation of the list of persons having access to personal data;
• familiarization of subjects with the requirements of federal legislation and the Operator's regulatory documents on the processing and protection of personal data;
• organization of accounting, storage and handling of information carriers;
• identification of threats to the security of personal data during their processing, formation on their basis of threat models;
• development of a personal data protection system based on the threat model;
• verification of readiness and effectiveness of the use of information protection means;
• differentiation of user access to information resources and software and hardware for information processing;
• registration and accounting of user actions in personal data information systems;
• use of antivirus tools and tools for restoring the personal data protection system;
• application, where necessary, of firewalls, intrusion detection systems, security analysis tools and cryptographic information protection tools;
• organization of access control to the Operator's territory, guarding premises with technical means for processing personal data.

V. FINAL PROVISIONS

Other rights and obligations of the Operator as a personal data operator are determined by the legislation of the Russian Federation in the field of personal data.
Officials of the Operator guilty of violating the norms regulating the processing and protection of personal data bear material, disciplinary, administrative, civil or criminal liability in the manner prescribed by federal laws.