Privacy Policy

1. Purpose and scope

This Policy of Polyus Arena LLC regarding the processing of personal data (hereinafter referred to as the Policy) is intended to determine the general principles for processing personal data of employees of Polyus Arena LLC (hereinafter referred to as the Company) and other persons whose personal data is processed by the Company in order to ensure the protection of rights and freedoms of a person and citizen - the subject of personal data when processing his personal data (hereinafter referred to as PD).

1.2 In accordance with subparagraph 2 of Article 3 of the Federal Law of July 27, 2006. No. 152 - Federal Law “On Personal Data” (hereinafter referred to as the Law) The Company is an operator of personal data, and can also process personal data on behalf of other operators on the basis of concluded agreements and in accordance with Part. 3 - 5 of Article 6 of the Law.

1.3 The Company has developed and put into effect local regulations and documents establishing the procedure for processing and ensuring the security of personal data, which ensure compliance with the requirements of the Law and regulations adopted in accordance with it.

1.4 This Policy applies to all transactions carried out in the Company with personal data using or without the use of automation tools.

1.5 The Policy is required for familiarization and compliance by all employees of the Company.

1.6 This Policy is published on the Company’s Website to ensure unrestricted access to it.

2. Terms and abbreviations

2.1 Terms

Term	Definition
Automated processing of personal data	processing of personal data using computer technology
Biometric personal data	information that characterizes the physiological and biological characteristics of a person, on the basis of which his identity can be established and which is used by the operator to establish the identity of the subject of personal data
Blocking personal data	temporary cessation of processing of personal data (except for cases where processing is necessary to clarify personal data)
Browser	application software installed on the device for viewing Internet pages
Law	Federal Law of July 27, 2006 No. 152 - Federal Law “On Personal Data”
Personal data information system	a set of personal data contained in databases and information technologies and technical means that ensure their processing
Cookies files	a piece of data about the history of visiting web pages, stored in the browser on the device of the Site user.
Processing of personal data	any action (operation) or set of actions (operations) performed using automation tools or without the use of such means with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer( distribution, provision), provision of access or implementation of logical and (or) arithmetic operations with such data, depersonalization, blocking, deletion, destruction of personal data
Operator	state body, municipal body, legal entity or individual, independently or jointly with other persons organizing and/or carrying out the processing of personal data, as well as determining the purposes of processing personal data, the composition of personal data to be processed, actions (operations) performed with personal data data
Society	Limited Liability Company "Polyus Arena"
Personal Information	any information relating to a directly or indirectly identified or identifiable individual (subject of personal data)
Personal datae, authorized by the subject of personal data for distribution	personal data, access to an unlimited number of persons to which is provided by the subject of personal data by giving consent to the processing of personal data authorized by the subject of personal data for distribution in the manner prescribed by the Law
Site User	personal data subject whose personal data is processed in connection with visiting the website https://polyus-arena.ru/
Providing personal data	actions aimed at disclosing personal data to a certain person or a certain circle of persons
Dissemination of personal data	actions aimed at disclosing personal data to an indefinite number of persons
Website	Website https://polyus-arena.ru/
Special categories of personal data	data relating to race, nationality, political views, religious or philosophical beliefs, health status, intimate life
Subject of personal data	a natural person who is directly or indirectly identified or identifiable by means of personal data
Cross-border transfer of personal data	transfer of personal data to a foreign state, a government agency of a foreign state, an international and foreign organization, a foreign citizen, a stateless person or a person authorized by them, a legal entity registered in a foreign state, or another structure without forming a legal entity, regardless of their organizational and legal form, located on the territory of a foreign state
Destruction of personal data	actions as a result of which it becomes impossible to restore the content of personal data in the personal data information system and (or) as a result of which material media of personal data are destroyed

2.2 Abbreviations

Reduction	Decoding
Polyus Arena LLC	Limited Liability Company "Polyus Arena"
LNA	Local regulations
PDn	Personal Information
RF	Russian Federation
Federal Law	the federal law

3. General provisions

3.1 The Company, being an operator, processes personal data of the following entities for the specified purposes:

applicants for vacant positions (candidates) - in the composition and for the period necessary for the Company to make a decision on hiring (placing a resume in the personnel reserve) or refusing to hire, as well as assistance in employment with the consent of the subject of personal data;
employees of the Company - in the composition and for the period necessary to achieve the goals provided for by the legislation of the Russian Federation, the implementation and fulfillment of the functions, powers and responsibilities assigned by the legislation of the Russian Federation to the Company as an employer (including the implementation of personnel, accounting, pension, tax accounting, compulsory social insurance of employees ), for concluding, executing, amending and terminating an employment contract to which the PD subject is a party, as well as for providing employees with additional guarantees, compensation and benefits with the consent of the PD subject;
relatives of the Company's employees - in the composition and for the period necessary to achieve the goals provided for by the legislation of the Russian Federation, to implement and fulfill the functions, powers and responsibilities assigned by the legislation of the Russian Federation to the Company as an employer, as well as to provide additional guarantees to the Company's employees,compensation and benefits with the consent of the PD subject;
foreign citizens recruited to work in the Russian Federation - in the composition and period necessary for processing entry documents, processing documents necessary for the work of foreign citizens on the territory of the Russian Federation, legal support for activities related to relations complicated by a foreign element with the consent of the subjects of personal data;
representatives of potential and existing counterparties of the Company - in the composition and for the period necessary for concluding, executing, amending and terminating contracts, conducting commercial, financial, legal negotiations aimed at concluding, executing, amending or terminating any contracts not prohibited by current legislation, regardless of the results of such negotiations, including the preparation, direction, modification of commercial proposals, the manifestation of the due degree of care and prudence when choosing a counterparty, as well as to achieve the goals provided for by the legislation of the Russian Federation, the implementation and fulfillment of the functions, powers and responsibilities assigned by the legislation of the Russian Federation to the Company;
visitors of the Company - in the composition and for the period necessary to organize the passage of visitors to the territory of the Company and compliance with the intra-facility and access control regime at the Company’s security facilities with the consent of the subjects of personal data;
users of the Company's website - in the composition and for the period necessary to ensure the possibility of using the Site.

3.2 The processing time for PD is determined taking into account:

established purposes for processing personal data;
the terms specified in agreements with PD subjects and in the consents of PD subjects for the processing of their PD;
deadlines determined by the Order of the Federal Archive of December 20, 2019. No. 236 “On approval of the List of standard management archival documents generated in the process of activities of state bodies, local governments and organizations, indicating their storage periods”;
storage periods for documentation established by the Company’s internal regulations;
liquidation of the Company.

3.3 The processed personal data is subject to destruction or depersonalization upon achievement of the processing goals or in the event of loss of the need to achieve these goals, unless otherwise provided by federal law.

4. Principles and conditions for processing personal data in the Company

4.1 The Company processes personal data on a legal and fair basis.

4.2 Processing of personal data in the Company is limited to the achievement of specific, predetermined and legitimate purposes. Processing of personal data that is incompatible with the purposes of collecting personal data is not permitted.

4.3 It is not allowed to combine databases containing personal data, the processing of which is carried out for purposes that are incompatible with each other.

4.4 Only personal data that meets the purposes of their processing are subject to processing.

4.5 The content and volume of processed PD correspond to the stated purposes of processing. The personal data processed is not redundant in relation to the stated purposes of their processing.

4.6 When processing personal data, their accuracy, sufficiency, and, if necessary, relevance in relation to the purposes of processing personal data are ensured. The Company takes the necessary measures or ensures their adoption to remove or clarify incomplete or inaccurate data.

4.7 The Company does not disclose or distribute personal data to third parties without the consent of the PD subject (unless otherwise provided by the federal law of the Russian Federation).

4.8 In the Company, for the purpose of information support, publicly available sources of PD may be created with the written consent of the PD subject. Information about the subject of personal data is excluded from publicly available sources of personal data at the request of the subject of personal data or by decision of a court or other authorized government bodies.

4.9 The Company may process PD authorized by the PD subject for distribution, subject to the provisions of Art. 10.1 of the Law and with the consent of the PD subject, which is drawn up separately from other consents of the PD subject for the processing of his PD.

4.10 The Company does not process special categories of PD except for the cases provided for in Part 2 of Article 10 of the Law. At the same time, the Company fulfills all requirements for the processing of special categories of personal data provided for by the Law.

4.11 The Company does not process biometric PD.

4.12 When collecting personal data, including through the information and telecommunications network "Internet", the Company ensures recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (provision, access), blocking, deletion, destruction .

4.13 GeneralThe company does not carry out cross-border transfer of personal data. Before starting activities for the cross-border transfer of personal data, the company undertakes to notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out cross-border transfer of personal data in accordance with Article 12 of the Law.

4.14 The Company does not make decisions that give rise to legal consequences in relation to the subject of personal data or otherwise affect his rights and legitimate interests, based solely on automated processing of personal data, except in cases of written consent of the subject of personal data or in cases provided for by federal laws, also establishing measures to ensure compliance with the rights and legitimate interests of the PD subject.

4.15 The Company, with the consent of the PD subject, may entrust the processing of PD to persons processing PD. At the same time, the Company fulfills all the requirements for ordering the processing of personal data provided for by the Law. The Company is responsible to the subject of personal data for the actions of these persons.

4.16 The Company processes personal data using and without automation tools. At the same time, the Company fulfills all the requirements for automated and non-automated processing of personal data provided for by the Law and regulatory legal acts adopted in accordance with it.

5. Rights of PD subjects processed by the Company

5.1 The PD subject has the right to appeal against the actions or inaction of the Company to the authorized body for the protection of the rights of PD subjects or in court if he believes that the processing of his PD is carried out in violation of the requirements of the Law or otherwise violates his rights and freedoms.

5.2 The PD subject has the right to protect his rights and legitimate interests, including compensation for losses and (or) compensation for moral damage in court.

5.3 The PD subject has the right to receive information regarding the processing of his PD, except for the cases provided for in Part. 8 tbsp. 14 of the Law. To obtain the specified information, the PD subject may send a written request to the location of the Company in the manner established by Part. 3 – 5 Article 14 of the Law.

5.4 The subject of personal data, if personal data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated purpose of processing, has the right to demand that the Company stop processing personal data, clarify it, block or destroy it, as well as take measures provided for by law to protect your rights.

6. Fulfillment of operator duties by the Company

6.1 The Company notified the authorized body for the protection of the rights of PD subjects of its intention to process PD and was included in the register of PD operators.

6.2 The Company receives personal data from PD subjects. If the PD is not received from the subject of the PD, the Company undertakes to comply with the requirements provided for in Parts 3 and 4 of Art. 18 of the Law.

6.3 The Company stops processing PD in the following cases:

upon achievement of the purposes of their processing, or in case of loss of the need to achieve these purposes;
at the request of the PD subject, if the personal data processed in the Company is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated purpose of processing;
in the event of unlawful processing of PD, if it is impossible to ensure the legality of PD processing;
in the event that the PD subject withdraws consent to the processing of his PD (if personal data is processed by the Company on the basis of the consent of the PD subject);
eliminating the reasons due to which PD was processed, unless otherwise established by federal law;
in case of liquidation of the Company.

6.4 When processing personal data, the Company takes measures necessary and sufficient to ensure the fulfillment of the obligations provided for by the Law and the regulatory legal acts adopted in accordance with it.

7. Processing of PD when using the Company Website

7.1 The Company does not check the PD provided by the Site User and cannot judge their reliability, as well as whether the Site User has sufficient legal capacity to provide the relevant PD. The Company assumes that Site Users provide reliable and sufficient PD, and also update PD in a timely manner.

In order to provide services on the Company's Website, a specialized CRM system is used. When creating an account, the CRM system receives personal data of the Site User: name, phone number, email address and / or others provided by the system.

The procedure for processing personal data, entryincluded in the CRM system, as well as the implemented requirements for the protection of personal data in the system, are contained in the privacy policy of the corresponding system operator.

7.2 The Company processes information about the email address of the Site User to send notifications, requests and information regarding the Site services and services provided, to process requests and applications for newsletters about news, events and special offers, to send notifications about the latest services, subject to the prior consent of the Site User . The Company takes the necessary organizational and technical measures to protect personal data.

When creating an account, as well as when subscribing to the newsletter, the Site User becomes familiar with the Company's Policy regarding the processing of personal data. Continued use of the Company's Site means the Site User's expression of unconditional consent to the specified Company Policy. Personal data is stored until the purpose of processing is achieved, and can be deleted upon appropriate request from the Site User to the Company.

7.3 To collect statistical information related to the operation of the Company’s Website, determine the actions of Users on the Company’s Website in order to improve the operation of the site, adapt the pages of the site taking into account the history of visits to the Site by the user, conduct various studies in order to improve the products and services provided, the Company can also use electronic data, network identifiers of the Site user's device (HTTP - headers, IP - address, web beacons / pixel tags, browser identifier data, information about hardware and software, wi-fi network data, date and time of access to the Site, information about activity while using the Site, geolocation information), as well as cookies stored in the browser of the Site User’s device.

The following types of cookies are processed on the Site:

strictly necessary cookies / technical cookies necessary for the operation of the Company’s Website and the provision of services; among other things, they allow the Company to identify the hardware and software of the Site User, including the type;
statistical / analytical cookies that allow you to recognize users, count their number and collect information such as transactions performed on the Company’s Website, including information about web pages visited and content received;
technical cookies that collect information about how the Website User interacts with the Company Website and/or Services, which allows identifying errors and testing new features to improve the performance of the Websites and Services;
functional cookies: these cookies enable us to provide certain functions to make your use of the Sites easier, for example by storing your preferences (such as language and location);
(third-party) tracking / advertising cookies: collecting information about Site Users, traffic sources, pages visited and advertisements displayed to you, as well as the one that leads the Site User to the advertised page.

To process information about the user of the Site, the following Internet services can be used: Google Analytics and Yandex. Metrics. The Company uses the information contained in cookies only for the purposes indicated above. Cookies are stored on the Site User's device for a period that may depend on the relevant type of cookies, but does not exceed the period necessary to achieve the purpose of processing, after which some cookies will be automatically deleted in accordance with their validity periods established by Internet services. Other types of cookies can be deleted from the device by the user independently.

Current list of cookies, the order of their processing and expiration dates governed by the privacy policies of the services Yandex , Google

The use of cookies stored on the user’s device for other purposes, including advertising, outside the Company’s website, may be subject to separate user agreements concluded by the user when visiting third-party websites.

When visiting the Company's Website for the first time, the Website User is notified of the site's use of cookies. The site user can at any time refuse the use of cookies and delete them from his device in accordance with the instructions of the device browser developerstva . If you refuse to use cookies, some functions of the Company's Website may not be available.

8. Regulatory references

This Policy has been developed in accordance with:

Council of Europe Convention No. 108 on the protection of individuals in connection with automatic processing of personal data;
Federal Law of July 27, 2006 No. 152 - Federal Law “On Personal Data”.

9. Procedure for making changes

The policy is subject to updating in the following cases:

changes in the legislation of the Russian Federation on personal data;
identifying inconsistencies affecting the processing and (or) protection of personal data based on the results of monitoring compliance with the requirements for processing and (or) protection of personal data;
by decision of the Company's management.

10. Control and responsibility for the implementation of the Policy

10.1.1 Monitoring compliance with the requirements of the Policy .
Control over compliance with the requirements of the Policy is carried out by the person responsible for organizing the processing of personal data in the Company.

10.1.2 Responsibility of employees. All employees of the Company bear disciplinary liability for failure to comply with the requirements of the Policy. The imposition of disciplinary sanctions for non-fulfillment or improper fulfillment of the requirements of this Policy is carried out in accordance with the norms of the labor legislation of the Russian Federation and in accordance with the current LNA of the Company.

11. Registering changes

Version	Type and name of NMD	Approval date	LNA details
1	Policy for processing and ensuring the security of personal data at Polyus Arena LLC

12. List of applications

Application number	Application name	Note
1	Reference list	Included in the Policy