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125167, Moscow,
47 Leningradsky Avenue, Building 3, Entrance 3

1.

General Provisions

1.1. This document establishes the Personal Data Processing Policy of RKS-NR LLC (hereinafter referred to as the Organization or the Operator) (hereinafter referred to as the Policy) and has been developed in accordance with Paragraph 2, Part 1, Article 18.1 of Federal Law No. 152-FZ of the Russian Federation dated July 27, 2006, “On Personal Data” (hereinafter referred to as the Personal Data Law).

1.2. The Policy is intended to ensure the protection of the rights of personal data subjects during the processing of their personal data by the Organization.

1.3. The procedures for processing personal data are established by the Regulations on the Protection and Processing of Personal Data of Data Subjects at RKS-NR LLC and by the rules governing the use of the ркс-нр.рф website.

2.

Information about the Personal Data Operator

2.1. Full company name: Limited Liability Company “RKS-NR”.

2.2. Short company name: RKS-NR LLC.

2.3. Address: 47 Leningradsky Prospekt, Building 3, Moscow 125167, tel.: +7 (495) 147-22-33, official website: https://rks-nr.ru/

3.

Categories of Personal Data Processed

3.1. The Organization processes the personal data of the following categories of data subjects:

  • individuals, in accordance with the purposes of personal data processing specified in Clause 4.1.

3.2. The Organization processes the following categories of personal data:

  • full name;
  • date and place of birth;
  • passport details;
  • SNILS and TIN;
  • registered and residential address;
  • contact information (telephone number, e-mail address);
  • information contained in contracts, applications, and other documentation.

Special categories of personal data and biometric personal data are not processed.

4.

Legal Basis for Personal Data Processing

4.1. Personal data are processed on the following legal grounds:

  • the consent of the personal data subject, provided by selecting the consent option in the data collection form;
  • processing is necessary for the fulfillment of obligations established by federal laws and for the exercise of powers vested in the Operator by applicable legal regulations;
  • processing is necessary for the performance of obligations imposed on the Operator under an agreement to which the data subject is a party;
  • processing is necessary for the exercise of the legitimate rights and interests of the Operator or third parties, provided that such processing does not violate the rights and freedoms of the personal data subject.
5.

Principles of Personal Data Processing within the Organization

5.1. The Organization processes personal data in accordance with the following principles:

  • personal data shall be processed lawfully and fairly;
  • personal data processing shall be limited to the achievement of specific, predetermined, and lawful purposes. Processing of personal data that is incompatible with the purposes for which the data were collected is not permitted;
  • the merging of databases containing personal data processed for purposes incompatible with one another is not permitted;
  • only personal data that are relevant to the purposes for which they are processed shall be processed;
  • the content and scope of the personal data processed shall be adequate, relevant, and limited to what is necessary for the stated purposes of processing. Personal data shall not be excessive in relation to those purposes;
  • the accuracy, sufficiency, and, where necessary, relevance of personal data to the purposes of processing shall be ensured. The Organization shall take the necessary measures to delete or rectify incomplete or inaccurate personal data;
  • personal data shall be stored in a form that permits the identification of the data subject for no longer than is necessary to achieve the purposes of processing, unless a longer retention period is required by federal law or by an agreement to which the data subject is a party. Upon achievement of the processing purposes, or if those purposes no longer exist, the personal data shall be destroyed or anonymized unless otherwise required by federal law.
6.

Purposes of Personal Data Processing

6.1. The Organization, acting as the Personal Data Operator, processes personal data for the following purposes:

  • to carry out its business activities and fulfill its corporate objectives, as well as to provide services in accordance with the Organization's areas of business;
  • to establish and perform contractual and pre-contractual relationships;
  • to comply with the legislation of the Russian Federation governing the activities of legal entities;
  • to protect the lawful rights and interests of the Organization;
  • to ensure compliance with the provisions established by the Organization's internal regulations;
  • to fulfill legal obligations and perform functions arising from the Organization's role as an employer;
  • to promote the Organization's services and activities in the marketplace.
7.

Rights of the Data Subject and the Procedure for Exercising Them

7.1. The personal data subject shall have the rights established by Articles 14, 20, and 21 of Federal Law No. 152-FZ.

To exercise these rights, the data subject may submit a request to:

  • Postal address: 47 Leningradsky Prospekt, Building 3, Moscow 125167;
  • Email: mail@rks-nr.ru.
  • The request shall include: the full name and contact details of the data subject; information confirming the data subject's relationship with the Operator; the data subject's signature (for written requests).

Requests shall be reviewed within 30 calendar days from the date of receipt.

8.

Withdrawal of Consent

8.1. The personal data subject has the right to withdraw their consent to the processing of personal data at any time by submitting a written or electronic request to the addresses specified in Section 7.1.

Upon withdrawal of consent, the processing of personal data shall cease, and the personal data shall be destroyed within no more than 30 calendar days, except where otherwise required by the legislation of the Russian Federation.

9.

Cross-Border Transfer of Personal Data

9.1. The cross-border transfer of personal data to countries that do not provide adequate protection of the rights of personal data subjects is not carried out.

Should the circumstances change and such a transfer become necessary, the Operator shall ensure compliance with the requirements of Article 12 of Federal Law No. 152-FZ.

10.

Data Retention and Destruction

10.1. Personal data shall be retained only for as long as necessary to fulfill the purposes of processing or as required by federal law, after which they shall be destroyed or anonymized.

The destruction of personal data shall be documented by an appropriate record.

11.

Use of Cookies

11.1. To improve the performance of the website and provide users with a personalized experience, the Operator may use cookies. Cookies are small data files stored on a user's device when visiting the website.

11.2. The cookies used by the Operator are categorized as follows:

  • Strictly Necessary Cookies — ensure the proper functioning of the website and its features, without which the service cannot operate;
  • Functional Cookies — remember user preferences, for example the interface language;
  • Analytical Cookies — help collect statistics on website visits and usage;
  • Marketing Cookies — are used to deliver personalized advertising content.

11.3. Users may change their browser settings at any time to block or delete cookies. Restricting the use of strictly necessary cookies may result in certain website functions operating improperly.

11.4. Where cookies directly or indirectly enable the identification of a user, the information collected through such cookies shall be processed as personal data in accordance with this Policy.

12.

Measures to Ensure the Security of Personal Data and Compliance with Personal Data Protection Requirements

12.1. When processing personal data, the Organization implements the necessary legal, organizational, and technical (software and hardware) measures to protect personal data against unauthorized or accidental access, destruction, modification, blocking, copying, disclosure, dissemination, and other unlawful actions.

12.2. The Organization's Personal Data Protection Policy is implemented through legal, organizational, and technical measures, including, but not limited to:

  • identifying the categories of personal data processed by the Organization;
  • identifying the persons authorized to process personal data;
  • granting access to personal data exclusively to duly authorized personnel;
  • appointing responsible persons for organizing personal data processing, for the conditions that ensure the safety of personal data and prevent unauthorized access to them, and for maintaining the security of personal data within the information system;
  • adopting internal regulations governing personal data processing, as well as internal procedures aimed at preventing and detecting violations of the legislation of the Russian Federation and mitigating the consequences of such violations;
  • assessing the potential harm that may be caused to personal data subjects in the event of violations of the Federal Law of the Russian Federation “On Personal Data”, comparing such harm with the measures implemented by the Operator to ensure compliance with the obligations set out in that federal law;
  • conducting internal monitoring and/or audits to verify compliance of personal data processing with the Federal Law of the Russian Federation “On Personal Data”, the regulations adopted pursuant thereto, the requirements for personal data protection, this Personal Data Processing Policy, and the Organization's internal regulations;
  • designating locations for the processing and storage of physical media containing personal data;
  • ensuring that employees directly involved in personal data processing are familiar with the legislation of the Russian Federation on personal data, including personal data protection requirements, with the documents that set out the Organization's personal data processing policy and with its internal regulations on personal data processing, and providing training for such employees where necessary;
  • using software products that comply with personal data protection requirements;
  • identifying the types of personal data security threats relevant to the information system;
  • timely detection of personal data security threats and implementation of appropriate protective measures;
  • using information security tools that have successfully undergone the required conformity assessment procedures;
  • maintaining backup copies of information resources;
  • approving the list of personal data information systems;
  • maintaining records of machine-readable media containing personal data;
  • timely detection of unauthorized access to personal data and implementation of appropriate response measures;
  • implementing other measures that do not conflict with the legislation of the Russian Federation.

Current version as of 13 August 2025