Lean Service LLC
Location address: 2, Gorbunova str., bld. 3, room II- 5, office A309.1, cab.1.
Postal address: 2, Gorbunova str., bld. 3, room II- 5, office A309.1, cab.1, 121596 Moscow, Russia
TIN: 7701068930
Primary state registration number: 1147748145236
E-mail: info@sk.consulting 1.


1. Purpose and scope of the document

1.1 POLICY OF LEAN SERVICE, LLC (hereinafter also the Company) concerning the processing of personal data (hereinafter Policy) defines the position and intentions of the Company in the field of processing and protection of personal data, in order to observe and protect human rights and freedoms, and in particular the right to privacy, personal and family secrets, protection of honor and good name.

1.2 The policy is strictly enforced by the heads and employees of all departments and branches of LEAN SERVICE LLC (if any).

1.3. This Policy shall apply to all personal data of the subjects processed in the Company with or without the use of automated means.

1.4. Any subject of personal data has access to this Policy.

2. Definitions

2.1 Personal data - any information relating directly or indirectly to a defined or identifiable individual (citizen). That is, such information may include, but is not limited to: full name, year, month, date and place of birth, address, information about family, social, property status, information about education, profession, income, as well as other information.

2.2 Processing of personal data - any action (operation) or a set of actions (operations) with personal data, performed with or without the use of automation tools. Such actions (operations) may include collection, receipt, recording, systematization, accumulation, storage, anonymization and pseudonymization, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), blocking, cross-border transfer, removal, destruction of personal data.

3. Subjects of personal data

LEAN SERVICE, LLC processes personal data on the following persons:

· personal data of employees
· personal data on job applicants
· personal data of users of the website https://sk.consulting
· personal data of the Company's contractors, including buyers and sellers (users of the website https://sk.consulting)
· personal data of founders, shareholders and sole executive bodies of counterparties.

4. Principles and conditions of personal data processing

4.1 Under security of personal data LEAN SERVICE LLC understands the protection of personal data from unauthorized or accidental access, destruction, modification, blocking, copying, providing, distribution of personal data, as well as from other unlawful actions in relation to personal data and takes necessary legal, organizational and technical measures for protection of personal data.

4.2 Processing and security of personal data in LLC LEAN SERVICE is carried out in accordance with the requirements of the Constitution of the Russian Federation, the Federal Law № 152-FZ "On Personal Data", subordinate legislation, other federal laws of the Russian Federation, guidance and methodological documents of FSTEC of Russia and the FSS of Russia determining the cases and features of personal data processing.

4.3 When processing personal data LEAN SERVICE LLC adheres to the following principles

· Personal data shall be processed on a legal and equitable basis
· Personal data processing shall be restricted by achieving specific pre-determined and legal purposes
· It is not allowed to process personal data for the purpose incompatible with that one of personal data collection
· It is not allowed to combine the data bases containing personal data to be processed for incompatible purposes
· There shall be processed only personal data that comply with the purposes of their processing.
· The scope and character of personal data to be processed shall comply with the intended purposes of such data processing. The personal data to be processed shall not be irrelevant to the declared purposes of their processing.

4.4 The Company shall process personal data only if at least one of the following conditions exists:

· the processing of personal data is carried out with the consent of the subject of personal data to the processing of their personal data
· processing of personal data is necessary to achieve the purposes provided by law, to implement and perform the functions, requirements and duties imposed on the operator by the legislation of the Russian Federation
· processing of personal data is necessary to perform the contract, which party or beneficiary or guarantor is the subject of personal data, as well as for the conclusion of the contract on the initiative of the personal data subject or the contract, under which the subject of personal data will be a beneficiary or guarantor
· processing of personal data is necessary to exercise the rights and legitimate interests of the Company or third parties or to achieve socially important objectives, provided that the rights and freedoms of the subject of personal data are not violated
· processing of personal data, access to which is granted to an unlimited range of persons by the subject of personal data or at his request
· processing of personal data subject to publication or mandatory disclosure in accordance with federal law.

4.5. LEAN SERVICE LLC is entitled to entrust processing of personal data of citizens to third parties based on an agreement concluded with these persons.

Third parties who process personal data on behalf of LEAN SERVICE LLC are obliged to comply with the principles and rules of processing and protection of personal data stipulated by the Federal Law № 152-FZ "On Personal Data". For each third party a list of actions (operations) with personal data, processing purposes are defined and to be executed by legal entity performing the processing of personal data, established the obligation of such third party to ensure confidentiality and security of personal data during their processing, as well as specified requirements for protection of processed personal data.

4.6 In cases established by the legislation of the Russian Federation, LEAN SERVICE LLC has the right to transfer personal data of citizens.

4.7 For the purpose of information supply in the Company can be created publicly accessible sources of personal data of employees, including directories and address books. Publicly available sources of personal data upon the consent of the employee may include his/her surname, name, patronymic, date and place of birth, position, contact telephone numbers, e-mail address. Information about the employee shall be excluded from publicly available sources of personal data at any time at the employee's request or by court order or decision of other authorized government agencies.

4.8 The Company shall destroy or depersonalize personal data upon attainment of the processing objectives or when it is no longer necessary to attain the processing objectives.


5. Rights of the subject of personal data
A citizen whose personal data is processed by LEAN SERVICE LLC has the right:

- To receive from LEAN SERVICE LLC:

· confirmation of the fact of processing of personal data by LEAN SERVICE LLC
· legal basis and purpose of processing personal data
· information on methods of personal data processing used by LEAN SERVICE LLC
· name and location of LEAN SERVICE LLC
· information about persons, who have access to personal data or to whom personal data may be disclosed based on agreement with LEAN SERVICE LLC or based on the federal law
· list of processed personal data related to citizen, from which the request was received and source of its collection, if other procedure of providing such data is not stipulated by the federal law
· information about the timing of the processing of personal data, including the period of their storage
· information about procedure of execution of rights, stipulated by the Federal Law "On personal data" № 152-FZ
· information about ongoing or envisaged trans-border transfer of personal data
· name and address of the person processing personal data on behalf of LEAN SERVICE LLC
· other information provided by the Federal Law "On Personal Data" № 152-FZ or other federal laws

- To request clarification of his/her personal data, their blocking or destruction in case if personal data is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing
- To withdraw its consent to the processing of personal data
- To demand elimination of wrongful actions of LEAN SERVICE LLC in relation to his personal data
- To appeal against actions or omissions of LEAN SERVICE LLC to the Federal Service for Supervision of Communications, Information Technology and Mass media (ROSKOMNADZOR) or in court, in case if a citizen thinks that LEAN SERVICE LLC processes his personal data in violation of requirements of the Federal Law № 152-FL "On Personal Data" or in any other way violates his rights and freedoms
- To defend his rights and legitimate interests, including compensation for losses and/or compensation for moral damages in court.

6. Liability

In case of non-compliance with the terms of this policy LEAN SERVICE LLC shall be liable in accordance with the current legislation of the Russian Federation.
To get Information on questions of processing of his personal data the citizen may apply in person to LEAN SERVICE LLC or by sending an official request by e-mail to info@sk.consulting or by post to the address: 2, Gorbunova str., bld. 3, room II- 5, office A309.1, cab.1, 121596 Moscow, Russia.

In case of sending an official request to LEAN SERVICE LLC, the following information should be specified in the text of the request:

· Full name
· Number of the document identifying the subject of personal data or his/her representative, information on the date of issue of the mentioned document and name of the body which issued it
· Information confirming your relations with LEAN SERVICE LLC or information which otherwise confirm the fact of processing of personal data by LEAN SERVICE LLC
· Signature of citizen (or his legal representative). If request is sent electronically, it should be executed in the form of electronic document and signed by electronic signature in accordance with the legislation of Russian Federation.

The site https://sk.consulting publishes the current version of the policy of LEAN SERVICE LLC regarding the processing of personal data.

7. When processing personal data LEAN SERVICE LLC takes necessary legal, organizational and technical measures for protection of personal data from unauthorized or accidental access to it, destruction, change, blocking, copying, providing, distribution of personal data, as well as from other unlawful actions in relation to personal data.

These measures, in accordance with Federal Law No. 152-FZ "On Personal Data", include:
· Identification of threats to the security of personal data while they are being processed in personal data filing systems
· Application of such organizational and technical measures for ensuring the security of personal data while they are being processed in personal data filing systems as are necessary to meet the requirements relating to the protection of personal data which shall be fulfilled in order to ensure the levels of protection of personal data which are established by the Government of the Russian Federation
· Application of means of data protection which have duly undergone conformity assessment procedures
· Assessment of the effectiveness of measures taken to ensure the security of personal data prior to the commissioning of a personal data filing system
· Detection of instances of unauthorized access to personal data and taking measures
· Restoration of personal data which have been modified or destroyed as a result of unauthorized access
· Establishment of the rules for access to personal data being processed in a personal data filing system and providing for the registration and recording of all actions performed on personal data in a personal data filing system
· Monitoring of measures taken to ensure the security of personal data and the level of protection of personal data filing systems
· Keeping of records of media containing personal data
· Arrangement of access control to the Company's premises
· Placement of technical means of personal data processing within the protected area
· Maintaining technical means of security, alarm system in constant readiness
· Monitoring the actions of users, conducting investigations on the facts of personal data security breach

In order to coordinate the activities to ensure security of personal data, LEAN SERVICE LLC appointed persons responsible for the security of personal data.
Personal Data Processing Policy
APPROVED
General manager
«Lean Service» LLC
Yury Makarov

January 1st, 2022
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