Privacy Statement

Privacy Statement

The present Privacy Policy (hereinafter referred to as the Policy) defines how IT Professional Solutions LLC (Perm, Russia; part of the ITPS Group of Companies) (hereinafter referred to as the Operator) collects, uses, stores, and discloses information received from users of the http://itps.com/ website (hereinafter referred to as the Website). This Policy applies to the Website, all subdomains of the Website, and all products and services offered by the Operator on the Website.

This Policy applies directly to the Website and the information obtained through it. The Policy does not apply to any other websites and does not apply to third-party websites that may contain references to the Website and from which links to the Website can be made and links from this Website to other websites on the Internet.

  1. TERMINOLOGY

1. The following basic terms are used in the Policy:

Automated processing of personal data is the processing of personal data using computer technology.

Blocking of personal data is a temporary cessation of the personal data processing (except when the processing is necessary for personal data clarification).

Personal data information system is a combination of personal data contained in databases and information technology and technical means ensuring its processing.

The anonymization of personal data is an action that makes it impossible to determine whether the personal data belongs to a specific personal data subject without the use of additional information.

Personal data processing means any action (operation), or a set of actions (operations) conducted with or without the use of means of automation with personal data, including collection, recording, organizing, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, destruction of personal data.

Operator is IT Professional Solutions LLC (OGRN 1135902002158), located at 614000, Perm, 51a Sovetskaya street, arranging and/or carrying out the processing of personal data, as well as determining the purposes of personal data processing, the composition of personal data to be processed, actions (operations) performed with personal data independently or jointly with other persons.

Personal data is any information relating to a directly or indirectly defined or identifiable natural person (the subject of personal data).

User is a legally capable natural person who has acceded to this Policy in their own interest or who acts for and on behalf of a legal entity they represent.

Provision of personal data is the act of disclosing personal data to a particular person or a specific group of persons.

Distribution of personal data is the act of disclosing personal data to an indefinite number of persons.

Website/Websites is any automated information system available on the Internet at network addresses in the following domains (including subdomains): itps.com.

Destruction of personal data is an action resulting in the impossibility to restore the content of personal data in a personal data information system and/or resulting in the destruction of physical storage media of personal data.

Cookies are small pieces of data sent by a web server and stored on a user's computer, which the web client or web browser sends to the web server each time it makes an HTTP request to open a page on the relevant Website.

IP address is a unique network address of a node in an IP-based computer network.

  1. GENERAL PROVISIONS

2.1. This Policy applies to the itps.com website accessed on all computer and mobile devices. The use of the Website by the User signifies agreement to these Terms and Conditions for the processing of the User's personal data. The User is aware and agrees that the consent is given electronically on the Website fully complies with the requirements of personal data legislation and enables the Operator to certify that it has been received.

2.2. The Operator may amend the Policy at any time. When changes are made to the Policy, the Operator shall notify the User by posting the current version on the itps.com Website.

2.3. The Policy only applies to the Website. The Operator does not control and is not responsible for the websites of third parties to which the User may be directed through the links available on the Website.

2.4. Registration on the Website implies that the User provides the Operator with correct information about themselves. The Operator is not under obligation to verify the accuracy of the information provided.

2.5. By registering on the Website, the User voluntarily and explicitly accepts the terms and conditions of the User Agreement and voluntarily consents to the processing of their personal data under this Policy.

2.6. The Operator is not an information intermediary (Article 1253.1 of the Civil Code of the Russian Federation).

2.7. The legal basis for the processing of personal data by the Operator includes:

  • Civil Code of the Russian Federation;
  • Federal Law of 27.07.2006 No. 152-FZ "On Personal Data" (hereinafter referred to as FZ-152, the Law).
  • Federal Law of the Russian Federation dated 27.07.2006 No. 149-FZ "On information, information technologies and information protection";
  • Resolution of the Government of the Russian Federation dated 01.11.2012 No. 1119 "On approval of requirements for the protection of personal data during their processing in personal data information systems";
  • Resolution of the Government of the Russian Federation dated 15.09.2008 No. 687 "On approval of the Regulation on peculiarities of processing of personal data is carried out without the use of the automated tools";
  • Resolution of the Federal Service for Technical and Export Control of the Russian Federation dated 18.02.2013 No. 21 "Composition and content of organizational and technical measures to ensure personal data security while processing in personal data information systems";
  • Other applicable laws and regulations;
  • Local regulations of the Operator;
  • The present Privacy Policy.
  1. SUBJECT OF CONFIDENTIALITY Policy

3.1. The present Policy establishes the responsibilities of the Operator for the non-disclosure and confidentiality regime of personal data, which the User provides at the request of the Operator when completing the communication form on the Operator's Website and/or when registering for an event announced on the Operator's Website.

3.2. The User consents to the processing of personal data, including the collection, processing, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, depersonalization, use, transfer, including on court order, including to third parties (including to Parma-Telecom LLC (Taxpayer Identification Number 5902191377) and other companies constituting ITPS Group), following measures to protect personal data from unauthorized access (distribution, provision, access), blocking, erasure, destruction, etc., at their own will and in their interest.  Personal data depending on the document (message, application for an event, feedback, etc.) includes the following personal data: full name, contact phone numbers, e-mail addresses, place of work and position, user data (information on the location, OS type and version, browser type and version, device type and its screen resolution, the source from which the User accessed the site (Website or advertisement), OS and browser language, the pages the User opens and the buttons the User presses, IP address, cookies), the information contained in the User's CV.

3.3. The Operator informs the User that the collection, storage, and other actions related to the processing of personal data of the User are performed for the following purposes: processing incoming requests from users to consult and answer questions; processing and reviewing information on Users (including their CVs) regarding vacancies posted on the Website; analysing the actions of Users on the Website and the functioning of the Website; analysing the activities of Users on the Website and the functioning of the Website; registering Users to participate in events announced on the Website; sending out promotional materials and newsletters.

The Operator collects statistics on its Users' IP addresses to identify and resolve technical problems.

Any other personal information not stipulated above is subject to retention and non-disclosure, except in the cases specified by the legislation of the Russian Federation.

3.4. The User has the right to withdraw their consent to processing personal data by drawing up a corresponding written document, which should be sent to the following address: Perm-Centre, P.O. Box 187, Russia, 614000.

  1. METHODS AND TIME LIMITS FOR PROCESSING PERSONAL DATA

4.1. The User's personal data shall be processed without any time limit, in any lawful manner, including in personal data information systems with or without the use of automation tools.

Personal data shall not be retained longer than required for processing or until the User sends the written withdrawal of personal data to the following address:  Perm-Centre, P.O. Box 187, Russia, 614000.

4.2. Personal data of the User may only be transferred to authorized state authorities of the Russian Federation on the grounds and according to the procedure established by the legislation of the Russian Federation.

4.3. The Website Administration takes the necessary organizational and technical measures to protect the User's personal data from unauthorized or accidental access, destruction, modification, blocking, copying, distribution, and other unlawful actions of third parties.

  1. OBLIGATIONS OF THE PARTIES

5.1. The User is obliged to:

5.1.1. Provide truthful information regarding personal data necessary for the use of the Website.

5.1.2. Update, supplement the provided personal data information in case the information changes.

5.2. The Operator is obliged to:

5.2.1. Use the information received solely for the purposes set out in point 3.3 of the present Policy;

5.2.2. Ensure that personal data is kept confidential, not disclosed without User's prior written consent, and not sold, exchanged, published, or disclosed in any other way possible, except as set out in clause 4.2 of this Policy;

5.2.3. Take precautions to protect the confidentiality of the User's personal data following the procedures generally used to protect this type of information in the current business environment.

5.2.4. Block the personal data relating to the relevant User from the moment of application or request by the User or their legal representative or an authorized body for the protection of personal data subjects' rights for the period of the verification, in case of revealing misleading personal data or unlawful actions.

5.3. Other rights and obligations of the Operator in terms of personal data operation are determined by the legislation of the Russian Federation regarding personal data.

  1. LIABILITY OF THE PARTIES

6.1. The Operator shall not be liable for any damage or losses caused to the Users due to errors or inaccuracies in the information provided by the User on the Website.

6.2. In case of full or partial unavailability of the Website due to maintenance or other technical activities ensuring normal functioning of the Website, the Operator shall not be held responsible before the Users for the failure of the latter to receive any information.

6.3. Any problems arising in the process of registration of the User and use of the Website shall be the sole responsibility of the User. The Operator shall not be liable for any damage or loss to the User arising from the User's error or negligence in using the Website.

  1. UPDATING, CORRECTING, DELETING, AND DESTROYING PERSONAL DATA

7.1. The Operator shall inform the User or their representative according to the procedure stipulated in Article 14 of the Federal Law 152 concerning the availability of personal data relating to such User, as well as provide an opportunity for familiarisation with such personal data upon request of the User or their representative within 30 (thirty) days from the date of receipt of the User's or their representative's request.

7.2. In case the fact of personal data inaccuracy is confirmed (clause 5.2.4 of this Policy), the Operator, based on information provided by the User or their representative, or by an authorized body for the protection of the rights of personal data subjects, or other necessary documents, undertakes to clarify the personal data or ensure its clarification (if personal data is processed by another person acting for the Operator) within 7 (seven) business days from the date such information is provided and to remove the blocking of the personal data

7.3. In the event of unauthorized processing of personal data by the Operator or by a person acting on behalf of the Operator, the Operator shall, within a period not exceeding three (3) business days from the date of such detection, stop the unauthorized processing of personal data or ensure that the person acting on behalf of the Operator stops the unauthorized processing of personal data. Suppose it is not possible to ensure the lawfulness of personal data processing. In that case, the Operator shall destroy such personal data or ensure its destruction within a period not exceeding ten (10) business days from the date the unlawful processing of personal data is detected.

7.4. The Operator shall destroy or ensure the destruction of the User's personal data (if the personal data is processed by another person acting on behalf of the Operator) within a period not exceeding thirty (30) days from the date of completed personal data processing or from the date the User withdraws their consent for the processing of personal data (if the storage of personal data is no longer required for personal data processing).

7.5. If personal data cannot be destroyed within the period specified in clauses 7.3-7.4 of this Policy, the Operator shall block such personal data or ensure its blocking (if the processing of personal data is carried out by another person acting on behalf of the Operator) and ensure destruction of personal data within a period not exceeding 6 (six) months, unless otherwise specified by Federal Laws.

  1. DISPUTE RESOLUTION

8.1. Prior to taking court action in disputes arising from the relationship between the User and the Operator, a claim (a written offer to resolve the dispute voluntarily) is mandatory. All correspondence between the Parties shall be sent using the following postal address: 614000, Perm-Centre, P.O. Box 187. The Operator is entitled to send written inquiries and/or complaints to the e-mail address specified by the User on the Website. Upon receiving the complaint, the Party shall provide a written reasoned response to the complaint within thirty (30) calendar days.

8.2. Failing agreement, the dispute will be referred to the court at the Operator's location.

8.3. This Policy and the relationship between the User and the Operator shall be governed by the applicable laws of the Russian Federation.

  1. ADDITIONAL PROVISIONS

9.1. The Operator may amend this Policy at any time without the consent of the User.

9.2. The new Privacy Policy becomes effective as soon as it is posted on the Website unless otherwise provided for in the new Policy.

9.3. Any suggestions or questions regarding this Policy should be submitted to the Operator by sending a written request to the following postal address: Perm-Centre, P.O. Box 187, Russia, 614000, or to the e-mail address info@itps-russia.ru with the obligatory indication of the subject line "On Privacy Policy."

9.4. The current version of the Privacy Policy is available at itps.com.

 

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