Private policy regarding the personal data processing of applicants (candidates) and website visitors

Version 3.00 from 06.04.2021

Protection of personal data of individuals is of great importance for JSC ANCOR (hereinafter referred to as "ANCOR", "we"). The document titled "Private Policy of Personal Data Processing of Applicants (Candidates) and Website Visitors" (hereinafter referred to as the "Policy") describes in detail what kind of information we collect to provide our services to job seekers and to interact with site visitors, and how such information is processed.

ANСOR processes personal data of applicants (candidates) and website visitors on legal grounds in accordance with part 1 of Article 6 of Federal Law No. 152-FZ On Personal Data, for example, to fulfill the terms of the offer accepted by the applicant (candidate), or on the basis of the consent granted to processing of personal data.

As a personal data operator, we have implemented multiple technical and organizational measures to ensure the fullest possible protection of personal data. However, if you do not wish to transfer your personal data over the Internet, you can select alternative methods (for example, personal delivery at ANCOR office).

• Who we are and how to contact us

  Joint-stock Company ANCOR

  Registered address: 109316, Moscow, Ostapovsky proezd, house 5, building 12, floor 2, office 200

  Physical address (location): 109544, Moscow, Bulvar Entuziastov, house 2, Golden Gate Business Center, tower A

  Telephone: +7 (495) 926-41-00

  E-mail: info@ancor.ru

  Website: www.ancor.ru

  Person responsible for data processing and protection:

  Sergey Muslaev

  Address: 109544, Moscow, Bulvar Entuziastov, house 2, Golden Gate Business Center, tower A

  E-mail: privacy@ancor.ru

• Principles of personal data processing

  When processing PD, ANCOR adheres to the following principles:

  • performs processing of personal data on the legal and fair basis;
  • identifies specific legitimate purposes prior to processing (including collection of) of personal data;
  • collects only those personal data that is necessary and sufficient for the stated purpose of processing;
  • restricts processing of personal data in order to achieve specific, pre-defined and legitimate goals;
  • performs incineration of personal data in order to achieve the purposes of processing or where it is no longer required to achieve the purposes (unless otherwise is stipulated in the contract or in other agreement with the data subject, or by the laws of the Russian Federation).
• Terms and methods of personal data processing in ANCOR

  Processing of personal data in ANCOR is performed solely on the proper legal basis: upon the person's consent obtained to processing of his or hers personal data, unless otherwise is stipulated in the applicable laws of the Russian Federation in the field of personal data.

  ANCOR does not process biometric personal data and special categories of personal data of website visitors and applicants (candidates) related to race, nationality, political views, religious or philosophical beliefs, or intimate life.

  ANCOR does not use the personal data of the personal data subjects to make decisions based solely on such data automated processing, which generate legal consequences for the personal data subject or otherwise affect their rights and legal interests.

  ANCOR processes personal health data solely to the extent required to comply with the labor laws of the Russian Federation.

  In case of cross-border transfer of personal data to countries that do not protect the rights of personal data subjects, save for the instances, where provided for under the laws of the Russian Federation, the cross-border transfer of data shall be effected on the basis of a separate written consent.

  ANCOR does not publish personal data in publicly available sources without a specific prior written consent of the personal data subject.

  ANCOR does not disclose, transfer or distribute personal data to third parties without a proper legal basis. For the purpose of transferring personal data of personal data subjects, third parties shall be warned by ANCOR without fail about confidentiality of the transferred information.

  ANCOR may engage third parties for processing of personal data upon consent of the personal data subject, unless otherwise is stipulated by the laws of the Russian Federation, on the basis of appropriate agreement entered into with such persons (hereinafter referred to as the "operator's" order).

  Persons who process personal data on the basis of a contract entered into with ANCOR (operator's order), undertake to comply with the principles and rules of processing and protection of personal data provided for by the laws of the Russian Federation. For each third party, a contract establishes a list of actions (transactions) with personal data to be performed by a third party processing personal data, the purposes of processing personal data, establishes the obligation of such a person to respect confidentiality and ensure security of personal data during processing, specifies the requirements for protection of processed personal data in accordance with the laws of the Russian Federation.

  Where ANCOR contracts other person for processing of personal data, ANCOR is responsible to the personal data subject for actions of such third person. A person processing personal data on behalf of ANCOR, who is operator of personal data, shall be liable to ANCOR.

  ANCOR shall process personal data by the following methods:

  • with the use of automation tools, inter alia, using information technologies and technical facilities, including computer equipment, IT and technical complexes and networks, facilities and systems for transmitting, receiving and processing personal data, specialist software (operating systems, database management systems, etc.), information security tools used in IT systems;
  • without using automation tools.

  The set of operations performed by ANCOR for processing personal data of applicants (candidates) and website visitors includes collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (provision, access), blocking, deletion, incineration of personal data.

• Personal data processed by ANCOR, grounds for processing, purposes of processing and processing deadlines

  Processing purpose	Processed data	Legal basis	Deadlines for storage
  Assistance in finding employment or organizing other types of cooperation with a potential employer, informing about emerging career opportunities, conducting a preliminary interview for employment or other types of employment, providing services/performing work on the basis of a civil contract, as well as for the purpose of carrying on ANCOR activities related to human resources management and labor market analysis	Applicants (candidates): surname, first name and patronymic; sex; photo; contact telephone number; email address; date of birth; citizenship; city and area of residence; address of personal web page in social networks; readiness to move and travel; marital status; work experience; information about education obtained; information about previous employment; level of computer proficiency ; level of foreign language proficiency; salary expectations; evaluation characteristics made by an employee of the Company; other PD to be included at your discretion into your resume; references from previous employers	Public offer accepted by the applicant (candidate)	Until termination of the public offer
  Mailing marketing materials and conducting social surveys	Job seekers: email address; IP Address sex; age group; level of education; information about existence of employment relationship at the time of the survey; industry previously worked in; professional specialization; region of residence; other data collected through specific social surveys	Applicant's consent to data processing	Before withdrawal of the consent to data processing
  Communicating information to unlimited number of people about ANCOR activities	Website visitors: cookies; IP addresses; other automatically collected data, and specifically: URL pages; page referrer; page title; browser and its version; operating system and its version; device model; screen height and width; information about whether the user has cookies and JavaScript enabled (ECMAScript); JavaScript events (maintaining a log of the user's interactions with the website, including the use of JavaScript API methods on the website, for example, sending a form, scrolling a page); time zone; browser language; screen color depth; width and height of the client part of the browser window; gender, age, and interests of website users; geographical data; page load parameters (for example, time before rendering and server response time); data about the pages viewed and the session, clicks on external links, file downloads, bounces, time spent on the website, and viewing depth	Consent of the website user to data processing	Cookie files– in accordance with the Cookie files Policy; Other data – until withdrawal of the consent to data processing
  Feedback from website users (including a publication of a review)	Website visitors (including job seekers and customer representatives): surname and forename; place of employment (company name); contact telephone number; email address; other PD you will include in your review yourself	Consent of the website user to data processing	Before withdrawal of the consent to data processing
  Subscription for the newsletter (vacancies, news)	Website visitors: forename; email address;	Consent of the website user to data processing	Before withdrawal of the consent to data processing

• Source of personal data

  The personal data of applicants (candidates) can be obtained by the ANCOR directly from you personally, from your representative who acts in your interests, or from the work sites on which you have posted your resume in accordance with the terms of use of the sites.

  Personal data of the website visitors may be obtained by ANCOR directly from you personally, from your representative who acts in your interests, or from your devices used by you to access the website.

• Recipients of personal data to whom the ANCOR may transmit the data of applicants (candidates) and website visitors
  • ANCOR clients-potential employers,
    ANCOR group of persons (in the meaning of the concept of a group of persons defined by Article 9 of the Federal Law On Protection of Competition under No. 135-FZ of 26/07/2006).
    Transfer purpose: execution of a public offer for provision of services to applicants (candidates) related to selection of personnel.
  • Companies of ANCOR Group: OOO TeamService (111024, Moscow, shosse Entuziastov, house 21, building 2) and Heliosoft LLC (115280, Moscow, Leninskaya Sloboda, house 19)
    Transfer purpose: support for ANCOR information systems.
• Personal data protection

  ANCOR implements a set of measures aimed at ensuring security of personal data in the process of ANCOR management and business operations.

  To protect personal data, ANCOR has the following measures in place:

  • appointment of the person responsible for organizing the processing of personal data and the person responsible for ensuring security of personal data in information systems;
  • development and approval of local acts for processing and protection of personal data;
  • use of information security tools;
  • keeping a record of tangible carriers of personal data;
  • discovery of unauthorized access to personal data and taking measures to prevent such incidents in the future;
  • recovery of personal data modified or destroyed as a result of unauthorized access to it;
  • establishing rules for access to personal data processed in information systems, as well as ensuring registration and keeping a record of all actions performed with personal data in information systems;
  • maintaining control over the measures undertaken to ensure security of personal data and the level of security of information systems;
  • assessment of the harm that may be caused to subjects of personal data in case of breach of requirements of laws, ratio between such harm measures undertaken by ANCOR to secure obligations established by laws;
  • compliance with terms and conditions preventing unauthorized access to tangible carriers of personal data and to secure safety of personal data;
  • having those ANCOR employees who are directly engaged in the processing of personal data, informed of the provisions of laws applicable to personal data, including requirements to protection of personal data, local acts regulating processing and protection of personal data;
  • organizing the procedure for destruction of information containing personal data;
  • advising ANCOR employees for preventing of threatened risk of loss of personal data;
  • organization of access control to ANCOR;
  • organization of procedures for protection and security of ANCOR areas, buildings, premises.
• Rights and obligations of ANCOR as an operator of personal data

  ANCOR is authorized to:

  • provide personal data to governmental and other competent authorities, if provided for by the laws of the Russian Federation (tax, law enforcement agencies, etc.);
  • refuse to provide personal data in cases stipulated by the laws of the Russian Federation;
  • process personal data of the subject without such subject's consent, in cases provided for by the laws of the Russian Federation.

  ANCOR is obligated to:

  • provide personal data subjects, upon their request, with information related to processing of their personal data;
  • explain to the personal data subjects the legal consequences of their refusal to provide ANCOR with their personal data, subject to the condition that such data shall be provided in mandatory manner in accordance with the laws of Russian Federation;
  • if personal data is not received from the personal data subject, save for instances set out in Part 4 of Article 18 of Federal Law No. 152 of 07/27/2006, before processing of such personal data, to provide the personal data subject with the following information: данных следующую информацию:
    1. name or surname, first name, patronymic and address of the Operator or the Operator`s representative;
    2. the purpose of personal data processing and its legal basis;
    3. designated users of personal data;
    4. the rights of the personal data subject established by Federal Law No. 152 of 07/27/2006;
    5. source of personal data collection;
  • for the purpose of collecting personal data, inter alia, via Internet, to secure recording, systematization, accumulation, storage, clarification (update, change), extraction of personal data of the citizens of the Russian Federation using databases located in the territory of the Russian Federation, save for the instances, set out in subcl. 2, 3, 4, 8 of Part 1 of Article 6 of Federal Law No. 152 of 07/27/2006.
• Rights of the personal data subject

  If ANCOR processes your data based on your consent¹ to processing of personal data, you can revoke such consent at any time.

  You may receive information² regarding processing of your personal data, its clarification or deletion³ the right to appeal against the actions performed by ANCOR⁴ and are entitled to compensation and indemnification of losses.⁵

  To exercise your rights, please contact us.

• Changes in this Policy

  This Policy may be amended from time to time to reflect possible changes in our personal data processing processes. We will notify you of any material changes to this Policy. The relative notices may be posted on the website (for example, in a pop-up window or banner) before such changes take effect, or may be sent to you via other communication channels (for example, by email, if you have provided us with your contact details).

  The date of the most recent change and the current version shall be stated at the beginning of the Policy.

• Appendix 1 Form for revoking consent to the processing of personal data

  I,
  _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ,
  

  (Forename, Surname, Patronymic) / (Full name)

  
  

  _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _,

  (passport data or other information enabling you to identify the subject of personal data, for example, date of birth, email, mobile phone)

  
  

  _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

  
  

  I withdraw from Joint-stock company ANCOR (location: 109316, Moscow, 5/12, Ostapovsky proezd, floor 2, office 200) and its group of persons⁶ my consent granted to processing of my personal data for (select, whichever is applicable):

  • mailing marketing materials and conducting social surveys;
  • providing feedback to the ANCOR on the website (including publication of the review);
  • subscription for the newsletter (vacancies, news)
  • other purposes:

  Please stop processing my personal data within a period not exceeding thirty days from the date ⁷ of receipt of this review.

  
  

  signature: _ _ _ _ _ _ _ _ _ /

  Full name: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ /

  Date: _ _ _ _ _ _ _ _ _ /

  city of: _ _ _ _ _ _ _ _ _ /