POLICY CONCERNING PERSONAL DATA PROCESSING OF GAMMA TRADING HOUSE JSC


1. Purpose and scope of the document


The Company's Personal data processing policy (hereinafter referred to as Policy) defines the Company's position and intent concerning processing and protection of personal data, respect of the rights and basic liberties of every individual and especially the right for privacy, personal and family secrets, protection of his or her honor and reputation.


The policy is to be studied and rigorously followed by managers and employees of all business units of the Company; it is also to be brought to the attention of persons that have contractual, civil legal or other relationships with the Company, of partners and other interested parties.


2. Composition of personal data processed by the Company


The Company processes the following personal data of the customers:



The Company processes personal data of job applicants in the scope required for making a decision about employing the applicant.


The Company processes personal data of employees in the scope required for performance of duties stipulated for the employer by the statutes in place.


The Company does not process biometric personal data as well as special categories of personal data (except for employee health data related to the issue of whether such employees would be able to execute their job functions).


3. The purposes of processing personal data


The Company processes personal data for the purposes of:



4. Provisions of the Policy


The Company implements the processing and provides the security of personal data in accordance with the requirements of the Constitution of the Russian Federation, the Labor Code of the Russian Federation, the Federal Law No. 152-FZ "On Personal Data", the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).


When processing personal data, the Company adheres to the following principles:



5. Individuals' rights concerning processing personal data


An individual whose personal data is processed by the Company has a right to:


1. receive from the Company:



2. demand the update of his personal data, its blocking or destruction in case the personal data is incomplete, outdated, incorrect, unlawfully received or is not needed for the stated purpose of processing


3. withdraw consent for personal data processing by sending a written request to the address: "Gamma TH" JSC 58 Krasnaya street, Solnechnogorsk, Moscow region, 141506 RUSSIA or e-mail on the Company’s address: export@firma-gamma.ru


4. opt out at any moment of an e-mail list by clicking the link "Cancel e-mail subscription" in the e-mail message or at the website at http://________________________


5. demand the correction of unlawful actions of the Company on his or her personal data


6. demand compensation for damages and/or moral injury by judicial procedure.


7. Information regarding implemented requirements for personal data protection


When processing personal data, the Company takes necessary legal, organizational and technical measures to provide the confidentiality of personal data and to protect it from unlawful actions:



PLEASE NOTE:


Individuals whose personal data is being processed by the Company can receive full clarification of the issues on their personal data’ processing by sending an official request to e-mail address export@firma-gamma.ru or to mailing address:


"Gamma TH" JSC


58 Krasnaya street, Solnechnogorsk, Moscow region, 141506 RUSSIA


In case of sending an official request to the Company the request has to include:



If the request is sent in the electronic format, it has to be executed as an electronic document and signed with an electronic signature in accordance with the laws of the Russian Federation.