Personal Data Processing Policy

This is an English translation provided for convenience. In case of any discrepancy, the Russian version shall prevail.

This Personal Data Processing Policy (the “Policy”) has been developed in accordance with Federal Law No. 152-FZ “On Personal Data” of 27.07.2006 (the “Law”) and sets out the procedure for processing personal data and the measures taken to ensure its security at Versus LLC (the “Operator”).

1. Personal data operator

Operator: Versus LLC (OOO «Versus»).
TIN (INN): 7838444600, OGRN: 1107847183652, KPP: 783901001.
Address: 83‑85 Rimskogo‑Korsakova Ave., apt. 9, Saint Petersburg, 190121, Russia.
Email:a@versus-ltd.org.
Phone: +7 (921) 339‑28‑54.
Registered in the Register of Personal Data Operators under registration number 78‑22‑038303 of 07.09.2022 (basis for inclusion: Roskomnadzor Order No. 448 of 29.09.2022).

2. Key terms

The terms used in this Policy have the meanings set out in the Law. In particular:

  • personal data — any information relating directly or indirectly to an identified or identifiable individual (the data subject);
  • processing of personal data — any action or set of actions performed with personal data, including collection, recording, systematization, accumulation, storage, clarification, retrieval, use, transfer, depersonalization, blocking, deletion and destruction;
  • operator — a person who organizes and (or) carries out the processing of personal data and determines the purposes of processing;
  • data subject — the individual to whom the processed personal data relate.

3. Purposes of processing

The Operator processes personal data for the following purposes:

  • handling enquiries and requests from visitors of the website versus‑ltd.org;
  • concluding, performing and terminating service agreements;
  • informing customers about the progress of work and the Operator’s services;
  • accounting, tax and HR record keeping;
  • fulfilling obligations imposed on the Operator by the legislation of the Russian Federation.

4. Legal grounds for processing

The Operator processes personal data on the following legal grounds:

  • the data subject’s consent to the processing of their personal data (given when filling in the contact form on the website versus‑ltd.org);
  • the need to conclude and (or) perform an agreement to which the data subject is a party, beneficiary or guarantor (clause 5, part 1, article 6 of the Law);
  • the need to perform the functions, powers and obligations imposed on the Operator by the legislation of the Russian Federation (clause 2, part 1, article 6 of the Law);
  • other grounds provided for by article 6 of the Law.

5. Categories of data subjects and data processed

The Operator processes personal data of the following categories of data subjects:

  • website visitors who submitted a request through the contact form. Data processed: last name and (or) first name; contact phone number; email address (if provided); content of the request (project description).
  • customers and representatives of customers (counterparties). Data processed: full name; position; contact details; details of an identity document (to the extent necessary to prepare documents); other data required to conclude and perform an agreement.
  • employees of the Operator and job applicants. The data processed are determined by the labor legislation of the Russian Federation.

The Operator does not process special categories of personal data (racial or ethnic origin, political opinions, religious or philosophical beliefs, health, intimate life) or biometric personal data, except where expressly provided for by law.

6. Procedure and conditions of processing

Personal data may be processed both with and without the use of automation tools.

The Operator does not transfer personal data across borders.

The Operator does not make decisions that produce legal consequences for the data subject or otherwise affect their rights and legitimate interests based solely on automated processing of personal data.

7. Transfer of personal data to third parties

The Operator does not transfer personal data to third parties, except as expressly provided for by the legislation of the Russian Federation and where such transfer is necessary to perform an agreement with the data subject (in particular, when engaging subcontractors with whom confidentiality agreements are concluded).

8. Processing and retention periods

Personal data are processed until the purposes of processing are achieved, the data subject withdraws consent, or the periods established by law expire. After these periods expire, personal data are destroyed or depersonalized.

9. Security measures

The Operator takes the necessary legal, organizational and technical measures to protect personal data against unlawful or accidental access, destruction, modification, blocking, copying, provision, dissemination and other unlawful actions, including:

  • appointing a person responsible for organizing the processing of personal data;
  • familiarizing the Operator’s employees directly involved in processing with the provisions of the legislation and this Policy;
  • using information security tools and restricting access to personal data;
  • keeping records of machine-readable media containing personal data;
  • detecting and responding to incidents involving unauthorized access to personal data.

10. Rights of the data subject

The data subject has the right to:

  • receive information about the processing of their personal data;
  • demand that their personal data be clarified, blocked or destroyed if the data are incomplete, outdated, inaccurate, unlawfully obtained or not necessary for the stated purpose of processing;
  • withdraw consent to the processing of personal data;
  • appeal against the actions or inaction of the Operator to the authorized body for the protection of the rights of data subjects (Roskomnadzor) or in court.

To exercise these rights, the data subject may send a request toa@versus-ltd.org or in writing to: 83‑85 Rimskogo‑Korsakova Ave., apt. 9, Saint Petersburg, 190121, Russia. The request must contain information that allows the data subject to be identified and the substance of the request.

11. Final provisions

This Policy is subject to change if the legislation of the Russian Federation on personal data changes, and in other cases by decision of the Operator. The current version of this Policy is published on the Operator’s official website versus‑ltd.org.