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Personal data processing policy

This document (hereinafter referred to as the Policy) is a systematized statement of the goals, principles, methods and conditions for processing personal data, information on the implemented requirements for the protection of personal data of Nord-Ost LLC (hereinafter referred to as theCompany). The Policy is based on the requirements of the Federal Law of the Russian Federation dated 27.07.2006 N 152-FL "On Personal Data" (hereinafter referred to as Federal Law N 152-FL), other regulatory legal acts of the Russian Federation establishing the procedure for processing and protecting personal data.

In accordance with Federal Law N 152-FL, the Company is the operator of personal data.

The purposes of personal data processing by the Company

- preparation for conclusion, including collection of applications for conclusion, conclusion, execution, termination of the contract for the provision of services of the Coworking "Yasnaya Polyana", implemented by OOO "Nord-Ost" in the premises belonging to it in the building at the address: St. Petersburg, Leo Tolstoy St., Building 1-3, Letter A, Room 40-N, Room 6, informing about the said services;

- processing incoming requests from individuals for the purpose of providing consultations; analytics of an individual's actions on the website https://www.coworkingspb.ru and the mobile application "Coworking "Yasnaya Polyana" and the functioning of the website https://www.coworkingspb.ru and the mobile application "Coworking "Yasnaya Polyana"; conducting advertising and news mailings;

- ensuring access to the territory of the premises of OOO "Nord-Ost" as part of organizing the safe operation of these premises and accounting of persons in them.

Principles of personal data processing by the Company

- legal basis for processing personal data, legal methods of processing personal data;

- limiting the processing of personal data to the achievement of predetermined and legitimate purposes;

- preventing the unification of databases containing personal data, the processing of which is carried out for incompatible purposes;

- processing only those personal data that meet the processing purposes;

- compliance of the content and volume of processed personal data with the processing purposes, inadmissibility of redundancy of processed personal data in relation to the stated processing purposes;

- ensuring the accuracy of personal data, their sufficiency and relevance in relation to the purposes of processing personal data;

- ensuring the adoption of necessary measures to delete or clarify incomplete or inaccurate data;

- storing personal data in a form that allows identifying the subject of personal data, but not longer than required by the purposes of processing personal data, unless the storage period of personal data is established by federal law, an agreement to which the subject of personal data is a party, beneficiary or guarantor. Processed personal data are subject to destruction or depersonalization upon achieving the processing objectives or in the event of loss of need to achieve these objectives, unless otherwise provided by federal law.

Methods of personal data processing by the Company

Non-automated processing of personal data (on paper); automated processing (with and without the use of automation tools), including: with and without transmission over the local network of Nord-Ost LLC, with and without transmission over the Internet; mixed processing of personal data. Nord-Ost LLC may independently choose the methods of processing personal data depending on the purposes of such processing and its own material and technical capabilities.

Confidentiality

The Company 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 personal data, unless otherwise provided by federal laws.

Consent of the personal data subject to the processing of their personal data

The personal data subject makes a decision to provide their personal data and gives consent to their processing freely, of their own free will and in their interests. Consent to the processing of personal data must be specific, informed and conscious. Consent to the processing of personal data may be given by the personal data subject or their representative in any form that allows confirming the fact of its receipt, unless otherwise established by federal laws. In the event of receiving consent to the processing of personal data from a representative of the personal data subject, the authority of this representative to give consent on behalf of the personal data subject is verified by the Company.

Consent to the processing of personal data may be revoked by the subject of personal data. In the event that the subject of personal data revokes consent to the processing of personal data, the operator has the right to continue processing personal data without the consent of the subject of personal data if there are grounds specified in paragraphs 2 - 11 of Part 1 of Article 6, Part 2 of Article 10 and Part 2 of Article 11 of Federal Law No. 152-FL.

In cases provided for by Federal Law No. 152-FL, personal data may only be processed with the written consent of the subject of personal data. Consent in the form of an electronic document signed in accordance with federal law with an electronic signature is recognized as equivalent to consent in writing on paper containing the personal signature of the subject of personal data.

Personal data may be received by the Company from a person who is not the subject of personal data, provided that the Company is provided with confirmation of the grounds specified in Federal Law No. 152-FL.

Rights of the personal data subject

When processing personal data, the Company provides the necessary conditions for the unimpeded exercise of the personal data subject's rights.

The personal data subject has the right to access their personal data. The personal data subject has the right to receive the information specified in Part 7 of Article 14 of Federal Law No. 152-FL. The right of the personal data subject to access their personal data is limited in cases provided for by Federal Law No. 152-FL.

The personal data subject has the right to protect their rights and legitimate interests, including compensation for damages and (or) compensation for moral damage in court.

Obligations of the Company

When processing personal data, the Company fulfills its obligations as a personal data operator stipulated by Federal Law No. 152-FL.

The Company takes measures necessary and sufficient to ensure the fulfillment of the obligations stipulated by Federal Law No. 152-FL and regulatory legal acts adopted in accordance with it.

The Company independently determines the composition and list of measures necessary and sufficient to ensure the fulfillment of the obligations stipulated by Federal Law No. 152-FL and regulatory legal acts adopted in accordance with it, unless otherwise provided by federal laws.

The Company provides unlimited access to this document (Policy), to information on the implemented requirements for the protection of personal data by posting it on the website at: https://www.coworkingspb.ru.

Information on the requirements for the protection of personal data implemented by the Company

When processing personal data, the Company takes the necessary legal, organizational and technical measures or ensures their adoption to protect personal data from unauthorized or accidental access to them, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other illegal actions in relation to personal data.

In order to protect personal data, the Company implements the requirements for the protection of personal data during their processing established by the Government of the Russian Federation.

Information on the measures taken by the Company to protect personal data is restricted access information.