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Personal Data Processing Policy

Personal Data Processing Policy

1. General provisions
2. Definitions
3. The Processor has the right to process the following personal data
4. Purposes of personal data processing
5. Legal basis for personal data processing
6. Collection, storage, transfer and other types of personal data processing
7. Cross-border transfer of personal data
8. Final provisions

1. General provisions

This Personal Data Processing Policy has been drafted in accordance with the Federal Law on Personal Data (No. 152-FZ dated 27 July 2006) and stipulates how FBK Grant Thornton (the “Processor”) should process and protect personal data.

The term “FBK Grant Thornton” herein includes the following legal entities: Financial and Accounting Consultants Limited Liability Company (FBK, LLC) (registered at 44/1 Myasnitskaya Street, Bldg 2AB, Moscow, 101990, Russia), FBK Limited Liability Company (FBK LLC) (registered at 44/1 Myasnitskaya Street, Bldg 2AB, Moscow, 101990, Russia), FBK Legal Limited Liability Company (FBK Legal LLC) (registered at 48 Myasnitskaya Street, Floor 2, Room I, Office 2, Moscow, 101990, Russia), FBK Cybersecurity Limited Liability Company (FBK CS LLC) (registered at 44 Myasnitskaya Street, Bldg 4, Moscow, 101990, Russia) and FBK Economic and Law School Nonprofit Organisation (NP FBK ELS) (registered at 2/21 Makarenko Street, Bldg 1, Office 29, Moscow, 103062, Russia).

1.1. The Processor is committed to the protection of fundamental rights and freedoms of data subjects in respect of data processing activities, including the protection of privacy, and the respect for private and family life.
1.2. This policy used by the Processor to process personal data (the “Policy”) applies to all data obtained by the Processor about visitors of the following websites: https://grantthornton.ru/, https://fbk-legal.com/, https://fbkcs.ru/en/index.html, http://elsfbk.ru/.

2. Definitions
2.1. ‘Automated personal data processing’ means processing of personal data by automated means.
2.2. ‘Blocking of personal data’ means temporary suspension of personal data processing (except when processing is required to update personal data).
2.3. ‘Website’ or ‘websites’ mean a set graphic and information content, as well as computer programmes and databases, available at https://grantthornton.ru/, https://fbk-legal.com/, https://fbkcs.ru/en/index.html, http://elsfbk.ru/.
2.4. ‘Personal data information system’ means a set of personal data in databases and information technologies used to process them.
2.5. ‘Anonymisation of personal data’ means actions taken to render it impossible to attribute personal data to a specific user or another data subject without the use of additional information.
2.6. ‘Personal data processing’ means any operation or set of operations which is performed on personal data, whether or not by automated means, such as collection, recording, structuring, storage, adaptation (updating or alteration), retrieval, use, disclosure (transmission, dissemination or otherwise making available), anonymisation, blocking, erasure or destruction of personal data.
2.7. ‘Processor’ means a public authority, municipal agency, natural or legal person which, independently or jointly with other persons, arranges processing of and/or processes personal data, as well as determines the purpose of personal data processing, the composition of personal data to be processed and operations performed with personal data.
2.8. ‘Personal data’ means any information relating, directly or indirectly, to an identified or identifiable user of the following websites: https://grantthornton.ru/, https://fbk-legal.com/, https://fbkcs.ru/en/index.html, http://elsfbk.ru/.
2.9. ‘User’ means any visitor of the following websites: https://grantthornton.ru/, https://fbk-legal.com/, https://fbkcs.ru/en/index.html, http://elsfbk.ru/.
2.10. ‘Provision of personal data’ means actions aimed at disclosure of personal data to a specific person or persons.
2.11. ‘Dissemination of personal data’ means any actions aimed at disclosure of personal data to non-specific persons (transfer of personal data) or making personal data available to unlimited audience, including disclosure in mass media, online publishing or provision of access by other means.
2.12. ‘Cross-border transfer of personal data’ means transfer of personal data to a foreign country, a public authority of a foreign country, a foreign natural or legal person.
2.13. ‘Destruction of personal data’ means any actions which render personal data irretrievable without any possibility to restore the content of personal data in the personal data information system and/or which destroy tangible media bearing personal data.

3. The Processor has the right to process the following personal data:
3.1. Full name.
3.2. Email address and phone number.
3.3. Employing company and title.
3.4. The website also collects and processes anonymised data about visitors (including cookies) using web analytics services (Yandex Metrica, Google Analytics etc.).
3.5. The above-listed data is referred to in this Policy as personal data.

4. Purposes of personal data processing
4.1. The purpose of a user’s personal data processing is to share information via emails and to provide access to services, information and/or materials published on the website.
4.2. The Processor has the right to send notifications about new products and services, special offers and various events. A user has the right to unsubscribe from email newsletters by sending an email to the Processor to fbk@fbk.ru with the following subject line: unsubscription from newsletters about new products, services and special offers.
4.3. Anonymised data collected using web analytics services is used to collect information about user activities on the website, as well as to improve the website quality and content.

5. Legal basis for personal data processing
5.1. The Processor processes a user’s personal data only when the user completes special forms and/or decides to send his or her personal data through special forms available on the following websites: https://grantthornton.ru/, https://fbk-legal.com/, https://fbkcs.ru/en/index.html, http://elsfbk.ru/. When a user completes those forms and/or send his or her personal data to the Processor, the user agrees with this Policy.
5.2. The Processor processes anonymised data about a user if it is allowed by the user’s browser settings (it is allowed to save cookie data and use JavaScript).

6. Collection, storage, transfer and other types of personal data processing
Personal data processed by the Processor is protected by legal, safety management and technical measures required to be in full compliance with the existing personal data protection laws.
6.1. The Processor protects personal data and takes all possible measures to prevent unauthorised access to personal data.
6.2. The Processor will not transfer a user’s personal data to third parties except when it is required by existing laws.
6.3. If a user finds inaccuracies in his or her personal data, the user can update them by sending an email to the Processor to fbk@fbk.ru with the following subject line: personal data update.
6.4. The personal data processing period is not limited. A user has the right to withdraw his or her consent to personal data processing by sending an email to the Processor to fbk@fbk.ru with the following subject line: withdrawal of personal data processing consent.

7. Cross-border transfer of personal data
7.1. Before a cross-border transfer of personal data, the Processor is obliged to make sure that a foreign country to which personal data is to be transferred applies reliable personal data protection policies.
7.2. Cross-border transfers of personal data to foreign countries that do not meet the above requirements are allowed only in case of a written consent of the data subject to cross-border transfers of his or her personal data and/or an agreement by and between the Processor and the data subject.

8. Final provisions
8.1. A user can ask any questions regarding personal data processing by sending an email to the Processor to fbk@fbk.ru.
8.2. This document will reflect any amendments to the Processor's personal data processing policy. The policy will remain in effect indefinitely until replaced by a new version.
8.3. The most recent version of the Policy is available online at https://grantthornton.ru/subscribe/