Company Policy Regarding Personal Data Processing

1. GENERAL PROVISIONS

This Personal Data Processing Policy (hereinafter referred to as the Policy) is developed in accordance with Federal Law of July 27, 2006, No. 152-FZ “On Personal Data” (hereinafter – FZ-152).

This Policy defines the procedure for processing personal data and the measures to ensure the security of personal data at the Sole Proprietor (Individual Entrepreneur) Shapaev Artem Valeryevich, Primary State Registration Number (OGRN) 307583833300012 dated November 29, 2007, Taxpayer Identification Number (INN) 583802143483, Legal Address: 442960, Penza Region, Zarechny, Stroitely Street, 24-73 (hereinafter referred to as the Operator), in order to protect the rights and freedoms of a person and citizen when processing his or her personal data, including the protection of the right to privacy, personal and family secrets.

The following basic concepts are used in the Policy:

• automated processing of personal data – the processing of personal data using computer technology;
• blocking of personal data – the temporary suspension of personal data processing (except in cases where processing is necessary to clarify personal data);
• information system of personal data – 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;
• personal data processing – any action (operation) or set of actions (operations) performed with or without the use of automation on 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 state body, municipal body, legal entity (including the Sole Proprietor Shapaev A.V.) or an individual, independently or jointly with other persons, organizing and (or) performing the processing of personal data, as well as determining the purposes of processing personal data, the composition of personal data to be processed, and actions (operations) performed with personal data;
• personal data – any information relating directly or indirectly to an identified or identifiable individual (subject of personal data);
• provision of personal data – actions aimed at disclosing personal data to a specific person or a specific group of persons;
• distribution of personal data – actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or making personal data available to an unlimited group of persons, including the publication of personal data in the media, posting in information and telecommunication networks, or otherwise providing access to personal data;
• cross-border transfer of personal data – the transfer of personal data to the territory of a foreign state to an authority of a foreign state, a foreign individual, or a foreign legal entity.
• destruction of personal data – actions that make it impossible to restore the contents of personal data in the personal data information system and (or) result in the destruction of tangible media containing personal data.

The Company is obliged to publish this Personal Data Processing Policy or otherwise ensure unrestricted access to it in accordance with part 2 of article 18.1 of FZ-152.

2. PRINCIPLES AND CONDITIONS FOR PERSONAL DATA PROCESSING

2.1 Principles of Personal Data Processing

The Operator processes personal data based on the following principles:

• legality and fair basis;
• limiting personal data processing to achieving specific, predetermined, and legitimate purposes;
• preventing the processing of personal data that is incompatible with the purposes of personal data collection;
• preventing the merger of databases containing personal data processed for purposes incompatible with each other;
• processing only those personal data that meet the purposes of their processing;
• ensuring the content and scope of the processed personal data correspond to the stated purposes of processing;
• preventing the processing of personal data that is excessive in relation to the stated purposes of processing;
• ensuring the accuracy, sufficiency, and relevance of personal data in relation to the purposes of personal data processing;
• destroying or depersonalizing personal data upon achieving the purposes of their processing or in case the need to achieve these purposes is lost, if it is impossible for the Operator to rectify violations committed with respect to personal data, unless otherwise provided by federal law.

2.2 Conditions for Personal Data Processing

The Operator processes personal data if at least one of the following conditions is met:

• the personal data are processed with the consent of the personal data subject to process his or her personal data;
• the processing of personal data is necessary to achieve the purposes stipulated by an international treaty of the Russian Federation or a law, to perform and fulfill the functions, powers, and obligations assigned to the Operator by the legislation of the Russian Federation;
• the processing of personal data is necessary for the administration of justice, enforcement of a court ruling, or a ruling of another authority or official, enforceable in accordance with the legislation of the Russian Federation on enforcement proceedings;
• the 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 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 guarantor;
• the processing of personal data is necessary for the 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 involves personal data to which an unlimited group of persons has been granted access by the personal data subject or at his/her request (hereinafter – publicly available personal data);
• the processing involves personal data subject to publication or mandatory disclosure in accordance with federal law.

2.3 Confidentiality of Personal Data

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

2.4 Public Sources of Personal Data

For the purpose of information support, the Operator may create public sources of personal data of subjects, including directories and address books. With the written consent of the subject, public sources of personal data may include his/her last name, first name, patronymic, contact telephone numbers, email address, and other personal data provided by the personal data subject.

The information about the subject shall be excluded from publicly available sources of personal data at any time at the request of the subject or by a decision of a court or other authorized public authorities.

2.5 Special Categories of Personal Data

The Operator may process special categories of personal data relating to race, national origin, political views, religious or philosophical beliefs, health, or private life in the following cases:

• the personal data subject has given written consent to the processing of his or her personal data;
• the personal data have 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, or 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 medical diagnosis, or the provision of medical and social services, provided that the processing of personal data is carried out by a person professionally engaged in medical activities who is required under the legislation of the Russian Federation to maintain medical confidentiality;
• the processing of personal data is necessary to establish or exercise the rights of the personal data subject or third parties, or in connection with the administration of justice;
• the processing of personal data is carried out in accordance with legislation on compulsory types of insurance and insurance legislation.

The processing of special categories of personal data must be immediately terminated if the reasons for which their processing was carried out are eliminated, unless otherwise established by federal law.

The Operator may process personal data on criminal records only in cases and in the manner determined in accordance with federal laws.

2.6 Biometric Personal Data

Information that characterizes the physiological and biological features of a person, based on which his/her identity can be established — biometric personal data — may be processed by the Operator only with the written consent of the subject.

2.7 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 that person. The person entrusted by the Operator with the processing of personal data is obligated to comply with the principles and rules of personal data processing provided for by FZ-152.

2.8 Cross-Border Transfer of Personal Data

The Operator is obliged to ensure that the foreign state to whose territory the personal data are to be transferred provides adequate protection of the rights of personal data subjects before such transfer begins.

Cross-border transfer of personal data to foreign states that do not provide adequate protection of the rights of personal data subjects may be carried out in the following cases:

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

3. RIGHTS OF THE PERSONAL DATA SUBJECT

3.1 Consent of the Personal Data Subject to the Processing of His or Her Personal Data

The personal data subject makes a decision to provide his or her personal data and gives consent to their processing freely, by his or her own will, and in his or her own 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 for confirmation 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 or her personal data or proof of the availability of grounds specified in FZ-152 rests with the Operator.

3.2 Rights of the Personal Data Subject

The personal data subject has the right to obtain from the Operator information regarding the processing of his or her personal data, if such a right is not restricted in accordance with federal laws. The personal data subject has the right to demand that the Operator clarify his or her personal data, block or destroy them if the personal data are incomplete, outdated, inaccurate, obtained illegally, or are not necessary for the stated purpose of processing, as well as to take legal measures to protect his or her rights.

The processing of personal data for the purpose of promoting goods, works, and services on the market by making direct contact with potential consumers via means of communication, as well as for the purpose of political campaigning, is allowed only with the prior consent of the personal data subject. Such processing of personal data is deemed to be carried out without the prior consent of the personal data subject if the Company cannot prove that such consent was obtained.

The Operator must immediately cease processing the personal data of the subject for the above-mentioned purposes upon the demand of the personal data subject.

It is prohibited to make decisions based solely on the automated processing of personal data that produce legal consequences for the personal data subject or otherwise affect his or her rights and legitimate interests, except in 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 is processing his or her personal data in violation of the requirements of FZ-152 or otherwise violating his or 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 or her rights and legitimate interests, including the right to compensation for losses and (or) moral damage in court.

4. ENSURING THE SECURITY OF PERSONAL DATA

4.1 Ensuring the Security of Personal Data

The security of personal data processed by the Operator is ensured by legal, organizational, and technical measures necessary to meet the requirements of federal legislation in the field of personal data protection.

In order to prevent unauthorized access to personal data, the Operator applies the following organizational and technical measures:

• appointing officials responsible for organizing the processing and protection of personal data;
• limiting the number of persons who have access to personal data;
• familiarizing subjects with the requirements of federal legislation and the Operator’s regulatory documents on the processing and protection of personal data;
• organizing the accounting, storage, and handling of information media;
• identifying threats to the security of personal data during their processing, creating threat models based on them;
• developing, based on the threat model, a personal data protection system;
• testing the readiness and effectiveness of information protection tools;
• delineating user access to information resources and hardware and software for data processing;
• registering and recording user actions in personal data information systems;
• using antivirus tools and personal data protection system recovery tools;
• in necessary cases, applying firewall tools, intrusion detection, vulnerability analysis, and cryptographic information protection tools;
• organizing a pass regime on the Operator’s territory and protecting premises with technical means for personal data processing.

4.2 Obligations of the Operator

The Operator undertakes to:

Take necessary and sufficient legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, distribution, as well as from other illegal actions with respect to personal data.

Carry out organizational and technical measures to protect personal data in accordance with the requirements of the legislation of the Russian Federation regarding the processing of personal data.

In order to ensure the protection of personal data, assess the damage that may be caused to personal data subjects in the event of a breach of the security of their personal data, as well as determine current threats to the security of personal data during their processing in personal data information systems.

Upon identifying current threats, apply necessary and sufficient legal, organizational, and technical measures to ensure the security of personal data, including:

• identifying threats to the security of information containing personal data during its processing;
• using organizational and technical measures to ensure the security of information containing personal data during its processing;
• evaluating the effectiveness of the measures taken before the commissioning of the personal data information system;
• accounting for computer media containing personal data;
• detecting unauthorized access to information containing personal data and taking action;
• restoring personal data modified or destroyed as a result of unauthorized access to them;
• establishing rules for access to information containing personal data, ensuring the registration and accounting of all actions performed on information containing personal data in the personal data information system;
• monitoring the measures taken.

4.3 Obligations and Responsibilities of the Operator’s Employees

The Operator’s employees who are granted access to personal data are obliged to:

• know and strictly follow the requirements of this Policy;
• process personal data only within the scope of their job duties;
• not disclose personal data obtained in the course of their job duties, as well as personal data that have become known to them by virtue of their work;
• prevent actions by third parties that may lead to the disclosure (destruction, distortion) of personal data;
• identify any disclosure (destruction, distortion) of personal data and inform their immediate supervisor;
• keep confidential any information containing personal data in accordance with the Organization’s local acts.

The Operator’s employees who are granted access to personal data are prohibited from unauthorized and unregulated copying of personal data on paper or onto any electronic media not intended for storing personal data.

Each new employee of the Operator who is directly involved in personal data processing is required to familiarize themselves with the requirements of the legislation of the Russian Federation on the processing and security of personal data, with this Policy, and with other local acts on the processing and security of personal data, and is obliged to comply with them.

5. FINAL PROVISIONS

Other rights and obligations of the Operator, as an operator of personal data, are determined by the legislation of the Russian Federation in the field of personal data.

The Operator’s officials found guilty of violating the norms governing the processing and protection of personal data bear material, disciplinary, administrative, civil, or criminal liability in the manner prescribed by federal laws.

The current version of the Policy in paper form is stored at: 442960, Penza Region, Zarechny, Demakova Avenue, 5, office 216

The electronic version of the current edition of the Policy is publicly available on the Operator’s website on the Internet: VideoProSport.com.

When changes are made, the date of approval of the current version of the Policy is indicated in the header of the Policy.

The Policy is updated and reapproved as changes are made to the regulatory legal acts in the field of personal data or to local acts governing the organization of processing and ensuring the security of personal data.