Personal data processing and protection policy
This policy for the processing and protection of personal data (hereinafter referred to as the Policy) is applied by Business Process Audit Limited Liability Company and/or its affiliates (hereinafter referred to as BPA LLC or we) to the websites, services, events and other products (services) of BPA LLC (hereinafter referred to as the Services).
The use of any of the Services may be subject to additional terms that may amend and/or supplement the Policy and/or have special conditions regarding personal data posted in the relevant documents of such Services.
1.
Scope of the Policy
1.1.
The personal data operator under the Policy is Business Process Audit Limited Liability Company (TIN 9729373310; OGRN 1247700282928), located at 119607, Russia, St. Moscow, Ramensky Boulevard, 1 or its affiliate providing the relevant Service.
1.2.
Your use of the Services means your unconditional acceptance of the Policy and the terms of personal data processing specified therein. If you do not agree to this Policy, you must immediately stop using the Services.
1.3.
In the Policy, we openly discuss all methods and conditions for processing personal data when using the Services.
1.4.
The policy was developed by BPA LLC in accordance with Federal Law No. 152-FZ of July 27, 2006 “On Personal Data” (hereinafter referred to as the Law).
2.
What is personal data?
2.1.
Personal data is any information relating directly or indirectly to a specific or identifiable individual. The concept of personal data is contextual. This means that, depending on the situation, the same data may or may not be personal data.
2.2.
For example, personal data may include last name, first name, middle name, email address, phone number.
2.3.
Personal data may also include technical information if it can be associated with you: for example, IP address, type of operating system, type of device (personal computer, mobile phone, tablet), browser type.
3.
The purposes of processing personal data by BPA LLC
Please note that the actual list of personal data processed by BPA LLC is determined based on the existing relationship between BPA LLC and you.
No. p/p
goal
List of personal data
Processing time
3.1
To provide you with our Services*
Last name, first name, phone number, email address, identifiers in messengers and social networks, information about the position, structural unit and current place of employment, personal identifiers, data about technical equipment (devices) **, information automatically received from the Services, including using cookies***, information obtained as a result of your actions, including information about comments, requests, feedback and questions you sent
During the period of your use of the relevant Service, and after the expiration of its use, during the limitation period, i.e. within 3 (three) years after you finish using such Service
3.2
To send you advertising and other communications about the Services of BPA LLC and its partners via various channels
Last name, first name, middle name, phone number, email address, messenger identifiers, information about the position, structural unit and current place of employment
During the period of validity of your marketing consent
3.3
For feedback to you
Last name, first name, middle name, phone number, email address, messenger IDs, information about comments, requests, feedback and questions you've sent
During the statute of limitations, i.e. within 3 (three) years from the time we sent you the last message (call) or from the moment we received your message if we were unable to contact you
3.4
To interact with you on employment issues
Last name, first name, middle name, phone number, email address, identifiers in messengers and social networks, work experience, educational information, professional qualifications, photo, date of birth or age, gender and other information that you included in your resume
During the period of validity of the consent to the processing of personal data that you provided on the Service when applying for a job
3.5
To conduct research, collect information about satisfaction with the Services, and improve the quality of the Services
Last name, first name, phone number, email address, messenger identifiers, information about the position, structural unit and current place of employment, personal identifiers, data on technical equipment (devices) **, information automatically received from the Services, including using cookie***, information obtained as a result of your actions, including information about sent, comments, requests, feedback and questions
During the period of your use of the relevant Service
3.6
To protect the Services, rights and legitimate interests of BPA LLC and our users/counterparties/partners****
Last name, first name, phone number, email address, identifiers in messengers and social networks, information about the position, structural unit and current place of employment, personal identifiers, data about technical equipment (devices) **, information automatically received from the Services, including using cookies***, information obtained as a result of your actions, including information about comments, requests, feedback and questions sent by you
Within the time limits established by the legislation of the Russian Federation, necessary to protect the Services, the rights and legitimate interests of BPA LLC and our users/counterparties/partners
* Providing you with our Services includes the proper fulfillment by BPA LLC of its obligations to you, the proper provision of services, registration in the Services, the recovery of your account password in the Services, as well as any other cases related to such actions.
** Data on technical equipment (devices) include IP address, type of operating system, type of device (personal computer, mobile phone, tablet), browser type, geographical location, fact of filling out a web form, provider of Internet services.
*** Cookies are pieces of text that are automatically stored in your browser's memory by using our site. This allows the Services to access and retrieve stored information on your computer when necessary. We use cookies to “remember” your preferences on the Services. Most browsers automatically save cookies, but you can always change your browser settings and opt out of saving cookies. You can read more about our use of cookies in section 9 of the Policy.
**** These situations include ensuring the performance and security of the Services, confirming your actions, preventing fraud, cyber attacks and other abuses, and investigating such cases.
4.
How we process your data
4.1.
Principles. Minimizing the volume is the main principle that we strictly adhere to when processing personal data: we do not collect it, store it or otherwise process it, unless it is really required.
We are also guided by the principles of personal data processing established by the current legislation of the Russian Federation, including the following:
The legality and fairness of personal data processing;
Processing personal data only for specific, predetermined and legitimate purposes;
Preventing the merger of personal databases that are processed for incompatible purposes;
The accuracy, sufficiency, relevance and reliability of personal data (as far as it depends on us*).
* BPA LLC does not verify the accuracy of the personal data provided to the idea of the ability of the person who provided it. When you transfer personal data to us, you guarantee that it is accurate, up-to-date and does not violate the laws of the Russian Federation.
4.2.
Ways. We can process personal data with or without automation tools, as well as process your personal data in a mixed manner. Processing may include collecting, recording, organizing, accumulating, storing, clarifying (updating, modifying), retrieving, receiving, using, transferring (providing, accessing, distributing), anonymizing, blocking, deleting and destroying personal data.
4.3.
Gathering. When collecting personal data from Russian citizens, we record, systematize, accumulate, store, refine (update, change) their personal data using databases located in the Russian Federation.
We may collect personal data in the following ways:
providing you with personal data when filling out forms on the Services;
automatic collection of information using technologies and services: web protocols, cookies, web tags that are launched only when you enter your data;
providing personal data in writing, including by means of communication.
4.4.
Storage. We store personal data exclusively on properly protected media, including electronic media. We have the right to combine personal data into an information system and process it using other software tools. Work with personal data information systems is carried out according to a generally accepted algorithm (collection, systematization, accumulation, storage, clarification, use, blocking, destruction, etc.).
4.5.
BPA LLC may involve third parties in the processing of your personal data by instructing third parties to process it and/or by transferring your personal data to third parties without instructing them to process it. Third parties may be involved only to achieve the purposes of processing personal data specified by us, as well as provided that such persons ensure the confidentiality and security of personal data during their processing.
Such persons, in particular, may include BPA LLC partners, including its affiliates, consultants, contractual contractors (including organizations that own servers, persons who make calls, SMS messages, any other types of mailings and notifications, persons who conduct surveys and research), contractors and agents. The actual composition of third parties involved by BPA LLC in the processing of personal data is determined based on the existing relationship between BPA LLC and you.
4.6.
Cross-border transfer. To achieve the goals set out in the Policy, we may transfer your personal data to countries other than the one in which it was collected. This may be necessary, for example, in situations where the event/study you want to participate in is organized by a foreign company. When making cross-border transfers, we protect your data in accordance with the Policy and current legislation of the Russian Federation.
4.7.
Dissemination. Dissemination means the disclosure of data to an indefinite number of people. For example, if you register for a public event we are hosting that you plan to participate in offline (live), we may post photos and videos from that event (including, possibly, your participation) on our Services.
On the Services, we post photos of our team members or partners, management contacts, and other information with the consent of these people or for other legal reasons. Their copying, publication on other Internet resources, inclusion in databases for mailing and other actions with them may be limited both by the legislation of the Russian Federation and by these people themselves.
4.8.
Extermination. By default, we destroy personal data when the purposes of their processing have been achieved or when it is no longer necessary to achieve them. In addition, we may destroy personal data in the following cases:
a threat to the security of the Services;
your violation of the terms of the Policy;
expiration of the personal data storage period;
your request or withdrawal of consent to the processing of personal data.
It is important to note that even if we receive a request from you to destroy personal data, we may continue to store it and otherwise process it if this is necessary to comply with the requirements of the current legislation of the Russian Federation or we have other grounds for processing this personal data (for example, an agreement concluded with you).
5.
Your rights
The basic rules for working with personal data and your rights as a data subject are described in detail in the Act that you can find hereto. For your convenience, here is a brief description of the fundamental rights provided for by the Act:
Right to know
You have the right to learn more details about the processing of your personal data by BPA LLC (Articles 18 and 18.1 of the Act).
Right to access
You have the right to ask us what personal data we process about you (art. 14 of the Act).
The right to rectify data and delete it
You can ask us to correct inaccurate, incomplete or outdated data or delete it (art. 20, para. 3 of the Act).
Right to withdraw consent
You can withdraw your consent to the processing of personal data when you deem it necessary (Article 9 (2) of the Act).
For any questions related to personal data, you can contact us in accordance with section 7 of the Policy.
6.
Personal data protection information
All personal information you provide is confidential by default. The protection of personal data processed by BPA LLC is ensured by legal, organizational and technical measures that are necessary and sufficient to meet the requirements of the legislation of the Russian Federation in the field of personal data protection. However, we always try to protect your data as much as possible and take more measures than are required by law. Some of them are listed below:
We have a person responsible for processing personal data. You can contact this person via email: privacy@bpa.tech;
We restrict access to your personal data and provide it only to our employees or our partners who need it to achieve the purposes for which we process your data;
We regularly assess the risks associated with the processing of personal data and take measures to eliminate or minimize them;
We conduct internal investigations to find facts related to unauthorized access to personal data if it is suspected that it has occurred;
We regularly monitor and analyze the security of BPA LLC's network infrastructure;
We introduce BPA LLC employees to the provisions of the legislation of the Russian Federation on personal data, including requirements for the protection of personal data, to BPA LLC's local acts on personal data processing, and also provide them with regular training;
We organize a security regime for rooms where personal data carriers are located, preventing uncontrolled entry into these premises or staying in them without the right of access.
7.
Requests from personal data subjects
7.1.
We are also guided by the principles of personal data processing established by the current legislation of the Russian Federation, including the following:
In writing to the address: 119607, Russia, Moscow. Moscow, Ramensky Boulevard, 1;
In the form of an electronic document by e-mail: privacy@bpa.tech.
7.2.
The request must include the following information:
the number of the main document proving your identity;
information on the date of issue of this document and the authority that issued it;
information confirming your relationship with us;
your signature.
7.3.
BPA LLC undertakes to consider the request received and send a response to it to the address specified in the request within 10 (ten) business days, if it concerns specifically the processing of your personal data by BPA LLC. If for some reason we need a little more time to respond, we'll send you a message explaining the reasons for the delay.
8.
Notification of technical data processing conditions and metric services
8.1.
Our Services may use captcha services. They are needed to verify requests and block robots on our websites and make using the Services more convenient for our users.
8.2.
For captcha services to work, we may instruct their owners to collect and process technical data about your device, its activity, and digital fingerprint (token, browser features, referer, timezone, etc.). This data is only collected when you use our Services that have a captcha widget installed. Captcha services use only technical data and only for the purpose of functioning and maintaining the captcha service on our website, as well as to improve the captcha service within the legitimate interest of its owner. The technical data collected by captcha services does not reliably identify you.
8.3.
We carefully select captcha services that must comply with all the requirements of the legislation of the Russian Federation on the collection, storage and other processing of user data.
8.4.
If you have any questions or concerns regarding the captcha services used on our sites, please contact us using the contacts listed on the site. A list of captcha services and links to their detailed operating conditions can be found on our websites and/or provided to you upon request.
8.5.
In addition, Yandex.Metrica may be used to collect and statistically analyze data related to the use of the Services. The data collected by Yandex.Metrica can be received and processed by the service provider (Yandex LLC). A list of data collected by Yandex.Metrica is available hereto.
9.
Cookie processing
Cookie type
Description
Strictly necessary
These cookies are necessary for our websites to function and cannot be turned off. They are generally only activated in response to your actions similar to requesting services, such as setting a privacy level, logging in, or filling out forms. You can set your browser to block these cookies or notify you when they are being used, but in this case some parts of our websites may not work or work incorrectly.
Operational
These cookies allow us to count visits and traffic sources to measure and improve the performance of our websites. Thanks to them, we know which pages are the most and least popular and see how visitors navigate websites.
Targeted
These cookies are set through our websites by our advertising partners. They may be used by these companies to collect data about your interests and show you relevant ads on other websites. If you do not agree to the use of these cookies, you will not be shown our targeted advertising on various websites.
Functional
These cookies allow us to provide improved functionality and personalization, for example for online chats and videos. They may be set up by us or by third party providers whose services are contained on our pages. If you do not agree to these cookies, some or all of these features may not work properly.
To opt out of the use of these cookies, you may use the features of our Services designed for this purpose. You can also use your browser settings where you can disable the use of cookies. Detailed instructions on how to disable cookies are available at the following external links:
10.
Restriction of the Policy and its amendment
10.1.
You must reasonably and responsibly post your personal data to the public, including on the Services when leaving feedback and comments.
10.2.
BPA LLC is not responsible for the actions of third parties who have gained access to your personal data through your fault.
10.3.
BPA LLC has the right to amend the Policy as needed. The policy must be reviewed in the event of significant changes in international or national legislation in the field of personal data.
11.
Contact information and details of BPA LLC
Full corporate name of the organization
Business Process Audit Limited Liability Company
Location address
119607, Russia, g. Moscow, Ramensky Boulevard, 1
Mailing address
119607, Russia, g. Moscow, Ramensky Boulevard, 1
Main state registration number
1247700282928
INN
9729373310
CHECKPOINT
772901001
Chief Executive Officer
Aleksandr Aleksandrovich Sizov
Contact phone
8 (800) 555-85-23
Email address
