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Terms of Use

General provisions

The policy of Nestle Russia Ltd. in relation to the processing of personal data (hereinafter referred to as the Policy) is the fundamental local act of the company regulating the issues of processing personal data in Nestle Russia LLC.

This Policy was developed in accordance with paragraph 2 of Part 1 of Article 18.1 of the Federal Law of July 27, 2006 No. 152 On Personal Data and is intended for familiarization of an unlimited circle of persons by publishing on the website of Nestle Russia LLC.

The policy discloses the main categories of personal data processed by Nestlé Russia LLC, the objectives, methods and principles of processing personal data, the rights of personal data subjects, and a list of measures applied by Nestlé Russia LLC in order to ensure the security of personal data during their processing.

The provisions of this Policy are the basis for the development of local company acts governing the processing and protection of personal data in Nestlé Russia LLC.

This Policy applies to all processes of Nestlé Russia LLC, within which personal data is processed, both using computer technology, including using information and telecommunications networks, and without using such tools.

The following basic concepts are used in this Policy:

Confidentiality of personal data – the requirement for the operator or other persons who have access to personal data to a person is mandatory 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 federal law.

Personal data processing – any action (operation) or a set of actions (operations) performed with the use of automation tools or without the use of such tools with personal data, including the collection, recording, systematization, accumulation, storage, refinement (update, change), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.

Operator – a state body, municipal body, legal or natural person, independently or jointly with other persons organizing and (or) processing personal data, as well as determining the purposes of personal data processing, the composition of personal data to be processed, actions (operations) performed with personal data.

Personal data – any information relating directly or indirectly to a specific or designated individual (subject of personal data).

The subject of personal data is an individual who has personal data directly or indirectly determining it.

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

An employee is an individual who has entered into an employment relationship with Nestlé Russia LLC on the basis of an employment contract and on other grounds provided for by article 16 of the Labor Code of the Russian Federation.

Company / Employer – Nestle Russia Limited.

Approval and revision

This Policy takes effect from the moment of its approval by the Director General of Nestle Russia LLC and is valid indefinitely.

Nestlé Russia Ltd revises the provisions of this Policy and updates them as necessary, but at least once every three years, as well as:

– changes in the regulatory framework affecting the principles and (or) processes of processing personal data in Nestlé Russia LLC;

– when creating new or making changes to existing personal data processing processes.

Purpose of the collection and processing of personal data

In order to maintain business reputation and ensure compliance with the requirements of the Federal Law No. 152-ФЗ dated July 27, 2006 On Personal Data and Regulatory Acts adopted in accordance with it, Nestlé Russia LLC, as an operator of personal data with relevant rights and duties, ensures the legality of personal data, as well as the appropriate level of security of the personal data processed.

The processing of personal data in Nestlé Russia LLC is carried out on a lawful and fair basis and is limited to the achievement of specific, predetermined and legitimate goals. Only personal data is processed that meets the purposes of processing it. The content and volume of processed personal data correspond to the stated processing objectives, the redundancy of the processed data is not allowed.

When processing personal data of Nestle Russia Ltd., the accuracy of personal data is ensured, its sufficiency and, if necessary, relevance in relation to the purposes of personal data processing. Nestle Russia Ltd. accepts and ensures that the necessary measures are taken to delete or clarify incomplete or inaccurate personal data.

Nestlé Russia LLC, in the framework of its core business, processes the personal data of its employees; relatives of employees; applicants for vacant positions in Nestle Russia Ltd., as well as candidates in the personnel reserve; contractors of Nestle Russia LLC, as well as persons representing contractors of Nestle Russia LLC; clients and participants of advertising and other events aimed at promoting Nestle products organized and (or) conducted by Nestle Russia LLC; visitors of the Nestle Russia LLC sites; healthcare providers – recipients of information about Nestle products; visitors to the office of Nestle Russia Ltd., its structural subdivisions (including production, trade branches and other separate subdivisions of Nestle Russia LLC).

The processing of personal data of the above personal data subjects is carried out by Nestlé Russia LLC for the following purposes:

– personal data of Nestlé Russia employees, including those laid off:

○ with the aim of concluding, supporting, changing, terminating employment contracts that are the basis for the emergence or termination of employment relations between employees and the employer;

○ for the purpose of fulfillment by the employer of obligations stipulated by local regulations, labor contracts, federal legislation and other regulatory legal acts, including for the purposes of personnel and accounting, tax compilation and other reporting mandatory for the employer;

○ to assist employees in training and promotions;

○ with the aim of concluding, amending, terminating voluntary health insurance and life insurance contracts;

○ for the purpose of ensuring the personal safety of employees, controlling the quantity and quality of work performed by employees, and ensuring the safety of property.

– personal data of relatives of Nestlé Russia employees:

○ for the purpose of fulfilling the obligations of Nestle Russia LLC stipulated by federal legislation (receiving alimony, making social payments, benefits);

○ in order to ensure appropriate insurance payments upon the occurrence of an insured event as a result of an accident when such relatives are appointed by the beneficiary;

○ with the aim of concluding, amending and canceling voluntary medical insurance contracts for relatives of employees;

○ to provide visa and migration support for family members of foreign workers who are highly qualified specialists

– personal data of candidates for vacant positions in Nestle Russia LLC, as well as candidates in the Nestle Russia personnel reserve:

○ with a view to reviewing resumes and selecting candidates for the vacant position for further employment in Nestlé Russia LLC;

○ for the purpose of maintaining the personnel reserve of Nestle Russia LLC;

○ in order to obtain other information about the applicant for the vacant position in Nestlé Russia LLC.

– personal data of counterparties of Nestle Russia LLC, as well as persons representing contractors of Nestle Russia LLC:

○ for the purpose of concluding, amending, canceling contracts, and fulfilling obligations under concluded contracts;

○ for the purpose of compliance and (or) execution of procedures and actions stipulated by local regulatory acts and (or) legislation of the Russian Federation, including for the purposes of accounting, tax reporting.

– personal data of customers, visitors of the Nestle Russia LLC websites, participants of advertising and other events aimed at promoting Nestle products organized and (or) conducted by Nestle Russia LLC:

○ to collect information about consumers of Nestle products, consumer opinions about Nestle products, in particular, about their quality;

○ to disseminate information about Nestle products;

○ for the purpose of informing participants about Nestle products, as well as about events held and (or) organized by Nestle Russia LLC;

○ for the purpose of customer service, order fulfillment, providing answers to customer requests.

– personal data of health professionals – recipients of information on Nestle products in order to timely inform health professionals about the indicators of quality, efficacy and safety, as well as to provide other information about Nestle products;

– personal data of visitors in order to allow visitors to enter the territory of the office of Nestle Russia LLC, its structural divisions (including production, trade branches and other separate divisions of Nestle Russia LLC).

Legal grounds for the processing of personal data

The bases for the processing of personal data of personal data subjects in Nestlé Russia LLC are as follows:

– processing of personal data of employees is carried out with the written consent of the employee to the processing of his personal data, the employment contract to which the employee is a party, as well as on the basis of labor, social and pension legislation;

– processing of personal data of dismissed workers is carried out in accordance with subclause 5 p. 3 Art. 24 of the Tax Code of the Russian Federation and Article 17 of the Federal Law of 21.11.1996 No. 129-ФЗ On Accounting, Article 62 of the Labor Code of the Russian Federation, as well as in accordance with clause 3. Article 3 FZ of 10.22.2004 N 125-FZ On Archival Affairs in the Russian Federation;

– processing of personal data of employees’ relatives is provided for by the Labor and Tax Code of the Russian Federation (receipt of alimony, social benefits), unified form No. T-2, approved by the State Statistics Committee of the Russian Federation of January 5, 2004 No. 1 On the approval of unified forms of primary accounting documentation for labor accounting and of its payment, Federal Law No. 115-FZ of July 25, 2002, On the Legal Status of Foreign Citizens in the Russian Federation and the written consent of the employee’s relative (registration of Hur voluntary medical insurance);

– processing of personal data of applicants for vacant positions in Nestle Russia LLC is carried out on the initiative of the applicant to conclude an agreement with Nestle Russia LLC and the written consent of the applicant to the processing of his personal data, signed during the on-site interview in Nestle Russia LLC;

– the processing of personal data of applicants in the personnel reserve of Nestle Russia Ltd. is carried out on the basis of the written consent of the applicant in the personnel reserve;

– the processing of personal data of counterparties, persons representing counterparties of Nestle Russia LLC, is carried out on the basis of contracts between contractors and Nestle Russia LLC;

– processing of personal data of customers, visitors of Nestlé Russia LLC websites, participants of advertising and other events aimed at promoting Nestle products organized and (or) conducted by Nestlé Russia LLC with the consent of the client / visitor / participant given during registration on the Nestlé Russia LLC websites, with the written consent of the participant when filling out registration forms in stores;

– the processing of personal data of health professionals – recipients of information on Nestle products – is done with the consent of medical professionals.

Volume and categories of personal data processed

Nestle Russia Ltd. processes the following categories of personal data:

– personal data of employees: last name, first name, patronymic, contact details, information about an identity document, date of birth, gender, place of birth, photo, address information, education details, information on foreign language proficiency, information on professional experience, information on employment history, information on the admission / dismissal / personnel transfer, information on the nature of the work, information about the position, information about the qualification category, information about salary, information about income, information about rewards and deductions, information about working hours, information about travel, information about vacations, information about temporary disability, information about a bank account and / or payment card, information about payments to the FTS of Russia and the FSS of Russia, to pension funds, information about pension insurance, including TIN and SNILS data, information on social benefits, information on citizenship, information on taxpayer status, information on migration card and work permit, information on address, information on marital status, information on family composition, information on military d duties, information about the driver’s license, information about real estate owned, names of organizations, the head or founder of which is the subject, information from the FSSP;

– personal data of applicants for a vacant position: surname, name, patronymic; Date and place of birth; contact details (email address, mobile phone number); information about the address of registration / address of actual residence / place of stay; information about the identity document (name of the document, series and number, when and by whom issued); information on citizenship; information on marital status, family and close relatives (including former); information about education (level of education, name of the educational institution and faculty, period of study, form of study, specialty, qualification, details of the document on education, information about additional education, certification); information on work experience and work experience (places of work, positions held, period of work, length of service, grounds for admission and dismissal); information about the qualification category (grade / class (qualification)); information on foreign language proficiency, degree of proficiency; Photo of the Candidate; information about the conflict of interest, information about income; the results obtained using the ability tests and questionnaires of Nestle Russia; the name of the organizations whose founder is the Candidate; personal questionnaire data;

– personal data of relatives of employees: last name, first name, patronymic, date of birth, degree of kinship, information about an identity document, contact details;

– personal data of customers, visitors of Nestle Russia LLC sites, participants of advertising and other events aimed at promoting Nestle products organized and (or) conducted by Nestle Russia LLC (last name, first name, patronymic, address of registration, address of actual residence, information about the document certifying identity (name of the document, series and number), contact details (email address, telephone number), TIN, age);

– personal data of counterparties of Nestlé Russia LLC, as well as persons representing counterparties of Nestlé Russia LLC: last name, first name, patronymic, contact details, information about the place of work, position information, information on the identity document.

Nestle Russia Ltd. processes biometric personal data (photo) of employees solely for the purpose of organizing a check mode.

Nestle Russia Ltd. collects data from visitors to the office: last name and initials, solely for the purpose of organizing the check mode.

Nestle Russia Ltd. processes cookies. Nestle Russia Ltd. receives information in the form of registration files that log the actions on the site and collect statistical data on the preferences of site visitors. By accessing the site, the user agrees to the processing of cookies by Nestle Russia LLC.

Nestlé Russia LLC does not process personal data relating to race, nationality, political views, religious or philosophical beliefs, and intimate life.

The processing of personal data relating to the state of health is carried out in the event that consent is obtained from the subject of personal data to the processing of such data, or in other cases expressly provided for by the current legislation of the Russian Federation.

The procedure and conditions for the processing of personal data

Nestlé Russia, when collecting personal data, provides for the recording, systematization, accumulation, storage, refinement (updating, modification) and extraction of personal data using databases located in the territory of the Russian Federation.

Nestlé Russia Ltd in the course of its activities entrusts the processing of personal data to third parties with the consent of the subjects of personal data, unless otherwise provided by the current legislation of the Russian Federation, provided that the person processing the personal data on behalf of Nestlé Russia has complied with the principles and rules for processing and securing security of personal data established by the legislation of the Russian Federation.

In the order for the processing of personal data, it is mandatory to determine:

– a list of actions with personal data that will be performed by a person who processes personal data, and the list of actions must not contradict the goals and actions stated to the personal data subject in the agreement with the operator, consent, etc. documents;

– the purposes of processing, while the goals should not contradict the goals stated before the subject of personal data in the contract with the operator, consent, etc. documents;

– the obligation of such a person to respect the confidentiality of personal data and to ensure the security of personal data during their processing;

– The requirements for the protection of personal data (the requirements for protection imposed on the person performing the processing should not be higher than the requirements fulfilled by the operator himself).

Nestle Russia Ltd. does not place personal data of the subject of personal data in publicly available sources without its prior consent.

Nestle Russia LLC in the course of its activities carries out cross-border transfer of personal data to legal entities in the territory of foreign countries. At the same time, issues of ensuring adequate protection of the rights of subjects of personal data and ensuring the security of their personal data during a cross-border transfer are a priority for Nestlé Russia LLC, the solution of which is implemented in accordance with the legislation of the Russian Federation in the field of personal data protection.

Cross-border transfer of personal data to the territory of foreign states that do not provide adequate protection of the rights of personal data subjects is carried out only in cases of the written consent of the personal data subject to the cross-border transfer of his personal data; performance of the contract to which the subject of personal data is a party; as well as other cases stipulated by law. In order to ensure adequate protection of personal data, Nestle Russia LLC conducts an assessment of the harm that can be caused to personal data subjects in the event of a breach of the security of their personal data, and also determines actual threats to the security of personal data during their processing in personal data information systems.

In order to ensure the security of personal data when it is processed, Nestlé Russia takes necessary and sufficient legal, organizational and technical measures to protect personal data from unauthorized or accidental access to it, destruction, modification, blocking, copying, submitting, disseminating personal data, and from other illegal actions in relation to personal data.

Nestlé Russia LLC strives to ensure that all measures implemented for the organizational and technical protection of personal data are carried out on a legal basis, including in accordance with the requirements of the legislation of the Russian Federation on personal data processing.

The management of Nestlé Russia LLC is aware of the importance and the need to ensure the security of personal data and encourages the continuous improvement of the personal data protection system processed in the framework of the core business of the company.

Nestlé Russia LLC has appointed persons responsible for organizing the processing and ensuring the security of personal data.

Each new employee of Nestlé Russia LLC, directly processing personal data, is subject to familiarization with the requirements of the legislation of the Russian Federation on processing and ensuring the security of personal data, with this Policy and other local company acts regarding the processing and implementation of personal data protection requirements and is responsible for their compliance.

The storage of personal data is carried out by the company Nestle Russia in the form allowing to determine the subject of personal data no longer than the purpose of processing personal data, unless the period for storing personal data is established by federal law, contract, of which the subject is beneficiary or guarantor personal data. The personal data to be processed shall be destroyed or depersonalized upon the achievement of processing objectives or in the event of the loss of the need to achieve these objectives, unless otherwise provided by federal law.

Processing requests for personal data subjects

In order to ensure compliance with the rights of personal data subjects established by the legislation, Nestlé Russia LLC has developed and introduced a procedure for handling requests and requests of personal data subjects, as well as the procedure for providing personal data subjects with information established by the legislation of the Russian Federation in the field of personal data.

This procedure ensures compliance with the following rights of the subject of personal data:

– the right to receive information concerning the processing of personal data of the relevant subject of personal data, including containing:

○ confirmation of the processing of personal data;

○ legal grounds and purposes for the processing of personal data;

○ the purposes and methods of personal data processing applied by Nestle Russia LLC;

○ name and location of Nestlé Russia Ltd., information about persons (except for employees of Nestlé Russia LLC) who have access to personal data or who may disclose personal data on the basis of an agreement with Nestlé Russia LLC or on the basis of other requirements of the Federal Law of the Russian Federation on July 27, 2006 No. 152-ФЗ On Personal Data;

○ the processed personal data related to the relevant subject of personal data, the source of their receipt, unless a different procedure for submitting such personal data is provided for by the Federal Law of the Russian Federation No. 152-ФЗ dated July 27, 2006 on personal data;

○ terms for processing personal data, including terms of their storage;

○ the procedure for the subject of personal data to exercise the rights provided for by the Federal Law of the Russian Federation of July 27, 2006 No. 15-FZ On Personal Data;

○ information on ongoing or alleged cross-border transfer of personal data;

○ name or surname, name, patronymic and address of the person who processes personal data on behalf of Nestlé Russia LLC, if the processing is entrusted to or will be entrusted to such person;

○ other information provided for by the Federal Law of the Russian Federation No. 152-ФЗ dated July 27, 2006 On Personal Data or other requirements of the legislation in the field of personal data;

– the right to clarify, block or destroy their personal data if personal data is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing, as well as take measures to protect their rights provided for by the legislation of the Russian Federation in the field of personal data.

The request of the subject of personal data must contain the number of the main document certifying the identity of the subject of personal data or his legal representative, information on the date of issue of the specified document and the issuing authority, information confirming the participation of the subject of personal data in relations with Nestlé Russia (contract number, date of contracts, conditional verbal designation and (or) other information), or information that otherwise confirms the fact of processing personal data of Nestlé Russia LLC, the signature subject and personal data or his representative, the date of treatment.

Employees of Nestle Russia Ltd. do not have the right to answer questions related to the transmission or disclosure of personal data by phone or fax due to the fact that in this case it is not possible to identify the identity of the appealing person.

Inquiries of subjects should be sent by mail to the following address: Nestlé LLC Russia, 115054, Moscow, Paveletskaya Sq. 2, bld. 1.

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