GENERAL PROVISIONS

This policy of NEWCONTACT LLC (hereinafter referred to as "the Company") determines the procedure for processing personal data and the measures which ensure the security of personal data with the Company.

This Policy applies to all operations that are carried out in the Company with personal data, both by using automation tools and without using them.

This Policy is drawn up in accordance with the Council of Europe Convention No. 108 on the Protection of the Person in сonnection with the Automatic Processing of Personal Data and the Federal Law of the Russian Federation "On Personal Data" No. 152-FZ dated 06/27/2006.

PRINCIPLES AND PURPOSES OF PROCESSING PERSONAL DATA

The processing of personal data with the Company is carried out on a fair and legal basis in order to achieve certain legal goals.

Only those personal data that correspond to the purposes of their processing are subject to such processing.The volume and content of the processed personal data are consistent with the established processing goals, and their redundancy is not allowed.

When processing personal data, the Company ensures their accuracy, sufficiency and relevance in relation to the purposes of their processing and take the necessary measures to delete or, if necessary, specify incomplete or inaccurate personal data.

The storage of personal data with the Company is provided in such a form that would allow it to determine the subject of personal data in not greater time than the purpose of their processing requires (if the storage period for personal data is not established by law or by a contract to which the beneficiary or guarantor is a party to which the personal data is the subject). At the same time, the processed personal data is subject to destruction or depersonalization upon achievement of the processing goals or in case of loss of the need to achieve these goals.

The Company does not disclose personal data to third parties and does not disseminate personal data without the consent of the subject of the personal data.

The Company processes personal data in the presence of one of the following conditions:

• The processing is carried out only with the consent of the subject of the personal data;
• The processing is necessary to achieve the goals stipulated by law, to implement and fulfill the functions, powers and responsibilities assigned to the operator by the legislation of the Russian Federation;
  
• The processing is necessary for the entering into and execution of the contract, the party or beneficiary, or the guarantor of which is the subject of the personal data, as well as for the entering into the contract at the initiative of the subject of the personal data;
• The processing is necessary to exercise the rights and legitimate interests of the Company or third parties, as well as to achieve socially significant goals, while the rights and freedoms of the subject of the personal data should not be violated;
  
• The processing of the personal data is carried out with access to it is granted to an unlimited circle of persons stipulated by the subject of the personal data or at their request;
  
• The processing of personal data is subject to publication or mandatory disclosure in accordance with the Federal Law;
• The processing of personal data is subject to other conditions stipulated by Federal Law No. 152-FZ dated July 27, 2006 "On Personal Data".
• The terms for processing personal data are determined by the Company taking into account the established processing goals, the duration of the consent to the processing of personal data, as well as the terms determined by Order of the Ministry of Culture of the Russian Federation No. 558 dated August 25, 2010.
• The processing of personal data is carried out in the following ways:
• Non-automated processing of personal data;
• Automated processing of personal data with the transfer of information received through telecommunication networks or without such transfer;
• Mixed processing of personal data.
• While carrying out its activities, the Company may perform cross-border transfer of personal data exclusively in accordance with international treaties of the Russian Federation and Federal Law No. 152-FZ dated July 27, 2006 "On Personal Data"

THE PURPOSES FOR PROCESSING PERSONAL DATA

The Company has identified the following purposes for processing personal data:

• CV review and selection of candidates for vacant positions for further employment, as well as conducting other personnel work, assistance to employees in training and obtaining benefits and compensations;
• Entering into, support, amendment, termination of contracts, as well as granting the employees the authority to enter into various transactions and other actions on behalf of the Company;
• Fulfillment of obligations stipulated by the legislation of the Russian Federation, local regulatory acts and contracts;
• Tax and accounting;
• Fulfillment of obligations stipulated by the agreements on the basis of which the Company is entrusted with the processing of personal data.
• Registering of customers, potential customers, their representatives (contacts) and / or other counterparties of their representatives, including potential ones;
• Development of business activities, events, newsletters, commercial offers, congratulatory actions and assistance in obtaining the pass to enter the Company premises.

LIST OF SUBJECTS OF PERSONAL DATA, WHOSE DATA ARE PROCESSED BY THE COMPANY

When carrying out its activities, the Company processes personal data of the following categories of subjects of personal data: 7

• Employees who are or were in labor relations with the Company and their relatives.
• Applicants for vacant positions.
• Representatives of counterparty companies and potential counterparties of the Company and individuals who are in contractual legal relations with the Company.
• Representatives of legal entities/ clients of companies to whom the Company provides services.
• Individuals/clients and potential clients of the companies to whom the Company provides services, as well as users of this site

SECURITY AND PROTECTION OF PERSONAL DATA.

The Company takes the necessary legal, technical and organizational measures to ensure the protection of personal data from unauthorized access, destruction, alteration, blocking and other illegal and unauthorized actions.

The Company has appointed people who are responsible for organizing the processing and protection of personal data.

The Company employees who are allowed to process personal data shall not disclose personal data that become available to them in the performance of their duties.

The Company has developed and implemented local documents that govern the processing of personal data.

THE RIGHTS OF SUBJECTS OF PERSONAL DATA.

The subjects of personal data have the following rights:

• To require clarification, blocking or destruction of their personal data if they are incomplete, outdated, inaccurate, illegally obtained or are not necessary for the stated purpose of processing, as well as to take measures prescribed by law to protect their rights;

withdraw their consent to the processing of personal data in the manner and on the terms specified in the Federal Law of the Russian Federation "On Personal Data" No. 152-FZ dated July 27, 2006;

• To receive information on the processing time of their personal data, including the storage time.
  
• To appeal to an authorized body for the protection of the rights of the subjects of personal data or to sue in court the unlawful actions or inaction of the Company in the processing of their personal data;
  
• To protect their rights and legitimate interests, including suing for damages and/or for compensation for non-pecuniary damage in court.
  

To obtain information about the goals, legal justification, timing and extent of the information being processed, the personal data subject may send a written request in the manner established by Article 14 of the Federal Law of the Russian Federation "On Personal Data" No. 152-FZ dated July 27, 2006 to the following address: 30 Krasnoproletarskaya St.,bldg.1, Moscow 127473, Russian Federation

DUTIES OF THE COMPANY AS AN OPERATOR OF PERSONAL DATA

The Company shall, at the request of the subject of personal data (subject to the conditions established by the Federal Law of the Russian Federation "On Personal Data" No. 152-FZ dated July 27, 2006), provide information within 30 days from the date of such request.
The Company shall stop processing personal data, if the consent to the processing of personal data has been revoked or expired, if the goals of processing it have been achieved according to the information of the Company, or if there is no longer a need for such processing, when the processing time limit for the personal data has expired, if it is discovered that personal data are processed unlawfully and it is impossible to ensure the legitimacy of processing in other cases provided for by the legislation of the Russian Federation.

The Company also has other obligations of a personal data operator provided for by the Federal Law of the Russian Federation "On Personal Data" No. 152-FZ dated July 27, 2006 and other applicable laws of the Russian Federation, which regulate the collection and processing of personal data.

FINAL PROVISIONS

The laws of the Russian Federation shall apply to this Policy and relations between the subject of personal data and the Company.

The Company, as well as its officers and employees shall bear civil, administrative and other responsibility for non-compliance with the principles and conditions for processing of personal data of individuals, as well as for disclosure or illegal use of personal data in accordance with the legislation of the Russian Federation.

PERSONAL DATA PROCESSING AGREEMENT

On the basis of the Federal Law dated July 27, 2006 No. 152-FZ "On Personal Data", I hereby express my consent to the processing by NEWCONTACT LLC (TIN 7702231594, PSRN 1037700174929), located at address 30 Krasnoproletarskaya St., bld. 1, Moscow 127473, Russian Federation) of my personal data in accordance with the following information:

• Surname, given name;
• Position;
• Phone number;
• Email address;
• Other personal data received from me.

I give my consent to the processing by NEWCONTACT LLC of my personal data, that is, the performance of actions in relation to the specified data, including, but not limited to, collection, recording, systematization, accumulation, storage, updating (revising, changing), extraction, use, transfer (distribution, provision, access), including cross-border transfer, depersonalization, blocking, deletion, and destruction of personal data.

Processing of personal data can be carried out using automation tools including using such Internet services as Google Analytics, Yandex.Metrica and/or without using such tools.

I hereby give my consent to the processing of personal data in order to be informed about the services provided by NEWCONTACT LLC. In connection with the above purposes, my personal data can be communicated to third parties, as well as (in anonymized form) for statistical and marketing purposes. Third parties are entitled to the processing of my personal data on the basis of this consent.

This consent is valid until the date of its withdrawal by me by sending an appropriate written statement to the address of NEWCONTACT LLC stated in this document.

I have been informed that I have the right to demand the clarification of my personal data, their blocking or destruction. if the personal data is incomplete, outdated, inaccurate or is not necessary for the stated processing purposes and take measures prescribed by law to protect their rights. I also have the right at any time to demand the termination of the processing of my personal data by sending a corresponding request to the address of NEWCONTACT LLC specified in this document.

I acknowledge that putting a "V"checkmark in the box to the left of the phrase "I accept the terms of the agreement on the processing of personal data and express my consent to the processing of such data" on the website www.neovox.ru, signifies my written consent to the conditions described in it.

AUTOMATED DATA COLLECTION

In some cases, the Company automatically collects certain types of information when you visit the site and/or fill out questionnaires. Technologies such as web server logs for collecting IP addresses and cookies and data for web analytics can be used for this purpose.

The collection of such information will allow us to improve the functional characteristics of the site as well as evaluate the productivity of our marketing activities.

Cookies are files or pieces of information that can be stored on your computer (or other Internet-compatible devices, such as a smart phone or tablet) when you first visit this website, which allow you to recognize your data when you visit it again. Such information can be used by us to improve the content and functioning of the website, conduct market research and collect statistics.

Cookies in no manner reveal your identity, nor do they constitute malicious software.

In many cases, web browsing software (a web browser) by default allows cookies to be stored on your device. You can also disable cookies at any time or configure your web browser to alert you to the receipt of such files. However, disabling cookies may limit access to certain features of this website.

GOOGLE ANALYTICS AND YANDEX.METRICA

The Google Analytics and Yandex Metrica Internet services are used for a detailed assessment of website traffic and analysis of the behavior of its users. You can find detailed information about using Google Analytics services at this address:
http://www.google.com/analytics/learn/privacy.html, about using Yandex.Metrica -
https://yandex.ru/support/metrika/general/how-it-w....

By default, Google Analytics and Yandex.Metrica collect information about all visitors to this website.

At your discretion, you can disable the collection of information about the websites you visited by using the Google Analytics blocker: https://tools.google.com/dlpage/gaoptout and / or Yandex.Metrica blocker: https://yandex.ru/support/metrika/general/opt-out.....