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Personal data processing policy.

General Provisions.

1.1. This document defines the policy of CROCUS JSC in relation to the processing of personal data (hereinafter the Policy) and is drawn up in accordance with Art. 18.1 of the Federal Law of the Russian Federation “On Personal Data” No. 152-FZ dated July 27, 2006 (hereinafter the Law).

1.2. JSC “CROCUS”, INN 7728115183, located at the address: 143402, Moscow region, Krasnogorsk district, Krasnogorsk, st. Mezhdunarodnaya, 18, (hereinafter the Company), being the operator of personal data, processes and protects personal data in order to respect the rights and freedoms of every person, in accordance with the Constitution of the Russian Federation, Federal Law of the Russian Federation “On Personal Data” No. 152-FZ of July 27, 2006, as well as other laws and by-laws in force in the territory of the Russian Federation.

1.3. The company understands the importance and value of personal data and therefore ensures their reliable protection.

1.4. This Policy applies to all personal data that will be received by the Company from individuals in the process:

acquisitions and / or intentions to purchase goods, works, services sold through the hypermarkets “Tvoydom” and also through the website www.tvoydom.ru; promotion of goods, works, services sold by hypermarkets “Tvoydom”, as well as on the website www.tvoydom.ru, including by organizing and conducting loyalty programs, marketing, advertising campaigns, research, surveys and other events.

1.5. This Policy applies to personal data received both before and after the entry into force of this Policy..

Basic concepts.

2.1. Personal data – any information relating directly or indirectly to a specific or identifiable natural person.

2.2. Personal data subject – an individual who provides the Company with his personal data.

2.3. Processing of personal data – any action (operation) or a set of actions (operations) performed using automation tools or without using such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.

2.4. Security of personal data – protection of personal data from illegal and / or unauthorized access to them, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other illegal actions in relation to personal data.

Purposes of processing personal data.

3.1. Personal data is processed by the Company in order to:

1) fulfillment of contractual obligations assumed by the Company;

2) promoting goods, works, services on the market, including by organizing and conducting loyalty programs, marketing and / or advertising campaigns, research, surveys and other events;

3) for other purposes if the relevant actions of the Company do not contradict the current legislation, the activities of the Company, and the consent of the subject of personal data has been obtained to carry out this processing.

3.2. The company processes the following personal data:

1) surname, name, patronymic of the subject of personal data;

2) date of birth of the personal data subject;

3) contact phone number, email, as well as other contact information about the subject of personal data;

4) place of residence of the subject of personal data;

5) other information about the subject of personal data required by the Company to implement the goals of this Policy.

Principles of processing personal data.

4.1. The company, implementing the Policy and processing personal data, is based on the following principles:

1) The processing of personal data is carried out on a legal and fair basis;

2) The processing of personal data is limited to the achievement of specific, predetermined and legal purposes. Personal data processing is not carried out that is incompatible with the purposes of collecting personal data;

3) The unification of databases containing personal data, the processing of which is carried out for purposes incompatible with each other, is not carried out;

4) Only personal data is processed that meet the purposes of their processing;

5) The content and volume of the processed personal data correspond to the stated purposes of the processing. The processed personal data are not redundant in relation to the stated purposes of their processing;

6) When processing personal data, the accuracy of personal data, their sufficiency, and, if necessary, relevance in relation to the purposes of processing personal data is ensured. The company takes the necessary measures or ensures their adoption to delete or clarify incomplete or inaccurate personal data;

7) The storage of personal data is carried out in a form that makes it possible to determine the subject of personal data, no longer than the purpose of processing personal data requires, unless the storage period for personal data is established by federal law, an agreement to which the subject of personal data is a party, beneficiary or guarantor … The processed personal data are subject to destruction or depersonalization upon achievement of the processing goals or in case of loss of the need to achieve these goals.

Rights and obligations of subjects of personal data, as well as the Company in terms of processing personal data.

5.1. The personal data subject has the right:

1) receive from the Company:

– confirmation of the fact of personal data processing by the Company;

– information on the legal basis and purposes of personal data processing;

– information about the methods of processing personal data used by the Company;

– information about the location (storage) of personal data;

– a list of processed personal data related to the subject of personal data, and information about the source of their receipt, unless another procedure for providing such personal data is provided for by federal law;

– information about the terms of processing personal data, including the terms of their storage;

– information on the procedure for the exercise by the subject of personal data of the rights provided for by the Law;

– other information provided for by the Law or other regulatory legal acts of the Russian Federation;

2) require the Company to clarify its 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;

3) withdraw your consent to the processing of personal data at any time;

4) demand the elimination of illegal actions of the Company in relation to his personal data;

5) to protect their rights and legitimate interests, including compensation for damages and / or compensation for moral damage in court.

5.2. In the process of processing personal data, the company is obliged to:

1) provide the subject of personal data, upon his request, with information regarding the processing of his personal data, or legally provide a refusal within thirty days from the date of receipt of the request from the subject of personal data or his representative;

2) explain to the subject of personal data the legal consequences of refusing to provide personal data if the provision of personal data is mandatory in accordance with federal law;

3) take the necessary legal, organizational and technical measures or ensure their adoption to protect personal data from unauthorized or accidental access to them, destruction, modification, blocking, copying, provision, dissemination of personal data, as well as from other illegal actions in relation to personal data ;

4) publish on the Internet and provide unrestricted access using the Internet to the document defining its policy regarding the processing of personal data, to information on the requirements for the protection of personal data being implemented;

5) block unlawfully processed personal data relating to the subject of personal data, or ensure their blocking (if the processing of personal data is carried out by another person acting on behalf of the Company) from the moment of contacting or receiving a request for the verification period, in case of unlawful processing of personal data when the subject of personal data or his representative contacts or at the request of the subject of personal data or his representative or the authorized body for the protection of the rights of subjects of personal data;

6) clarify personal data or ensure their clarification (if the processing of personal data is carried out by another person acting on behalf of the Company) within 7 working days from the date of submission of information and remove the blocking of personal data, in case of confirmation of the fact of inaccuracy of personal data based on the information provided the subject of personal data or his representative;

7) stop the unlawful processing of personal data or ensure the termination of the unlawful processing of personal data by a person acting on behalf of the Company in the event of unlawful processing of personal data carried out by the Company or a person acting on the basis of an agreement with the Company, within a period not exceeding 3 working days from the date of this discovery;

8) stop the processing of personal data or ensure its termination and destroy personal data or ensure their destruction if the subject of personal data withdraws consent to the processing of personal data, if the Company is not entitled to process personal data without the consent of the subject of personal data.

The procedure for applying personal data subjects to the Company.

6.1. Personal data subjects have the right to send their requests to the Company, including requests regarding the use of their personal data, in writing..

6.2. The request must contain the following information:

1) last name, first name, patronymic of the subject of personal data;

2) contact information of the subject of personal data (address of residence, phone, email);

3) information confirming the participation of the subject of personal data in relations with the Company (for example, the number of the loyalty card, the number of the Internet order issued on the website, etc.).

6.3. The company undertakes to consider and send a response to the request received by the subject of personal data within 30 days from the date of receipt of the request.

Personal data protection requirements.

7.1. When processing personal data, the company takes the necessary legal, organizational and technical measures to protect personal data from unauthorized and / or unauthorized access to them, destruction, alteration, blocking, copying, provision, dissemination of personal data, as well as from other illegal actions in relation to personal data. data.

7.2. Such measures include, in particular:

1) appointment of a person responsible for organizing the processing of personal data and a person responsible for ensuring the security of personal data;

2) development and approval of local acts on the processing and protection of personal data;

3) the application of legal, organizational and technical measures to ensure the security of personal data;

4) control over the measures taken to ensure the security of personal data and the level of protection of information systems of personal data;

5) compliance with the conditions excluding unauthorized access to material carriers of personal data and ensuring the safety of personal data;

6) familiarization of the employees of the Company who directly process personal data with the provisions of the legislation of the Russian Federation on personal data, including the requirements for the protection of personal data, local acts on the processing and protection of personal data, and training of employees of the Company.

7.3. The company has the right to entrust the processing of personal data to another person with the consent of the subject of personal data, unless otherwise provided by federal law, on the basis of an agreement concluded with this person.

Final provisions.

8.1. This Policy is a local regulation of the Company. This Policy is publicly available. The general availability of this Policy is ensured by the publication on the Company’s Website.

8.2. In case of failure to comply with the provisions of this Policy, the Company and its employees are liable in accordance with the current legislation of the Russian Federation.

8.3 Control over the fulfillment of the requirements of this Policy is carried out by persons responsible for organizing the processing of personal data of the Company, as well as for the security of personal data.

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