10XRate

1 GENERAL PROVISIONS

This Policy defines the procedure for processing personal data and measures to ensure the security of personal data in order to protect the rights and freedoms of a person and citizen when processing his personal data, including the protection of the rights to privacy, personal and family secrets.

The Policy uses the following basic concepts: automated processing of personal data – processing of personal data using computer technology;

blocking of personal data – temporary cessation of 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 that make it impossible to determine the ownership of personal data by a specific subject of personal data without the use of additional information;

processing of personal data – any action (operation) or set of actions (operations) performed with the use of automation tools or without the use of such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data;

operator – a government agency, municipal agency, 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 processing personal data, the composition of personal data to be processed, actions (operations) performed with personal data;

personal data – any information related to a directly or indirectly determined or determinable individual (subject of personal data);

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; cross-border transfer

of personal data – transfer of personal data to the territory of a foreign state to a government body of a foreign state, a foreign individual or a foreign legal entity.

destruction of personal data – actions as a result of which it becomes impossible to restore the content of personal data in the personal data information system and (or) as a result of which the tangible carriers of personal data are destroyed;

2 PRINCIPLES AND CONDITIONS OF PERSONAL DATA PROCESSING

2.1 Principles of personal data processing

The Operator processes personal data based on the following principles:
legality and fairness;
limitation of personal data processing to achieving specific, predetermined and legitimate purposes;
prevention of processing of personal data incompatible with the purposes of collecting personal data;
prevention of 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; compliance of the content and volume of processed personal data with the stated purposes of processing;
prevention of 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 processing personal data;
destruction or depersonalization of personal data upon achieving the purposes of their processing or in the event of loss of the need to achieve these purposes, if the Operator is unable to eliminate the violations of personal data committed, unless otherwise provided by federal law.

2.2 Terms of personal data processing

The operator processes personal data if at least one of the following conditions is met:
personal data is processed with the consent of the personal data subject to the processing of his/her personal data;
personal data is processed in connection with the participation of a person in constitutional, civil, administrative, criminal proceedings, proceedings in arbitration courts;
personal data is processed necessary for the execution of a judicial act, an act of another body or official subject to execution in accordance with the law (hereinafter referred to as the execution of a judicial act);
personal data is processed for the execution of an agreement to which the personal data subject is a party, 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 a beneficiary or guarantor. The agreement concluded with the subject of personal data may not contain provisions that limit the rights and freedoms of the subject of personal data, establish cases of processing personal data of minors, unless otherwise provided by law, as well as provisions that allow inaction of the subject of personal data as a condition for concluding an agreement; the processing of personal data is necessary for the exercise of the rights and legitimate interests of the operator or third parties or for the achievement of socially significant goals, provided that the rights and freedoms of the subject of personal data are not violated;
the processing of personal data is subject to publication or mandatory disclosure in accordance with federal law.

2.3 Confidentiality of personal data

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

2.4 Publicly available sources of personal data

For the purposes of information support, the Operator may create publicly available sources of personal data of personal data subjects, including directories and address books. Publicly available sources of personal data may include, with the written consent of the personal data subject, their last name, first name, patronymic, date and place of birth, position, contact phone numbers, email address and other personal data provided by the personal data subject.

Information about the personal data subject must be excluded from publicly available sources of personal data at any time at the request of the personal data subject, the authorized body for the protection of the rights of personal data subjects, or by a court decision.

2.5 Special categories of personal data

The Operator may process special categories of personal data related to race, nationality, political views, religious or philosophical beliefs, health status, or intimate life in cases where
the subject of personal data has given written consent to the processing of their personal data;
the processing of personal data permitted by the subject of personal data for distribution is carried out in compliance with prohibitions and conditions,
the processing of personal data is carried out in accordance with the legislation on state social assistance, labor legislation, the processing of personal data is necessary to protect the life, health, or other vital interests of the subject of personal data or the life, health, or other vital interests of other persons and obtaining the consent of the subject of personal data is impossible;
the processing of personal data is carried out for medical and preventive purposes, in order to establish a medical diagnosis, and provide medical and medical social services.
the processing of personal data is necessary to establish or exercise the rights of the subject of personal data 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 insurance legislation.
The processing of personal data on criminal records may be carried out by the Operator exclusively in cases and in the manner 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 consent of the subject of personal data in writing.

Provision of biometric personal data cannot be mandatory. The Operator has no right to refuse service in the event of refusal of the subject of personal data to provide biometric personal data and (or) to give consent to the processing of personal data, if in accordance with federal law, obtaining consent for the processing of personal data by the operator is not mandator.

3 RIGHTS OF THE PERSONAL DATA SUBJECT

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

The subject of personal data makes a decision on the provision of his personal data and gives consent to their processing freely, of his own free will and in his own interests. Consent to the processing of personal data may be given by the subject of personal data or his representative in any form that allows confirming the fact of its receipt, unless otherwise established by federal law.

3.2 Rights of the personal data subject

The personal data subject has the right to receive information from the Operator regarding the processing of his personal data, unless such right is limited in accordance with federal laws. The personal data subject has the right to demand that the Operator clarify his personal data, block or destroy it if the personal data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated purpose of processing, and also to take measures provided by law to protect his rights.

The processing of personal data for the purpose of promoting goods, works, services on the market by means of direct contacts with the personal data subject (potential consumer) using communication tools, as well as for the purposes of political campaigning is permitted only with the prior consent of the personal data subject.

The Operator is obliged to immediately stop, 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 in relation to the subject of personal data or otherwise affect his rights and legitimate interests, except for cases stipulated by federal laws, or in the presence of written consent of the subject of personal data.

If the subject of personal data believes that the Operator processes his personal data in violation of the requirements or otherwise violates his rights and freedoms, the subject of personal data has the right to appeal the actions or inaction of the Operator to the Authorized Body for the Protection of the Rights of Subjects of Personal Data or 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, the Operator applies the following organizational and technical measures:
appointment of officials responsible for organizing the processing and protection of personal data;
limiting the composition of persons admitted to the processing of personal data; familiarizing subjects with the requirements of federal legislation and regulatory documents of the Operator on the processing and protection of personal data; organizing the accounting, storage and circulation of media containing information with personal data;
identifying threats to the security of personal data during their processing, forming threat models on their basis;
developing a personal data protection system based on the threat model;
checking the readiness and effectiveness of the use of information security tools; delimiting user access to information resources and software and hardware for information processing;
registering and recording the actions of users of personal data information systems;
using anti-virus tools and tools for restoring the personal data protection system;
application, where necessary, of firewalling, intrusion detection, security analysis and cryptographic information protection tools;
organization of access control to the Operator’s territory, security of premises with technical means for processing personal data.

5 FINAL PROVISIONS

Other rights and obligations of the Operator in connection with the processing of personal data are determined by the legislation in the field of personal data.

Employees of the Operator guilty of violating the rules governing the processing and protection of personal data bear material, disciplinary, administrative, civil or criminal liability in the manner prescribed by law.