The company's policy regarding the processing of personal data

1 GENERAL PROVISIONS

Policy of personal data processing (hereinafter – the Policy) was developed in accordance with the Federal law of 27.07.2006. №152-FZ "On personal data" (hereinafter – FZ-152).

This Policy defines the procedure for processing personal data and measures to ensure the security of personal data "Costabonita Prestige S. L."" (hereinafter – the Operator) to protect the rights and freedoms of man and citizen when processing his personal data, including protection of rights to privacy, personal and family secrets.

The following basic concepts are used in the Policy:

automated processing of personal data – processing of personal data using computer technology; blocking of personal data-temporary termination of processing of personal data (except in cases where processing is necessary to clarify personal data); personal data information system - a set of personal data contained in databases, and information technologies and technical means that ensure their processing; depersonalization of personal data - actions, as a result of which it is impossible to determine, without the use of additional information, the identity of personal data to a specific subject of personal data;processing of personal data - any action (operation) or a set of actions (operations) performed with or without the use of automation tools with personal data, including the collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data; the operator - state body, municipal body, legal entity or individual, independently or jointly with other persons, organizing and (or) performing 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; personal data – any information related directly or indirectly to a specific or identifiable individual (subject of personal data); provision of personal data – actions aimed at disclosing personal data to a certain person or a certain circle of persons; dissemination of personal data - actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or at familiarizing an unlimited number of persons with personal data, including the publication of personal data in the mass media, placement in information and telecommunications networks or providing access to personal data in any other way;destruction of personal data - actions that make it impossible to restore the content of personal data in the personal data information system and / or destroy the material storage media of personal data;The Company is obliged to publish or otherwise provide unrestricted access to this Personal Data Processing Policy in accordance with Part 2 of Article 18.1. of Federal Law 152.

2PRINCIPES AND CONDITIONS FOR PROCESSING PERSONAL DATA

2.1 Principles

of personal data processing The Operator's personal data is processed on the basis of the following principles:

restrictions on the processing of personal data to achieve specific, pre-defined and legitimate goals; preventing the processing of personal data that is incompatible with the purposes of collecting personal data;preventing the integration of databases containing personal data that are processed for purposes that are incompatible with each other;processing only those personal data that meet the purposes of their processing;compliance of the content and scope of the processed personal data with the stated purposes of processing;preventing the processing of personal data, excessive in relation to the stated purposes of their processing;ensuring the accuracy, sufficiency and relevance of personal data in relation to the purposes of personal data processing;destruction or depersonalization of personal data upon achievement of the purposes of their processing or in case of loss of the need to achieve these goals, if it is impossible for the Operator to eliminate the violations of personal data, unless otherwise provided by federal law.2.2 Terms of personal data processing

The operator processes personal data in the presence of at least one of the following conditions:

the processing of personal data is carried out with the consent of the personal data subject to the processing of his personal data;the processing of personal data is necessary to achieve the goals provided for by an international treaty of the Russian Federation or by law, to perform and fulfill the functions, powers and duties assigned to the operator by the legislation of the Russian Federation;the processing of personal data is necessary for the administration of justice, the execution of a judicial act, an act of another body or official, processing of personal data is necessary for the performance of a contract to which the subject of personal data is a party or beneficiary or guarantor, as well as for the conclusion of a contract on the initiative of the subject of personal data or the contract, the processing of personal data is necessary for the exercise of the rights and legitimate interests of the operator or third parties or for achieving socially significant goals, provided that the rights and freedoms of the personal data subject are not violated;personal data is processed, access to which is granted to an unlimited number of persons by the personal data subject or at his request (hereinafter referred to as - publicly available personal data); personal data subject to publication or mandatory disclosure in accordance with federal law is processed.2.3 Confidentiality of personal data

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

2.4 Publicly available sources of personal data

For the purpose of information support, the Operator may create publicly available sources of personal data of personal data subjects, including reference books and address books. Publicly available sources of personal data may include, with the written consent of the personal data subject, his / her last name, first name, patronymic, date and place of birth, position, contact phone numbers, email address, and other personal data provided by the personal data subject.

Information about the personal data subject must be excluded from publicly available sources of personal data at any time at the request of the personal data subject, the authorized body for the protection of the rights of personal data subjects, or by a court decision.

2.5 Special categories of personal data

Processing by the Operator of special categories of personal data concerning race, nationality, political views, religious or philosophical beliefs, health status, intimate life, is allowed in cases where:

the personal data subject has agreed in writing to the processing of their personal data;the personal data is made publicly available by the personal data subject;the processing of personal data is carried out in accordance with the legislation on state social assistance, labor legislation, the legislation of the Russian Federation on state pension pensions, on labor pensions;the processing of personal data is necessary to protect the life, health or other vital interests of the personal data subject or the life of the personal data subject., it is not possible to obtain the consent of the subject of personal data;the processing of personal data is carried out for medical and preventive purposes, for the purpose of establishing a medical diagnosis, providing medical and medical and social services, provided that the processing of personal data is carried out by a person, the processing of personal data is necessary for the establishment or exercise of the rights of the subject of personal data or third parties, as well as in connection with the administration of justice;the processing of personal data is carried out in accordance with the legislation on mandatory types of insurance, with the insurance legislation.Processing of special categories of personal data, carried out in the following cases:, provided for in paragraph 4 of Article 10 of the Federal Law No. 152, it must be immediately terminated if the reasons for their processing have been eliminated, unless otherwise established by federal law.

The processing of personal data on criminal records may be carried out by the Operator only in cases and in accordance with the procedure determined in accordance with federal laws.

2.6 Biometric personal data

Information that characterizes the physiological and biological characteristics of a person, on the basis of which it is possible to establish his identity - biometric personal data - can be processed by the Operator only with the written consent of the subject of personal data.

2.7 Assignment of personal data processing to another person

The company's policy regarding the processing of personal data

1 GENERAL PROVISIONS

Policy of personal data processing (hereinafter – the Policy) was developed in accordance with the Federal law of 27.07.2006. №152-FZ "On personal data" (hereinafter – FZ-152).

This Policy defines the procedure for processing personal data and measures to ensure the security of personal data "Costabonita Prestige S. L."" (hereinafter – the Operator) to protect the rights and freedoms of man and citizen when processing his personal data, including protection of rights to privacy, personal and family secrets.

The following basic concepts are used in the Policy:

automated processing of personal data – processing of personal data using computer technology; blocking of personal data-temporary termination of processing of personal data (except in cases where processing is necessary to clarify personal data); personal data information system - a set of personal data contained in databases, and information technologies and technical means that ensure their processing; depersonalization of personal data - actions, as a result of which it is impossible to determine, without the use of additional information, the identity of personal data to a specific subject of personal data;processing of personal data - any action (operation) or a set of actions (operations) performed with or without the use of automation tools with personal data, including the collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data; the operator - state body, municipal body, legal entity or individual, independently or jointly with other persons, organizing and (or) performing 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; personal data – any information related directly or indirectly to a specific or identifiable individual (subject of personal data); provision of personal data – actions aimed at disclosing personal data to a certain person or a certain circle of persons; dissemination of personal data - actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or at familiarizing an unlimited number of persons with personal data, including the publication of personal data in the mass media, placement in information and telecommunications networks or providing access to personal data in any other way;destruction of personal data - actions that make it impossible to restore the content of personal data in the personal data information system and / or destroy the material storage media of personal data;The Company is obliged to publish or otherwise provide unrestricted access to this Personal Data Processing Policy in accordance with Part 2 of Article 18.1. of Federal Law 152.

2PRINCIPES AND CONDITIONS FOR PROCESSING PERSONAL DATA

2.1 Principles

of personal data processing The Operator's personal data is processed on the basis of the following principles:

restrictions on the processing of personal data to achieve specific, pre-defined and legitimate goals; preventing the processing of personal data that is incompatible with the purposes of collecting personal data;preventing the integration of databases containing personal data that are processed for purposes that are incompatible with each other;processing only those personal data that meet the purposes of their processing;compliance of the content and scope of the processed personal data with the stated purposes of processing;preventing the processing of personal data, excessive in relation to the stated purposes of their processing;ensuring the accuracy, sufficiency and relevance of personal data in relation to the purposes of personal data processing;destruction or depersonalization of personal data upon achievement of the purposes of their processing or in case of loss of the need to achieve these goals, if it is impossible for the Operator to eliminate the violations of personal data, unless otherwise provided by federal law.2.2 Terms of personal data processing

The operator processes personal data in the presence of at least one of the following conditions:

the processing of personal data is carried out with the consent of the personal data subject to the processing of his personal data;the processing of personal data is necessary to achieve the goals provided for by an international treaty of the Russian Federation or by law, to perform and fulfill the functions, powers and duties assigned to the operator by the legislation of the Russian Federation;the processing of personal data is necessary for the administration of justice, the execution of a judicial act, an act of another body or official, processing of personal data is necessary for the performance of a contract to which the subject of personal data is a party or beneficiary or guarantor, as well as for the conclusion of a contract on the initiative of the subject of personal data or the contract, the processing of personal data is necessary for the exercise of the rights and legitimate interests of the operator or third parties or for achieving socially significant goals, provided that the rights and freedoms of the personal data subject are not violated;personal data is processed, access to which is granted to an unlimited number of persons by the personal data subject or at his request (hereinafter referred to as - publicly available personal data); personal data subject to publication or mandatory disclosure in accordance with federal law is processed.2.3 Confidentiality of personal data

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

2.4 Publicly available sources of personal data

For the purpose of information support, the Operator may create publicly available sources of personal data of personal data subjects, including reference books and address books. Publicly available sources of personal data may include, with the written consent of the personal data subject, his / her last name, first name, patronymic, date and place of birth, position, contact phone numbers, email address, and other personal data provided by the personal data subject.

Information about the personal data subject must be excluded from publicly available sources of personal data at any time at the request of the personal data subject, the authorized body for the protection of the rights of personal data subjects, or by a court decision.

2.5 Special categories of personal data

Processing by the Operator of special categories of personal data concerning race, nationality, political views, religious or philosophical beliefs, health status, intimate life, is allowed in cases where:

the personal data subject has agreed in writing to the processing of their personal data;the personal data is made publicly available by the personal data subject;the processing of personal data is carried out in accordance with the legislation on state social assistance, labor legislation, the legislation of the Russian Federation on state pension pensions, on labor pensions;the processing of personal data is necessary to protect the life, health or other vital interests of the personal data subject or the life of the personal data subject., it is not possible to obtain the consent of the subject of personal data;the processing of personal data is carried out for medical and preventive purposes, for the purpose of establishing a medical diagnosis, providing medical and medical and social services, provided that the processing of personal data is carried out by a person, the processing of personal data is necessary for the establishment or exercise of the rights of the subject of personal data or third parties, as well as in connection with the administration of justice;the processing of personal data is carried out in accordance with the legislation on mandatory types of insurance, with the insurance legislation.Processing of special categories of personal data, carried out in the following cases:, provided for in paragraph 4 of Article 10 of the Federal Law No. 152, it must be immediately terminated if the reasons for their processing have been eliminated, unless otherwise established by federal law.

The processing of personal data on criminal records may be carried out by the Operator only in cases and in accordance with the procedure determined in accordance with federal laws.

2.6 Biometric personal data

Information that characterizes the physiological and biological characteristics of a person, on the basis of which it is possible to establish his identity - biometric personal data - can be processed by the Operator only with the written consent of the subject of personal data.

2.7 Assignment of personal data processing to another person