Personal Data Processing Policy

1.General provisions

This personal data processing policy has been drawn up in accordance with the Law of the Republic of Moldova No. 133 of 08.07.2011 on Personal Data Protection (hereinafter — the Law on Personal Data Protection) and defines the procedure for processing personal data and the measures to ensure the security of personal data taken by VELMIRU AGENCY (hereinafter — the Operator).

1.1. The Operator sets as its most important goal and condition for the implementation of its activities the observance of human and civil rights and freedoms when processing personal data, including the protection of the rights to privacy, personal and family secrets.

1.2. This Policy of the Operator regarding the processing of personal data (hereinafter — the Policy) applies to all information that the Operator may receive about visitors to the website https://kryxre.ru/.

2.Key terms used in the Policy

2.1. Automated processing of personal data — processing of personal data using computer technology.

2.2. Blocking of personal data — temporary cessation of the processing of personal data (except for cases where processing is necessary to clarify personal data).

2.3. Website — a set of graphic and informational materials, as well as computer programs and databases that ensure their availability on the Internet at the network address https://kryxre.ru/.

2.4. Personal data information system — a set of personal data contained in databases and information technologies and technical means that ensure their processing.

2.5. Depersonalization of personal data — actions as a result of which it is impossible to determine, without the use of additional information, the ownership of personal data to a specific User or other subject of personal data.

2.6. Processing of personal data — any action (operation) or set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.

2.7. Operator — a public authority, legal entity or individual, independently or jointly with other persons organizing and/or carrying out the processing of 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.

2.8. Personal data — any information relating directly or indirectly to a specific or identifiable User of the website https://kryxre.ru/.

2.9. Personal data authorized by the subject of personal data for distribution — personal data, access to which is provided by the subject of personal data to an unlimited circle of persons by giving consent to the processing of personal data authorized by the subject of personal data for distribution in the manner prescribed by the Law on Personal Data Protection (hereinafter — personal data authorized for distribution).

2.10. User — any visitor to the website https://kryxre.ru/.

2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific circle of persons.

2.12. Dissemination of personal data — any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or at familiarizing an unlimited circle of persons with personal data, including the publication of personal data in the media, placement in information and telecommunication networks or providing access to personal data in any other way.

2.13. Cross-border transfer of personal data — transfer of personal data to the territory of a foreign state to a foreign state authority, foreign individual or foreign legal entity.

2.14. Destruction of personal data — any actions as a result of which personal data are destroyed irrevocably with the impossibility of further restoration of the content of personal data in the personal data information system and/or material carriers of personal data are destroyed.

3.Rights and obligations of the Operator

3.1. The Operator has the right to:

• receive from the subject of personal data reliable information and/or documents containing personal data;
• in the event of withdrawal by the subject of personal data of consent to the processing of personal data, as well as sending a request to terminate the processing of personal data, the Operator has the right to continue processing personal data without the consent of the subject of personal data if there are grounds specified in the Law on Personal Data Protection;
• independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations provided for by the Law on Personal Data Protection and regulatory legal acts adopted in accordance with it, unless otherwise provided by the legislation of the Republic of Moldova.

3.2. The Operator is obliged to:

• provide the subject of personal data, upon his/her request, with information regarding the processing of his/her personal data;
• organize the processing of personal data in the manner established by the current legislation of the Republic of Moldova;
• respond to appeals and requests of subjects of personal data and their legal representatives in accordance with the requirements of the Law on Personal Data Protection;
• report to the National Center for Personal Data Protection (NCPDP) at the request of this body the necessary information within the period established by the legislation of the Republic of Moldova;
• publish or otherwise provide unrestricted access to this Policy regarding the processing of personal data;
• take legal, organizational and technical measures to protect personal data from unauthorized or accidental access to them, destruction, modification, blocking, copying, provision, dissemination of personal data, as well as from other unlawful actions in relation to personal data;
• cease the transfer (dissemination, provision, access) of personal data, cease processing and destroy personal data in the manner and cases provided for by the Law on Personal Data Protection;
• fulfill other obligations provided for by the Law on Personal Data Protection.

4.Rights and obligations of subjects of personal data

4.1. Subjects of personal data have the right to:

• receive information regarding the processing of his/her personal data, except for cases provided for by the legislation of the Republic of Moldova. Information is provided to the subject of personal data by the Operator in an accessible form, and it should not contain personal data relating to other subjects of personal data, except for cases where there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Law on Personal Data Protection;
• require the operator to clarify his/her personal data, block or destroy them if the personal data are incomplete, outdated, inaccurate, illegally obtained or are not necessary for the stated purpose of processing, as well as take measures provided by law to protect their rights;
• put forward a condition of prior consent when processing personal data for the purpose of promoting goods, works and services on the market;
• withdraw consent to the processing of personal data, as well as send a request to terminate the processing of personal data;
• appeal to the National Center for Personal Data Protection or in court against unlawful actions or inaction of the Operator when processing his/her personal data;
• exercise other rights provided for by the legislation of the Republic of Moldova.

4.2. Subjects of personal data are obliged to:

• provide the Operator with reliable data about themselves;
• inform the Operator about the clarification (update, change) of their personal data.

4.3. Persons who have provided the Operator with false information about themselves or information about another subject of personal data without the consent of the latter shall be liable in accordance with the legislation of the Republic of Moldova.

5.Principles of personal data processing

5.1. The processing of personal data is carried out on a legal and fair basis.

5.2. The processing of personal data is limited to the achievement of specific, predetermined and legitimate purposes. Processing of personal data incompatible with the purposes of collecting personal data is not allowed.

5.3. It is not allowed to combine databases containing personal data processed for incompatible purposes.

5.4. Only personal data that meet the purposes of their processing are subject to processing.

5.5. The content and volume of processed personal data correspond to the stated purposes of processing. Redundancy of processed personal data in relation to the stated purposes of their processing is not allowed.

5.6. When processing personal data, the accuracy of personal data, their sufficiency, and, where necessary, relevance in relation to the purposes of processing personal data are ensured. The Operator takes the necessary measures and/or ensures their adoption to remove or clarify incomplete or inaccurate data.

5.7. Storage of personal data is carried out in a form that allows determining the subject of personal data, no longer than required by the purposes of processing personal data, if the storage period of personal data is not established by the legislation of the Republic of Moldova, an agreement to which the subject of personal data is a party, beneficiary or guarantor. Processed personal data are destroyed or depersonalized upon achievement of the processing goals or in case of loss of necessity in achieving these goals, unless otherwise provided by the legislation of the Republic of Moldova.

6.Purposes of personal data processing

6.1. Transactional emails. The Operator sends the User service letters related to the processing of a job application: confirmation of receipt of the resume, notifications about the status of the application review, invitations to interviews and similar messages. Such letters are not advertising and are sent within the framework of the provision of services requested by the User.

6.2. Marketing emails. With the separate consent of the User, the Operator may send to the specified email address information about new suitable vacancies, service updates and other advertising and informational materials (hereinafter — marketing emails).

7.Conditions of personal data processing

7.1. The processing of personal data is carried out with the consent of the subject of personal data to the processing of his/her personal data.

7.2. The processing of personal data is necessary to achieve the goals provided for by an international treaty of the Republic of Moldova or by law, to exercise the functions, powers and duties assigned to the operator by the legislation of the Republic of Moldova.

7.3. The processing of personal data is necessary for the administration of justice, execution of a judicial act, an act of another body or official subject to execution in accordance with the legislation of the Republic of Moldova on enforcement proceedings.

7.4. The processing of personal data is necessary for the performance of an agreement to which the subject of personal data is a party or beneficiary or guarantor, as well as for concluding an agreement on the initiative of the subject of personal data or an agreement under which the subject of personal data will be the beneficiary or guarantor.

7.5. The processing of personal data is necessary for the exercise of the rights and legitimate interests of the operator or third parties or for the achievement of socially significant goals, provided that the rights and freedoms of the subject of personal data are not violated.

7.6. Processing of personal data to which access is provided by the subject of personal data or at his/her request to an unlimited circle of persons is carried out (hereinafter — publicly available personal data).

7.7. Processing of personal data subject to publication or mandatory disclosure in accordance with the law is carried out.

8.Procedure for collection, storage, transfer and other types of personal data processing

The security of personal data processed by the Operator is ensured through the implementation of legal, organizational and technical measures necessary to fully comply with the requirements of the current legislation of the Republic of Moldova in the field of personal data protection.

8.1. The Operator ensures the safety of personal data and takes all possible measures to exclude access to personal data by unauthorized persons.

8.2. The User's personal data will never, under any circumstances, be transferred to third parties, except for cases related to the implementation of current legislation of the Republic of Moldova or if the subject of personal data has given consent to the Operator to transfer data to a third party to fulfill obligations under a civil law contract.

8.3. In case of inaccuracies in personal data, the User can update them independently by sending a notification to the Operator's email address admin@kryxre.ru with the note "Updating personal data".

8.4. The period for processing personal data is determined by the achievement of the purposes for which the personal data were collected, unless another period is provided for by the contract or current legislation of the Republic of Moldova. The User may at any time withdraw his/her consent to the processing of personal data by sending a notification via email to the Operator's email address admin@kryxre.ru with the note "Withdrawal of consent to the processing of personal data".

8.5. All information collected by third-party services, including payment systems, communication means and other service providers, is stored and processed by these persons (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data has the right to familiarize themselves with these documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.

8.6. The prohibitions established by the subject of personal data on the transfer (except for granting access), as well as on processing or conditions of processing (except for obtaining access) of personal data authorized for distribution, do not apply in cases of processing personal data in state, public and other public interests defined by the legislation of the Republic of Moldova.

8.7. The Operator ensures the confidentiality of personal data when processing them.

8.8. The Operator stores personal data in a form that allows determining the subject of personal data, no longer than required by the purposes of processing personal data, if the storage period is not established by the legislation of the Republic of Moldova, an agreement to which the subject of personal data is a party, beneficiary or guarantor.

8.9. The condition for terminating the processing of personal data may be the achievement of the purposes of processing personal data, the expiration of the consent of the subject of personal data, the withdrawal of consent by the subject of personal data or a request to terminate the processing of personal data, as well as the detection of unlawful processing of personal data.

9.List of actions performed by the Operator with the received personal data

9.1. The Operator carries out collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion and destruction of personal data.

9.2. The Operator carries out automated processing of personal data with or without receiving and/or transmitting the received information via information and telecommunication networks.

10.Cross-border transfer of personal data

10.1. Before starting cross-border transfer of personal data, the Operator must comply with the conditions established by the Law on Personal Data Protection, including notification of the National Center for Personal Data Protection (NCPDP) in cases provided for by the legislation of the Republic of Moldova.

10.2. Before carrying out cross-border transfer of personal data, the Operator must ensure that the foreign state, foreign state authority, foreign individual or foreign legal entity provides an adequate level of personal data protection, or obtain appropriate permissions or information in the manner established by the legislation of the Republic of Moldova.

11.Confidentiality of personal data

The Operator and other persons who have gained access to personal data are obliged not to disclose to third parties and not to distribute personal data without the consent of the subject of personal data, unless otherwise provided by law.

12.Final provisions

12.1. The User can receive any clarifications on issues of interest regarding the processing of his/her personal data by contacting the Operator via email admin@kryxre.ru.

12.2. This document will reflect any changes to the personal data processing policy by the Operator. The Policy is valid indefinitely until replaced by a new version.

12.3. The current version of the Policy is freely available on the Internet at https://kryxre.ru/privacy.html.