1. General provisions

This Policy on the processing of personal data has been prepared in accordance with the requirements of Federal Law No. 152-FZ of July 27, 2006 “On Personal Data” (hereinafter — the Personal Data Law) and determines the procedure for processing personal data and measures to ensure the security of personal data undertaken by Limited Liability Company “Atlas” (hereinafter — the Operator). 1.1. The Operator’s most important goal and condition for carrying out its activities is 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 secrecy. 1.2. This Operator’s Policy on the processing of personal data (hereinafter — the Policy) applies to all information that the Operator may obtain about visitors to the website https://buroatlas.com/.

2. Basic Terms Used in the Policy

2.1. Automated processing of personal data – processing of personal data using computer technology. 2.2. Blocking of personal data – temporary suspension of the processing of personal data (except where processing is necessary to clarify personal data). 2.3. Website — a collection of graphic and informational materials, as well as software and databases ensuring their accessibility on the Internet at https://buroatlas.com 2.4. Information system of personal data — a set of personal data contained in databases and information technologies and technical means ensuring their processing. 2.5. Depersonalization of personal data — actions that result in the impossibility of determining, without additional information, whether personal data belongs to a specific User or another personal data subject. 2.6. 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, and destruction of personal data. 2.7. Operator — a state body, municipal body, legal or natural person who, independently or jointly with other persons, organizes and/or carries out the processing of personal data, as well as determines the purposes of personal data processing, the composition of personal data to be processed, and the actions (operations) performed with personal data. 2.8. Personal data — any information relating directly or indirectly to a specific or identifiable User of the website https://buroatlas.com 2.9. Personal data permitted for dissemination — personal data to which the personal data subject has granted access to an unlimited number of persons by giving consent for processing such data for dissemination as provided for by the Personal Data Law. 2.10. User — any visitor to the website https://buroatlas.com 2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific group of persons. 2.12. Dissemination of personal data — any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or making personal data available to an unlimited number of persons, including publication in the media, placement in information and telecommunication networks, or providing access to personal data in any other way. 2.13. 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. 2.14. Destruction of personal data — any actions resulting in the irreversible destruction of personal data with the impossibility of further restoration of the content of personal data in the personal data information system and/or the destruction of physical media containing personal data.

3. Main Rights and Obligations of the Operator

3.1. The Operator has the right to: — receive from the personal data subject reliable information and/or documents containing personal data. — in case the personal data subject withdraws consent to the processing of personal data, or submits a request to cease processing, continue processing personal data without consent if there are legal grounds provided by the Personal Data Law. — independently determine the composition and list of measures necessary and sufficient to ensure compliance with the obligations established by the Personal Data Law and other regulatory acts, unless otherwise provided by federal law. 3.2. The Operator must: — provide the personal data subject, upon request, with information regarding the processing of their personal data; — organize the processing of personal data in accordance with the laws of the Russian Federation; — respond to inquiries and requests from personal data subjects or their legal representatives in accordance with the requirements of the Personal Data Law; — submit the required information to the authorized body for the protection of the rights of personal data subjects within ten (10) days of receiving such a request; — publish or otherwise ensure unrestricted access to this Policy regarding the processing of personal data; — take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision, dissemination, as well as other unlawful actions; — cease transfer (distribution, provision, access), processing, and destroy personal data in the manner and cases established by the Personal Data Law; — fulfill other obligations established by the Personal Data Law.

4. Main Rights and Obligations of Personal Data Subjects

4.1. Personal data subjects have the right to: — obtain information regarding the processing of their personal data, except in cases provided by federal law. The Operator shall provide such information to the subject in an accessible form and without disclosing personal data related to other subjects unless there are lawful grounds for such disclosure. The list of information and the procedure for obtaining it are established by the Personal Data Law; — request that the Operator 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 take measures to protect their rights as provided by law; — require prior consent for the processing of personal data for the purpose of promoting goods, works, or services; — withdraw consent to the processing of personal data or demand termination of processing; — appeal to the authorized body for the protection of personal data subjects’ rights or to a court against unlawful actions or omissions of the Operator in the processing of their personal data; — exercise other rights provided by the laws of the Russian Federation.. 4.2. Personal data subjects must: — provide the Operator with accurate data about themselves; — notify the Operator of clarifications (updates, changes) to their personal data. 4.3. Persons who have provided the Operator with false information about themselves or information about another personal data subject without their consent shall be held liable in accordance with the laws of the Russian Federation.

5. Principles of Personal Data Processing

5.1. Processing of personal data shall be carried out on a lawful and fair basis. 5.2. Processing of personal data shall be limited to achieving specific, predetermined, and lawful purposes. Processing of personal data incompatible with the purposes of personal data collection shall not be permitted. 5.3. It is prohibited to combine databases containing personal data if such data are processed for purposes that are incompatible with each other. 5.4. Only personal data that correspond to the purposes of their processing shall be subject to processing. 5.5. The content and scope of the personal data processed shall correspond to the stated purposes of processing. Processing of excessive personal data in relation to the stated purposes of their processing shall not be permitted. 5.6. When processing personal data, accuracy, sufficiency, and, where necessary, relevance of personal data to the purposes of processing shall be ensured. The Operator shall take necessary measures and/or ensure their implementation to delete or clarify incomplete or inaccurate data. 5.7. Personal data shall be stored in a form that allows identification of the personal data subject for no longer than required by the purposes of personal data processing, unless a different storage period is established by federal law, a contract to which the personal data subject is a party, beneficiary, or guarantor. The processed personal data shall be destroyed or depersonalized upon achievement of processing purposes or when there is no longer a need to achieve such purposes, unless otherwise provided by federal law.

6. Purposes of Personal Data Processing

6.1. Purposes of Processing Purpose: 1. Implementation of the functions, powers, and obligations of the employer in accordance with the Civil Code of the Russian Federation and the Labor Code of the Russian Federation; 2. Processing of applications and requests. Personal Data Last name, first name, patronymic; email address; phone numbers; year, month, date, and place of birth; photographs; information about education, profession, specialty and qualification; details of educational documents; information about previously held positions and employment history; military obligation and registration; other information contained in a résumé (CV). Categories of Personal Data Subjects: For the purposes specified in paragraph 1 of section 6.1 of this Policy: ● job applicants (candidates); ● employees; ● close relatives of employees. For the purposes specified in paragraph 2 of section 6.1 of this Policy: ● authorized representatives of counterparties; ● employees of counterparties. 6.2. The Operator may process personal data of job candidates and employees of LLC “Atlas” for the purposes specified in paragraph 1 of section 6.1 of this Policy, within the scope established by the Labor Code of the Russian Federation, as well as other data under the conditions of consent of the personal data subject. 6.3. The Operator shall not process special categories of personal data relating to racial or ethnic origin, political opinions, religious or philosophical beliefs, health status, or sexual life, except in cases provided for by part 2 of article 10 of Federal Law No. 152-FZ “On Personal Data” dated July 27, 2006. 6.4. The Operator does not process biometric personal data. 6.5. The Operator does not carry out cross-border transfer of personal data. 6.6. The Operator shall not place personal data in publicly available sources without the prior consent of the personal data subject, unless otherwise provided by the legislation of the Russian Federation. 6.7. The Operator may receive personal data of the subject from a person who is not the subject of personal data, provided that the Operator is presented with confirmation of the existence of grounds specified in subparagraphs 2–11 of part 1 of article 6, part 2 of article 10, and part 2 of article 11 of Federal Law No. 152-FZ “On Personal Data,” or other grounds provided by federal legislation. 6.8. Processing of personal data may be carried out both with and without the use of automation tools.

7. Conditions for Personal Data Processing

7.1. Processing of personal data shall be carried out with the consent of the personal data subject to the processing of their personal data. 7.2. 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 performance of functions, powers, and obligations imposed on the Operator by the legislation of the Russian Federation. 7.3. Processing of personal data is necessary for the administration of justice, the execution of a judicial act, or an act of another body or official enforceable under the legislation of the Russian Federation on enforcement proceedings. 7.4. Processing of personal data is necessary for the performance of a contract to which the personal data subject is a party, beneficiary, or guarantor, as well as for the conclusion of a contract on the initiative of the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor. 7.5. Processing of personal data is necessary to exercise the rights and legitimate interests of the Operator or third parties, or to achieve socially significant purposes, provided that this does not violate the rights and freedoms of the personal data subject. 7.6. Processing of personal data made publicly available by the personal data subject or at their request (hereinafter — publicly available personal data) shall be carried out. 7.7. Processing of personal data subject to publication or mandatory disclosure in accordance with federal law shall be carried out. 7.8. The Operator has the right to entrust the processing of personal data to a third party with the consent of the personal data subject and in other cases provided by the legislation of the Russian Federation, based on a contract concluded with such a party. The third party processing personal data on behalf of the Operator must comply with the requirements for the level of protection of personal data established by the regulatory legal acts of the Russian Federation.

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

The security of personal data processed by the Operator is ensured by implementing legal, organizational, and technical measures necessary to fully comply with the requirements of current legislation in the field of personal data protection. 8.1. The Operator ensures the confidentiality of personal data and takes all possible measures to prevent unauthorized access to personal data. 8.2. Personal data of the User shall never, under any circumstances, be transferred to third parties, except in cases related to compliance with applicable law or when the personal data subject has given the Operator consent to transfer data to a third party for the performance of obligations under a civil law contract. 8.3. If inaccuracies in personal data are identified, the User may update them independently by sending a notification to the Operator’s email address info@buroatlas.com marked “Update of personal data”. 8.4. The period of personal data processing shall be determined by the achievement of the purposes for which the personal data were collected, unless another period is provided by contract or applicable law. The User may at any time withdraw their consent to the processing of personal data by sending a notification to the Operator via email at info@buroatlas.com marked “Withdrawal of consent to personal data processing”. 8.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, shall be stored and processed by such entities (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject shall familiarize themselves with such documents. The Operator shall not be responsible for the actions of third parties, including the service providers mentioned in this clause. 8.6. Restrictions established by the personal data subject regarding the transfer (except for granting access), as well as the processing or conditions of processing (except for access) of personal data permitted for dissemination, shall not apply in cases of processing personal data for state, public, or other public interests established by the legislation of the Russian Federation. 8.7. The Operator shall ensure the confidentiality of personal data when processing them. 8.8. The Operator shall store personal data in a form that allows identification of the personal data subject for no longer than required by the purposes of personal data processing, unless otherwise established by federal law or contract. 8.9. Grounds for termination of personal data processing may include the achievement of processing purposes, expiration of the consent period, withdrawal of consent by the personal data subject, or identification of unlawful processing.

9. List of Actions Performed by the Operator with Received Personal Data

9.1. The Operator carries out collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data. 9.2. The Operator performs automated processing of personal data with or without the use of information and telecommunication networks.

10. Border Transfer of Personal Data

10.1. Before beginning activities involving cross-border transfer of personal data, the Operator must notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out such transfer (this notification is sent separately from the notification of intent to process personal data). 10.2. Before submitting the above notification, the Operator must obtain from the authorities of the foreign state, foreign individuals, or foreign legal entities to whom cross-border transfer of personal data is planned, the relevant information required by law.

11. Confidentiality of Personal Data

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

12. Final Provisions

12.1. The User may obtain any clarifications regarding questions related to the processing of their personal data by contacting the Operator via email at info@buroatlas.com. 12.2. Any changes to the Operator’s personal data processing policy will be reflected in this document. The Policy is valid indefinitely until replaced by a new version. 12.3. The current version of the Policy is freely available on the Internet at https://buroatlas.com.

Information about the Operator

Name: Limited Liability Company “Atlas” (INN 7704499533) Address: 119048, Moscow, intracity territory of the municipal district Khamovniki, 4 Kooperativnaya St., bldg. 15, premises 1/3 Phone: +7 (916) 322-29-85 Personal Data Operator Registry Number: 77-22-027640 Responsible person for organizing personal data processing: Sytnikova Alexandra Vadimovna Email: info@buroatlas.com