Personal Data Processing Policy

1. Terms and definitions

personal data - any information relating directly or indirectly to a specific or identifiable individual (subject of personal data);
personal data operator (operator) - a state body, municipal body, legal entity or individual, independently or jointly with other persons organizing and (or) processing personal data, as well as determining the purposes of processing personal data, the composition of personal data to be processed, actions (operations) performed with personal data;
processing of personal data - any action (operation) or a set of actions (operations) with personal data performed using automation tools or without their use.

The processing of personal data includes, inter alia:

collection;
recording;
systematization;
accumulation;
storage;
clarification (update, change);
extraction;
usage;
transfer (distribution, provision, access);
depersonalization;
blocking;
removal;
destruction.
automated processing of personal data - processing of personal data using computer technology;
provision of personal data - actions aimed at disclosure of personal data to a certain person or a certain circle of persons;
blocking of personal data - temporary termination of the processing of personal data (except in cases where processing is necessary to clarify personal data);
destruction of personal data - actions as a result of which it becomes impossible to restore the content of personal data in the personal data information system and (or) as a result of which the material carriers of personal data are destroyed;
depersonalization of personal data - actions as a result of which it becomes impossible to determine the identity of personal data to a specific personal data subject without the use of additional information;

2. General provisions

2.1. This policy defines the procedure for processing personal data and measures to ensure the security of personal data of FLAT LLC (hereinafter referred to as the Operator), which is the operator of personal data.

The operator ensures the processing of personal data in accordance with the requirements of Federal Law No. 152-FZ "On Personal Data" dated 27.07.2006.

This Policy is publicly available and is intended to familiarize the subjects of personal data whose personal data is processed by the operator

3. Processing of personal data

3.1. If you have submitted a request on the website, we process your name, surname, phone number and/or email address, as well as messages that you send to us through the Feedback form and other information that you voluntarily provided to us.

3.2. When visiting the website (emeraldcity.properties), we process your activity data on our website. In more detail, paragraph 10 of this Policy.

3.3. If you are in the process of purchasing (including in the process of approving a loan application), we will process (in addition to the data specified in clause 2.2) your taxpayer identification number, information about your identity document, address, information about your family, professional status, data on selected specifications for your property, as well as other information, including financial information, which you voluntarily provided to us for the specified purposes.

3.4. If you have purchased an object from us, we will process the data provided by you for the purpose of concluding an agreement in accordance with the terms of such an agreement.

3.5. We process the data disclosed by you by sending resumes and (or) cover letters to our address in connection with the job search. For these purposes, we are equally entitled to delete such information without processing it and (or) after taking measures aimed at confirming the fact of sending a resume directly by you as an applicant, use them for the purpose of making a decision on hiring and registration of employment relations (if there is a written consent from you on data processing for the period of making a decision on acceptance or rejection).

3.6. If you are our counterparty or a representative of the counterparty, we process the data to the extent disclosed to us during the conclusion and execution of the contract. In this case, the data of the authorized persons are transferred to the Operator directly by the party under the contract. Each party to the contract ensures the processing of personal data of its employees and/or engaged specialists in accordance with applicable legal norms; in accordance with the purposes for which data processing is carried out; ensuring that data subjects are informed about such processing, its purposes, deadlines, about the processing of data by third parties, as well as about the rights of the subject in connection with such processing.

4. Purposes of personal data processing

4.1. We process the above data for the following purposes:

(a) if you are a potential customer, or are interested in the information posted on our website, or have subscribed to the newsletter, other information through our website:

Sending newsletters and other marketing materials, information about promotions by e-mail and/or SMS;
Sending and displaying information of interest to you - based on the data that you have provided to us - as well as projects that you have shown interest in, and other projects by e-mail, SMS and/or by phone;
Sending invitations to events related to projects in which you have shown interest, or in relation to similar projects;
Conducting market and customer analysis, market reviews and statistics;
Preparation, conclusion and execution of contracts;

(b) if you are our client or his representative:

Fulfillment of our contractual and other legal obligations, fulfillment of legal requirements and protection from lawsuits;
Managing our relations with you related to the execution of the contract, for example, communicating with you about a specific project, communicating with you about working with us, reviewing your appeals, etc.;
Maintaining archival records and storing documents by a third organization;
Ensuring the operability of personal data information systems by third-party service providers, including for the purpose of storing in electronic databases and performing backup of these information systems;
providing information to third parties who, under an agreement with us, carry out activities to ensure the fulfillment of contracts with clients by us;

Checking the availability of professional experience, competencies, and other information provided by you by sending resumes, other cover letters to our address, the requirements of the company (if there are open vacancies) in order to make a decision on hiring;

(d) if you are our counterparty or its representative/employee:

Fulfillment of our contractual and other legal obligations, fulfillment of legal claims and protection from lawsuits;
Maintaining archival records and storing documents by a third organization;
Ensuring the operability of personal data information systems by third-party service providers, including for the purpose of storing in electronic databases and performing backup of these information systems.
providing information to third parties who, under an agreement with us, carry out activities to ensure the execution of contracts with customers by us;

(e) Are you in an employment relationship with us:

organization of personnel accounting;
conclusion and fulfillment of obligations under employment contracts;
HR records management;
assistance to employees in finding employment;
training and promotion of employees;
compliance with the requirements of tax legislation in connection with the calculation and payment of personal income tax, as well as the unified social tax;
compliance with the requirements of pension legislation in the formation and presentation of personalized data on each recipient of income taken into account when calculating insurance premiums for mandatory pension insurance and provision;
implementation of additional health insurance programs;
fulfillment of other requirements stipulated by the legislation of the Russian Federation related to the fulfillment of our obligations within the framework of labor relations.

5. Destruction of personal data

5.1. We retain your data for as long as it is necessary to fulfill the purposes specified above and within the statutory retention periods. The processed personal data is subject to destruction or depersonalization upon achievement of the processing goals or in case of loss of the need to achieve these goals, unless otherwise provided by the legislation of the Russian Federation.

5.2. The terms of data storage are determined in accordance with the requirements of the Order of the Ministry of Culture of the Russian Federation dated 25.08.2010 N 558 "On approval of the List of standard administrative archival documents formed in the course of the activities of state bodies, local self-government bodies and organizations, indicating the terms of storage".

6. Legal grounds for processing personal data?

6.1. Most of our data processing operations are performed to process your requests, perform precontractual measures and fulfill the terms of concluded contracts.

6.2. Some data processing operations, for example, distribution of marketing materials and information about our services and our products, as well as market and customer analysis, market reviews and statistics are based on your consent, expressed, inter alia, by sending a request (subscription) to our address to receive news or other information through the emeraldcity website.properties

6.3. Some data processing operations, for example, checking the availability of professional experience and competencies, are based on your consent, expressed, inter alia, by sending resumes and cover letters to our address via the emeraldcity.properties website

6.4. Some data processing operations are based on legitimate interests. These include: optimization of our sales and marketing activities, prevention of abuse and fraud, market analysis, ensuring the functionality of the website (www.emerald.properties) and statistical analysis to optimize the site, ensuring the operability of information systems of personal data emeraldcity.properties by third-party service providers, including for storage in electronic databases and the implementation of backup of these information systems.

7. Principles of personal data processing

automated and non-automated data processing;
data (content and volume) that meet the purposes of processing; the processed data cannot be redundant in relation to the stated purposes of their processing;
the confidentiality regime of the processed personal data is removed in cases of their depersonalization or inclusion in publicly available sources in accordance with the procedure established by the Federal Law "On Personal Data" N 152-FZ;
the storage of personal data is carried out in a form that allows determining the data subject, no longer than the processing purposes require, unless the storage period is established by federal law, an agreement to which the data subject is a party, beneficiary or guarantor. The processed data is subject to destruction or depersonalization upon achievement of the processing goals or in case of loss of the need to achieve these goals, unless otherwise provided by the legislation of the Russian Federation;
data containing information about race, nationality, political views, religious and philosophical beliefs, and the health status of personal data subjects are not processed.

8. Personal data protection

8.1. Employees who have access to the processed personal data are familiar with the privacy policy.

8.2. We transfer data only for the purpose of proper processing in connection with the execution of concluded contracts or in connection with other purposes for which such data was collected, or other organizational measures, or in connection with the requirements of the legislation of the Russian Federation.

In particular, in connection with the provision of newsletters and information about our projects, your personal data may be transferred by us to external companies providing services to us (for example, an information service provider, a customer service provider). In addition, we will disclose your personal information to government organizations if this is required in accordance with the requirements of the legislation of the Russian Federation.

8.3. The companies to which we disclose your personal information may use it only in accordance with our instructions and the purposes of its collection and processing, and within the framework of agreements that ensure a high level of security of your personal data.

8.4. We take the necessary legal, organizational and technical measures to ensure the security of personal data in accordance with the requirements of the legislation of the Russian Federation, including:

we identify threats to data security during their processing in information systems;
we apply organizational and technical measures necessary to comply with data protection requirements, the implementation of which ensures the levels of personal data protection established by the Government of the Russian Federation;
we use information security tools that have passed the compliance assessment procedure in accordance with the established procedure;
evaluate the effectiveness of the measures taken to ensure data security prior to the commissioning of information systems;
we establish rules for access to data processed in the information system, as well as ensure registration and accounting of all actions performed with data in the information system;
we monitor the measures taken to ensure data security and the level of security of information systems.

The objects of protection are:

documents containing personal data;
data stored on electronic media, as well as elements of information systems on which automated processing of personal data is carried out.

The protection of data processed in personal data information systems from unauthorized access, distortion and destruction of information, as well as from other illegal actions, is provided by technical measures in accordance with the requirements of regulatory legal acts of federal executive authorities performing functions for the development of state policy and regulatory regulation in the established field of activity.

9. Rights and obligations of the personal data subject

The subject of personal data has the right:

the right to receive information about what personal information (what personal data) we process about you, as well as other information related to the processing of personal data (with restrictions provided for in Part 8 of Article 14 of Federal Law No. 152-FZ of 27.07.2006);
the right to correct, correct, clarify;
the right to delete (destroy) your personal data;
the right to request restriction (blocking, i.e. temporary termination) of the processing of your personal data, for example, if you doubt the accuracy of the data that we process;
you can revoke (revoke) any consent given to us for the processing of your personal data.

Feedback can be sent by email to info@emeraldcity.properties whether in writing to the above address. Please note that the cancellation does not apply to such data processing, which is carried out in accordance with the requirements of the law, and which therefore can be processed without your consent.

Your consent to receive marketing materials and information, as well as customer surveys by e-mail and SMS messages, may be revoked at any time by unsubscribing from the link contained in each e-mail or SMS.

The subject of personal data is obliged to:

provide reliable information about yourself in the manner and to the extent provided for by the legislation of the Russian Federation;
in case of changes in the information constituting the PD in the established cases, inform us about it

10. Use of cookies and scope

10.1. The emeraldcity.properties website contains cookies. A cookie is a small text file that recommends saving a website you have visited on your computer. Cookies are used on many websites to provide visitors with access to various functions. Our Cookies are used for the purposes specified in this Policy. In particular, for internal purposes – for example, to receive and transmit statistical data and information about the general state of the market, to conduct marketing and advertising events, to improve the quality of our services in order to meet the requirements of our users, and to improve the emeraldcity.properties website in general.

10.2. About your consent to the use of cookies.

You agree to our use of cookies by continuing to use our website.

In order to avoid saving Cookies, you can configure your browser to automatically refuse to save Cookies, or set a request for permission to save Cookies. Previously saved cookies can be deleted using a web browser. Please refer to the Help web browser pages for more information. If you choose not to save Cookies, you can still use the website, albeit with limited functionality.

You can revoke your consent at any time by blocking and/or deleting cookies.

You can block the use of cookies in your browser settings. As a result, either the storage of cookies is automatically rejected, or you will be notified every time a website wants to save a cookie on your

device.

Previously saved cookies can be deleted in your browser settings. The required procedure depends on the browser.

Please note that blocking cookies may not give you full access to all pages and functions of our website.