Policy regarding the processing of personal data.

General provisions

This personal data processing policy has been compiled in accordance with the requirements of Federal Law No. 152-FZ dated 07/27/2006 "On Personal Data" (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 taken by INCOR LLC (hereinafter referred to as the Operator).

1. The Operator sets as its most important goal and condition for the implementation of its activities the observance of human and civil rights and freedoms in the processing of his personal data, including the protection of the 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 can receive about visitors to the website https://eu.incor-ru.com/.

2. Basic concepts used in Politics

2.1. Automated processing of personal data — processing of personal data using computer technology.

2.2. Blocking of personal data — temporary termination of the processing of personal data (except in cases where processing is necessary to clarify personal data).

2.3. Website — a set of graphic and information materials, as well as computer programs and databases that ensure their availability on the Internet at a network address https://incor-ru.com /.

2.4. Personal data information system — a set of personal data contained in databases and information technologies and technical means that ensure their processing.

2.5. Depersonalization of personal data — actions as a result of which it is impossible to determine, without using additional information, the identity of personal data to a specific User or other personal data subject.

2.6. Processing of personal data — any action (operation) or a set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.

2.7. Operator — a state body, municipal body, legal entity or individual, independently or jointly with other persons organizing and/or processing 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 related directly or indirectly to a specific or identifiable User of the website https://eu.incor-ru.com/.

2.9. Personal data authorized by the subject of personal data for dissemination — personal data, access to which is provided to an unlimited number of persons by the subject of personal data by giving consent to the processing of personal data authorized by the subject of personal data for dissemination in accordance with the procedure provided for by the Law on Personal Data (hereinafter — personal data authorized for dissemination).

2.10. User — any visitor to the website https://eu.incor-ru.com/.

2.11. Provision of personal data — actions aimed at disclosing personal data to a certain person or a certain circle of persons.

2.12. Dissemination of personal data — any actions aimed at disclosure of personal data to an indefinite circle of persons (transfer of personal data) or familiarization with personal data of an unlimited number of persons, including disclosure of personal data in the media, posting in information and telecommunications networks or providing access to personal data in any other way.

2.13. Cross—border transfer of personal data is 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.

2.14. Destruction of personal data — any actions as a result of which personal data is permanently destroyed with the inability to further restore the content of personal data in the personal data information system and/or the material carriers of personal data are destroyed.

3. Basic rights and obligations 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 Law on Personal Data;

— independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations provided for by the Law on Personal Data and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Law on Personal Data or other federal laws.

3.2. The Operator is obliged to:

— to provide the subject of personal data, at his request, with information concerning the processing of his 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 requests from personal data subjects and their legal representatives in accordance with the requirements of the Law on Personal Data;

— to inform the authorized body for the protection of the rights of personal data subjects at the request of this body of the necessary information within 10 days from the date of receipt of such a request;

— to publish or otherwise provide unrestricted access to this Policy regarding the processing of personal data;

— take legal, organizational and technical measures 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;

— stop transferring (distributing, providing, accessing) personal data, stop processing and destroy personal data in the manner and in the cases provided for by the Law on Personal Data;

— perform other duties provided for by the Law on Personal Data.

4. Basic rights and obligations of personal data subjects

4.1. Personal data subjects have the right to:

— receive information regarding the processing of his personal data, except in cases provided for by federal laws. The information is provided to the personal data subject by the Operator in an accessible form, and it should not contain personal data related to other personal data subjects, except in cases where there are legitimate grounds for disclosure of such personal data. The list of information and the procedure for obtaining it is established by the Law on Personal Data;

— to require the operator to clarify his personal data, block or destroy them if the personal data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated purpose of processing, as well as to take measures provided for by law to protect their rights;

— to put forward a condition of prior consent when processing personal data in order to promote goods, works and services on the market;

— to revoke consent to the processing of personal data, as well as to send a request to terminate the processing of personal data;

— to appeal to the authorized body for the protection of the rights of personal data subjects or in court against illegal actions or inaction of the Operator during the processing of his personal data;

— to exercise other rights provided for by the legislation of the Russian Federation.

4.2. The subjects of personal data are obliged to:

— provide the Operator with reliable data about themselves;

— inform the Operator about the clarification (updating, modification) of their personal data.

4.3. Persons who have provided the Operator with false information about themselves or information about another personal data subject without the latter's consent are liable in accordance with the legislation of the Russian Federation.

5. Principles of personal data processing

5.1. The processing of personal data is carried out on a lawful and fair basis.

5.2. The processing of personal data is limited to achieving specific, predetermined and legitimate goals. Processing of personal data incompatible with the purposes of personal data collection is not allowed.

5.3. It is not allowed to combine databases containing personal data, the processing of which is carried out for purposes incompatible with each other.

5.4. Only personal data that meet the purposes of their processing are subject to processing.

5.5. The content and volume of the processed personal data correspond to the stated purposes of processing. Redundancy of the processed personal data in relation to the stated purposes of their processing is not allowed.

5.6. When processing personal data, the accuracy of personal data, their sufficiency, and, if necessary, relevance in relation to the purposes of personal data processing are ensured. The Operator takes the necessary measures and/or ensures that they are taken to delete or clarify incomplete or inaccurate data.

5.7. The storage of personal data is carried out in a form that allows determining the subject of personal data, no longer than the purposes of personal data processing require, unless the period of personal data storage is established by federal law, an agreement to which the subject of personal data is a party, beneficiary or guarantor. The processed personal data is destroyed or depersonalized upon achievement of the processing goals or in case of loss of the need to achieve these goals, unless otherwise provided by federal law.

6. Purposes of personal data processing

The purpose of processing: to provide the User with access to the services, information and/or materials contained on the website

Personal data: last name, first name, patronymic, email address, phone numbers

Legal grounds: Federal Law "On Information, Information Technologies and Information Protection" dated 07/27/2006 No. 149-FZ Personal data processing methods: Collection, recording, systematization, accumulation, storage, destruction and depersonalization of personal data

7. Terms of personal data processing

7.1. The processing of personal data is carried out with the consent of the personal data subject to the processing of his personal data.

7.2. The processing of personal data is necessary to achieve the goals provided for by an international agreement of the Russian Federation or by law, to carry out the functions, powers and duties assigned to the operator by the legislation of the Russian Federation.

7.3. The processing of personal data is necessary for the administration of justice, the execution of a judicial act, an act of another body or official to be executed in accordance with the legislation of the Russian Federation on enforcement proceedings.

7.4. The processing of personal data is necessary for the performance of an agreement to which the personal data subject is a party or beneficiary or guarantor, as well as for the conclusion of an agreement on the initiative of the personal data subject or an agreement under which the personal data subject will be the beneficiary or guarantor.

7.5. The processing of personal data is necessary to exercise the rights and legitimate interests of the operator or third parties or to achieve socially significant goals, provided that the rights and freedoms of the personal data subject are not violated.

7.6. Personal data is processed, access to which is provided to an unlimited number of persons by the subject of personal data or at his request (hereinafter referred to as publicly available personal data).

7.7. Personal data subject to publication or mandatory disclosure in accordance with federal law is processed.

8. The procedure for the collection, storage, transfer and other types of personal data processing

The security of personal data processed by the Operator is ensured through the implementation of legal, organizational and technical measures necessary to fully comply with the requirements of current legislation in the field of personal data protection.

8.1. The Operator ensures the safety of personal data and takes all possible measures to exclude access to personal data of unauthorized persons.

8.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to the implementation of current legislation or if the subject of personal data has given consent to the Operator to transfer data to a third party to fulfill obligations under a civil contract.

8.3. In case of inaccuracies in personal data, the User can update them independently by sending a notification to the Operator to the Operator's e-mail address info@incor-ru.com marked "Updating of personal data".

8.4. The period of processing of personal data is determined by the achievement of the purposes for which personal data was collected, unless another period is provided for by the contract or current legislation.The User can withdraw his consent to the processing of personal data at any time by sending a notification to the Operator via e-mail to the Operator's e-mail address info@incor-ru.com marked "Withdrawal of consent to the processing of personal data".

8.5. All information collected by third-party services, including payment systems, means of communication and other service providers, is stored and processed by these persons (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data and/or with the specified documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this paragraph.

8.6. The prohibitions established by the subject of personal data on the transfer (except for granting access), as well as on the processing or conditions of processing (except for obtaining access) of personal data allowed for distribution, do not apply in cases of processing personal data in the state, public and other public interests defined by the legislation of the Russian Federation.

8.7. The Operator ensures the confidentiality of personal data when processing personal data.

8.8. The Operator stores personal data in a form that allows determining the subject of personal data for no longer than the purposes of processing personal data require, unless the period of storage of personal data is established by federal law, an agreement to which the subject of personal data is a party, beneficiary or guarantor.

8.9. The condition for the termination of personal data processing may be the achievement of the purposes of personal data processing, the expiration of the consent of the personal data subject, the withdrawal of consent by the personal data subject or the requirement 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), extracts, uses, transfers (distributes, provides, accesses), depersonalizes, blocks, deletes and destroys personal data.

9.2. The Operator performs automated processing of personal data with or without receiving and/or transmitting the received information via information and telecommunication networks.

10. Cross-border transfer of personal data

10.1. Prior to the start of cross-border transfer of personal data, the Operator is obliged to notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out cross-border transfer of personal data (such notification is sent separately from the notification of the intention to process personal data).

10.2. Before submitting the above notification, the Operator is obliged to receive relevant information from the authorities of a foreign state, foreign individuals, and foreign legal entities to whom the cross-border transfer of personal data is planned.

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

12. Final provisions

12.1. The User can receive any clarifications on issues of interest related to the processing of his personal data by contacting the Operator via e-mail info@incor-ru.com .

12.2. This document will reflect any changes to the Operator's personal data processing policy. The policy is valid indefinitely until it is replaced by a new version.

12.3. The current version of the Policy is freely available on the Internet at https://eu.incor-ru.com/#popup:privacy_policy.

This Regulation on the Processing of Personal data of Candidates (hereinafter referred to as the "Regulation") is intended to inform candidates for vacant positions (hereinafter referred to as "Candidates") about how INCOR LLC and/or its affiliates, including those belonging to the same group as INCOR LLC and registered in the territory of the Russian Federation (hereinafter referred to as "INCOR"), process their personal data.

The regulation is based on data protection legislation, including the Federal Law "On Personal Data" dated 07/27/2006 No. 152-FZ ("FZ-152") and by-laws adopted in accordance with it.

The terms used in the Regulation have the meaning established in the legislation. In particular:

The personal data operator is a legal entity that independently or jointly with other persons organizes and (or) performs the processing of personal data, as well as determines the purposes of processing personal data, the composition of personal data to be processed, actions (operations) performed with personal data.

Personal data is any information related directly or indirectly to a specific or identifiable individual (subject of personal data). The subject of personal data is a candidate for a vacant position.

Personal data processing is any action (operation) or set of actions (operations) performed in relation to personal data using automation tools or without the use of such tools, including collection, recording, systematization, accumulation, storage, clarification (update, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.

1. The operator

The operator of the personal data processed under this Regulation is a legal entity of the INCOR Group of companies, for which you are responding to an open vacancy. In particular, the operator in relation to your personal data may be:

INCOR Limited Liability Company, registered at the address: 196006, St. Petersburg, Zastavskaya str., 31, room 1, room 2H

You can always get additional information about the operator by studying the job description, asking the hiring manager a question, or using the contact details provided in section 10 of the Regulations.

2. Purposes and legal grounds for processing personal data

INCOR processes your personal data in order to (1) discuss employment prospects with you; (2) considering your candidacy for an open vacant position; (3) checking your skills, qualifications and business qualities; (4) making a final decision on employment; (5) preparing for the conclusion of an employment contract in case of successful selection for an open vacant position; (6) informing you about vacancies suitable for length of service and specialization; (7) compliance with the requirements of applicable legislation; (8) conducting analytics to improve the effectiveness of recruitment processes; (9) checking for conflicts of interest; (10) sending invitations to events held by INCOR; (11) sending information and other materials related to INCOR's activities; (12) collecting feedback on the employment process; (13) within the limits established by law - to protect the rights and legitimate interests of the INCOR group of companies.

INCOR processes personal data based on your specific, informed and conscious consent to the processing of personal data. In cases provided for by law, INCOR has the right to rely on other legal grounds, including:

Compliance with the duties and functions provided for by the current legislation (paragraph 2 of Part 1 of Article 6 of FZ-152);

Processing of personal data in connection with participation in legal proceedings or for the execution of a judicial act, an act of another body or official (paragraph 3 of part 1 of Article 6 of FZ-152, paragraph 3.1 of Part 1 of Article 6 of FZ-152);

The need to fulfill a contract with a personal data subject or to conclude a contract on the initiative of a personal data subject (clause 5, part 1, Article 6 of Federal Law 152);

Exercising the rights and legitimate interests of INCOR or third parties (Clause 7, Part 1, Article 6 of Federal Law 152);

Processing of personal data for statistical or other research purposes, subject to mandatory depersonalization of personal data (Clause 9, Part 1, Article 6 of Federal Law 152);

Other legal grounds provided for by applicable law.

3. Categories of personal data and actions (operations) performed with them

In order to achieve the goals set out in section 2 of the Regulations, INCOR processes the personal data provided by you at the time of responding to the vacancy and during the further selection process, including, if applicable:

FULL name;

Date of birth;

Place of birth;

Address;

Citizenship / residence permit;

Paul;

Marital status;

Work permit;

Passport data;

Data from other documents;

Contact information (email, phone number, postal address);

Social media profiles;

Information about education and specialization;

Information about seniority and work experience;

Characteristics from previous jobs;

Information about the expected salary;

Information about skills and business qualities;

Health information (if required to participate in a competition for an open vacant position);

Photo;

The results of the test task;

Information required to pass a conflict of interest check;

Other information provided by you in your resume or otherwise provided to Yandex for the purposes listed in Section 2 of the Regulations.

INCOR performs the following actions (operations) using automation tools and without using such tools in relation to the above-mentioned personal data: collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (provision, access), depersonalization, blocking, deletion, destruction personal data.

When collecting your personal data, INCOR ensures their recording, systematization, accumulation, storage, clarification (updating, modification), extraction using databases located on the territory of the Russian Federation.

4. Recipients of personal data

INCOR may transfer your personal data to third parties solely for the purposes specified in Section 2 of the Regulations. In particular, INCOR may transfer your personal data to the following third parties:

Affiliated persons belonging to the INCOR group of companies ;

Partners who verify the data provided by candidates for vacant positions;

Partners who carry out the initial verification of a candidate's compliance with the requirements of an open vacancy;

Providers of systems for managing recruitment and HR processes;

External platforms for passing the test task;

To other third parties, when it is necessary to achieve the goals specified in section 2 of the Regulations.

INCOR LLC has the right to carry out cross-border transfer of personal data to the countries where its affiliates are located, solely for the purposes defined in this Regulation.

5. Terms of storage of personal data

INCOR stores personal data until the purposes of processing personal data specified in Section 2 of the Regulations are achieved.

If you consent to be informed about vacancies suitable for experience and specialization, your personal data will be processed within the time limits specified in such consent, but in any case no longer than is required to achieve the stated purpose of processing.

6. Basic rights of personal data subjects

In accordance with the law on personal data, you have the following rights in relation to your personal data:

1. The right to access personal data. You can request confirmation of the processing of your personal data, as well as details related to their processing.

2. The right to clarify personal data. You can request that the specified personal data be corrected if it is incomplete, outdated or inaccurate.

3. The right to destroy personal data. You can request the destruction of your personal data in cases provided for by law. For example, if they are no longer necessary to achieve the purposes of processing, if you have withdrawn your consent to the processing of personal data, and INCOR has no other legal basis for processing them, or if personal data has been processed illegally.

4. The right to block personal data. You may request the temporary termination of the processing of your personal data in cases provided for by law. For example, if you doubt the accuracy of the personal data provided or if you request to restrict the use of personal data due to the alleged illegality of their processing.

To exercise these rights, you can contact INCOR using the contact details specified in section 10 of the Regulations.

If you believe that your rights as a personal data subject have been violated, you have the right to appeal the actions or omissions of INCOR to the authorized body for the protection of the rights of personal data subjects or in court.

7. Withdrawal of consent to the processing of personal data

In cases where the processing of personal data is based on consent, you have the right to withdraw your consent at any time. Withdrawal of consent does not affect the legality of processing based on consent and carried out before its withdrawal. To revoke consent, the subject of personal data may contact INCOR LLC using the contact information specified in section 10 of the Regulation.

8. Sources of personal data

INCOR LLC receives personal data directly from you when you respond to a vacancy on our websites or directly send us your resume. In addition, in some cases, we may receive your personal data from recruiting agencies, current INCOR employees and other persons who recommend you for a vacant position, from specialized Internet resources designed to publish open vacancies, or during communication with you on social networks and so on.

9. Personal Data protection measures

INCOR LLC ensures the confidentiality and security of your personal data, and also takes all necessary legal, organizational and technical measures to protect personal data from unauthorized or accidental access to them, destruction, modification, blocking, copying, dissemination of personal data, as well as from other illegal actions with such data in accordance with the requirements of art. 19 FZ-152. In particular, INCOR provides:

identification of threats to the security of personal data during their processing in personal data information systems;

the application of organizational and technical measures to ensure the security of personal data during their processing in personal data information systems necessary to meet the requirements for personal data protection, the fulfillment of which ensures the levels of personal data protection established by the Government of the Russian Federation, including the requirements established by Decree of the Government of the Russian Federation dated 01.11.2012 No. 1119;

assessment of the effectiveness of measures taken to ensure the security of personal data prior to the commissioning of the personal data information system;

accounting for machine-based personal data carriers;

detection of unauthorized access to personal data and taking measures;

recovery of personal data modified or destroyed due to unauthorized access to them;

establishing rules for access to personal data processed in the personal data information system, as well as ensuring registration and accounting of all actions performed with personal data in the personal data information system;

control over the measures taken to ensure the security of personal data and the level of security of personal data information systems.

10. Contact information

You can contact INCOR with any questions regarding the processing of your personal data within the framework of this Regulation using the following means of communication:

Email address: team@incor-ru.com

Postal address: 196006, St. Petersburg, Zastavskaya str., 31, room 1, room 2H