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Company policy on processing personal data

This document, hereinafter referred to as Policy, is a systematic statement on purposes, principles, methods, terms of personal data processing, and information on requirements followed in order to guarantee protection of the personal data owned by "Praktik", LLC, hereinafter referred to as Company. This policy is based on the requirements provided by Russian Federation Federal Law N152-FZ dated 27.07.2006 "On personal data" hereinafter referred to as Federal Law N152-FZ, on other regulatory legal acts of the Russian Federation that establish the procedure of handling and protecting personal data.

According to the Federal Law N152-FZ, the Company is a personal data controller.

The Company's personal data processing purposes:

- Preparing for effecting a contract that includes collecting requests for effecting, effecting a contract, executing a contract, terminating a contract for rendering of the "Praktik" coworking services implemented by "Praktik", LLC and reporting about the services indicated herein;
- Processing incoming requests from individuals for providing advisory work, for analyzing an individual's actions and overall operational behavior on the https://praktik.work website, and for running email marketing campaigns and newsletter campaigns;
- Ensuring entrance to the premises of the "Praktik", LLC facilities during the process of organizing safe operation of the thereby mentioned premises and accounting for the present individuals.
- Creating legitimate grounds for personal data processing and the legal methods of personal data processing;
- Limiting personal data processing by meeting the previously defined legitimate purposes;
- Zero tolerance to data warehousing when the processing of separate databases is conducted with mutually exclusive purposes;
- Solely processing the personal data that serve the processing purposes;
- Correlation of the content and the size of processed personal data to the processing purposes; processed personal data redundancy inadmissibility when evaluated against the stated processing purposes;
- Ensuring the accuracy of personal data, its sufficiency and relevance against the purposes of processing personal data;
- Ensuring the necessary means for deleting or correcting/updating incomplete or inaccurate data;
- Storing personal data in a form that allows to determine the personal data owner/subject, however only for the period of time no longer than is required by the personal data processing purposes, unless the period of personal data storage is otherwise established by a federal law or a contract to which the personal data owner/subject is a beneficiary or a guarantor party. The processed personal data shall be destroyed or depersonalized upon meeting the processing purposes or in the event of the loss of the need to achieve these goals, unless otherwise specified by a federal law.

Company's personal data processing methods:

Non-automated personal data processing with predominant paper medium, automated processing with or without utilizing automation controls, inter alia with or without transferring via "Praktik", LLC intranet, with or without transferring via the internet, and combined methods of personal data processing. "Praktik", LLC holds the right to discretionarily select the methods of personal data processing depending on the processing goals and its own material and technical resources and capabilities.

Confidentiality

The Company or any other parties granted access to the personal data shall not disclose of transfer the personal data to any third parties without the personal data owner's/subject's explicit consent, unless otherwise specified by federal laws.
Personal data owner/subject consent to processing the personal data
Personal data owner/subject makes the decision on providing their personal data and consents to its processing freely, with their will and in their own interest. Consent to personal data processing shall be specific, informed, and conscious. Consent to personal data processing may be granted by the personal data owner/subject or by their representative in any form guaranteeing the receipt confirmation, unless otherwise provided by federal laws. In case of receiving consent to personal data processing from the personal data owner/subject representative, the power of this representative to consent on behalf of the personal data owner/subject is verified by the Company.
Personal data processing consent may be withdrawn by the personal data owner/subject. In the event that an owner/subject withdraws the consent to the processing of personal data, the controller holds the right to continue processing personal data without the consent of the personal data owner/subject in the presence of grounds specified in clauses 2-11 of part 1 of article 6, part 2 of article 10 and part 2 of article 11 of Federal Law N152-FZ.

To the extent permitted by the applicable Federal Law N152-FZ, the personal data processing is executed solely upon the personal data owner/subject written consent. Consent granted in the form of an electronic document signed electronically in accord with the federal law is deemed equitable to the hard copy paper form containing the personal handwritten signature of the personal data owner/subject.

Company may collect personal data from an individual who is not a personal data owner/subject, provided that the Company obtains a confirmation of the grounds specified in Federal Law N152-FZ.
Personal data owner/subject rights
In the process of handling personal data, the Company ensures that the personal data owner/subject is guaranteed unobstructed opportunity to exercise their rights.
The personal data owner/subject holds the right to access their personal data as well as to obtain the information specified in part 7 of article 14 of Federal Law N152-FZ. The right to access personal data may be limited for the owner/subject under the terms specified by Federal Law N152-FZ.
The personal data owner/subject holds the right to protect their rights and lawful interests, inter alia compensation for damages and/or compensation for moral harm in a legal procedure.

Company's liabilities

In the process of handling personal data, the Company discharges its liabilities as a personal data controller as specified by Federal Law N152-FZ.
The Company takes necessary and sufficient measures to ensure executing the duties provided by Federal Law N152-FZ and accordingly adopted regulatory legal acts.
The Company discretionarily determines the composition and the list of measures necessary and sufficient to ensure executing the duties provided by Federal Law N152-FZ and accordingly adopted regulatory legal acts, unless otherwise specified by federal laws.
The Company guaranteed unlimited access to the Policy outlined herein and to the information on implemented requirements for protecting personal data by posting the Policy at https://praktik.work.

Information on implemented requirements for protecting personal data

When processing personal data, the Company makes necessary legal, organizational, and technical provisions or provides for their adoption to protect personal data from unauthorized or inadvertent access, destruction, modification, blocking, copying, providing, dissemination of personal data, as well as any other wrong acts in the matters of handling personal data.

In order to protect personal data, the Company implements the requirements to its protection during the processing as specified by the Government of the Russian Federation.
Information on measures taken by the Company to protect personal data is considered limited access information.