I. Purpose and scope of the document.
- The purpose of Mobi-Soft Ltd Policy of privacy is to procure the protection of a person's rights and liberties while processing his/her personal data, including the right to privacy, personal and family secrecy.
- The Policy shall be strictly adhered to by all employees of Mobi-Soft Ltd.
- The Policy applies to all personal data of the involved entities, being processed by the Company with the use of automation tools and without using them.
Any personal data subject has access to this Policy.
- Personal data – any information referring directly or indirectly to a particular or identified individual (hereinafter referred to as "personal data subject"). Such information may include in particular: surname, name, patronymic, date and place of birth, address, contact telephone number, e-mail address, information about the family, social, property status, information on education, profession, income, health, as well as other information.
- Personal data processing – any action (operation) or a combination of actions (operations) performed both automatically and manually with personal data, including collection, recording, arrangement, accumulation, storage, specification (updating, changing), extraction, use, distribution (including transfer), anonymizing, blocking and destruction of personal data.
III. Mobi-Soft Ltd. processes personal data of the following persons:
- subjects with which civil-law agreements are concluded;
- employees of Mobi-Soft Ltd.;
- candidates for filling vacancies in Mobi-Soft Ltd.;
- representatives of legal entities.
IV. Personal data collection.
Processing of personal data is carried out with the consent of the data subject to the processing of his personal data.
The purpose of data collection and processing is provision of services for software development and consulting in that area.
Operator may collect, request and process the data when clients contact the company.
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V. Principles and Terms of Personal Data Processing.
- The security of personal data is treated by Mobi-Soft Ltd. as protection of the personal data from unauthorized or accidental access to them, destruction, modification, blocking, copying, provision, dissemination thereof, as well as other illegal actions in relation to the personal data, and it takes necessary legal, organizational and technical measures to protect the personal data.
- Processing and securitization of personal data is effected by Mobi-Soft Ltd. in accordance with the provisions of the Constitution of the Russian Federation, Federal Law No. 152-FZ On Personal Data dated 27.07.2006, by-laws, other federal laws of the Russian Federation covering the cases and peculiarities of the personal data processing, guidelines and methodological documents of the Federal Service for Technical and Export Control of the Russian Federation and the Federal Security Service of the Russian Federation.
- When processing personal data, Mobi-Soft Ltd. adheres to the following principles:
- legality and fair basis;
- restrictions on personal data processing through achievement of specific, pre-defined and legitimate purposes;
- preventing personal data processing that might be incompatible with the purposes of personal data collection;
- prevention of unification of databases containing personal data processed for purposes incompatible with each other;
- personal data processing meeting the objectives of the processing;
- content compliance.
- The Company processes personal data only if at least one of the following conditions exists:
- processing of personal data is carried out with the consent of the data subject to the processing of his personal data;
- personal data processing is necessary to achieve the purposes provided for by law, for implementation and performance of functions, powers and duties imposed by the legislation of the Russian Federation on the operator;
- personal data processing is required for performance of an agreement to which a personal data subject is a party or under which the data subject is a beneficiary or surety, or for conclusion of an agreement on the initiative of a personal data subject or an agreement under which a personal data subject shall be a beneficiary or surety;
- processing of personal data is required for realization of the rights and legitimate interests of an operator or third parties or for the attainment of socially significant objectives, provided that this not cause the rights and freedoms of the personal data subject to be violated;
- processing of personal data with access of unlimited number of persons to them, if permitted by the personal data subject or at his/her request;
- the personal data being processed are subject to publication or compulsory disclosure in accordance with federal laws.
- Mobi-Soft Ltd. has the right to entrust processing of personal data of individuals to third parties, on the basis of an agreement concluded with these persons. The persons engaged in personal data processing on behalf of Mobi-Soft Ltd. commit themselves to comply with the principles and rules for processing and protection of the personal data, as provided for by Federal Law No. 152-FZ On Personal Data of 27.07.2006. A list of actions (operations) with personal data will be specified for every person, to be performed by a legal entity processing the personal data; the purpose of processing, with specification of a duty of such legal entity to observe confidentiality and security of the personal data during their processing, as well as the requirements for protection of the processed personal data.
- In cases established by the legislation of the Russian Federation, Mobi-Soft Ltd. has the right to transfer personal data of individuals.
- For the purposes of information support, the Company may compile publicly available sources of the employees' personal data, including directories and address books. The following may be included in the public sources of the personal data, with the consent of the employee: his/her surname, name, patronymic, date and place of birth, position, contact phone numbers, e-mail address. The information about the employee must be excluded at any time from the publicly available sources of the personal data at his/her request or by decision of the court or other authorized government agencies.
- The Company shall destroy or depersonalize personal data upon achievement of the processing objectives or in the event of loss of the need to effect processing.
VI. Rights and obligations of an Operator.
Mobi-Soft Ltd. as personal data Operator is obliged:
- to provide to the personal data subject, upon his request, the information which is provided for by Federal Law No. 152-FZ On Personal Data dated 27.07.2006 when collecting personal data;
- to explain to the personal data subject the legal consequences of refusing to provide his personal data where the provision of personal data is compulsory in accordance with federal laws;
- to provide the following information to the personal data subject before beginning to process the personal data (except in cases provided for by Federal Law No. 152-FZ On Personal Data dated 27.07.2006) where personal data have been obtained other than from the personal data subject:
- name or surname, first name and patronymic and the address of the operator or its representative;
- the purpose and legal basis of the processing of the personal data;
- the expected users of the personal data;
- the rights of the personal data subject as established by this Federal Law;
- the source from which the personal data were obtained.
- Mobi-Soft Ltd. as personal data Operator has the right:
- to defend its rights and interests in the court;
- to provide personal data of individuals to third persons in cases established by the legislation of the Russian Federation (government agencies);
- to reject a provision of personal data providing in cases established by the legislation of Russian Federation;
- to use personal data of the subject in cases established by the legislation of the Russian Federation.
VII. Rights of a personal data subject.
An individual whose personal data are processed by Mobi-Soft Ltd. is entitled:
- to demand specification of his/her personal data, their blocking or destruction in the event that the personal data are incomplete, outdated, inaccurate, illegally obtained or are not necessary for the stated purpose of processing;
- to receive a list of processed personal data relating to an individual who has served a relevant request, and the source of these data;
- name and address of a person engaged in personal data processing on behalf of Mobi-Soft Ltd.;
- to receive the information on the timing of personal data processing, including on the period of their storage;
- to demand notification of persons who previously received incorrect or incomplete personal data about all of their exceptions, corrections or additions;
- to withdraw his consent to personal data processing;
- to appeal to the Federal Service for Supervision in the Sphere of Communications, Information Technology, and Mass Media (Roskomnadzor) or to court against the actions or inactivity of Mobi-Soft Ltd. if the individual believes that Mobi-Soft Ltd. carries out processing of his/her personal data with violation of the requirements of Federal Law No. 152-FZ On Personal Data dated 27.07.2006 or otherwise infringes his/her rights and freedoms;
- to protect his/her rights and legitimate interests, including to claim compensation for damages and/or compensation of moral harm in court.
VIII. Responsibilities for data security.
In the event of non-compliance with the provisions of this Policy, Mobi-Soft Ltd. is liable in accordance with the current legislation of the Russian Federation.
The current version of the Policy of Mobi-Soft Ltd. with respect to personal data processing is published in the website www.coddyschool.com
Mobi-Soft Ltd. when processing personal data takes the necessary legal, organizational and technical measures to protect the personal data from unauthorized or accidental access to them, destruction, modification, blocking, copying, provision, dissemination, as well as from other illegal actions regarding the personal data.
Such measures, in accordance with Federal Law 152-FZ On Personal Data dated 27.07.2006, include:
- identification of threat to security of personal data during their processing in personal data information systems;
- application of organizational and technical measures to ensure security of personal data in the course of their processing in personal data information systems, necessary to meet the requirements for personal data protection aimed to comply with the assigned levels of the personal data protection, established by the Government of the Russian Federation;
- application of means of data protection which have duly undergone conformity assessment procedures;
- assessment of efficiency of measures taken to ensure personal data protection prior to commissioning of the personal data information system;
- detection of facts of unauthorized access to personal data and taking due measures;
- retrieval of personal data modified or destroyed following the unauthorized access to them;
- establishment of rules for accessing personal data being processed in the personal data information system, as well as providing registration and recording of all actions performed with personal data in the personal data information system;
- control over applied measures aimed to ensure personal data safety and due level of security of personal data information systems;
- registration of personal-data machine-readable media;
- by organizing access control to company’s premises;
- placement of technical means for processing personal data within the protected area;
- maintenance of technical means of protection and alarm systems in the state of instant readiness;
- monitoring of user actions, investigation in case of violation of the requirements to personal data protection.
IX. Contact us.
You may receive clarification on the issues regarding processing of your personal data by sending a written request to the mailing address: 117105, Moscow, Varshavskoye Highway, 33 or to e-mail: firstname.lastname@example.org