1. General statement.

2.The principles and conditions of personal data processing.

3.Rights of the data subject.

4.Security of personal data.

5.The use of cookies.

6.Final provisions.

Insurance group (SG)of the Group combines JSC “Alfa Strakhovanie”, LLC “AlfaStrakhovanie-Life”, LLC “AlfaStrakhovanie-OMS”, OOO “Medicine AlfaStrakhovanie”, JSC “Altametrics”.

They are linked by the appropriate confidentiality agreements and the procedure for providing data. In addition, they are guided by the present Policy of personal data processing.

In Politics following basic concepts are used:

automated processing of personal data — processing of personal data by means of computer technology;

blocking of personal data — the temporary cessation of personal data processing (except when processing is needed for personal data specification);

information system of personal data — a set of databases of personal data, and ensure their processing of information technologies and technical means;

depersonalization of personal data — actions as a result of which it is impossible to determine without additional information membership personal data specific the subject of personal data;

personal data processing — any action (operation) or set of actions (operations) committed with use of
means of automation or without use of such means with personal data including collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, granting, access), depersonalization, blocking, deletion, destruction of personal data;

operator — a state authority, municipal authority, legal or natural person who independently or together with other persons organizing and (or) carrying out processing of personal data, and also defining purposes of processing of personal data, the composition of personal data to be processed, actions (operations) committed with personal data;

personal data — any information relating directly or indirectly to an identified or identifiable individual (the subject personal data);

the provision of personal data — actions aimed at the disclosure personal data certain face or a certain circle of persons;

dissemination of personal data — actions aimed at revealing personal data to an indefinite circle of persons (transfer of personal data) or on acquaintance with personal data of an unlimited circle of persons, including promulgation of personal data in the media, accommodation in information and telecommunication networks or granting of access to personal data any different way;

cross-border transfer personal data — transfer of personal data to a foreign state on the authority of a foreign state, foreign natural or foreign legal entity.

destruction of personal data — actions as a result of which it is impossible to restore the contents personal data in the information system of personal data and (or) the result of which are destroyed material carriers of personal data.

A Cookie is a small data file (typically containing letters and numbers) that websites can leave on your computer or mobile device when you visit a particular site or page.
The cookie will help this or another website to recognise your device the next time you visit. This task can also carry web beacons or other similar files. In this policy we use the term “cookies” applied to all files that collect information in this way. Alfa Strakhovanie JSC is obliged to publish or otherwise provide unrestricted access to this Policy processing of personal data in accordance with part 2 of article 18.1. FZ-152.
2. The principles and conditions of personal data processing.

2.1. Treatment personal data in JSC Alfa Strakhovanie is based on the following principles:

law and fair basis;

restrict the processing of personal data by the achievement of specific, explicit, and legitimate purposes;
prevent the processing of personal data incompatible with purposes of personal data collection;
prevent the merging of databases containing personal data the processing of which is carried out for the purposes incompatible with each other;
process only those personal data that meet the purposes of their processing;
matching the content and scope of processed personal data to the declared purpose of processing;
prevent the processing of personal data, excessive in relation to the declared purposes of their processing;
ensure accuracy, adequacy and relevance of personal data in relation to the purpose of processing personal data;
destruction or depersonalization of personal data for achieving the purposes of processing or in case of loss necessary to achieve these goals, if it is impossible to eliminate by the Operator of violations of personal data unless otherwise provided by Federal law.

2.2. JSC Alfa Strakhovanie processing of 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 personal data subject to the processing of personal data;
the processing of personal data necessary to achieve the objectives stipulated international contract The Russian Federation or the law, for the implementation and execution of assigned legislation of the Russian Federation at JSC Alfa Strakhovanie functions, powers and duties;
the processing of personal data necessary for the implementation of justice, the execution of the judicial act, act of another body or officials that must be performed in accordance with the legislation of the Russian Federation about Executive production;
the processing of personal data necessary for the execution of the contract to which either the beneficiary or the guarantor which is the subject of personal data, and also for the contract at the initiative of the subject of personal data or of a Treaty, by which the subject personal data will be the beneficiary or surety;
processing of personal data is necessary to protect the life, health or other vital interests of the subject of personal data, if obtaining the consent of the subject of personal data is impossible
the processing of personal data necessary for the implementation of rights and legitimate interests of JSC Alfa Strakhovanie or third parties or to achieve important public purposes, provided that it does not violate the rights and freedoms of the subject of personal data;
is treatment personal data access unlimited to which is provided by the subject of personal data or at the request of (hereinafter — public personal information);
the processing of personal data subject to publication or mandatory disclosure in accordance with Federal law.

2.3. All personal data collection is recorded in the base data, in the territory of the Russian Federation, which is, if necessary, clarification of, change or update.

2.4. JSC Alfa Strakhovanie does not disclose personal data subject to third parties and does not distribute personal data without the consent of the data subject, unless otherwise provided by law.

2.5. Processing special categories of personal data in JSC Alfa Strakhovanie, Concerning racial, national origin, political views, religious or philosophical convictions, state of health, intimate life, is allowed in cases if:

the data subject has consented in writing to the processing of their personal data;
personal data made publicly available subject of personal data;
personal data shall be processed in accordance with the law on state social assistance, labour legislation, legislation of the Russian Federation on pensions for the state pension provision on retirement pensions;
processing of personal data is necessary to protect the life, health or other vital interests of the subject
of personal data or the life, health or other vitally important interests of other persons and obtaining the consent of the subject of personal data is impossible;
personal data shall be processed in medico prophylactic the purposes of establishing a medical diagnosis, rendering of medical and medical-social services under the condition that the processing of personal data is carried out by a person professionally working in medical activities and obliged in accordance with the legislation of the Russian Federation to keep medical secret;
personal data shall be processed in accordance with the law on compulsory types of insurance,insurance legislation.

2.6. Create photos and videos is JSC Alfa Strakhovanie for the purpose of monitoring compliance with the law and the rule of law and prevent illegal acts, manifestations of extremism and terrorist acts, and subsequent transfer to law enforcement authorities if necessary. These photos and video is not
used to identify the subjects of personal data and are not considered JSC Alfa Strakhovanie as biometric personal data.

2.7. JSC Alfa Strakhovanie is entitled to entrust the processing of personal data to another person with the consent of the data subject, unless otherwise provided by Federal law, on the basis of concluded with this person of the contract order processing personal data. Face exercising processing personal data on behalf of JSC Alfa Strakhovanie, must respect the principles and rules of processing of personal data, stipulated by FZ-152 “About personal data”. In case of JSC AlfaStrakhovanie instructs the processing of personal data to another person, the liability to the data subject for the actions of said person carries JSC Alfa Strakhovanie. Face Exercising processing personal data on behalf of JSC Alfa Strakhovanie, bears responsibility before the JSC Alfa Strakhovanie.

2.8. JSC Alfa Strakhovanie has an obligation to ensure that foreign the state on whose territory it is supposed to carry out the transmission of personal data is ensured adequate protection of the rights of personal data subjects before the commencement of such transfer. Cross-border transfer of personal data on the territory of foreign States providing adequate protection of the rights of subjects of personal data may be carried out in cases:

the consent of in writing subject of personal data cross-border transfer of personal data;
the execution of the contract which is the subject of personal data.

3. Rights of the data subject.

3.1. The subject personal data takes the decision on providing his personal data and gives consent to their treatment willingly and in their interest. Consent to personal data processing may be the subject of personal data or his representative in any allowing to confirm the receipt of the form, unless otherwise provided by Federal law. The obligation to provide proof of obtaining the consent of personal data subject to the processing of personal data or proof of the grounds specified in FZ-152, is assigned to JSC Alfa Strakhovanie.

3.2.The data subject has the right to receive from JSC Alfa Strakhovanie information regarding the processing of their personal data, if this right is not restricted in accordance with Federal laws. The subject of personal data is entitled to demand from JSC Alfa Strakhovanie refinement of his personal data, their blocking or destruction in case, if the personal data are incomplete, outdated, inaccurate, illegally obtained or are not necessary for stated goal processing and also make legal action to protect their rights.

3.3. Processing JSC Alfa Strakhovanie personal data for the purpose of promotion of goods, works and services in the market through implementation of direct contacts with the potential consumer by means of communication permitted only with the prior consent of the data subject. JSC Alfa Strakhovanie shall immediately to stop at the request of the subject of personal data processing of personal data for the purposes described above.

3.4. If the subject personal data considers what is JSC the Company carries out the processing of personal data in violation of law or in any other way violates his rights and freedoms, a subject of personal data right to appeal action or inaction JSC Alfa Strakhovanie to the Authorized body for the protection of the rights of subjects of personal data (Roskomnadzor) or in judicial order. The data subject has the right to protect their rights and legitimate interests, including on indemnification and (or) compensation of moral harm in a judicial order.
4. Security of personal data.

4.1. Security personal data processed JSC Alfa Strakhovanie, supported by the implementation of legal, organizational and technical measures required to ensure the requirements of the Federal legislation on protection of personal data for prevent unauthorized access to personal data in JSC Alfa Strakhovanie apply the following organizational and technical measures:

the appointment of officials responsible for organizing the processing and protection of personal data;
the limitation of the number of employees that handle personal data and have access to personal data while performing their labor responsibilities regulation order the provision of such access;
familiarization of employees with the requirements of legislation and internal normative documents of JSC Alfa Strakhovanie for the processing and protection of personal data;
software accounting and storage material media personal data and the procedure for handling, aimed at preventing the theft, spoofing, unauthorized copying and destruction;
definition of threats to security of personal data during their processing, the formation on their basis of models of threats;
the development of model-based threats to the system of protection of personal data;
check the readiness and efficiency of use of means of information protection;
password protection user access to the information system of personal data;
differentiation of user access to information resources and software and hardware of information processing;
registration and recording of actions of users of information systems of personal data;
the application controls access to communication ports, input devices and output information, machine removable media, and external storage;
the use of antivirus tools and means of restoring the system of protection of personal data;
the use of appropriate cryptographic protection of information to ensure the security of personal data during transmission over open channels of communication;
application firewalling;
detection intrusion in corporate network JSC Alfa Strakhovanie, which disturbs or creates prerequisites for violation of installed requirements at to ensure the security of personal data;
security analysis of information systems of personal data of JSC AlfaStrakhovanie with the use of specialized software tools (security scanners);
centralized system management the protection of personal data;
backup information;
the training of workers using the means of protection of information applied in information systems of personal data, the rules of working with them;
the organization throughput mode on the territory of JSC Alfa Strakhovanie, protection of premises and technical means of personal data processing.

5. The use of cookies.

5.1. Like many web sites, the sites of JSC Alfa Strakhovanie use technologies such as cookies and web beacons (web beacons), which enable us to facilitate Your stay on our web site, to make it more efficient and more valuable by providing You with a customized environment for You and knew you when You visit our web site. You can browse great part websites JSC Alfa Strakhovanie, by not accepting cookies, however, some website functions may be lost due to deactivation cookie on Your computer. For other web pages, JSC Alfa Strakhovanie, in particular, those for which requires a user name (login) and password, a cookie is needed, such pages cannot be used if You deactivated cookies in your browser. JSC Alfa Strakhovanie can also use the customize links or similar technologies to track references to the email address on which You click. We are able to compare this information with Your personal information in order to provide You with email more focused on You messages or information about your purchases or services. Each message sent by e -mail includes a link to unsubscribe allowing You to stop delivery of messages of this kind.

5.2. The cookies used on our web sites are divided into categories. We use the following categories on our websites and other online services:

Necessary cookies.These cookies are essential to browse around our websites and use their features. Without them it is impossible to provide services such as shopping cart and online payment.
Performance cookies. These cookies collect information about your use of the websites, for instance about most visited pages. Such data can be used to customize our web sites and simplify navigation. These cookies are also used by our affiliates in order to determine crossed if you are on our web site with site affiliates take any advantage you our services and if you bought our products as a result of a visit to the web site, including what products and the services you bought. All information collected through them designed for statistical purposes and remains anonymous.
Functional cookies. These cookies allow our websites to remember choices you make while browsing the website. For example, file cookie maybe remember your location that will allow us to display our web site in the language of your country. These files can also be used to remember settings, such as the size and font of text as well as other custom site settings. These files can also be used to keep track of featured products in order to avoid repetition. The information provided by such cookies do not allow to identify you. They are not designed to keep track of your work on web sites that are not relevant to the JSC Alfa Strakhovanie.

5.3. If You prefer not to receive cookies while browsing our web site or via e-mail in HTML format, You can set Your browser to warn You before accepting cookies or to block the cookie when Your browser alerts You to the presence of a cookie. You can also opt out of all cookies by turning them off in Your browser.

6. Final provisions.

6.1. Other rights and obligations of JSC Alfa Strakhovanie related to treatment her personal data define the law of personal data.6.2. Officials of JSC Alfa Strakhovanie, is guilty of a violation of norms regulating processing and protection of personal data, shall bear material, disciplinary, administrative, civil and criminal liability in the order established by the legislation and internal normative documents of JSC Alfa Strakhovanie.