Privacy policy
"Alloggio" GmbH regarding the processing of personal data.
This policy uses the following key concepts:
- Personal data - any information relating to a directly or indirectly identified or identified person (subject of personal data);
- Operator - Alloggio GmbH. Independently organizes and carries out the processing of personal. It also determines the purposes of processing personal data, the composition of personal data to be processed and actions (operations) performed with personal data;
- Processing of personal data - any action (operation) or a set of actions (operations) performed with personal data using automation tools or without using such tools, including: collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data;
- Automated processing of personal data - processing of personal data using computer technology;
- Dissemination of personal data - actions aimed at disclosing personal data to an indefinite circle of persons;
- Providing personal data - actions aimed at disclosing personal data to a certain person or a certain circle of persons;
- Blocking of personal data - temporary suspension of the processing of personal data (unless the processing is necessary to clarify personal data);
- Destruction of personal data - actions, as a result of which it becomes impossible to restore the content of personal data in the information system of personal data and (or) as a result of which material carriers of personal data are destroyed;
- Depersonalization of personal data - actions, as a result of which it becomes impossible to determine the ownership of personal data by a specific subject of personal data without the use of additional information;
- Information system of personal data - a set of personal data contained in databases and information technologies and technical means that ensure their processing;
- Cross-border transfer of personal data - the transfer of personal data to the territory of a foreign state to the authorities of a foreign state, a foreign individual or a foreign legal entity.
Alloggio GmbH, based on the goals of unconditional fulfillment of the requirements of the local legislation and maintaining its business reputation, considers its tasks to fulfill the principles of justice, legality, confidentiality, and security in the processing of personal data. This personal data processing policy:
- Developed taking into account the requirements of the local legislation and regulatory legal acts of personal data;
- Defines the basic principles, purposes and methods of processing personal data, the composition of personal data subjects and their rights, actions of Alloggio GmbH when processing personal data, the measures taken by Alloggio GmbH on the protection of personal data, as well as measures to monitor compliance with the requirements of the law and this policy;
- It is a publicly available document that regulates the activities of Alloggio GmbH when processing personal data.
Company name: Alloggio GmbH, Oberer Buchwald 28, 83236 Berlin, Germany, Registration number 666005467852, VAT code 315668600002232, tel: +7 49 30 266 433 888
This policy regarding the processing of personal data is drawn up in accordance with the requirements of the following regulatory legal acts of the local legislation:
- Constitution;
- Labor code;
- Federal laws;
- Other regulatory legal acts and regulatory documents of authorized state authorities.
Alloggio GmbH processes personal data solely for the purposes of:
- Carrying out economic activities aimed at making a profit through retail, wholesale trade;
- Organization of a network of trade enterprises;
- Organizations of warranty service;
- Execution of an agreement, one of the parties (or beneficiary) of which is the subject of personal data (including labor relations with the Operator's employees, relations with counterparties/suppliers and with the Operator's buyers/clients).
It is not allowed to process personal data that does not meet the purposes of processing.
In information systems of personal data of Alloggio GmbH personal data of the following personal data subjects are processed:
- Full-time and non-staff employees who are in labor / contractual relations with Alloggio GmbH;
- Individuals — buyers/clients of Alloggio GmbH;
- Individuals - counterparties under contracts concluded by Alloggio GmbH.
Alloggio GmbH processes the following categories of personal data of a general category: last name, first name, patronymic, date of birth, month of birth, year of birth, place of birth, data of identity documents, military registration documents, address (registration at the place of residence and actual residence), contact details (phone numbers, email addresses), data on the place of work and position, data contained in the work book, data on education, data on marital status, data on property status (including information on income, financial obligations of the subject of personal data), TIN, data of the insurance certificate of the state pension fund, details of a power of attorney or other document confirming the authority, site user metadata (cookie, IP address and location data).
Processing of personal data at Allogio GmbH is carried out taking into account the protection of the rights and freedoms of both employees of Alloggio GmbH and other people in the processing of their personal data, including the rights to privacy, personal and family secrets based on the principles:
- Legality and fairness of the processing of personal data;
- Limiting the processing of personal data to the achievement of specific, predetermined and legitimate purposes;
- Compliance of the purposes and methods of processing personal data with the purposes that were declared during the collection of data;
- The inadmissibility of combining databases created for different purposes for the processing of personal data;
- Compliance with the need and sufficiency of the volume, nature and methods of processing personal data for the stated purposes of their processing;
- Ensuring accuracy, reliability and, if necessary, relevance in relation to the purposes of processing;
- Storing personal data in a form that allows determining the subject of personal data for no longer than required by the purposes of processing, the requirements of the law or the contract under which the beneficiary is the subject of personal data;
- Destruction or depersonalization of personal data upon achievement of the goals or the loss of the need to achieve these goals, unless otherwise provided by the requirements of the law.
IP Alloggio GmbH collects, records, systematizes, accumulates, stores, clarifies (updates, changes), extracts, uses, transfers (distributes, provides, accesses), depersonalizes, blocks, deletes, destroys personal data.
In Alloggio GmbH processing of personal data is carried out in the following ways:
- Automated processing of personal data;
- Non-automated processing of personal data;
- Mixed processing of personal data.
- Information carriers containing personal data are stored in special strictly controlled premises located within the boundaries of controlled and protected zones.
- The premises where personal data is stored and the technical means by which personal data is processed are under round-the-clock security.
- Information access to the technical means by which personal data is processed is implemented through automated workstations protected from unauthorized access. Depending on the degree of criticality of the information, the differentiation (restriction) of access is carried out by software and hardware means for identifying and authenticating users.
- The access of personnel and unauthorized persons to protected premises and premises where informatization and communication facilities are located as well as where media with personal data are stored is differentiated (limited).
- Information is available only to strictly defined employees. Recording (logging) of entry / exit of employees to / from the operating system (s), work in automated workstations, access to databases.
- Implemented protection of information from hardware failures and malicious software. An information recovery system is used.
- When working in networks, information security is ensured by means of a firewall, the creation of demilitarized zones, virtual private networks, secure communication channels, the use of secure information transfer protocols and software and hardware information encryption.
Responsible for compliance with the requirements of the legislation in the field of personal data and this policy is Alloggio GmbH.
The person responsible for organizing and ensuring the security of personal data, within the framework of the implementation of the provisions of this policy and the legal acts in the field of personal data, is authorized to:
- Determine threats to the security of personal data during their processing in personal data information systems;
- Plan the application of organizational and technical measures to ensure the security of personal data during their processing in personal data information systems, necessary to counter threats to the security of personal data and fulfill the requirements for the protection of personal data;
- Organize control and / or audit of the compliance of the protection measures taken when processing personal data with regulatory legal acts, the requirements of regulatory acts for the protection of personal data, local acts;
- Assess the effectiveness of the measures taken to ensure the security of personal data prior to the commissioning of the personal data information system and organize monitoring of the level of protection of personal data during the operation of the personal data information system;
- Conduct an analysis on the facts of violation of the provisions of this policy;
- Develop and take appropriate measures to maintain the required level of personal data security;
The subject of personal data has the right to receive information about the processing of his personal data in Alloggio GmbH, including information containing:
- Confirmation of the fact of personal data processing;
- Legal basis, purposes and terms of personal data processing;
- Ways of processing personal data;
- Other information provided for by the legislation.
The right of the subject of personal data to access his personal data may be limited:
- If the processing of personal data, including those obtained as a result of operational-search activities, is carried out in order to strengthen the defense of countries, ensure the security of the state and protect law and order;
- If the processing of personal data is carried out in accordance with the legislation on combating the legalization (laundering) of proceeds from crime and the financing of terrorism;
- If the access of the subject of personal data violates the rights and legitimate interests of third parties;
- Provided that the processing of personal data is carried out by bodies that detain the subject of personal data on suspicion of committing a crime, or charged the subject of personal data in a criminal case, or applied a measure of restraint to the subject of personal data before bringing charges, with the exception of those provided for by the criminal procedural legislation in cases where it is allowed to familiarize the suspect or the accused with such personal data;
- If the processing of personal data is carried out in cases provided for by the local legislation on transport security, in order to ensure the sustainable and safe functioning of the transport complex, protect the interests of the individual, society and the state in the field of the transport complex from acts of unlawful interference.
- Confirmation of the fact of personal data processing;
- Legal basis, purposes and terms of personal data processing;
- Ways of processing personal data;
- Other information provided for by the legislation.
The right of the subject of personal data to access his personal data may be limited:
- Clarification of your personal data, their blocking or destruction, if the personal data is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing;
- Withdrawal of consent to the processing of personal data;
- Exercise of other rights provided for by the legislation in the field of personal data.
To exercise their rights and legitimate interests, the subject of personal data may contact Alloggio GmbH.
The subject of personal data has the right to appeal against the actions or inaction of Alloggio GmbH by contacting the authorized body for the protection of the rights of personal data subjects.
The subject of personal data has the right to protect their rights and legitimate interests, including in court.
This policy has been developed and approved by Alloggio GmbH.
This Policy is an internal document of the Operator, publicly available and is subject to posting on the official website of the Operator.
This Policy is subject to change, addition in the event of the emergence of new legislative acts and special regulatory documents on the processing and protection of personal data.
Control over the fulfillment of the requirements of this Policy is carried out by those responsible for ensuring the security of personal data.
The responsibility of the Operator's officials who have access to personal data for failure to comply with the requirements of the rules governing the processing and protection of personal data is determined in accordance with local legislation and the internal documents of the Operator.