This Personal Data Processing Policy (hereinafter the "Policy") defines the procedure and conditions for the processing of personal data, as well as the measures taken to ensure its security, adopted by Victoria International LLC (ООО «Виктория Интернейшнл») (hereinafter the "Operator"), and applies to all personal data that the Operator may obtain from data subjects when using the website https://victoriainternational.ru (hereinafter the "Website") and when providing recruitment services.

The Policy is developed in accordance with the requirements of clause 2 of part 1 of Article 18.1 of Federal Law No. 152-FZ of 27 July 2006 "On Personal Data" (hereinafter "Law No. 152-FZ") and defines the Operator’s policy regarding the processing of personal data.

Use of the Website constitutes the data subject’s consent to this Policy and to the conditions for processing their personal data. If the data subject does not agree with the terms of the Policy, they must refrain from using the Website.

The Policy applies to the processing of personal data carried out both with and without the use of automation tools.

The following key terms are used in the Policy:

• personal data — any information relating to a directly or indirectly identified or identifiable natural person (data subject);
• operator — an organization that, independently or jointly with others, organizes and (or) carries out the processing of personal data, and also determines the purposes and composition of the personal data being processed;
• processing of personal data — any action (operation) or set of actions performed on personal data, with or without the use of automation tools (collection, recording, systematization, accumulation, storage, updating, retrieval, use, transfer, blocking, deletion, destruction);
• automated processing — the processing of personal data using computing equipment;
• dissemination / provision — actions aimed at disclosing personal data to an indefinite or a defined group of persons;
• blocking — the temporary suspension of the processing of personal data (except where processing is necessary to update such data);
• destruction — actions as a result of which it becomes impossible to restore the content of personal data and (or) the material carriers of such data are destroyed;
• anonymization (de-identification) — actions as a result of which it becomes impossible, without the use of additional information, to determine the attribution of personal data to a specific data subject.

• Full name: Victoria International Limited Liability Company (ООО «Виктория Интернейшнл»).
• Short name: Victoria International LLC (ООО «Виктория Интернейшнл»).
• Address (location): 195220, Saint Petersburg, intra-city territory Grazhdanka municipal district, Grazhdansky Prospekt, 22, lit. A, premises 8-N, office 308.
• INN (Taxpayer ID): 7804704391.
• KPP (Tax Registration Reason Code): 780401001.
• OGRN (Primary State Registration Number): 1237800111988.
• General Director: Singkh Viktoria Nikolaevna.
• Email: victoriainternational@yandex.ru.

On all matters related to the processing of personal data, the data subject may contact the Operator at the specified email address or by post at the Operator’s registered location.

The Operator processes personal data on the basis of:

• the Constitution of the Russian Federation and Law No. 152-FZ;
• the consent of the data subject to the processing of their personal data;
• agreements concluded between the Operator and the data subject (or the organization that the data subject represents), to which the data subject is a party or a beneficiary;
• other federal laws and regulatory legal acts in the field of personal data protection.

The Operator processes the personal data of the following categories of data subjects:

• Employer contact persons — (representatives of organizations submitting inquiries and recruitment requests, and users of the employer’s personal account): surname, first name, patronymic; position; contact phone number; email address; information voluntarily provided in an inquiry or request.
• Website users — who have completed the feedback (request) form: name, contact phone number and (or) email address, and the content of the inquiry.
• Operator employees and authorized persons — (operators, system administrators) who hold accounts: user name, email address, service role, and authentication data.

The Operator does not process special categories of personal data (relating to racial or ethnic origin, political, religious or philosophical beliefs, health, or sexual life) or biometric personal data. The Operator does not collect the personal data of minors.

The processing of the personal data of candidates (applicants) and other persons, envisaged for subsequent stages of the service’s development, is carried out on the basis of separate consent and in the manner determined by separate Operator documents, and is not the subject of the current revision of the Policy.

The Operator processes personal data for the following purposes:

• providing recruitment services and supporting employers’ requests;
• registering and identifying users in the personal account and providing access to the Website’s features;
• processing inquiries and requests submitted through the Website’s forms and providing feedback to the data subject;
• performing agreements to which the data subject or the organization they represent is a party;
• sending informational and service notifications related to the provision of services;
• ensuring information security, maintaining activity (audit) logs, and preventing unlawful actions;
• complying with the requirements of the legislation of the Russian Federation.

The processing of personal data is based on the following principles:

• the lawfulness and fairness of the purposes and methods of processing;
• limiting processing to the achievement of specific, predefined, and lawful purposes;
• prohibiting the merging of databases containing personal data processed for mutually incompatible purposes;
• consistency of the content and volume of the processed data with the stated purposes of processing;
• the accuracy, sufficiency, and relevance of personal data;
• storing data in a form that allows the data subject to be identified for no longer than required by the purposes of processing;
• destroying or anonymizing personal data upon achievement of the purposes of processing or upon loss of the need to achieve them.

The Operator processes personal data with the data subject’s consent, as well as in other cases provided for by Law No. 152-FZ. Personal data is collected when the data subject voluntarily provides data through the Website’s forms and when registering in a personal account.

Processing includes the collection, recording, systematization, accumulation, storage, updating (renewal, modification), retrieval, use, transfer (in the cases provided for by the Policy), blocking, deletion, and destruction of personal data.

The recording, systematization, accumulation, storage, updating, and retrieval of the personal data of citizens of the Russian Federation are carried out using databases located within the territory of the Russian Federation (part 5 of Article 18 of Law No. 152-FZ).

Access to personal data is granted only to Operator employees who need it to perform their official duties, on the basis of access rights segregation. The service architecture excludes direct access by employers and candidates to each other’s data.

The Operator does not disclose to third parties or disseminate personal data without the data subject’s consent, unless otherwise provided by the legislation of the Russian Federation.

Personal data may be transferred to persons engaged by the Operator to provide services (in particular, to a hosting provider whose equipment is located within the territory of the Russian Federation), on the basis of agreements that oblige such persons to maintain confidentiality and ensure the security of personal data.

The transfer of personal data to government authorities is carried out on the grounds and in the manner established by the legislation of the Russian Federation.

Cross-border transfer of personal data is not carried out under the current revision of the Policy. Should such a need arise, it will be carried out in compliance with the requirements of Article 12 of Law No. 152-FZ.

For the operation of the Website, the Operator uses technically necessary cookies, including to maintain the user session and ensure secure authentication (storing the session refresh token in a secure cookie). These files are not used for advertising profiling.

When accessing the Website, technical data (IP address, browser information, date and time of access) may be processed automatically in order to ensure the operability and security of the service. The data subject may restrict the use of cookies through their browser settings; however, certain Website features may then become unavailable.

Personal data is processed for the period necessary to achieve the purposes of processing, unless a different period is established by an agreement or by the legislation of the Russian Federation.

The processing of personal data ceases upon achievement of the purposes of processing, upon expiry of the consent, upon withdrawal of consent by the data subject, and also upon detection of unlawful processing. Upon achievement of the purposes of processing or in the said cases, personal data is subject to destruction or anonymization within the periods established by law, unless there are other legal grounds for its further processing.

The Operator takes the necessary legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision, or dissemination, as well as from other unlawful actions, including:

• appointing a person responsible for organizing the processing of personal data;
• segregating and controlling access rights to information systems, with authorization verification on the server side;
• applying encryption of transmitted data (HTTPS/TLS protocol);
• securely storing passwords as irreversible hash values;
• maintaining logs of significant user actions (auditing);
• backing up data and following documented data recovery procedures;
• familiarizing employees who carry out processing with the provisions of the legislation and internal acts on personal data protection.

The data subject has the right to:

• obtain information concerning the processing of their personal data, in the manner provided for by Law No. 152-FZ;
• demand the updating, blocking, or destruction of personal data if it is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing;
• withdraw previously given consent to the processing of personal data;
• object to the processing of their personal data;
• appeal against the actions or inaction of the Operator to the authorized body for the protection of the rights of data subjects (Roskomnadzor) or in court;
• protect their rights and legitimate interests, including the recovery of losses and (or) compensation for moral harm.

To exercise their rights, as well as to withdraw consent to the processing of personal data, the data subject sends a corresponding request to the Operator at the email address victoriainternational@yandex.ru or in writing to the Operator’s registered location.

The request must contain information that allows the data subject (or their representative) to be identified, as well as information confirming the data subject’s participation in relations with the Operator. The Operator reviews the request and provides a response within the periods established by Law No. 152-FZ.

Withdrawal of consent does not terminate processing in cases where processing may continue on other legal grounds provided for by the legislation of the Russian Federation.

The Operator has the right to make amendments to this Policy. The current revision of the Policy is permanently available on the Website at https://victoriainternational.ru/privacy. A new revision takes effect from the moment of its publication, unless otherwise provided by the new revision.