1. GENERAL TERMS

1.1. This Personal Data Processing Policy (hereinafter – the "Policy") is accepted by "MORSKAYA PRAKTIKA" LLC with a view to ensuring the implementation of the requirements of the applicable laws of the Russian Federation.

Terms and definitions

1.2. "MORSKAYA PRAKTIKA" means "MORSKAYA PRAKTIKA" LLC,

Legal address: office VII, domain No.8, Pokryshkin Str., 119602 Moscow, INN 7729447745, KPP 772901001, registered under the applicable laws of the Russian Federation and processing the personal data of the personal data subjects.

The term "personal data subject" means any individual identified by their personal data.

The term "personal data" means any information that relates directly or indirectly to a particular person.

The term "personal data processing" means any actions performed by MORSKAYA PRAKTIKA with any personal data including their collection, recording, systematization, accumulation, storage, clarification (updating, amendments), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion or destruction with or without the automation facilities.

The term "automated processing of the personal data" means processing of the personal data by means of any computer equipment (computers).

The term "personal data information system" means the database of MORSKAYA PRAKTIKA that contains the personal data, as well as any information technologies and technical means that allow processing of the personal data with or without any automation facilities.

The term "personal data protection" means the cumulative organizational and technical actions on the part of MORSKAYA PRAKTIKA aimed at the personal data protection.

The term "personal data blocking" means any temporary termination of the personal data processing (except where the processing is necessary to update the personal data).

The term "personal data depersonalization" means any actions that make it impossible to determine the reference of any particular personal data to any particular personal data subject without the use of any additional information.

The term "personal data provision" means any actions aimed at disclosure of the personal data to a certain person or a certain group of persons.

The term "personal data distribution" means any actions aimed at disclosure of the personal data to the general public.

The term "personal data confidentiality" means a mandatory requirement for MORSKAYA PRAKTIKA or any other person having access to the personal data not to disclose such personal data to any third parties, or not to distribute such personal data without the consent of the personal data subject or under any other legal grounds.

The term "personal data storage" means the direct availability of the personal data in the personal data information system of MORSKAYA PRAKTIKA.

The term "personal data destruction" means any actions resulting in impossibility to restore the content of the personal data in the personal data information system and (or) resulting in destruction of any material media bearing the personal data.

2.1. Principles of the personal data processing

• the personal data processing is to be carried out on a legal and fair basis;
• it is prohibited to process the personal data if it defeats the purposes of collection (acquisition) of the personal data;
• the personal data processing is to be limited to the achievement of certain lawful purposes;
• the personal data processing is to be allowed only with the consent of the personal data subject;
• it is allowed to process the personal data that meet the purposes of their processing specified in Para. 2.2. of this Section;
• it is not allowed to process the personal data that don't meet the purposes of their processing;
• the storage of the personal data is to be made in any form that allows identifying the personal data subject within the term corresponding to the purposes of the personal data processing, unless such a term is established by the federal law or any agreement under which the personal data subject is a party, beneficiary or guarantor.

2.2. Purposes of the personal data processing

• compliance with the provisions of the applicable laws of the Russian Federation;
• due and accurate keeping of the personnel records of the employees of MORSKAYA PRAKTIKA, salary accounting thereto, maintenance of the health insurance and payment for services of any persons in accordance with the civil contracts executed therewith;
• provision of any services and execution of any contracts and agreements concluded by MORSKAYA PRAKTIKA with any individuals;
• any other purposes for which MORSKAYA PRAKTIKA requires to process the personal data under the applicable laws of the Russian Federation.

3.1. The personal data subjects include the persons as follows:

3.1.1. in the field of employment relationship:

• employees of MORSKAYA PRAKTIKA working therein under the employment agreements;
• candidates to any vacant positions in MORSKAYA PRAKTIKA.

3.1.2. in the field of civil relationship:

• any legally capable individuals having the civil contracts with MORSKAYA PRAKTIKA;
• any legally capable individuals who are going to enter into or have already entered into any contracts with MORSKAYA PRAKTIKA and who act as a party, beneficiary or guarantor under such contracts.

3.1.3. in any other (neighboring) fields:

• any visitors of the office of MORSKAYA PRAKTIKA;
• any representatives (employees) of the counterparties of MORSKAYA PRAKTIKA;
• any other persons whose personal data processing may be required by MORSKAYA PRAKTIKA in accordance with the requirements of the applicable laws of the Russian Federation.

4.1. The personal data subject is entitled to receive any information that relates to the processing of their personal data in accordance with the applicable laws.

4.2. In order to exercise their rights and legal interests, the personal data subject is entitled to apply to MORSKAYA PRAKTIKA for provision of any information related to the processing and protection of the personal data. MORSKAYA PRAKTIKA examines the applications of the personal data subjects, gives explanations and takes measures to protect the personal data. If there are any claims or complaints from the personal data subjects, MORSKAYA PRAKTIKA shall takes all the necessary measures to remedy any possible breaches, identify the perpetrators and try to resolve any disputes under a pre-action protocol.

4.3. The right of the personal data subject to access to their personal data may be restricted in cases established by the applicable laws of the Russian Federation.

4.4. Other rights defined by the Federal Law "Concerning personal data".

5. CATEGORIES OF PERSONAL DATA TO BE PROCESSED AND SOURCES OF THEIR RECEIPT

5.1. MORSKAYA PRAKTIKA processes the following categories of the personal data in the personal data information system:

5.1.1. In accordance with Para. 3.1.1. of Section 3 of this Policy:

For employees of MORSKAYA PRAKTIKA

• surname, name, patronymic;
• passport details;
• date and place of birth;
• registration address;
• marital status;
• education;
• occupation;
• INN;
• bank details;
• data of the pension insurance certificate;
• data of the medical insurance policies;
• data on children and marriage or divorce;
• data on military registration;
• place of employment;
• capacity;
• employment history (employment record book);
• phone.

For relatives of the employees of MORSKAYA PRAKTIKA

• surname, name, patronymic;
• date of birth;
• degree of relationship.

5.1.2. In accordance with Para. 3.1.2. of Section 3 of this Policy:For individuals having the civil contracts with MORSKAYA PRAKTIKA

• surname, name, patronymic;
• passport details;
• date and place of birth;
• registration address;
• INN;
• data of the pension insurance certificate;
• bank details;
• e-mail;
• contact telephone;
• any other information that may relate to these individuals.

5.1.3. In accordance with Para. 3.1.3. of Section 3 of this Policy:

• surname, name, patronymic;
• passport details;
• phone;
• any other information that may relate to these individuals.

5.1.4. The personal data sources include as follows:
For employment relationship and personnel records of the employees of MORSKAYA PRAKTIKA, as well as for any individuals having the civil contracts with MORSKAYA PRAKTIKA and for any other persons whose personal data should be processed by MORSKAYA PRAKTIKA

• any documents and information provided personally by the employees and individuals having the civil contracts.

For any individuals who are going to enter into or have already entered into any contracts with MORSKAYA PRAKTIKA and who act as a party, beneficiary or guarantor under such contracts;

any information provided personally by such individuals during registration and creation of their accounts while using the software or website of MORSKAYA PRAKTIKA and filling in the relevant electronic forms. The required information is specifically marked. Any other information is provided by the individuals at their own discretion.

6. PRIVACY

6.1. All the information being the personal data that has become known to MORSKAYA PRAKTIKA due to the processing thereof shall be confidential and shall be protected by the applicable laws of the Russian Federation. MORSKAYA PRAKTIKA shall take all the necessary measures to protect such information.

6.2. The employees of MORSKAYA PRAKTIKA and any other persons who have gained access to the processed personal data should sign a Confidential Disclosure Agreement and be aware of possible disciplinary, administrative, civil or criminal liability in case of their violation of the provisions of the applicable laws of the Russian Federation related to the personal data processing and protection.

7. MEASURES TO ENSURE THE SAFETY OF PERSONAL DATA DURING THEIR PROCESSING

7.1. While processing the personal data, MORSKAYA PRAKTIKA takes all the necessary legal, organizational and technical measures to protect such data from any unauthorized or accidental access thereto, from any destruction, amendment, blocking, copying, provision or distribution thereof, as well as from any other illegal actions with regard thereto.

7.2. The key measures aimed at the personal data protection which are implemented by MORSKAYA PRAKTIKA:

• appointment of the employees of MORSKAYA PRAKTIKA responsible for the personal data processing;
• internal control (audit) of compliance of the personal data processing with the requirements of the Federal Law No 152-FZ of 27.07.2006 "Concerning personal data" and any other regulatory legal acts governing the same;
• introduction of the provisions of the applicable laws of the Russian Federation related to the personal data, including the requirements to the personal data processing and protection, local regulations, as well as this Policy to the employees of MORSKAYA PRAKTIKA directly engaged in the personal data processing;
• implementation of organizational and technical measures aimed at ensuring the safety of the personal data during their processing in the personal data information systems necessary to comply with the requirements to the personal data processing and protection;
• control of any physical personal data storage media (computers);
• establishment of the facts of any unauthorized access to the personal data and taking all the necessary measures;
• recovery of the personal data amended or destroyed due to any unauthorized access thereto;
• establishment of the rules to access the personal data processed in the personal data information system, as well as registration and control of all the actions performed with the personal data in the personal data information system;
• control of the measures taken to ensure the personal data safety.

8.1. MORSKAYA PRAKTIKA is entitled to make any amendments into this Policy. The new edition of this Policy comes into force from the moment of its signing by the official of MORSKAYA PRAKTIKA and the official publication of the electronic version thereof on the website of MORSKAYA PRAKTIKA at the Internet address as follows: https://sea-practice.ru/

8.2. The persons responsible for ensuring the personal data safety shall control the implementation of the Policy requirements.