PRIVACY POLICY

 

1. GENERAL PROVISIONS

• This Personal Data Processing Policy of 4PAS LLC (hereinafter referred to as the Policy) is developed in accordance with Part 2 of Art. 18.1 of the Federal Law of 27.07.2006, No. 152-FZ "On Personal Data".
• This Policy defines the rules, requirements and principles for ensuring the security of personal data at 4PAPAS LLC (hereinafter referred to as the Company).
• This Policy is an internal document of the Company and must be posted on the official website.

2. SUBJECTS OF PERSONAL DATA PROCESSED BY THE COMPANY

• Information constituting personal data in the Company is any information relating directly or indirectly to a specific or identifiable individual (subject of personal data).
• The company processes the personal data of the following subjects: 
• personal data of Clients (potential Clients, Counterparties), as well as personal data of the head, employee of a legal entity that is a Client (potential Client, Counterparty) of the Company;
• personal data of employees (employees) of the Company;
• personal data of Candidates for filling vacancies
• personal data of other subjects transferred to the Company by other persons on the basis of concluded agreements and instructions for processing personal data.

3. PURPOSES OF PROCESSING PERSONAL DATA

• Purposes of processing personal data:
• fulfillment of the terms of the employment contract and the exercise of rights and obligations in accordance with labor legislation;
• making a decision on employment;
• fulfillment of the Company's contractual obligations.
• fulfillment of the Company's obligations to the Client, communication with the Client, including sending notifications, inquiries, information messages in order to provide services, participation in the Papa Bonus loyalty program via mobile radiotelephone networks to the subscriber phone number specified when placing an order, as well as for sending e-mails and other forms of sending / receiving information by phone or e-mail to the Client, as well as in order to process requests and applications from Clients;
• evaluation and improvement of the quality of services, the work of the Company, the development of new services and dishes;
• promotion of services and dishes;
• statistical and marketing research, including those related to the work of the Company, product quality, quality of service;
• to conduct marketing activities, send advertising messages and offers for participation in special promotions and events.

 

4. TERMS OF PROCESSING OF PERSONAL DATA

• When determining the storage periods for personal data of personal data subjects (Clients, Counterparties, Candidates for filling vacant positions), the Company is guided by the requirements of the Federal Law of July 27, 2006 No. 152-FZ "On Personal Data" and other regulations.
• The processing of personal data of the Company's Clients is terminated upon reaching the purpose of processing personal data or the period specified in the consent to the processing of personal data.
• The processing of personal data of other subjects of personal data is terminated upon achievement of the purpose of processing personal data or the period specified in the consent to the processing of personal data or upon reaching the storage time of personal data established by regulatory enactments
• The termination of the processing of personal data of subjects of personal data is also made upon the withdrawal of the subject of personal data of consent to the processing of personal data in accordance with the requirement

5. PRINCIPLES OF PROCESSING PERSONAL DATA

• The company in its activities ensures compliance with the principles of personal data processing. 
• The company does not process special categories of personal data related to race, nationality, political views, religious, philosophical beliefs, health.
• The company does not make decisions on the basis of solely automated processing of personal data, giving rise to legal consequences in relation to the subject of personal data or otherwise affecting his rights and legitimate interests.
• The transfer of personal data to other persons can be carried out only with the consent of the subject of personal data, drawn up in the manner prescribed by law or in other cases provided for by the requirements of the Federal Law
• The company has the right to entrust the processing of personal data to another person with the consent of the subject of personal data, on the basis of an agreement concluded with this person. If the Company instructs another person to process personal data, the condition of the contract will be the obligation to comply with the principles and rules for processing personal data. The order of the Company defines a list of actions (operations) with personal data that will be performed by the person processing personal data, the purpose of processing, the obligation to maintain the confidentiality of personal data and ensure the security of personal data during their processing, as well as requirements for the protection of processed personal data

6. RIGHTS OF THE PERSONAL DATA SUBJECT 

• The personal data subject has the right to receive information about the processing of his personal data. The subject of personal data has the right to demand clarification of the processed personal data, their blocking or destruction if the personal data is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing, as well as to take measures provided for by law to protect their rights.
• To exercise his rights and protect legitimate interests, the subject of personal data has the right to contact the Company. The Company considers appeals and complaints from subjects of personal data, investigates the facts of violations and takes the necessary measures to immediately eliminate them and resolve disputes and conflict situations.
• The personal data subject has the right to appeal against the actions or inaction of the Company by contacting the authorized body for the protection of the rights of personal data subjects.

7. PRINCIPLES AND CONDITIONS OF PERSONAL DATA PROCESSING

• The processing of personal data by the Company is carried out on the basis of the principles:
•  compliance of the purposes of processing personal data with the purposes predetermined and declared when collecting personal data;
•  the legality and fairness of the purposes and methods of processing personal data;
•  destruction of personal data in the event of certain requirements of the Federal Law
• The storage of personal data is carried out in a form that allows you to determine the subject of personal data, no longer than the purpose of processing personal data requires, if the storage period for personal data is not established by federal law, an agreement to which the subject of personal data is a party. 

8. INFORMATION ABOUT IMPLEMENTED REQUIREMENTS FOR PERSONAL DATA PROTECTION

• When processing personal data, the Company takes all the necessary legal, organizational and technical measures to protect personal data from unauthorized or accidental access to them, destruction, alteration, blocking, copying, provision, dissemination of personal data, as well as from other illegal actions. 
• Ensuring the security of personal data is achieved, in particular:
•  appointment of a person responsible for organizing the processing of personal data;
•  the application of legal, organizational and technical measures to ensure the security of personal data in accordance with Article 19 of the Federal Law;

9. FINAL PROVISIONS

• This Policy is subject to change, addition in case of changes in legislation
• Control over the fulfillment of the requirements of this Policy is carried out by the person responsible for organizing the processing of personal data in the Company.
• The responsibility of the Company's officials with access to personal data for failure to comply with the requirements of the rules governing the processing and protection of personal data is determined in accordance with the legislation