1. General Provisions
1.1. This document (hereinafter referred to as the "Policy") defines the policy regarding the processing of personal data of users of the website of Bollard LLC (hereinafter referred to as the "Operator") on the website on the information and telecommunications network Internet at: https://bollard-marine.group/ (hereinafter referred to as the "Website").
1.2. This Policy has been developed on the basis of Clause 2, Part 1, Article 18.1 of Federal Law No. 152-FZ dated July 27, 2006 "On Personal Data", as well as the Recommendations for drawing up a document defining the operator's policy regarding the processing of personal data, in accordance with the procedure established by Federal Law No. 152-FZ dated July 27, 2006 "On Personal Data".
1.3. In compliance with the requirements of Part 2, Article 18.1 of Federal Law No. 152-FZ dated July 27, 2006 "On Personal Data", the Policy is published in free access on the information and telecommunications network Internet on the Operator's Website at: https://bollard-marine.group/
1.4. This Policy applies only to the Website. The Operator does not control and is not responsible for third-party websites that the User may access via links available on the Website.
1.5. The concepts contained in Article 3 of Federal Law No. 152-FZ dated July 27, 2006 "On Personal Data" are used in this Policy with the same meaning.
1.6. This Policy also uses the following terms:

• User – any person visiting the Website and using the information, materials, and services of the Website. The Website User is a personal data subject within the meaning of Federal Law No. 152-FZ dated July 27, 2006 "On Personal Data".
• Website Services – interactive (dialog) software components on the Website pages used for integration with information systems and providing Website users with certain capabilities to access information on the Website (hereinafter referred to as "Services", "Website Services").

1.7. Rights and Obligations of the Operator.
1.7.1. The Operator must:

• process personal data solely for the purposes specified in the Policy, in accordance with the procedure established by the current legislation of the Russian Federation, and take measures necessary and sufficient to ensure the fulfillment of duties provided for by Federal Law No. 152-FZ dated July 27, 2006 "On Personal Data" and regulatory legal acts adopted in compliance with it;
• not disclose personal data without the User's consent, unless otherwise provided for by the current legislation of the Russian Federation;
• process personal data in compliance with the principles and rules provided for by Federal Law No. 152-FZ dated July 27, 2006 "On Personal Data";
• organize the protection of personal data in accordance with the requirements of the legislation of the Russian Federation;
• consider requests from the User (their legal representative) regarding the processing of personal data and provide reasoned responses;
• provide the User (their legal representative) with the opportunity for free access to their personal data;
• take measures to clarify, block, and destroy the User's personal data in cases established by Federal Law No. 152-FZ dated July 27, 2006 "On Personal Data".

1.7.2. The Operator has the right:

• to independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of duties provided for by Federal Law No. 152-FZ dated July 27, 2006 "On Personal Data" and regulatory legal acts adopted in compliance with it, unless otherwise provided by Federal Law No. 152-FZ dated July 27, 2006 "On Personal Data" or other federal laws;
• in the event of the User withdrawing consent to the processing of personal data, to continue processing personal data without the User's consent if there are grounds specified in Federal Law No. 152-FZ dated July 27, 2006 "On Personal Data";
• to receive from the User reliable information and/or documents containing the User's personal data for the processing purposes specified in Clause 2.2 of the Policy;
• to require the User to timely update the provided personal data.

1.8. Rights and Obligations of the User.
1.8.1. The User must:

• ensure the reliability of the personal data provided to the Operator necessary for the processing purposes specified in Clause 2.2 of the Policy;
• provide the Operator, if necessary, with information to clarify (update, change) the provided personal data.

1.8.2. The User has the right:

• to full information regarding the processing of their personal data by the Operator, except for cases provided for by the legislation of the Russian Federation;
• to have their personal data clarified, blocked, or destroyed in cases where the personal data is incomplete, outdated, inaccurate, illegally obtained, or not necessary for the stated purpose of processing;
• to withdraw consent to the processing of personal data;
• to take measures provided by law to protect their rights;
• to appeal against unlawful actions or inaction of the Operator in the processing of their personal data to the authorized body for the protection of the rights of personal data subjects or in court;
• to give prior consent to the processing of personal data for the purposes of receiving advertising and feedback.

The Operator and Users also have other rights and bear other obligations provided for by the legislation of the Russian Federation.

2. Purposes of Personal Data Processing
2.1. The processing of personal data is limited to the achievement of specific, predetermined, and lawful purposes. Processing of personal data incompatible with the purposes of collecting personal data is not allowed. The processed personal data must not be excessive in relation to the stated purposes of their processing. Only personal data that meets the purposes of their processing is subject to processing.
2.2. The Operator processes the User's personal data for the following purposes:
2.2.1. The Operator processes the personal data of Users – candidates for vacant positions – for the purpose of considering the candidate for a vacant position and making a decision on hiring or refusing to hire.
2.2.2. Informing about the operation of the Website (Services), monitoring and improving the quality of Services.
2.2.3. Providing the User with access to personalized resources of the Website.
2.2.4. Establishing feedback with the User, including sending notifications, requests regarding the use of the Website, provision of services, performance of work, processing requests from the User.
2.2.5. Determining the User's location to ensure security and prevent fraud using the User's personal data on the Website.
2.2.6. Creating an account for internal use by Users (employees of the Operator), if the User has consented to the creation of an account and has taken actions to create it.
2.2.7. Providing the User with effective customer and technical support when problems arise related to the use of the Website via requests to the technical support email address vdolzhikov@bollard-marine.group.
2.2.8. Anonymized User data collected using internet statistics services serves to collect information about User actions on the website, improve the quality of the website and its content.
2.2.9. On the website https://bollard-marine.group/ ("Website"), Bollard LLC uses one or more third-party metric programs: Yandex Metrica. The composition and conditions for collecting anonymized data using third-party software (Yandex Metrica) are determined directly by their copyright holders and may include: browser data (type, version, cookies), device data and its location, operating system data (type, version, screen resolution), request data (time, source of transition, IP address). The Operator is not responsible for the procedure for using anonymized data by third parties (Yandex Metrica). At the same time, disabling cookies may result in the inability to access parts of the website, cause incorrect operation, or lack of access to the website.

3. Legal Grounds for Processing Personal Data
3.1. The legal grounds for processing personal data by the Operator are:

• The Constitution of the Russian Federation;
• The Civil Code of the Russian Federation;
• Federal Law No. 149-FZ dated July 27, 2006 "On Information, Information Technologies and Protection of Information";
• Federal Law No. 294-FZ dated December 26, 2008 "On the Protection of the Rights of Legal Entities and Individual Entrepreneurs in the Exercise of State Control (Supervision) and Municipal Control";
• Decree of the President of the Russian Federation No. 188 dated March 6, 1997 "On Approval of the List of Confidential Information";
• Decree of the Government of the Russian Federation No. 1119 dated November 1, 2012 "On Approval of Requirements for the Protection of Personal Data during their Processing in Personal Data Information Systems";
• Order of the FSTEC of Russia No. 21 dated February 18, 2013 "On Approval of the Composition and Content of Organizational and Technical Measures to Ensure the Security of Personal Data during their Processing in Personal Data Information Systems";
• Consent to the processing of personal data on the Website;
• The Regulation on Personal Data of Bollard LLC.

4. Scope and Categories of Processed Personal Data, Categories of Personal Data Subjects
4.1. The Operator may process the personal data of the following Users: visitors to the Operator's website.
4.2. The personal data processed by the Operator (in the event of the User filling out an information collection form) includes (the list is not exhaustive):

• surname, first name, patronymic of the User;
• place of residence (region/city);
• mobile phone number;
• email address;
• date of birth;
• information about the city of residence and city of registration;
• information about the professional profile;
• information about the desired position;
• information about work experience in the declared position;
• information about total sea service;
• information about education;
• information about the preferred employment format;
• information about the expected period of starting work;
• information about current employment;
• information about the presence, registration status, dates of issue and validity periods of the seafarer's book (working diploma);
• information about the presence, registration status, dates of issue and validity periods of the GMDSS certificate;
• information about the presence, registration status and dates of issue of the qualification certificate;
• information about the presence, registration status, dates of issue and validity periods of basic safety training documents;
• information about the presence, registration status, dates of issue and validity periods of training documents for survival craft and rescue boats;
• information about the presence, registration status, dates of issue and validity periods of security training documents;
• information about the presence of a valid medical certificate;
• information about undergoing a chemical-toxicological study;
• information about the absence of documents from the medical unit;
• information about the presence of experience working on ASD tugs;
• information about the presence of experience participating in port operations;
• information about the ports in which the candidate worked;
• information about the types and power of engines the candidate worked with;
• information about the desired salary level;
• information about pension status;
• information about the presence of a disabled child;
• information about the presence of three or more children;
• information about the status of a combat veteran;
• information about the date/period of readiness to start work;
• information about the fact of familiarization with the policy and providing consent to the processing of personal data.
• data that is automatically transferred to the Website Services during their use using the software installed on the User's device, namely: IP address, cookie data, information about the User's browser (or other program used to access the Services), technical characteristics of the hardware and software used by the User, date and time of access to the Services, addresses of requested pages, history of requests and views on the Website and its Services.

4.3. The Operator ensures that the content and scope of the processed personal data correspond to the stated processing purposes provided for in Section 2 of the Policy.
4.4. The Operator does not process biometric personal data (information that characterizes the physiological and biological characteristics of a person, on the basis of which their identity can be established), nor special categories of personal data concerning racial or national origin, political views, religious or philosophical beliefs, or intimate life.

5. Procedure and Conditions for Processing Personal Data
5.1. The Operator processes personal data in accordance with the requirements of the legislation of the Russian Federation using the following methods:

• non-automated processing of personal data;
• automated processing of personal data with or without transmission of the received information via information and telecommunications networks;
• mixed processing of personal data.

5.2. List of actions performed by the Operator with the User's personal data for the purposes specified in Clause 2.2 of the Policy: collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, anonymization, blocking, deletion, destruction.
5.3. The processing of personal data is carried out by the Operator subject to obtaining the User's consent (hereinafter referred to as "Consent"), obtained in accordance with the requirements of Federal Law No. 152-FZ dated July 27, 2006 "On Personal Data", except for cases established by the legislation of the Russian Federation where the processing of personal data may be carried out without such Consent.
5.3.1. Posting of resumes by candidates for vacant positions on electronic internet resources (job aggregators) is carried out in accordance with the rules of these resources. By sending a resume to the Operator's email address, candidates for vacant positions thereby give consent in a conclusive form to the processing of their personal data.
5.4. The User decides to provide their personal data and gives Consent freely, of their own will, and in their own interest.
5.5. The period for processing personal data is determined by the achievement of the purposes for which the personal data was collected, unless a different period is provided for by an agreement with the User or applicable law. A condition for terminating the processing of personal data may be the achievement of the purposes of processing personal data or the loss of the need to achieve these purposes, the expiration of the Consent period or the withdrawal of Consent by the User, as well as the detection of unlawful processing of personal data.
5.6. If a personal data subject submits a request to Bollard LLC to cease processing personal data, the operator is obliged, within a period not exceeding 10 business days from the date the operator receives the relevant request, to cease processing it or ensure the cessation of such processing (if such processing is carried out by a person processing personal data), except for cases provided for by the Federal Law "On Personal Data". This period may be extended, but by no more than 5 business days, if the operator sends a reasoned notification to the personal data subject indicating the reasons for extending the period for providing the requested information. If it is impossible to destroy personal data within the specified period, Bollard LLC blocks such personal data or ensures its blocking (if the processing of personal data is carried out by another person acting on behalf of Bollard LLC) and ensures the destruction of personal data within a period not exceeding 6 months, unless a different period is established by federal laws.
5.7. The Operator distributes personal data authorized by the User for distribution, i.e., carries out actions aimed at disclosing them to an indefinite circle of persons, in compliance with the requirements, prohibitions, and conditions established by Part 9, Article 9, and Article 10.1 of Federal Law No. 152-FZ dated July 27, 2006 "On Personal Data". Disclosure of personal data to third parties and distribution of personal data without the User's consent is not allowed, unless otherwise provided for by federal law. Consent to the processing of personal data authorized by the User for distribution is formalized separately from other consents of the User to the processing of his personal data, taking into account the Requirements for the content of consent to the processing of personal data authorized by the personal data subject for distribution, approved by Order of Roskomnadzor No. 18 dated February 24, 2021.
5.8. When processing personal data, the Operator adopts or ensures the adoption of necessary legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, alteration, blocking, copying, provision, distribution of personal data, as well as from other unlawful actions in relation to personal data.
5.9. Personal data is stored in a form that allows the User to be identified for a period no longer than is required by the purposes of processing personal data, except for cases where the storage period for personal data is established by federal law, an agreement to which the User is a party, beneficiary, or guarantor.
5.10. When processing personal data, the Operator complies with the requirements of Article 18 of Federal Law No. 152-FZ dated July 27, 2006 "On Personal Data".
5.11. When processing personal data, the Operator undertakes to maintain the confidentiality of personal data.
5.12. The Operator does not carry out cross-border transfer of personal data.
5.13. In the event of unlawful or accidental transfer (provision, distribution, access) of personal data, the Operator informs the User of this within 5 (five) business days from the date the fact was discovered by the Operator.
5.14. The Operator, together with the User, takes all necessary measures to prevent losses or other negative consequences caused by the unlawful or accidental transfer (provision, distribution, access) of the User's personal data.

6. Blocking, Clarification, and Destruction of Personal Data. Responses to User Requests for Access to Personal Data
6.1. In the event of detection of unlawful processing of personal data upon a request from the User (their representative) or upon a request from the User (their representative) or an authorized body for the protection of the rights of personal data subjects, the Operator blocks the unlawfully processed personal data relating to the relevant User, or ensures their blocking from the moment of such a request or receipt of the said User request for the period of verification. In the event of detection of inaccurate personal data upon a request from the User or their representative, or upon their request, or upon a request from the authorized body for the protection of the rights of personal data subjects, the Operator blocks the personal data relating to that User, or ensures their blocking from the moment of such a request or receipt of the said request for the period of verification, if blocking of personal data does not violate the rights and legitimate interests of the User or third parties.
6.2. In the event of confirmation of the fact of inaccuracy of personal data, the Operator, based on information provided by the User (their representative) or the authorized body for the protection of the rights of personal data subjects, or other necessary documents, clarifies the personal data or ensures their clarification within seven business days from the date of provision of such information.
6.3. In the event of detection of unlawful processing of personal data, the Operator, within a period not exceeding three business days from the date of this detection, ceases the unlawful processing of personal data or ensures the cessation of unlawful processing of personal data, and if it is impossible to ensure the lawfulness of processing, within a period not exceeding ten business days from the date of detection of unlawful processing of personal data, destroys such personal data or ensures their destruction.
6.4. Upon achieving the purpose of processing personal data, the Operator destroys the personal data or ensures their destruction within a period not exceeding thirty days from the date of achieving the purpose of processing personal data, unless otherwise provided by an agreement to which the User is a party, beneficiary, or guarantor, by another agreement between the Operator and the User, or unless the Operator is not entitled to process personal data without the User's consent on the grounds provided for by Federal Law No. 152-FZ dated July 27, 2006 "On Personal Data" or other federal laws.
6.5. In the event of the User withdrawing consent to the processing of their personal data and if the retention of personal data is no longer required for the purposes of processing personal data, the Operator destroys the personal data or ensures their destruction within a period not exceeding thirty days from the date of receipt of the said withdrawal, unless otherwise provided by an agreement to which the User is a party, beneficiary, or guarantor, by another agreement between the Operator and the User, or unless the Operator is not entitled to process personal data without the User's consent on the grounds provided for by Federal Law No. 152-FZ dated July 27, 2006 "On Personal Data" or other federal laws.
6.6. Within a period not exceeding seven business days from the date the User (their representative) provides information confirming that such personal data was illegally obtained or is not necessary for the stated purpose of processing, the Operator destroys such personal data.
6.7. Processed personal data is subject to destruction in the event of the loss of the need to achieve the processing purposes, unless otherwise provided by federal law.
6.8. The Operator responds to requests and appeals from the User (their representative) regarding the processing of personal data carried out by them in the following order: in accordance with Articles 14 and 20 of Federal Law No. 152-FZ "On Personal Data", providing information or a reasoned refusal within 30 days using the same method by which the request was received.

7. Liability of the Parties
7.1. The Operator is liable for violations of the requirements of Federal Law No. 152-FZ dated July 27, 2006 "On Personal Data" in accordance with the legislation of the Russian Federation.

8. Dispute Resolution
8.1. In the event of disputes and/or disagreements arising from the relationship between the User and the Operator, such issues are resolved in accordance with the current legislation of the Russian Federation.
8.2. The current legislation of the Russian Federation applies to the Policy and the relationship between the User and the Operator.

9. Final Provisions
9.1. The Operator has the right to make changes to the Policy without the User's consent.
9.2. The new version of the Policy comes into force from the moment it is posted on the Website, unless otherwise provided by the new version of the Policy. The new version of the Policy applies to relations arising after its entry into force.
9.3. All suggestions or questions regarding the Policy should be sent to the following email address: info@bollard-marine.group.