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Policy the processing of personal data



Historical Literature Publishing House Limited Liability Company policy in relation to processing of personal data
Historical Literature Publishing House
Limited Liability Company policy
in relation to processing of personal data

Approved by the Order of Director General dated 12/04/17

1. Purpose and scope of the document
1.1. The policy of Historical Literature Publishing House LLC (hereinafter also referred to as the Company)
in relation to processing of personal data (hereinafter — the Policy) determines the Company
position and intentions in respect to personal data processing and protection and provides
observation and protection of any person’s rights and freedoms, in particular, right to personal and
family privacy, protection of honor and good name.
1.2. The Policy is strictly followed by the management and employees of Historical Literature Publishing
House LLC.
1.3. The Policy is applied to all personal data processed by the Company with or without electronic
means.
1.4. This Policy is available for any personal data subject.
2. Terms and definitions
2.1. Personal data — any information directly or indirectly concerning an identified or identifiable
person (citizen). Such information, in particular, include: name, year, month, date and place of birth,
address, details of family, social, property status, information on education, occupation, income, and
other information.
2.2. Personal data processing — any action (procedure) or a combination of actions (procedures)
performed with personal data with or without electronic means. Such actions (procedures) include:
collection, receipt, recording, systematization, accumulation, storage, clarification (update,
modification), extraction, use, transfer (distribution, provision or access), anonymizing, blocking,
deletion, destruction of personal data.
2.3. Operator — the governmental body, municipal authority, legal entity or an individual person which
alone or with others organizes and (or) performs personal data processing, as well as defines the
personal data processing purposes, structure of personal data to be processed and actions
(procedures) performed with personal data.
2.4. Personal data electronic procession — processing of personal data by means of computer tools.
2.5. Provision of personal data — actions aimed at the disclosure of personal data to a certain person or
a certain group of people.
2.6. Distribution of personal data — actions aimed at the disclosure of personal data to the public.
2.7. Cross-border transfer of personal data — transfer of personal data to a foreign state.
Historical Literature Publishing House Limited Liability Company policy in relation to processing of personal data
2.8. Personal data blocking — temporary suspension of personal data processing (except in cases when
processing is necessary for the personal data clarification).
2.9. Destruction of personal data — actions as a result of which it becomes impossible to restore
personal data content in the information system and (or) the tangible media of personal data are
destroying.
2.10. Anonymizing of personal data — actions as a result of which it becomes impossible without
additional information to determine if personal data belong to a particular person.
2.11. Personal data information system — a set of personal data stored in databases and information
technologies and equipment need for personal data processing.
3. Personal data subjects
3.1. Historical Literature Publishing House LLC processes personal data of the following persons:
3.1.1. employees of Historical Literature Publishing House LLC;
3.1.2. entities, with which contracts are concluded under civil law;
3.1.3. job candidates of the Historical Literature Publishing House LLC;
3.1.4. customers of Historical Literature Publishing House LLC;
3.1.5. registered users of the site of Historical Literature Publishing House LLC;
3.1.6. representatives of legal entities;
3.1.7. suppliers (individual entrepreneurs).
4. Principles and conditions of personal data processing
4.1. Under the personal data security the Historical Literature Publishing House LLC understands the
protection of personal data against unauthorized or accidental access, destruction, modification,
blocking, copying, provision, distribution, as well as other illegal actions related to personal data and
takes necessary legal, organizational and technical actions to protect personal data.
4.2. Processing and provision of security of personal data in the Historical Literature Publishing House LLC
are in accordance with the requirements of the Constitution of the Russian Federation, the Federal
Law No. 152-FZ “On Personal Data”, by-laws and other federal laws of the Russian Federation
defining events and special aspects of personal data processing, regulations and guidelines of
Federal Service for Technical and Export Control (FSTEC) of Russia and Federal Security Service (FSB)
of Russia.
4.3. When processing personal data Historical Literature Publishing House LLC adheres to the following
principles:
4.3.1. the rules of law and fairness shall be observed;
Historical Literature Publishing House Limited Liability Company policy in relation to processing of personal data
4.3.2. personal data shall be processed only for specific, predefined and legitimate purposes;
4.3.3. personal data shall not be processed for the purpose incompatible with the personal data
collection purposes;
4.3.4. databases with personal data shall not be combined if purposes of their processing are
incompatible;
4.3.5. it is allowed to process the only personal data which meet their processing purposes;
4.3.6. the content shall be complied.
4.4. The Company processes personal data only if there is at least one of the following conditions:
4.4.1. personal data are processed with the consent of the personal data subject for such
processing;
4.4.2. personal data processing is necessary for the purposes provided by law and for the
implementation and fulfillment of operator’s functions, powers and duties under the laws
of Russian Federation;
4.4.3. personal data processing is necessary for the performance of a contract of which the
personal data subject is a party or beneficiary or surety, as well as for conclusion of a
contract on the initiative of the personal data subject or a contract of which the personal
data subject will be the beneficiary or guarantor;
4.4.4. personal data processing is necessary for the exercise of the rights and legitimate interests
of the Company or third parties, or for achieving the objectives of public interest, provided
that it does not violate the rights and freedoms of the personal data subject;
4.4.5. personal data are processed without access limits with consent of personal data subject or
at his/her request;
4.4.6. personal data are processed to be published or mandatory disclosed in accordance with
the federal law.
4.5. Historical Literature Publishing House LLC is entitled to contract the third parties for personal data
processing.
4.6. Legal entities engaged by Historical Literature Publishing House LLC to process personal data shall
observe the principles and rules for processing and protection of personal data provided by the
Federal Law No. 152-FZ “On Personal Data”. For each engaged legal entity there is a list of actions
(procedures) with personal data to be processed by the legal entity, containing the following
information: purposes of the data processing, confidentiality and safety requirements for data
processing, as well as the requirements for the protection of the personal data to be processed.
Historical Literature Publishing House Limited Liability Company policy in relation to processing of personal data
4.7. In cases established by the legislation of the Russian Federation, Historical Literature Publishing
House LLC is entitled to transfer personal data of citizens.
4.8. To provide information support, the Company may establish the public sources of employees’
personal data, including directories and address books. The public sources of personal data with the
consent of employee or client may include his/her name, first name, patronymic, date and place of
birth, position, contact telephone numbers, e-mail. The employee details should be at any time
excluded from public sources of personal data on the request of the employee, or by decision of a
court or other authorized public bodies.
4.9. Company shall destroy or anonymize the personal data in cases of processing purposes achievement
or absence of further need to achieve processing purposes.
5. Personal data subject rights
5.1. A citizen whose personal data are processed by Historical Literature Publishing House LLC, is entitled
to require from the Historical Literature Publishing House LLC:
5.1.1. confirmation of actual processing of personal data by Historical Literature Publishing
House LLC;
5.1.2. legal basis and purposes of personal data processing;
5.1.3. information on applied by Historical Literature Publishing House LLC methods of personal
data processing;
5.1.4. name and location of Historical Literature Publishing House LLC;
5.1.5. information on the persons who have access to personal data or to whom the personal
data can be disclosed based on the contract with Historical Literature Publishing House
LLC or according to federal law requirement;
5.1.6. list of the personal data to be processed related to the citizen, submitting a request and
the data source, unless a different procedure for the provision of such data is not provided
for by federal law;
5.1.7. information on personal data processing terms, including their storage time;
5.1.8. information on the exercise of the citizen’s rights under the Federal Law “On Personal
Data” No. 152-FZ;
5.1.9. information on ongoing or proposed transboundary transfer of personal data;
5.1.10. name and address of the party processing the personal data on behalf of Historical
Literature Publishing House LLC;
5.1.11. other information provided by the Federal Law “On Personal Data” No. 152-FZ, or other
federal laws;
5.1.12. clarification of his/her personal data, their blocking or destruction if personal data are
incomplete, outdated, inaccurate, unlawfully obtained or are not necessary for the stated
processing purpose;
Historical Literature Publishing House Limited Liability Company policy in relation to processing of personal data
5.1.13. withdrawal of his/her consent to the processing of personal data;
5.1.14. elimination of illegal actions of Historical Literature Publishing House LLC in respect of
his/her personal data;
5.1.15. contest of action or inaction of Historical Literature Publishing House LLC at the Federal
Service for Supervision of Communications, Information Technologies and Mass
Communications (Roskomnadzor) or at law if according to the citizen the Historical
Literature Publishing house LLC processes his/her personal data in violation of the Federal
Law No. 152-FZ “On Personal Data” or otherwise violates his/her rights and freedoms;
5.1.16. protection of his/her rights and legitimate interests, including for payment of damages
and/or compensation for moral damage in court.
6. Liability
6.1. In case of failure to comply with the provisions of the Policy the Historical Literature Publishing
House LLC bears responsibility as set forth by the applicable legislation of the Russian Federation.
Historical Literature Publishing House Limited Liability Company policy in relation to processing of personal data
NOTE:
If you have any questions on your personal data processing details please contact the Historical Literature
Publishing House LLC personally or by mail: 26-1, Volgogradsky prospect, 109316, Moscow.
If a formal request is sent to Historical Literature Publishing House LLC, the request shall contain the following
information:
1. full name of the personal data subject;
2. number of the main personal identity document of the personal data subject or his/her
representative, the document date of issue, and the issuing authority;
3. confirmation of your relationship with Historical Literature Publishing House LLC or other
information, confirming the processing of personal data by Historical Literature Publishing House
LLC;
4. signature of the citizen (or his/her legal representative). If the request is submitted in electronic
form, it shall be executed as electronic document and have electronic signature in accordance
with Russian Federation law.
Actual version of Historical Literature Publishing House LLC policy in relation to personal data processing is
published on the site histlit.com.
Historical Literature Publishing House Limited Liability Company policy in relation to processing of personal data
Information on actual requirements for personal data protection
Historical Literature Publishing House LLC while processing of personal data shall take the necessary
legal, organizational and technical measures to protect personal data against unauthorized or accidental
access, destruction, modification, blocking, copying, provision, distribution of personal data, as well as other
illegal actions in relation to personal data.
Such measures, in accordance with the Federal Law No. 152-FZ “On Personal Data” include:
• identification of the risks when personal data are processed in the information systems of personal
data;
• application of organizational and technical measures to protect the personal data while processing
within personal data information systems, compliant with the personal data protection requirements,
providing the levels of personal data protection set by the Russian Federation Government;
• use of the information protection means corresponding to the compliance evaluation procedure;
• evaluation of the personal data protection measures efficiency prior to commissioning of personal
data information system;
• detection of unauthorized access to personal data and respond actions;
• recovery of personal data, modified or destroyed as a result of unauthorized access;
• making rules of access to personal data processed within the personal data information system, as
well as providing registration and control of all personal data actions within the personal data
information system;
• control of the adopted personal data protection measures and of the personal data information
systems protection level;
• control of personal data computer-based media;
• organization of access to the Company territory via check-point;
• placement of the technical means for personal data processing within the protected area;
• maintenance of security equipment and alarms in continuous availability;
• monitoring of users’ activity, conducting of investigations of personal data security breach.
In order to coordinate the protection of personal data the Historical Literature Publishing House LLC has
designated officers responsible for the protection of personal data.