Policy Regarding Personal Data Processing
1. General Provisions
This personal data processing policy is compiled in accordance with the requirements of Federal Law No. 152-FZ "On Personal Data" dated 27.07.2006 (hereinafter referred to as the Personal Data Law) and defines the procedure for processing personal data and measures to ensure the security of personal data undertaken by AGS Foods DMCC (hereinafter referred to as the Operator).
1.1. The Operator's primary goal and condition for carrying out its activities is to respect human and civil rights and freedoms in the processing of personal data, including the protection of rights to privacy, personal and family secrets.
1.2. This Operator's policy regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator may receive about visitors to the website https://www.agsfoods.net.
2. Basic Concepts Used in the Policy
2.1. Automated processing of personal data - processing of personal data using computing technology.
2.2. Blocking of personal data - temporary cessation of the processing of personal data (except when processing is necessary for clarification of personal data).
2.3. Website - a set of graphic and informational materials, as well as software and databases, ensuring their availability on the Internet at the network address https://www.agsfoods.net.
2.4. Information system of personal data - a set of personal data contained in databases and ensuring their processing using information technologies and technical means.
2.5. Depersonalization of personal data - actions that result in the impossibility of determining the ownership of personal data by a specific User or another subject of personal data without additional information.
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, changing), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
2.7. Operator - a state authority, municipal authority, legal or physical person, 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, 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://www.agsfoods.net.
2.9. Personal data allowed by the subject of personal data for dissemination - personal data to which access is provided to an unlimited number of persons by the subject of personal data through consent to the processing of personal data allowed by the subject of personal data for dissemination in the manner prescribed by the Personal Data Law (hereinafter referred to as personal data allowed for dissemination).
2.10. User - any visitor to the website https://www.agsfoods.net.
2.11. Provision of personal data - actions aimed at disclosing personal data to a specific person or a specific circle of persons.
2.12. Dissemination of personal data - any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or at making personal data available to an unlimited circle of persons, including publishing personal data in the media, posting 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, foreign physical or foreign legal person.
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 the material carriers of personal data. Automated processing of personal data - processing of personal data using computing technology.
3. Main Rights and Duties of the Operator
3.1. The Operator has the right to:
— Receive reliable information and/or documents containing personal data from the subject of personal data;
— In case of withdrawal by the subject of personal data of consent to the processing of personal data, as well as sending a request to terminate 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 the Personal Data Law;
— Independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations provided by the Personal Data Law and adopted in accordance with it regulatory legal acts, unless otherwise provided by the Personal Data Law or other federal laws.
3.2. The Operator is obliged to:
— Provide the subject of personal data, upon their request, with information regarding the processing of their personal data;
— Organize the processing of personal data in accordance with the procedure established by the current legislation of the Russian Federation;
— Respond to requests and inquiries from subjects of personal data and their legal representatives in accordance with the requirements of the Personal Data Law;
— Report to the authorized body for the protection of the rights of subjects of personal data, upon request of this body, the necessary information within 10 days from the date of receipt of 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 of personal data, as well as from other unlawful actions with respect to personal data;
— Terminate the transfer (dissemination, provision, access) of personal data, terminate processing, and destroy personal data in the manner and in cases provided by the Personal Data Law;
— Fulfill other duties provided by the Personal Data Law.
4. Main Rights and Duties of Subjects of Personal Data
4.1. Subjects of personal data have the right to:
— Receive information regarding the processing of their personal data, except in cases provided by federal laws. Information is provided to the subject of personal data by the Operator in an accessible form, and it should not contain personal data relating to other subjects of personal data, except in cases where there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it is established by the Personal Data Law;
— Request the Operator to clarify their personal data, block or destroy them if the personal data are incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the declared purpose of processing, as well as to take measures provided by law to protect their rights;
— Set a condition of prior consent when processing personal data for the purpose of promoting goods, works, and services on the market;
— Withdraw consent to the processing of personal data, as well as to send a request to terminate the processing of personal data;
— Complain to the authorized body for the protection of the rights of subjects of personal data or to the court about unlawful actions or inactions of the Operator in the processing of their personal data;
— Exercise other rights provided by the legislation of the Russian Federation.
4.2. Subjects of personal data are obliged to:
— Provide the Operator with reliable data about themselves;
— Inform the Operator about the clarification (updating, changing) of their personal data.
4.3. Persons who have transferred false information about themselves to the Operator, or information about another subject of personal data without the consent of the latter, bear responsibility in accordance with the legislation of the Russian Federation.
5. Principles of Personal Data Processing
5.1. Personal data processing is carried out on a lawful and fair basis.
5.2. The processing of personal data is limited to achieving specific, predetermined, and legitimate purposes. The processing of personal data incompatible with the purposes of collecting personal data is not allowed.
5.3. Combining databases containing personal data, the processing of which is carried out for purposes incompatible with each other, is not allowed.
5.4. Only personal data that meet the purposes of their processing are subject to processing.
5.5. The content and volume of processed personal data correspond to the stated purposes of processing. Excessive processing of personal data in relation to the stated purposes of their processing is not allowed.
5.6. Accuracy, sufficiency, and, if necessary, relevance of personal data in relation to the purposes of personal data processing are ensured. The Operator takes the necessary measures and/or ensures their adoption to delete or clarify incomplete or inaccurate data.
5.7. Personal data is stored in a form that allows determining the subject of personal data, no longer than required by the purposes of personal data processing, unless the retention period for personal data is established by federal law, a contract to which the subject of personal data is a party, a beneficiary, or a guarantor. Processed personal data is destroyed or depersonalized upon achieving the purposes of processing or if the necessity of achieving these purposes is lost, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing
Purpose of processing: Collection and processing of personal data for reviewing job applications, communication with users regarding investment, PR, purchasing/selling products, employment, and other issues specified by users.
Personal data:
Types of personal data processing: Collection, recording, systematization, accumulation, storage, clarification (updating, changing), retrieval, use, transfer (dissemination, provision, access), depersonalization, blocking, deletion, destruction. Transfer of personal data to third parties for the purposes specified.
7. Conditions for Personal Data Processing
7.1. Personal data processing is carried out with the consent of the subject of personal data to process their personal data.
7.2. The processing of personal data is necessary to achieve the purposes stipulated by an international treaty of the Russian Federation or by law, to carry out the functions, powers, and duties imposed by the legislation of the Russian Federation on the operator.
7.3. The processing of personal data is necessary for the administration of justice, execution of a judicial act, an act of another body, or an official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. The processing of personal data is necessary for the execution of a contract to which the subject of personal data is a party, beneficiary, or guarantor, as well as for the conclusion of a contract on the initiative of the subject of personal data or a contract under which the subject of personal data will be a beneficiary or guarantor.
7.5. The processing of personal data is necessary for the realization of the rights and legitimate interests of the operator or third parties or for achieving socially significant purposes, provided that this does not violate the rights and freedoms of the subject of personal data.
7.6. The processing of personal data, to which access is granted to an unlimited number of persons by the subject of personal data or at their request (hereinafter referred to as publicly available personal data), is carried out.
7.7. The processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.
8. Procedure for the 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 the 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. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to the execution of current legislation or if the subject of personal data has given consent to the Operator to transfer data to a third party for the fulfillment of obligations under a civil contract.
8.3. If inaccuracies in personal data are detected, the User can update them independently by sending a notification to the Operator's email address it@agsfoods.net with the subject line "Update of personal data."
8.4. The period for processing personal data is determined by the achievement of the purposes for which the personal data were collected unless another period is provided by the contract or current legislation. The User may at any time revoke their consent to the processing of personal data by sending a notification to the Operator via email to the Operator's email address it@agsfoods.net with the subject line "Withdrawal of consent to the processing of personal data."
8.5. All information collected by third-party services, including payment systems, communication facilities, and other service providers, is stored and processed by these parties (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data and/or agrees with these documents. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this clause.
8.6. The prohibitions established by the subject of personal data on the transfer (except for access), as well as on the processing or conditions of processing (except for access) of personal data permitted for dissemination, do not apply in cases of processing personal data in state, public, and other public interests as defined by the legislation of the Russian Federation.
8.7. The Operator ensures the confidentiality of personal data during their processing.
8.8. The Operator stores personal data in a form that allows determining the subject of personal data no longer than required by the purposes of personal data processing unless the period for storing personal data is established by federal law, a contract to which the subject of personal data is a party, a beneficiary, or a guarantor.
8.9. The condition for terminating the processing of personal data may be the achievement of the purposes of processing personal data, the expiration of the consent of the subject of personal data, the withdrawal of consent by the subject of personal data, or a request to terminate the processing of personal data, as well as the identification of unlawful processing of personal data.
9. List of Actions Performed by the Operator with the Received Personal Data
9.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), retrieves, uses, transfers (disseminates, provides, accesses), depersonalizes, blocks, deletes, and destroys personal data.
9.2. The Operator performs automated processing of personal data with the receipt and/or transfer of received information via information and telecommunication networks or without it.
10. Cross-Border Transfer of Personal Data
10.1. Before starting activities on the cross-border transfer of personal data, the Operator must notify the authorized body for the protection of the rights of subjects of personal data of its intention to carry out cross-border transfer of personal data (this notification is sent separately from the notification of intention to process personal data).
10.2. Before submitting the above notification, the Operator must obtain from the authorities of the foreign state, foreign individuals, foreign legal entities to which the cross-border transfer of personal data is planned, the relevant information.
11. Confidentiality of Personal Data
The Operator and other persons who have gained access to personal data are obliged not to disclose to third parties and not to disseminate personal data without the consent of the subject of personal data unless otherwise provided by federal law.
12. Final Provisions
12.1. The User can obtain any clarifications on matters of interest regarding the processing of their personal data by contacting the Operator via email at it@agsfoods.net.
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://www.agsfoods.net/ru/privacy or https://www.agsfoods.net/en/privacy.
1. General Provisions
This personal data processing policy is compiled in accordance with the requirements of Federal Law No. 152-FZ "On Personal Data" dated 27.07.2006 (hereinafter referred to as the Personal Data Law) and defines the procedure for processing personal data and measures to ensure the security of personal data undertaken by AGS Foods DMCC (hereinafter referred to as the Operator).
1.1. The Operator's primary goal and condition for carrying out its activities is to respect human and civil rights and freedoms in the processing of personal data, including the protection of rights to privacy, personal and family secrets.
1.2. This Operator's policy regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator may receive about visitors to the website https://www.agsfoods.net.
2. Basic Concepts Used in the Policy
2.1. Automated processing of personal data - processing of personal data using computing technology.
2.2. Blocking of personal data - temporary cessation of the processing of personal data (except when processing is necessary for clarification of personal data).
2.3. Website - a set of graphic and informational materials, as well as software and databases, ensuring their availability on the Internet at the network address https://www.agsfoods.net.
2.4. Information system of personal data - a set of personal data contained in databases and ensuring their processing using information technologies and technical means.
2.5. Depersonalization of personal data - actions that result in the impossibility of determining the ownership of personal data by a specific User or another subject of personal data without additional information.
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, changing), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
2.7. Operator - a state authority, municipal authority, legal or physical person, 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, 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://www.agsfoods.net.
2.9. Personal data allowed by the subject of personal data for dissemination - personal data to which access is provided to an unlimited number of persons by the subject of personal data through consent to the processing of personal data allowed by the subject of personal data for dissemination in the manner prescribed by the Personal Data Law (hereinafter referred to as personal data allowed for dissemination).
2.10. User - any visitor to the website https://www.agsfoods.net.
2.11. Provision of personal data - actions aimed at disclosing personal data to a specific person or a specific circle of persons.
2.12. Dissemination of personal data - any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or at making personal data available to an unlimited circle of persons, including publishing personal data in the media, posting 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, foreign physical or foreign legal person.
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 the material carriers of personal data. Automated processing of personal data - processing of personal data using computing technology.
3. Main Rights and Duties of the Operator
3.1. The Operator has the right to:
— Receive reliable information and/or documents containing personal data from the subject of personal data;
— In case of withdrawal by the subject of personal data of consent to the processing of personal data, as well as sending a request to terminate 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 the Personal Data Law;
— Independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations provided by the Personal Data Law and adopted in accordance with it regulatory legal acts, unless otherwise provided by the Personal Data Law or other federal laws.
3.2. The Operator is obliged to:
— Provide the subject of personal data, upon their request, with information regarding the processing of their personal data;
— Organize the processing of personal data in accordance with the procedure established by the current legislation of the Russian Federation;
— Respond to requests and inquiries from subjects of personal data and their legal representatives in accordance with the requirements of the Personal Data Law;
— Report to the authorized body for the protection of the rights of subjects of personal data, upon request of this body, the necessary information within 10 days from the date of receipt of 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 of personal data, as well as from other unlawful actions with respect to personal data;
— Terminate the transfer (dissemination, provision, access) of personal data, terminate processing, and destroy personal data in the manner and in cases provided by the Personal Data Law;
— Fulfill other duties provided by the Personal Data Law.
4. Main Rights and Duties of Subjects of Personal Data
4.1. Subjects of personal data have the right to:
— Receive information regarding the processing of their personal data, except in cases provided by federal laws. Information is provided to the subject of personal data by the Operator in an accessible form, and it should not contain personal data relating to other subjects of personal data, except in cases where there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it is established by the Personal Data Law;
— Request the Operator to clarify their personal data, block or destroy them if the personal data are incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the declared purpose of processing, as well as to take measures provided by law to protect their rights;
— Set a condition of prior consent when processing personal data for the purpose of promoting goods, works, and services on the market;
— Withdraw consent to the processing of personal data, as well as to send a request to terminate the processing of personal data;
— Complain to the authorized body for the protection of the rights of subjects of personal data or to the court about unlawful actions or inactions of the Operator in the processing of their personal data;
— Exercise other rights provided by the legislation of the Russian Federation.
4.2. Subjects of personal data are obliged to:
— Provide the Operator with reliable data about themselves;
— Inform the Operator about the clarification (updating, changing) of their personal data.
4.3. Persons who have transferred false information about themselves to the Operator, or information about another subject of personal data without the consent of the latter, bear responsibility in accordance with the legislation of the Russian Federation.
5. Principles of Personal Data Processing
5.1. Personal data processing is carried out on a lawful and fair basis.
5.2. The processing of personal data is limited to achieving specific, predetermined, and legitimate purposes. The processing of personal data incompatible with the purposes of collecting personal data is not allowed.
5.3. Combining databases containing personal data, the processing of which is carried out for purposes incompatible with each other, is not allowed.
5.4. Only personal data that meet the purposes of their processing are subject to processing.
5.5. The content and volume of processed personal data correspond to the stated purposes of processing. Excessive processing of personal data in relation to the stated purposes of their processing is not allowed.
5.6. Accuracy, sufficiency, and, if necessary, relevance of personal data in relation to the purposes of personal data processing are ensured. The Operator takes the necessary measures and/or ensures their adoption to delete or clarify incomplete or inaccurate data.
5.7. Personal data is stored in a form that allows determining the subject of personal data, no longer than required by the purposes of personal data processing, unless the retention period for personal data is established by federal law, a contract to which the subject of personal data is a party, a beneficiary, or a guarantor. Processed personal data is destroyed or depersonalized upon achieving the purposes of processing or if the necessity of achieving these purposes is lost, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing
Purpose of processing: Collection and processing of personal data for reviewing job applications, communication with users regarding investment, PR, purchasing/selling products, employment, and other issues specified by users.
Personal data:
- Surname, first name, patronymic
- Email address
- Phone numbers
- Year, month, date, and place of birth
- Photographs
- Citizenship certificate
- Details of the identity document
- Address of actual residence and registration at the place of residence and/or stay
- Information about education, profession, specialty, and qualifications, details of educational documents
- Information about marital status and family composition
- Income information
- Information about previously held positions and work experience, military obligations, military registration
- Other data specified by users in submitted resumes and forms
Types of personal data processing: Collection, recording, systematization, accumulation, storage, clarification (updating, changing), retrieval, use, transfer (dissemination, provision, access), depersonalization, blocking, deletion, destruction. Transfer of personal data to third parties for the purposes specified.
7. Conditions for Personal Data Processing
7.1. Personal data processing is carried out with the consent of the subject of personal data to process their personal data.
7.2. The processing of personal data is necessary to achieve the purposes stipulated by an international treaty of the Russian Federation or by law, to carry out the functions, powers, and duties imposed by the legislation of the Russian Federation on the operator.
7.3. The processing of personal data is necessary for the administration of justice, execution of a judicial act, an act of another body, or an official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. The processing of personal data is necessary for the execution of a contract to which the subject of personal data is a party, beneficiary, or guarantor, as well as for the conclusion of a contract on the initiative of the subject of personal data or a contract under which the subject of personal data will be a beneficiary or guarantor.
7.5. The processing of personal data is necessary for the realization of the rights and legitimate interests of the operator or third parties or for achieving socially significant purposes, provided that this does not violate the rights and freedoms of the subject of personal data.
7.6. The processing of personal data, to which access is granted to an unlimited number of persons by the subject of personal data or at their request (hereinafter referred to as publicly available personal data), is carried out.
7.7. The processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.
8. Procedure for the 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 the 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. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to the execution of current legislation or if the subject of personal data has given consent to the Operator to transfer data to a third party for the fulfillment of obligations under a civil contract.
8.3. If inaccuracies in personal data are detected, the User can update them independently by sending a notification to the Operator's email address it@agsfoods.net with the subject line "Update of personal data."
8.4. The period for processing personal data is determined by the achievement of the purposes for which the personal data were collected unless another period is provided by the contract or current legislation. The User may at any time revoke their consent to the processing of personal data by sending a notification to the Operator via email to the Operator's email address it@agsfoods.net with the subject line "Withdrawal of consent to the processing of personal data."
8.5. All information collected by third-party services, including payment systems, communication facilities, and other service providers, is stored and processed by these parties (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data and/or agrees with these documents. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this clause.
8.6. The prohibitions established by the subject of personal data on the transfer (except for access), as well as on the processing or conditions of processing (except for access) of personal data permitted for dissemination, do not apply in cases of processing personal data in state, public, and other public interests as defined by the legislation of the Russian Federation.
8.7. The Operator ensures the confidentiality of personal data during their processing.
8.8. The Operator stores personal data in a form that allows determining the subject of personal data no longer than required by the purposes of personal data processing unless the period for storing personal data is established by federal law, a contract to which the subject of personal data is a party, a beneficiary, or a guarantor.
8.9. The condition for terminating the processing of personal data may be the achievement of the purposes of processing personal data, the expiration of the consent of the subject of personal data, the withdrawal of consent by the subject of personal data, or a request to terminate the processing of personal data, as well as the identification of unlawful processing of personal data.
9. List of Actions Performed by the Operator with the Received Personal Data
9.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), retrieves, uses, transfers (disseminates, provides, accesses), depersonalizes, blocks, deletes, and destroys personal data.
9.2. The Operator performs automated processing of personal data with the receipt and/or transfer of received information via information and telecommunication networks or without it.
10. Cross-Border Transfer of Personal Data
10.1. Before starting activities on the cross-border transfer of personal data, the Operator must notify the authorized body for the protection of the rights of subjects of personal data of its intention to carry out cross-border transfer of personal data (this notification is sent separately from the notification of intention to process personal data).
10.2. Before submitting the above notification, the Operator must obtain from the authorities of the foreign state, foreign individuals, foreign legal entities to which the cross-border transfer of personal data is planned, the relevant information.
11. Confidentiality of Personal Data
The Operator and other persons who have gained access to personal data are obliged not to disclose to third parties and not to disseminate personal data without the consent of the subject of personal data unless otherwise provided by federal law.
12. Final Provisions
12.1. The User can obtain any clarifications on matters of interest regarding the processing of their personal data by contacting the Operator via email at it@agsfoods.net.
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://www.agsfoods.net/ru/privacy or https://www.agsfoods.net/en/privacy.