COMPANY'S POLICY FOR PROCESSING OF PERSONAL DATA

• 1. GENERAL PROVISIONS

  This Policy determines the procedure for processing of personal data and measures to ensure the security of personal data in LITRES OPERATIONS LIMITED (hereinafter referred to as the Operator) in order to protect the rights and freedoms of a person and a citizen in the processing of their personal data, including the protection of rights to privacy, personal and family secret.

  The Policy uses the following basic concepts:

  automated processing of personal data – processing of personal data by means of computer facilities;

  blocking of personal data – temporary termination of processing of personal data (except for cases when processing is necessary for specification of personal data);

  information system of personal data – a set of personal data contained in databases and information technology and technical means ensuring their processing;

  depersonalization of personal data – actions, as a result of which it is impossible to determine without the use of additional information the belonging of personal data to a specific subject of personal data;

  personal data processing – any action (operation) or a set of actions (operations) performed using automation tools or without using such tools with personal data, including collection, recording, systematization, accumulation, storage, specification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data;

  operator – a state body, a municipal body, a legal entity or an individual, independently or jointly with other persons organizing and (or) carrying out the processing of personal data, as well as defining the purposes of personal data processing, the composition of personal data subject to processing, actions (operations) performed with personal data;

  personal data – any information relating to directly or indirectly determined or determinable individual (personal data subject);

  provision of personal data – actions aimed at disclosing personal data to a specific person or a certain circle of persons;

  distribution of personal data – actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or for acquaintance with personal data of an unlimited number of persons, including promulgation of personal data in the mass media, placement in information and telecommunication networks or provision of access to personal data in any other way;

  cross-border transfer of personal data – the transfer of personal data to the territory of a foreign state to the authority of a foreign state, to a foreign physical or foreign legal entity;

  destruction of personal data – actions, as a result of which it is impossible to restore the contents of personal data in the personal data information system and (or) as a result of which material data carriers of personal data are destroyed.

  The Company is obliged to publish or otherwise provide unlimited access to this Policy for processing of personal data.

  LITRES OPERATIONS LIMITED undertakes to comply with the legal requirements set out in Regulation (EU) 2016/679 of the European Parliament and of the Council of the European Union of 27 April 2016 in relation to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation, GDPR).

• 2. PRINCIPLES AND CONDITIONS OF PERSONAL DATA PROCESSING

  • 2.1 Principles of personal data processing

    The processing of personal data by the Operator is carried out on the basis of the following principles:

    • legality and fair basis;
    • limitation of personal data processing to the achievement of specific, pre-determined and legitimate purposes;
    • preventing the processing of personal data incompatible with the purposes of personal data collecting;
    • prevention of the unification of databases containing personal data, processing of which is carried out for purposes incompatible with each other;
    • processing only that personal data that meets the purposes of its processing;
    • conformity of the content and volume of processed personal data to the stated processing purposes;
    • the prevention of the processing of personal data that is redundant in relation to the stated purposes of their processing;
    • ensuring the accuracy, adequacy and relevance of personal data in relation to the purposes of personal data processing;
    • destruction or depersonalization of personal data upon the achievement of the purposes of its processing or in the event of a loss of the need to achieve these purposes, if the Operator cannot eliminate the admitted violations of personal data, unless otherwise provided by the applicable law.

  • 2.2 Conditions of personal data processing

    The Operator performs the processing of personal data in the presence of at least one of the following conditions:

    • processing of personal data is carried out with the consent of the subject of personal data for the processing of their personal data;
    • the processing of personal data is necessary for the administration of justice, the enforcement of a court order, an order of another body or official subject to enforcement in accordance with the applicable legislation on enforcement proceedings;
    • the processing of personal data is necessary for the performance of an agreement, to which the subject of personal data or a beneficiary or guarantor is a party, as well as for the execution of an agreement on the initiative of a personal data subject or an agreement whereby the personal data subject will be a beneficiary or guarantor;
    • processing of personal data is necessary for the exercise of the rights and legitimate interests of the operator or third parties or for the achievement of socially significant purposes, provided that the rights and freedoms of the subject of personal data are not thereby violated;
    • processing of personal data, access to which of an unlimited circle of persons is provided by the subject of personal data or at their request (hereinafter referred to as publicly available personal data);
    • processing of personal data subject to publication or mandatory disclosure in accordance with federal law.

  • 2.3 Confidentiality of personal data

    The operator and other persons who have access to personal data shall not disclose personal data to third parties or disseminate it without the consent of the personal data subject, unless otherwise provided by applicable law.

  • 2.4 Public sources of personal data

    For the purposes of information support, the Operator can create publicly accessible sources of personal data of personal data subjects, including directories and address books. The public sources of personal data with the written consent of the personal data subject may contain their surname, name, patronymic, date and place of birth, position, contact phone numbers, e-mail address and other personal data reported by the subject of personal data.

    Information on the subject of personal data shall be deleted at any time from publicly available personal data sources at the request of the personal data subject, authorized body for protection of the rights of subjects of personal data or by court order.

  • 2.5 Special categories of personal data

    The processing by the Operator of special categories of personal data relating to race, nationality, political views, religious or philosophical beliefs, health status, intimate life is allowed in cases where:

    • the subject of personal data has given their consent in writing to the processing of their personal data;
    • personal data is made publicly available by the subject of personal data;
    • the processing of personal data is carried out in accordance with the applicable legislation;
    • processing of personal data is necessary to protect the life, health or other vital interests of the subject of personal data or the life, health or other vital interests of others, and obtaining the consent of the personal data subject is impossible;
    • the processing of personal data is carried out for medical and preventive purposes, in order to establish a medical diagnosis, provide medical and medico-social services, upon condition that the processing of personal data is carried out by a person professionally engaged in medical activities and required to maintain medical secrecy in accordance with the applicable legislation;
    • the processing of personal data is necessary to establish or implement the rights of the subject of personal data or third parties, as well as in connection with the implementation of justice;
    • processing of personal data is carried out in accordance with the legislation on compulsory types of insurance, with insurance legislation.
    • The processing of personal data on the criminal record can be carried out by the Operator only in cases and in the manner determined in accordance with applicable laws.

  • 2.6 Biometric personal data

    Information that characterizes the physiological and biological characteristics of a person on the basis of which it is possible to establish their identity, i.e. biometric personal data, can be processed by the Operator only if the subject of the personal data has given the consent in writing.

  • 2.7 Instruction of processing of personal data to a third party

    The Operator has the right to entrust the processing of personal data to a third party with the consent of the personal data subject, unless otherwise provided by applicable law, on the basis of an agreement made with that party. A party carrying out the processing of personal data on behalf of the Operator is obliged to comply with the principles and rules for the processing of personal data provided by this Policy.

  • 2.8. Cross-border transfer of personal data

    Before the commencement of such transfer, the Operator is obliged to make sure that the foreign state, into whose territory it is intended to transfer personal data, provides adequate protection of the rights of subjects of personal data.

    Cross-border transfer of personal data into the territories of foreign states that do not provide adequate protection of the rights of subjects of personal data may be carried out in the following cases:

    • the consent in writing of the subject of personal data to the cross-border transfer of their personal data;
    • the performance of an agreement to which the subject of personal data is a party.

• 3. RIGHTS OF THE PERSONAL DATA SUBJECT

  • 3.1. Consent of the subject of personal data to the processing of their personal data

    The subject of personal data decides to provide their personal data and agrees to their processing freely, with their will and in their interest. Consent to the processing of personal data may be given by the subject of personal data or their representative in any form that allows confirming the fact of its receipt, unless otherwise provided by federal law.

  • 3.2. Rights of the personal data subject

    The subject of personal data has the right to receive information from the Operator concerning the processing of their personal data, if such right is not restricted in accordance with federal laws. The data subject has the right to require the Operator to verify his personal data, blocking or destroying it in case personal data are incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing, and also take measures provided by law to protect their rights.

    Processing of personal data in order to promote goods, work, services on the market by making direct contact with the personal data subject (potential consumer) by means of communication means, as well as for political agitation is allowed only with the prior consent of the subject of personal data.

    The operator shall immediately stop, at the request of the personal data subject, the processing of their personal data for the above purposes.

    It is prohibited to make decisions based solely on the automated processing of personal data resulting in legal consequences with respect to the subject of personal data or otherwise affecting their rights and legitimate interests, with the exception of cases provided for by applicable law or with the written consent of the subject of personal data.

    If the personal data subject considers that the Operator carries out the processing of their personal data violating his rights and freedoms, the subject of personal data has the right to appeal against the actions or omissions of the Operator to the Authorized body for the protection of the rights of subjects of personal data or in court.

    The subject of personal data has the right to protect their rights and legitimate interests, including compensation for losses and (or) compensation for moral damage.

    The data subject shall have the right to obtain from the controller the erasure of personal data concerning him or her without undue delay and the controller shall have the obligation to erase personal data without undue delay. To exercise this rights Buyer need to contact Seller by e-mail at gdpr@litres.com.

• 4. ENSURING THE SECURITY OF PERSONAL DATA

  The security of personal data processed by the Operator is provided by the implementation of legal, organizational and technical measures necessary to ensure the requirements of applicable legislation in the field of personal data protection.

  To prevent unauthorized access to personal data, the Operator applies the following organizational and technical measures:

  • appointment of officials responsible for organizing the processing and protection of personal data;
  • restriction of the number of persons admitted to the processing of personal data;
  • familiarization of subjects with the requirements of the applicable legislation and regulatory documents of the Operator for the processing and protection of personal data;
  • organization of records, storage and circulation of carriers containing information with personal data;
  • the identification of threats to the security of personal data during processing, the generation of threat models on their basis;
  • the development on the basis of the threat model of the personal data protection system;
  • checking the readiness and effectiveness of using information protection tools;
  • differentiation of users' access to information resources, software and hardware of information processing;
  • registration and recording of actions of users of information systems of personal data;
  • the use of anti-virus tools and means of restoring the protection of personal data;
  • application of firewalling, intrusion detection, security analysis and means of cryptographic protection of information in necessary cases;
  • the organization of an access control within the territory of the Operator, the protection of premises with technical means for personal data processing.

• 5. FINAL PROVISIONS

  Other rights and obligations of the Operator in connection with the processing of personal data are determined by the applicable legislation in the field of personal data.