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PERSONAL DATA PROCESSING POLICY
of the Sape Space Agency
Contents
1. General Provisions
2. Basic Definitions
3. Principles and Rules for the Processing of Personal Data
4. Legal Grounds for the Processing of Personal Data
5. Organisation of Personal Data Processing
6. Rights of the Data Subject
7. Final Provisions
1. General Provisions
This Policy, developed in accordance with the Federal Law “On Personal Data,” sets out the purposes, key principles, rules and legal grounds for the processing of personal data, and defines the main measures taken to ensure their security.
This Policy has been developed so that the “Sape Space” Agency can implement the requirements of Russian Federation legislation on personal data, and to ensure the protection of individuals' rights when their personal data is processed.
The provisions of this Policy form the basis for developing and updating the administrative and organisational-legal documents at the “Sape Space” Agency that govern the processing of personal data belonging to various categories of data subjects, as well as the procedures for implementing measures to protect the personal data being processed.
The provisions of this Policy are binding on all employees of the “Sape Space” Agency who have access to personal data.
The list of purposes for processing personal data at the “Sape Space” Agency, the composition of personal data and their categories, and the categories of data subjects, are set out in the Appendix.
2. Basic Definitions
The following definitions are used in this Policy:
1) automated processing of personal data – the processing of personal data by means of computing equipment;
2) security of personal data – a state of protection of personal data, characterised by the ability of users, technical resources and information technologies to ensure the confidentiality, integrity and availability of personal data when processed in information systems;
3) biometric personal data – information characterising the physiological and biological features of a data subject, on the basis of which their identity can be established, and which is used by the operator to establish the identity of the data subject;
4) information system – a combination of the information contained in databases and the information technologies and technical resources that enable its processing;
5) counterparty / client – a Russian or foreign legal entity or individual with whom the “Sape Space” Agency has, or plans to enter into, a contractual relationship, excluding employment relationships;
6) confidentiality of personal data – the mandatory requirement not to disclose personal data to third parties and not to distribute it without the consent of the data subject, unless otherwise provided for by the legislation of the Russian Federation;
7) physical medium – a paper or machine-readable medium intended for recording, transmitting and storing personal data;
8) non-automated processing of personal data – the processing of personal data carried out with the direct involvement of an employee, without the use of computing equipment;
9) processing of personal data – any action (operation) or set of actions (operations) performed on personal data, whether or not using automation tools, including collection, recording, systematisation, accumulation, storage, clarification (updating, amendment), retrieval, use, transfer (distribution, provision, access), depersonalisation, blocking, erasure (including redaction), and destruction of personal data;
10) operator – a state authority, municipal authority, legal entity or individual that organises and/or carries out the processing of personal data, whether alone or jointly with others, and that determines the purposes of processing, the personal data to be processed, and the actions (operations) performed on that data;
11) personal data – any information relating directly or indirectly to an identified or identifiable individual (data subject);
12) personal data permitted by the data subject for distribution – personal data to which an unrestricted circle of persons has been granted access by the data subject, by way of consent to the processing of personal data permitted by the data subject for distribution, in the manner provided for by the Federal Law “On Personal Data”;
13) user of Sape Space Agency services – a consumer, buyer/their representative, or any other individual or legal entity making use of the services provided by the “Sape Space” Agency;
14) provision of personal data – actions aimed at disclosing personal data to a specific person or specific group of persons;
15) distribution of personal data – actions aimed at disclosing personal data to an indefinite group of persons;
16) special categories of personal data – categories of personal data relating to racial or ethnic origin, political views, religious or philosophical beliefs, state of health, intimate life, and criminal record;
17) data subjects – service users, counterparties, their close relatives, job candidates (applicants), citizens, legal entities and/or their official representatives, as well as other persons whose personal data has become known to the “Sape Space” Agency in the course of its activities;
18) cross-border transfer of personal data – the transfer of personal data to the territory of a foreign state, to an authority of a foreign state, or to a foreign individual or legal entity;
19) destruction of personal data – actions as a result of which it becomes impossible to restore the content of personal data in an information system and/or on a physical medium, and/or as a result of which the physical media containing personal data are destroyed.
3. Principles and Rules for the Processing of Personal Data
The processing of personal data at the “Sape Space” Agency is carried out in compliance with the following principles and rules:
1) processing is carried out on a lawful and fair basis;
2) processing is limited to the achievement of specific, predetermined and lawful purposes;
3) only personal data that corresponds to the purposes of processing is subject to processing, with the volume and content of the data mandatorily matching the stated purposes of processing;
4) the combination of databases containing personal data processed for mutually incompatible purposes is not permitted;
5) the accuracy and sufficiency of personal data is ensured during processing, and, where necessary, its relevance to the purposes of processing, with measures taken (or arranged to be taken) to erase or clarify incomplete or inaccurate data;
6) personal data is stored in a form that allows the data subject to be identified for no longer than is required by the purposes of processing, unless a longer retention period is established by federal law, or by a contract to which the data subject is a party, beneficiary, or guarantor;
7) personal data that has been processed is destroyed or depersonalised once the purposes of processing have been achieved, or if the need to achieve those purposes no longer exists, unless otherwise provided for by the legislation of the Russian Federation.
8. When processing personal data, the “Sape Space” Agency ensures its confidentiality and security.
4. Legal Grounds for the Processing of Personal Data
The legal grounds on which the processing of personal data is permitted at the “Sape Space” Agency are as follows:
1) the consent of the data subject to the processing of their personal data, in compliance with the requirements established by the legislation of the Russian Federation for the relevant category of personal data;
2) the achievement of purposes provided for by an international treaty of the Russian Federation or by law, and the exercise and performance of the functions, powers and duties assigned to the “Sape Space” Agency by the legislation of the Russian Federation;
3) judicial acts, or acts of another authority or official, subject to enforcement at the “Sape Space” Agency in accordance with the legislation of the Russian Federation on enforcement proceedings;
4) a contract to which the data subject is a party, beneficiary, or guarantor, as well as a contract concluded at the initiative of the data subject, or a contract under which the data subject will be a beneficiary or guarantor;
5) the protection of the life, health, or other vital interests of the data subject, where obtaining the data subject's consent is not possible;
6) the exercise of the rights and legitimate interests of the “Sape Space” Agency or of third parties, or the achievement of socially significant purposes, provided that the rights and freedoms of the data subject are not thereby infringed;
7) the exercise of professional journalistic activity and/or the lawful activity of a mass media outlet, or scientific, literary or other creative activity, provided that the rights and legitimate interests of the data subject are not thereby infringed;
8) the processing of personal data for statistical or other research purposes, provided the data is mandatorily depersonalised;
9) the processing of personal data for the purpose of publication or mandatory disclosure of information in accordance with the legislation of the Russian Federation.
5. Organisation of Personal Data Processing
In order to organise personal data processing effectively and to ensure the security of personal data, the “Sape Space” Agency appoints a person responsible for organising the processing of personal data, who, within their established authority, ensures:
1) internal oversight of compliance with the requirements of Russian Federation legislation on personal data at the “Sape Space” Agency, including requirements for the protection of personal data at the Agency;
2) that employees of the “Sape Space” Agency are made aware of the provisions of Russian Federation legislation on the processing of personal data, as well as the requirements for the protection of personal data;
3) oversight of the handling of enquiries and requests from data subjects or their representatives concerning breaches of personal data legislation committed by employees of the “Sape Space” Agency.
Personal data is processed by employees of “Sape Space” who have been granted this right by management, as well as by persons duly authorised to process personal data.
These persons are entitled to process only the personal data that is necessary for the performance of their duties.
The processing of personal data at the “Sape Space” Agency is carried out using automation tools and/or without the use of such tools.
The processing of special categories of personal data, as well as biometric personal data, at the “Sape Space” Agency is carried out in accordance with the requirements of Russian Federation legislation.
In order to implement the rights of data subjects when processing their personal data, the “Sape Space” Agency:
1) applies legal, organisational and technical measures to protect the personal data of data subjects against unlawful or accidental access, destruction, alteration, blocking, copying, provision, distribution, and other unlawful actions;
2) explains to data subjects the legal consequences of refusing to provide their personal data and/or to give consent to its processing, where the provision of personal data is mandatory under Russian Federation legislation;
3) blocks, clarifies and destroys unlawfully processed personal data, and terminates its unlawful processing;
4) notifies the data subject of the remedy of any breaches identified, or of the destruction of their personal data;
5) provides, at the request of the data subject or their representative, information concerning the processing of their personal data, in the manner established by Russian Federation legislation;
6) carries out internal monitoring and/or auditing of compliance with Russian Federation legislation in the processing of personal data;
7) assesses the harm that may be caused to data subjects in the event of a breach of Russian Federation legislation on personal data, weighed against the measures taken by the “Sape Space” Agency to ensure compliance with the obligations set out in Russian Federation legislation on personal data.
The processing of personal data that the data subject has permitted for distribution is carried out in compliance with the prohibitions and conditions set out in Article 10.1 of the Federal Law “On Personal Data.”
Consent to the processing of personal data permitted by the data subject for distribution is drawn up separately from any other consents given by the data subject.
Personal data is transferred to third parties only with the written consent of the data subjects, except where this is necessary to prevent a threat to the life or health of data subjects, or in other cases established by Russian Federation legislation.
Personal data may be transferred to state authorities without the data subject's consent, in the manner and in the cases provided for by Russian Federation legislation.
Cross-border transfer of personal data is carried out with due regard to the restrictions and prohibitions provided for by Russian Federation legislation on personal data.
Before beginning a cross-border transfer of personal data, “Sape Space”:
● assesses the measures taken by the authorities of the foreign state, or by the foreign individuals and legal entities to whom the cross-border transfer of personal data is planned, to ensure the confidentiality and security of personal data;
● notifies the authorised body for the protection of the rights of data subjects of its intention to carry out a cross-border transfer of personal data.
The “Sape Space” Agency is entitled to entrust the processing of personal data to another party with the consent of the data subject, unless otherwise provided for by Russian Federation legislation, on the basis of a contract concluded with that party.
When collecting personal data, including via the Internet, the “Sape Space” Agency ensures that the recording, systematisation, accumulation, storage, clarification (updating, amendment) and retrieval of the personal data of Russian Federation citizens is carried out using databases located on the territory of the Russian Federation, except in cases provided for by Russian Federation legislation.
The security of personal data, including when processed in information systems, is ensured in accordance with Russian Federation legislation and the requirements of the authorised body for the protection of the rights of data subjects, the federal executive authority responsible for security, and the federal executive authority responsible for counteracting technical intelligence activities and technical information protection.
The periods for processing and storing personal data for each processing purpose set out in Appendix No. 1 to this Policy are determined with due regard to Russian Federation legislation and/or the terms of any contract to which the data subject is a party, beneficiary or guarantor, and/or the data subject's consent to the processing of their personal data.
The procedure and methods for destroying personal data at the “Sape Space” Agency are determined in accordance with Russian Federation legislation.
Personal data is subject to destruction in the following cases:
1) once the purposes of processing have been achieved, or the need to achieve the purposes of processing personal data no longer exists;
2) if the data subject withdraws their consent to the processing of their personal data, except in cases provided for by Russian Federation legislation;
3) where the data subject or their representative provides information confirming that the personal data: (a) is incomplete, outdated, or inaccurate (provided that it cannot be clarified); (b) was obtained unlawfully; (c) is not necessary for the stated purpose of processing;
4) where unlawful processing of personal data is identified (where it is not possible to ensure the lawfulness of the processing);
5) where a data subject requests that the processing of their personal data be terminated, except in cases provided for by Russian Federation legislation.
6. Rights of the Data Subject
Data subjects have the right to:
1) receive, upon request, full information about their personal data being processed at the “Sape Space” Agency;
2) review their personal data by contacting the “Sape Space” Agency;
3) have their personal data clarified, blocked, or destroyed if it is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing;
4) request that the processing of their personal data be terminated;
5) provide their personal data and their consent to its processing freely, of their own will and in their own interest;
6) withdraw their consent to the processing of their personal data;
7) appeal, in accordance with Russian Federation legislation, any actions (or inaction) of the “Sape Space” Agency in the processing of personal data;
8) exercise other rights provided for by Russian Federation legislation.
7. Final Provisions
Liability for breaches of the requirements of Russian Federation legislation and of the “Sape Space” Agency's own regulatory documents in the field of personal data is determined in accordance with Russian Federation legislation.
This Policy is a publicly available document and is to be published on the official website of the “Sape Space” Agency at: https://sapespace.com/policy
of the Sape Space Agency
Contents
1. General Provisions
2. Basic Definitions
3. Principles and Rules for the Processing of Personal Data
4. Legal Grounds for the Processing of Personal Data
5. Organisation of Personal Data Processing
6. Rights of the Data Subject
7. Final Provisions
1. General Provisions
This Policy, developed in accordance with the Federal Law “On Personal Data,” sets out the purposes, key principles, rules and legal grounds for the processing of personal data, and defines the main measures taken to ensure their security.
This Policy has been developed so that the “Sape Space” Agency can implement the requirements of Russian Federation legislation on personal data, and to ensure the protection of individuals' rights when their personal data is processed.
The provisions of this Policy form the basis for developing and updating the administrative and organisational-legal documents at the “Sape Space” Agency that govern the processing of personal data belonging to various categories of data subjects, as well as the procedures for implementing measures to protect the personal data being processed.
The provisions of this Policy are binding on all employees of the “Sape Space” Agency who have access to personal data.
The list of purposes for processing personal data at the “Sape Space” Agency, the composition of personal data and their categories, and the categories of data subjects, are set out in the Appendix.
2. Basic Definitions
The following definitions are used in this Policy:
1) automated processing of personal data – the processing of personal data by means of computing equipment;
2) security of personal data – a state of protection of personal data, characterised by the ability of users, technical resources and information technologies to ensure the confidentiality, integrity and availability of personal data when processed in information systems;
3) biometric personal data – information characterising the physiological and biological features of a data subject, on the basis of which their identity can be established, and which is used by the operator to establish the identity of the data subject;
4) information system – a combination of the information contained in databases and the information technologies and technical resources that enable its processing;
5) counterparty / client – a Russian or foreign legal entity or individual with whom the “Sape Space” Agency has, or plans to enter into, a contractual relationship, excluding employment relationships;
6) confidentiality of personal data – the mandatory requirement not to disclose personal data to third parties and not to distribute it without the consent of the data subject, unless otherwise provided for by the legislation of the Russian Federation;
7) physical medium – a paper or machine-readable medium intended for recording, transmitting and storing personal data;
8) non-automated processing of personal data – the processing of personal data carried out with the direct involvement of an employee, without the use of computing equipment;
9) processing of personal data – any action (operation) or set of actions (operations) performed on personal data, whether or not using automation tools, including collection, recording, systematisation, accumulation, storage, clarification (updating, amendment), retrieval, use, transfer (distribution, provision, access), depersonalisation, blocking, erasure (including redaction), and destruction of personal data;
10) operator – a state authority, municipal authority, legal entity or individual that organises and/or carries out the processing of personal data, whether alone or jointly with others, and that determines the purposes of processing, the personal data to be processed, and the actions (operations) performed on that data;
11) personal data – any information relating directly or indirectly to an identified or identifiable individual (data subject);
12) personal data permitted by the data subject for distribution – personal data to which an unrestricted circle of persons has been granted access by the data subject, by way of consent to the processing of personal data permitted by the data subject for distribution, in the manner provided for by the Federal Law “On Personal Data”;
13) user of Sape Space Agency services – a consumer, buyer/their representative, or any other individual or legal entity making use of the services provided by the “Sape Space” Agency;
14) provision of personal data – actions aimed at disclosing personal data to a specific person or specific group of persons;
15) distribution of personal data – actions aimed at disclosing personal data to an indefinite group of persons;
16) special categories of personal data – categories of personal data relating to racial or ethnic origin, political views, religious or philosophical beliefs, state of health, intimate life, and criminal record;
17) data subjects – service users, counterparties, their close relatives, job candidates (applicants), citizens, legal entities and/or their official representatives, as well as other persons whose personal data has become known to the “Sape Space” Agency in the course of its activities;
18) cross-border transfer of personal data – the transfer of personal data to the territory of a foreign state, to an authority of a foreign state, or to a foreign individual or legal entity;
19) destruction of personal data – actions as a result of which it becomes impossible to restore the content of personal data in an information system and/or on a physical medium, and/or as a result of which the physical media containing personal data are destroyed.
3. Principles and Rules for the Processing of Personal Data
The processing of personal data at the “Sape Space” Agency is carried out in compliance with the following principles and rules:
1) processing is carried out on a lawful and fair basis;
2) processing is limited to the achievement of specific, predetermined and lawful purposes;
3) only personal data that corresponds to the purposes of processing is subject to processing, with the volume and content of the data mandatorily matching the stated purposes of processing;
4) the combination of databases containing personal data processed for mutually incompatible purposes is not permitted;
5) the accuracy and sufficiency of personal data is ensured during processing, and, where necessary, its relevance to the purposes of processing, with measures taken (or arranged to be taken) to erase or clarify incomplete or inaccurate data;
6) personal data is stored in a form that allows the data subject to be identified for no longer than is required by the purposes of processing, unless a longer retention period is established by federal law, or by a contract to which the data subject is a party, beneficiary, or guarantor;
7) personal data that has been processed is destroyed or depersonalised once the purposes of processing have been achieved, or if the need to achieve those purposes no longer exists, unless otherwise provided for by the legislation of the Russian Federation.
8. When processing personal data, the “Sape Space” Agency ensures its confidentiality and security.
4. Legal Grounds for the Processing of Personal Data
The legal grounds on which the processing of personal data is permitted at the “Sape Space” Agency are as follows:
1) the consent of the data subject to the processing of their personal data, in compliance with the requirements established by the legislation of the Russian Federation for the relevant category of personal data;
2) the achievement of purposes provided for by an international treaty of the Russian Federation or by law, and the exercise and performance of the functions, powers and duties assigned to the “Sape Space” Agency by the legislation of the Russian Federation;
3) judicial acts, or acts of another authority or official, subject to enforcement at the “Sape Space” Agency in accordance with the legislation of the Russian Federation on enforcement proceedings;
4) a contract to which the data subject is a party, beneficiary, or guarantor, as well as a contract concluded at the initiative of the data subject, or a contract under which the data subject will be a beneficiary or guarantor;
5) the protection of the life, health, or other vital interests of the data subject, where obtaining the data subject's consent is not possible;
6) the exercise of the rights and legitimate interests of the “Sape Space” Agency or of third parties, or the achievement of socially significant purposes, provided that the rights and freedoms of the data subject are not thereby infringed;
7) the exercise of professional journalistic activity and/or the lawful activity of a mass media outlet, or scientific, literary or other creative activity, provided that the rights and legitimate interests of the data subject are not thereby infringed;
8) the processing of personal data for statistical or other research purposes, provided the data is mandatorily depersonalised;
9) the processing of personal data for the purpose of publication or mandatory disclosure of information in accordance with the legislation of the Russian Federation.
5. Organisation of Personal Data Processing
In order to organise personal data processing effectively and to ensure the security of personal data, the “Sape Space” Agency appoints a person responsible for organising the processing of personal data, who, within their established authority, ensures:
1) internal oversight of compliance with the requirements of Russian Federation legislation on personal data at the “Sape Space” Agency, including requirements for the protection of personal data at the Agency;
2) that employees of the “Sape Space” Agency are made aware of the provisions of Russian Federation legislation on the processing of personal data, as well as the requirements for the protection of personal data;
3) oversight of the handling of enquiries and requests from data subjects or their representatives concerning breaches of personal data legislation committed by employees of the “Sape Space” Agency.
Personal data is processed by employees of “Sape Space” who have been granted this right by management, as well as by persons duly authorised to process personal data.
These persons are entitled to process only the personal data that is necessary for the performance of their duties.
The processing of personal data at the “Sape Space” Agency is carried out using automation tools and/or without the use of such tools.
The processing of special categories of personal data, as well as biometric personal data, at the “Sape Space” Agency is carried out in accordance with the requirements of Russian Federation legislation.
In order to implement the rights of data subjects when processing their personal data, the “Sape Space” Agency:
1) applies legal, organisational and technical measures to protect the personal data of data subjects against unlawful or accidental access, destruction, alteration, blocking, copying, provision, distribution, and other unlawful actions;
2) explains to data subjects the legal consequences of refusing to provide their personal data and/or to give consent to its processing, where the provision of personal data is mandatory under Russian Federation legislation;
3) blocks, clarifies and destroys unlawfully processed personal data, and terminates its unlawful processing;
4) notifies the data subject of the remedy of any breaches identified, or of the destruction of their personal data;
5) provides, at the request of the data subject or their representative, information concerning the processing of their personal data, in the manner established by Russian Federation legislation;
6) carries out internal monitoring and/or auditing of compliance with Russian Federation legislation in the processing of personal data;
7) assesses the harm that may be caused to data subjects in the event of a breach of Russian Federation legislation on personal data, weighed against the measures taken by the “Sape Space” Agency to ensure compliance with the obligations set out in Russian Federation legislation on personal data.
The processing of personal data that the data subject has permitted for distribution is carried out in compliance with the prohibitions and conditions set out in Article 10.1 of the Federal Law “On Personal Data.”
Consent to the processing of personal data permitted by the data subject for distribution is drawn up separately from any other consents given by the data subject.
Personal data is transferred to third parties only with the written consent of the data subjects, except where this is necessary to prevent a threat to the life or health of data subjects, or in other cases established by Russian Federation legislation.
Personal data may be transferred to state authorities without the data subject's consent, in the manner and in the cases provided for by Russian Federation legislation.
Cross-border transfer of personal data is carried out with due regard to the restrictions and prohibitions provided for by Russian Federation legislation on personal data.
Before beginning a cross-border transfer of personal data, “Sape Space”:
● assesses the measures taken by the authorities of the foreign state, or by the foreign individuals and legal entities to whom the cross-border transfer of personal data is planned, to ensure the confidentiality and security of personal data;
● notifies the authorised body for the protection of the rights of data subjects of its intention to carry out a cross-border transfer of personal data.
The “Sape Space” Agency is entitled to entrust the processing of personal data to another party with the consent of the data subject, unless otherwise provided for by Russian Federation legislation, on the basis of a contract concluded with that party.
When collecting personal data, including via the Internet, the “Sape Space” Agency ensures that the recording, systematisation, accumulation, storage, clarification (updating, amendment) and retrieval of the personal data of Russian Federation citizens is carried out using databases located on the territory of the Russian Federation, except in cases provided for by Russian Federation legislation.
The security of personal data, including when processed in information systems, is ensured in accordance with Russian Federation legislation and the requirements of the authorised body for the protection of the rights of data subjects, the federal executive authority responsible for security, and the federal executive authority responsible for counteracting technical intelligence activities and technical information protection.
The periods for processing and storing personal data for each processing purpose set out in Appendix No. 1 to this Policy are determined with due regard to Russian Federation legislation and/or the terms of any contract to which the data subject is a party, beneficiary or guarantor, and/or the data subject's consent to the processing of their personal data.
The procedure and methods for destroying personal data at the “Sape Space” Agency are determined in accordance with Russian Federation legislation.
Personal data is subject to destruction in the following cases:
1) once the purposes of processing have been achieved, or the need to achieve the purposes of processing personal data no longer exists;
2) if the data subject withdraws their consent to the processing of their personal data, except in cases provided for by Russian Federation legislation;
3) where the data subject or their representative provides information confirming that the personal data: (a) is incomplete, outdated, or inaccurate (provided that it cannot be clarified); (b) was obtained unlawfully; (c) is not necessary for the stated purpose of processing;
4) where unlawful processing of personal data is identified (where it is not possible to ensure the lawfulness of the processing);
5) where a data subject requests that the processing of their personal data be terminated, except in cases provided for by Russian Federation legislation.
6. Rights of the Data Subject
Data subjects have the right to:
1) receive, upon request, full information about their personal data being processed at the “Sape Space” Agency;
2) review their personal data by contacting the “Sape Space” Agency;
3) have their personal data clarified, blocked, or destroyed if it is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing;
4) request that the processing of their personal data be terminated;
5) provide their personal data and their consent to its processing freely, of their own will and in their own interest;
6) withdraw their consent to the processing of their personal data;
7) appeal, in accordance with Russian Federation legislation, any actions (or inaction) of the “Sape Space” Agency in the processing of personal data;
8) exercise other rights provided for by Russian Federation legislation.
7. Final Provisions
Liability for breaches of the requirements of Russian Federation legislation and of the “Sape Space” Agency's own regulatory documents in the field of personal data is determined in accordance with Russian Federation legislation.
This Policy is a publicly available document and is to be published on the official website of the “Sape Space” Agency at: https://sapespace.com/policy
1. Personnel and Accounting Records
General categories of personal data:
Full name; year, month, date and place of birth; marital status; social status; income; sex; email address; home and registration address; phone number; personnel number; SNILS (Russian pension insurance number); INN (taxpayer number); citizenship; identity document details; driving licence details; foreign identity document details; birth certificate details; bank card and account details; profession; position; employment history (including length of service and current employment details); military registration status; education details; full postal address; compulsory medical insurance policy details; marriage certificate details; military registration document details; academic degree details; foreign language proficiency; employee photograph; details from the employment contract and any amendments to it; details of time spent abroad; security clearance details; details of state and other awards and honours; details of professional retraining and/or continuing education; results of the employee's medical fitness examination; details of paid annual leave, study leave, and unpaid leave; salary details; travel origin, destination and route type; travel dates/periods.
Special categories of personal data:
Health information; criminal record information.
Categories of data subjects:
Employees; employees' relatives; former employees; counterparties; pensioners registered with the “Sape Space” Agency; individuals engaged under civil-law contracts.
2. Compliance with Russian Federation Labour Legislation
General categories of personal data:
Full name; date and place of birth; marital and social status; sex; email address; home and registration address; phone number; personnel number; SNILS; INN; citizenship; identity and driving licence details; foreign identity document details; bank account details; profession; position; employment history; military registration status; education details; postal address; medical insurance and marriage certificate details; military registration document details; academic degree details; employee photograph; employment contract details; results of corporate assessment procedures; details of time spent abroad; security clearance and award details; professional development details; medical fitness results; salary details.
Special categories of personal data:
Health information; criminal record information.
Categories of data subjects:
Employees; job applicants; employees' relatives; former employees; contractual beneficiaries; legal representatives.
3. Compliance with Russian Federation Education Legislation
General categories of personal data:
Full name; date and place of birth; income; sex; email address; home and registration address; phone number; personnel number; SNILS; citizenship; identity document details; birth certificate details; profession; position; employment history; education details; postal address; academic degree details; employee photograph; employment contract details; award details; professional development details; salary details.
Special categories of personal data:
None.
Categories of data subjects:
Employees; employees' relatives; counterparties; pupils; students; legal representatives.
4. Staff Training and Professional Development
General categories of personal data:
Full name; date and place of birth; income; sex; email address; home and registration address; phone number; personnel number; SNILS; citizenship; identity document details; birth certificate details; profession; position; employment history; education details; postal address; academic degree details; employee photograph; employment contract details; award details; professional development details; salary details.
Special categories of personal data:
None.
Categories of data subjects:
Employees; staff, counterparties; pupils; students; legal representatives.
5. Preparation, Conclusion and Performance of Civil-Law Contracts
General categories of personal data:
Full name; date and place of birth; sex; email address; registration address; phone number; INN; citizenship; identity document details; bank account details; profession; position; full postal address.
Special categories of personal data:
None.
Categories of data subjects:
Employees; counterparties; counterparties' representatives; clients; individuals engaged under civil-law contracts.
6. Recruitment of Applicants for Agent/Operator Positions
General categories of personal data:
Full name; date and place of birth; marital and social status; income; sex; email address; home and registration address; phone number; personnel number; SNILS; INN; citizenship; identity and driving licence details; foreign identity document details; birth certificate details; profession; position; employment history; military registration status; education details; postal address; academic degree details; foreign language proficiency; employee photograph; employment contract details; details of time spent abroad; security clearance and award details; professional development details; results of corporate assessment procedures; salary details; medical fitness results; travel origin, destination, route type and dates.
Special categories of personal data:
Health information; criminal record information.
Categories of data subjects:
Employees; job applicants; relatives of employees and applicants; former employees; counterparties and their representatives; clients; pupils; students; pensioners; individuals engaged under civil-law contracts.
7. Compliance with Russian Federation Insurance Legislation
General categories of personal data:
Full name; date and place of birth; marital and social status; income; sex; home and registration address; phone number; personnel number; SNILS; INN; citizenship; identity document and birth certificate details; bank card and account details; profession; position; employment history; postal address; paid and unpaid leave details; salary details.
Special categories of personal data:
Health information.
Categories of data subjects:
Employees.
8. Compliance with Russian Federation Transport Security Legislation
General categories of personal data:
Full name; date and place of birth; sex; email address; home and registration address; phone number; INN; citizenship; identity document details; bank account details; position; postal address.
Special categories of personal data:
None.
Categories of data subjects:
Employees; counterparties and their representatives; users of Sape Space services; individuals engaged under civil-law contracts.
9. Access Control on Operator Premises
General categories of personal data:
Full name; date and place of birth; home and registration address; citizenship; identity document details; position; employee photograph.
Special categories of personal data:
None.
Categories of data subjects:
Employees; visitors to Sape Space premises (where administrative buildings are in use).
10. Compliance with Russian Federation Tax Legislation
General categories of personal data:
Full name; date and place of birth; marital status; income; sex; email address; home and registration address; phone number; personnel number; SNILS; INN; citizenship; identity and foreign identity document details; bank card and account details; profession; position; employment history; education details; postal address; academic degree details; foreign language proficiency; employment contract details; security clearance and award details; professional development details; paid and unpaid leave details; salary details; travel origin, destination, route type and dates.
Special categories of personal data:
None.
Categories of data subjects:
Employees; employees' relatives; former employees; counterparties and their representatives; contractual beneficiaries; pupils; students; legal representatives; individuals engaged under civil-law contracts.
11. Compliance with Russian Federation Pension Legislation
General categories of personal data:
Full name; date and place of birth; income; sex; email address; home and registration address; phone number; personnel number; SNILS; INN; citizenship; identity and foreign identity document details; profession; position; employment history; postal address; employment contract details; paid and unpaid leave details.
Special categories of personal data:
None.
Categories of data subjects:
Employees; former employees; legal representatives; registered pensioners; individuals engaged under civil-law contracts.
12. Compliance with Russian Federation Security Legislation
General categories of personal data:
Full name; date and place of birth; marital status; sex; email address; home and registration address; phone number; personnel number; SNILS; identity document details; profession; position; employment history; education details; marriage certificate details; employee photograph; employment contract details; professional development details.
Special categories of personal data:
None.
Categories of data subjects:
Employees.
13. Voluntary Medical Insurance
General categories of personal data:
Full name; date and place of birth; sex; home and registration address; phone number; personnel number; SNILS; position; full postal address.
Special categories of personal data:
None.
Categories of data subjects:
Employees.
14. Implementation of International Treaties of the Russian Federation
General categories of personal data:
Full name; date and place of birth; email address; home and registration address; phone number; identity and foreign identity document details; position; postal address; employee photograph; details of time spent abroad; travel origin, destination, route type and dates.
Special categories of personal data:
None.
Categories of data subjects:
Employees; counterparties and their representatives; clients; service users and other persons using the services; individuals engaged under civil-law contracts; visitors to departments (where administrative buildings are in use).
General categories of personal data:
Full name; year, month, date and place of birth; marital status; social status; income; sex; email address; home and registration address; phone number; personnel number; SNILS (Russian pension insurance number); INN (taxpayer number); citizenship; identity document details; driving licence details; foreign identity document details; birth certificate details; bank card and account details; profession; position; employment history (including length of service and current employment details); military registration status; education details; full postal address; compulsory medical insurance policy details; marriage certificate details; military registration document details; academic degree details; foreign language proficiency; employee photograph; details from the employment contract and any amendments to it; details of time spent abroad; security clearance details; details of state and other awards and honours; details of professional retraining and/or continuing education; results of the employee's medical fitness examination; details of paid annual leave, study leave, and unpaid leave; salary details; travel origin, destination and route type; travel dates/periods.
Special categories of personal data:
Health information; criminal record information.
Categories of data subjects:
Employees; employees' relatives; former employees; counterparties; pensioners registered with the “Sape Space” Agency; individuals engaged under civil-law contracts.
2. Compliance with Russian Federation Labour Legislation
General categories of personal data:
Full name; date and place of birth; marital and social status; sex; email address; home and registration address; phone number; personnel number; SNILS; INN; citizenship; identity and driving licence details; foreign identity document details; bank account details; profession; position; employment history; military registration status; education details; postal address; medical insurance and marriage certificate details; military registration document details; academic degree details; employee photograph; employment contract details; results of corporate assessment procedures; details of time spent abroad; security clearance and award details; professional development details; medical fitness results; salary details.
Special categories of personal data:
Health information; criminal record information.
Categories of data subjects:
Employees; job applicants; employees' relatives; former employees; contractual beneficiaries; legal representatives.
3. Compliance with Russian Federation Education Legislation
General categories of personal data:
Full name; date and place of birth; income; sex; email address; home and registration address; phone number; personnel number; SNILS; citizenship; identity document details; birth certificate details; profession; position; employment history; education details; postal address; academic degree details; employee photograph; employment contract details; award details; professional development details; salary details.
Special categories of personal data:
None.
Categories of data subjects:
Employees; employees' relatives; counterparties; pupils; students; legal representatives.
4. Staff Training and Professional Development
General categories of personal data:
Full name; date and place of birth; income; sex; email address; home and registration address; phone number; personnel number; SNILS; citizenship; identity document details; birth certificate details; profession; position; employment history; education details; postal address; academic degree details; employee photograph; employment contract details; award details; professional development details; salary details.
Special categories of personal data:
None.
Categories of data subjects:
Employees; staff, counterparties; pupils; students; legal representatives.
5. Preparation, Conclusion and Performance of Civil-Law Contracts
General categories of personal data:
Full name; date and place of birth; sex; email address; registration address; phone number; INN; citizenship; identity document details; bank account details; profession; position; full postal address.
Special categories of personal data:
None.
Categories of data subjects:
Employees; counterparties; counterparties' representatives; clients; individuals engaged under civil-law contracts.
6. Recruitment of Applicants for Agent/Operator Positions
General categories of personal data:
Full name; date and place of birth; marital and social status; income; sex; email address; home and registration address; phone number; personnel number; SNILS; INN; citizenship; identity and driving licence details; foreign identity document details; birth certificate details; profession; position; employment history; military registration status; education details; postal address; academic degree details; foreign language proficiency; employee photograph; employment contract details; details of time spent abroad; security clearance and award details; professional development details; results of corporate assessment procedures; salary details; medical fitness results; travel origin, destination, route type and dates.
Special categories of personal data:
Health information; criminal record information.
Categories of data subjects:
Employees; job applicants; relatives of employees and applicants; former employees; counterparties and their representatives; clients; pupils; students; pensioners; individuals engaged under civil-law contracts.
7. Compliance with Russian Federation Insurance Legislation
General categories of personal data:
Full name; date and place of birth; marital and social status; income; sex; home and registration address; phone number; personnel number; SNILS; INN; citizenship; identity document and birth certificate details; bank card and account details; profession; position; employment history; postal address; paid and unpaid leave details; salary details.
Special categories of personal data:
Health information.
Categories of data subjects:
Employees.
8. Compliance with Russian Federation Transport Security Legislation
General categories of personal data:
Full name; date and place of birth; sex; email address; home and registration address; phone number; INN; citizenship; identity document details; bank account details; position; postal address.
Special categories of personal data:
None.
Categories of data subjects:
Employees; counterparties and their representatives; users of Sape Space services; individuals engaged under civil-law contracts.
9. Access Control on Operator Premises
General categories of personal data:
Full name; date and place of birth; home and registration address; citizenship; identity document details; position; employee photograph.
Special categories of personal data:
None.
Categories of data subjects:
Employees; visitors to Sape Space premises (where administrative buildings are in use).
10. Compliance with Russian Federation Tax Legislation
General categories of personal data:
Full name; date and place of birth; marital status; income; sex; email address; home and registration address; phone number; personnel number; SNILS; INN; citizenship; identity and foreign identity document details; bank card and account details; profession; position; employment history; education details; postal address; academic degree details; foreign language proficiency; employment contract details; security clearance and award details; professional development details; paid and unpaid leave details; salary details; travel origin, destination, route type and dates.
Special categories of personal data:
None.
Categories of data subjects:
Employees; employees' relatives; former employees; counterparties and their representatives; contractual beneficiaries; pupils; students; legal representatives; individuals engaged under civil-law contracts.
11. Compliance with Russian Federation Pension Legislation
General categories of personal data:
Full name; date and place of birth; income; sex; email address; home and registration address; phone number; personnel number; SNILS; INN; citizenship; identity and foreign identity document details; profession; position; employment history; postal address; employment contract details; paid and unpaid leave details.
Special categories of personal data:
None.
Categories of data subjects:
Employees; former employees; legal representatives; registered pensioners; individuals engaged under civil-law contracts.
12. Compliance with Russian Federation Security Legislation
General categories of personal data:
Full name; date and place of birth; marital status; sex; email address; home and registration address; phone number; personnel number; SNILS; identity document details; profession; position; employment history; education details; marriage certificate details; employee photograph; employment contract details; professional development details.
Special categories of personal data:
None.
Categories of data subjects:
Employees.
13. Voluntary Medical Insurance
General categories of personal data:
Full name; date and place of birth; sex; home and registration address; phone number; personnel number; SNILS; position; full postal address.
Special categories of personal data:
None.
Categories of data subjects:
Employees.
14. Implementation of International Treaties of the Russian Federation
General categories of personal data:
Full name; date and place of birth; email address; home and registration address; phone number; identity and foreign identity document details; position; postal address; employee photograph; details of time spent abroad; travel origin, destination, route type and dates.
Special categories of personal data:
None.
Categories of data subjects:
Employees; counterparties and their representatives; clients; service users and other persons using the services; individuals engaged under civil-law contracts; visitors to departments (where administrative buildings are in use).
Contact
Dubai, Control Tower: Office Building - Al Hebiah First - Dubai Motor City - Dubai
