Privacy Policy LSR Group


1. Definitions and abbreviations used in the Policy

1.1. The headings to the sections and subsections of the Policy (hereinafter the Policy) are used solely for convenience and references to them and will not be used to interpret any paragraph of this document.

1.2. The following terms and definitions used in the Policy have the following meaning:

2. General Provisions

2.1. The Policy is mandatory for the application and execution of a local regulatory act, a fundamental document containing the general goals, principles and norms of the Operator in the processing of PD.

2.2. The Policy was developed in accordance with Article 18.1 of Law No. 152-FZ in order to implement the requirements of the legislation of the Russian Federation in the field of PD processing and protection and is aimed at ensuring the protection of human and civil rights and freedoms when processing the PD by the Operator, including the protection of the rights to privacy, personal and family secrets.

2.3. The relations related to the processing and protection of PD provided by the PD subject are regulated by the Policy, local regulations of the Operator and the legislation of the Russian Federation.

2.4. The legal grounds for processing PD are the following:

2.5. The Policy applies to relations related to the processing of PD received by the Operator both before and after its approval, except in cases where, for legal, organizational and other reasons, the provisions of the Policy cannot be extended to relations for the processing and protection of PD received before its approval.

3. Purposes of PD processing, categories of PD subjects, list and categories of PD being processed

3.1. PD is processed by the Operator for purposes that do not contradict the legislation of the Russian Federation and in their legitimate interests, if such processing does not violate the rights of PD subjects.

3.2. PD processing that is redundant in relation to the stated purpose of its processing is not allowed.

3.3. Purposes of PD processing:

3.4. Operator processes the PD of the following PD subjects:

3.5. The PD of visitors of the Operator's website, users of the Operator's mobile application, customers, employees and applicants of the Operator, their relatives includes information provided by the subjects of PD, including during the registration of a personal account on the Operator's website or in the Operator's mobile application.

3.6. Operator processes the following PD received from visitors of the Operator's website or users of the Operator's mobile application:

3.7. The following information applies to the PD of the Operator's users and potential users:

3.8. The PD of individuals who are representatives or participants of contractors and potential contractors of the Operator includes the following information:

3.9. Processing PD of employees and the Applicants:

3.9.1. The PD of employees and applicants includes documented information obtained from the official documents of the Applicants, presented to them for the purpose of employment and when applying for a job, as well as from documents received from the employee in the course of his employment.

3.9.2. When concluding an employment contract, a person applying for employment with the Operator shall present documents in accordance with Article 65 of the Labour Code of the Russian Federation and consent to the processing of his/her PD.

3.9.3. The following information shall be included in the employee's or applicant's PD:

3.10. The list of processed PD of the Operator's participants is determined by the legislation of the Russian Federation.

3.11. Special categories of PD, as well as biometric PD of PD subjects, are processed by the Operator in accordance with the procedure established by the legislation of the Russian Federation.

4. Conditions for processing PD and its transfer to third parties

4.1. The PD of the PD subject is processed within the period necessary for the purposes specified in the Policy in any legal way, including in the IP of the PD, using automation aids or without the use of such aids.

4.2. In cases provided for by Law No. 152-FZ, it is allowed for the Operator to distribute PD (disclosure of PD to any number of unspecified persons).

4.3. The content and volume of processed PD are determined by the purposes of their processing, given in section 3 of the Policy, and are indicated in the consent of the PD subject to the processing of its PD, except in cases where PD processing can be carried out without obtaining such consent.

4.4. By submitting their PD to the Operator, the PD subjects confirm familiarization with the Policy and agrees that the Operator has the right to process PD, namely: collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (provision, access), depersonalization, blocking, deletion, destruction of PD, including the right to transfer these PD to third parties, in particular, subsidiaries of the LSR Group, contractors servicing the Operator's website or mobile application of the Operator, credit organizations, other legal entities and individuals, providing marketing and other services to the Operator, including for the purpose of conducting excursions and other events.

4.5. PD may be transferred by the Operator to authorized state authorities only on the grounds and in accordance with the procedure established by the legislation of the Russian Federation.

4.5.1. The Operator has the right to transfer PD to third parties in the following cases:

4.6. By completing and submitting to the Operator the form (feedback / questionnaire, when creating a personal account; hereinafter referred to as the form), in which the PD are entered on the Operator's website or in the Operator's mobile application, the data subject confirms that he/she:

4.6.1. The Operator does not verify the reliability of the received (collected) information about the PD subject, except for cases when such verification is necessary for the purpose of fulfillment of obligations to the PD subject.

4.7. When processing PD, the Operator shall be guided by the legislation of the Russian Federation, the Policy and local regulatory acts of the Operator.

4.8. When processing PD, the Operator uses databases located on the territory of the Russian Federation.

4.9. The Operator does not carry out cross-border transfer of PD.

5. Feedback

5.1. Operator's contact details for contacting PD subjects on issues related to Personal Data:

5.2. By contacting the contact details specified in clause 5.1 of the Policy, the subject of the PD processed by the Operator may receive information related to the processing of his/her PD, including information containing:

5.3. The Data Subject has the right to receive information regarding the processing of his/her PD, unless this right is restricted in accordance with federal laws. The data subject has the right to demand that the Operator clarify his/her PD, block or destroy it if it is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing, as well as to take measures provided for by law to protect his/her rights.

5.3.1. The Operator assumes that the PD subject agrees that, upon his written request, notification of the destruction of PD will be sent/delivered to his e-mail addresses or place of residence specified in the consent to PD processing, or to his representative personally or at the address of the place of residence.

5.3.2. The PD subject's request for information, withdrawal of consent to PD processing, a request to stop processing or transferring PD, or an appeal for the destruction of PD (hereinafter referred to as the Request) contains:

5.3.3. The request to terminate the transfer of PD also contains contact information (phone number, e-mail address or postal address) of the PD subject, as well as a list of PD whose processing is subject to termination. Requests may be sent in the form of a corresponding notification by e-mail from the e-mail address provided by the PD subject to the Operator's e-mail address ( ) or in the form of a written document by sending to the Operator by registered mail with a notification of delivery with an inventory of the attachment to the address: 36 Kazanskaya Street, letter B, floor 4, room 32-N (18), room 404, Saint Petersburg, the Russian Federation, 190031.

5.4. The Information is provided by the Operator to the PD subject or his representative within 10 (ten) business days from the date of the Request or receipt by the Operator of the Request. The specified period may be extended, but not more than 5 (five) business days if the Operator sends a reasoned notification to the PD subject indicating the reasons for extending the period for providing the requested information.

5.5. If the information concerning the PD processing of the PD subject, as well as the PD being processed, were provided to the PD subject for review upon his request, the PD subject has the right to contact the Operator again or send a repeated request for PD receipt no earlier than 30 (thirty) days after the initial request or sending the initial request.

5.6. If the PD subject withdraws consent to PD processing, the Operator has the right to continue PD processing without the PD subject's consent if there are grounds provided for by the legislation of the Russian Federation.

6. Safety of PD processing

6.1. The main task of ensuring the safety of PD during their processing by the Operator is to prevent unauthorized access to them by third parties, to prevent deliberate software, technical and other influences in order to steal PD, destroy or distort them during processing.

6.2. The Operator takes necessary and sufficient technical and organizational measures to ensure information security and protect PD from unauthorized or accidental access, destruction, modification, blocking, copying, distribution, as well as from other illegal actions with them by third parties.

6.3. The Operator does not process PD that is incompatible with the purposes of their collection. Unless otherwise provided by federal law, upon completion of PD processing by the Operator, including upon achievement of the goals of their processing or loss of the need to achieve these goals, the PD processed by the Operator will be destroyed or depersonalized.

6.4. When processing PD, their accuracy, sufficiency, and, if necessary, relevance in relation to the purposes of processing are ensured. The Operator takes the necessary measures to remove or clarify incomplete or inaccurate PD.

7. Miscellaneous

7.1. The Operator has the right to make changes to the Policy. The changes take effect from the moment specified in the new version of the Policy.

7.2. The Policy is a publicly available document and is subject to placement in places accessible to PD subjects.