Policy on personal data processing

UAB «BRAINSTORM EUROPE»

Laisves pr. 60-1314, LT-05120, Vilnius, Lithuania

ID/VAT 302724222/LT100006674119

This policy of personal data processing is drawn up in accordance with the requirements of the Federal Law dated 27.07.2006. No. 152 FL "On Personal Data" hereinafter referred to as the Law on Personal Data and determines the order of personal data processing and measures to ensure the security of personal data of UAB "BRAINSTORM EUROPE" hereinafter referred to as the Operator.

1.1 The Operator sets as its most important goal and condition of its activity the observance of human and citizen's rights and freedoms during the processing of personal data, including the protection of the right to privacy, personal and family secrecy.

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 obtain about the visitors of the website https://grunbaumtech.com.

2.1 Automated processing of personal data Processing of personal data by means of computer hardware.

2.2 Blocking of personal data is a temporary cessation of personal data processing, except for cases when processing is necessary to clarify personal data.

2.3 Web site is a set of graphic and informational materials, as well as computer programs and databases ensuring their availability on the Internet at the network address https://grunbaumtech.com.

2.4 Personal data information system is a set of personal data contained in databases and information technologies and technical means ensuring their processing.

2.5 Anonymization of personal data actions as a result of which it is impossible to determine without the use of additional information the belonging of personal data to a particular User or other subject of personal data.

2.6 Processing of personal data any action operation or set of actions operations performed with the use of automation means or without the use of such means with personal data including collection recording systematization accumulation storage clarification updating updating modification retrieval use transfer dissemination making available depersonalization blocking deletion destruction of personal data.

2.7 Operator is a state authority municipal body legal or natural person independently or jointly with other persons organizing and or carrying out processing of personal data, as well as determining the purposes of personal data processing the composition of personal data subject to processing actions and 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://grunbaumtech.com.

2.9 Personal data authorized by the subject of personal data for dissemination personal data access to which is granted by the subject of personal data to an unlimited number of persons by giving consent to the processing of personal data authorized by the subject of personal data for dissemination in the manner prescribed by the Law on Personal Data hereinafter referred to as personal data authorized for dissemination.

2.10. User any visitor of the website https://grunbaumtech.com.

2.11. Provision of personal data actions aimed at disclosure of 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 number of persons transfer of personal data or familiarization with personal data to an unlimited number of persons, including disclosure of personal data in mass media placement 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 authority to a foreign natural person or a foreign legal entity.

2.14. Destruction of personal data any actions as a result of which personal data are irretrievably destroyed with the impossibility of further recovery of the content of personal data in the information system of personal data or material carriers of personal data are destroyed.

3.1 The Operator has the right

• to receive from the subject of personal data reliable information and or documents containing personal data
• In case the subject of personal data withdraws his/her consent to personal data processing as well as submits a request to stop processing of personal data, the Operator has the right to continue processing of 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 fulfillment of obligations stipulated by the Personal Data Law and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.

3.2 The Operator is obliged to

• provide the personal data subject, upon his/her request, with information regarding the processing of his/her personal data
• organize processing of personal data in accordance with the procedure established by the current legislation of the Russian Federation
• respond to appeals and inquiries of 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 the necessary information within 10 days from the date of receipt of such request
• to publish or otherwise ensure unrestricted access to this Policy on personal data processing
• to take legal organizational and technical measures to protect personal data from unlawful or accidental access to them destruction modification blocking copying providing dissemination of personal data as well as from other unlawful actions in relation to personal data
• to stop transferring, disseminating, providing access to personal data to stop processing and destroy personal data in the manner and cases provided for by the Law on personal data
• fulfill other obligations provided for by the Personal Data Law.

4.1 Personal data subjects have the right to

• to receive information regarding the processing of his/her personal data except for cases provided for by federal laws Information is provided to the subject of personal data by the Operator in an accessible form and must not contain personal data relating to other subjects of personal data except for cases when there are legal 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 demand from the operator to clarify his personal data, block or destroy them if the personal data are incomplete, outdated, inaccurate, illegally obtained or are not necessary for the stated purpose of processing, as well as to take measures provided for by law to protect his rights.
• to impose the condition of prior consent for the processing of personal data for the purpose of marketing of goods, works and services
• to revoke the consent to the processing of personal data, as well as to submit a request to stop 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 unlawful acts or omissions of the Operator in the processing of his personal data
• Exercise other rights provided for by the legislation of the Russian Federation

4.2 Personal data subjects are obliged to

• provide the Operator with accurate data about themselves
• to inform the Operator about updates and changes to their personal data.

4.3 Persons who passed to the Operator false information about themselves or information about another subject of personal data without the consent of the latter shall be liable in accordance with the legislation of the Russian Federation.

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

5.2 The processing of personal data shall be limited to the achievement of specific predetermined and legitimate purposes. Processing of personal data incompatible with the purposes of personal data collection is not allowed.

5.3 It is not allowed to merge databases containing personal data processed for incompatible purposes.

5.4 Only personal data that corresponds to the purposes for which it is processed may be processed.

5.5 The content and scope of processed personal data correspond to the stated purposes of processing. Redundancy of 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 shall be ensured, their sufficiency and, where necessary, relevance in relation to the purposes of personal data processing The Operator shall take the necessary measures or ensure that they are taken to remove or clarify incomplete or inaccurate data.

5.7 Storage of personal data is carried out in a form that allows to identify the subject of personal data no longer than required by the purposes of personal data processing, unless the period of personal data storage is established by federal law by the contract to which the subject of personal data is a party, beneficiary or guarantor. Processed personal data shall be destroyed or depersonalized upon achievement of the processing purposes or in case of loss of necessity to achieve these purposes unless otherwise provided for by federal law.

Purpose of processing - to provide the User with access to services, information and or materials contained on the website.

Personal data - surname first name patronymic; e-mail address; telephone numbers.

Legal grounds - Federal Law On Information Information Information Technologies and Information Protection" dated 27.07.2006 N 149 FL"

Types of personal data processing - Collection recording systematization accumulation storage destruction and depersonalization of personal data; Sending information letters to e-mail address.

7.1 Processing of personal data shall be carried out with the consent of the personal data subject to the processing of his/her personal data.

7.2 The processing of personal data is necessary to achieve the purposes provided for by the international treaty of the Russian Federation or by law in order to fulfill the functions, powers and duties assigned to the operator by the legislation of the Russian Federation.

7.3 Processing of personal data is necessary for realization of justice of execution of a judicial act of another body or 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 personal data subject is a party or a beneficiary or guarantor, as well as for the conclusion of a contract at the initiative of the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor.

7.5 The processing of personal data is necessary for the exercise of the rights and legitimate interests of the operator or third parties or for the achievement of socially important purposes, provided that the rights and freedoms of the personal data subject are not violated.

7.6 The processing of personal data is carried out with the access of an unlimited number of persons to which the personal data subject has granted access or at his/her request hereinafter referred to as publicly available personal data.

7.7 Processing of personal data subject to publication or mandatory disclosure in accordance with federal law.

Security of personal data processed by

The Operator ensures the security of personal data processed by implementing legal, organizational and technical measures necessary for full compliance with the requirements of the current legislation in the field of personal data protection.

8.1 The Operator shall ensure safety of personal data and take all possible measures to exclude access to personal data by unauthorized persons.

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

8.3 In case of identifying inaccuracies in personal data, the User may update them independently by sending a notification to the Operator to the Operator's e-mail address info@grunbaumtech.com, with the note "Personal Data Update"

8.4 The term of personal data processing is determined by the achievement of the purposes for which the personal data were collected, unless another term is provided for by the contract or applicable law, the User may at any time withdraw his/her consent to the processing of personal data by sending a notice to the Operator by e-mail to the Operator's e-mail address info@grunbaumtech.com, with the remark "Withdrawal of consent to the processing of personal data".

8. 5. All information that is collected by third-party services, including payment systems, means of communication and other service providers is stored and processed by the Operators in accordance with their User Agreement and Privacy Policy of the Personal Data Subject and or 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 personal data subject on the transfer of personal data other than access, as well as on the processing or conditions of processing other than access, of personal data authorized for dissemination do not apply in cases of personal data processing in the state public and other public interest as defined by the legislation of the Russian Federation.

8.7 When processing personal data, the Operator shall ensure confidentiality of personal data.

8.8 The Operator shall store personal data in a form that allows to identify the subject of personal data no longer than required by the purposes of personal data processing, unless the period of personal data storage is established by federal law by the contract to which the personal data subject is a party, beneficiary or guarantor.

8.9 The condition for termination of personal data processing may be the achievement of the purposes of personal data processing, expiration of the personal data subject's consent, revocation of consent by the personal data subject or the requirement to terminate personal data processing, as well as detection of unlawful processing of personal data.

9.1 The Operator shall collect, record, systematize, accumulate, store, clarify, update, modify, retrieve, use, transfer, disseminate, make available, depersonalize, block, delete and destroy 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.

10.1 Prior to the commencement of transborder transfer of personal data, the Operator shall notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out transborder transfer of personal data such notification shall be sent separately from the notification on the intention to carry out personal data processing.

10.2 Before submitting the above-mentioned notification, the Operator is obliged to obtain relevant information from foreign authorities of foreign state of foreign natural persons of foreign legal entities to whom trans-border transfer of personal data is planned.

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

12.1 The User can get any explanations on any questions concerning the processing of his/her personal data by contacting the Operator via e-mail info@grunbaumtech.com.

12.2 This document will reflect any changes to the Operator's personal data processing policy 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 the following address https://grunbaumtech.com/offer/.