Personal Data Policy

1. General provisions

This personal data policy has been compiled in compliance with Federal Law No. 152-FZ "On Personal Data" dated July 27, 2006 and determines the procedure for processing personal data and measures for ensuring personal data security used by Yakov and Partners LLC (INN 7710708760, OGRN 1087746280225) (hereinafter the "Operator").

1.1. Observing human and civil rights and freedoms, including the rights to personal and family privacy, when processing personal data is a top priority for the Operator and a necessary condition for carrying out its business operations.

1.2. The Operator's policy on personal data processing (hereinafter the "Policy") shall be applicable to all information about the visitors of the Website www.yakovpartners.com that can be obtained by the Operator.

2. Key definitions used in the Policy

2.1. Automated Personal Data Processing means processing of personal data using computer technology.

2.2. Website refers to a set of graphic and text information, as well as computer software and databases that ensure their availability on the Internet at the following web address: www.yakovpartners.com.

2.3. Personal Data Information System refers to a set of personal data contained in databases, as well as hardware and software used to process them.

2.4. User means any visitor of the Website www.yakovpartners.com.

2.5. Personal Data means any information directly or indirectly related to a specific or identifiable User of the Website www.yakovpartners.com

3. Details about the Personal Data processed while using the Website:

Purpose of processing: providing the User with access to the basic functions of the Website, including performing statistical analysis of Website traffic, managing the Website and improving its operation and user experience
Categories and list of processed Personal Data	General information: Cookie files Web beacons IP address Page URL Page header and referrer Estimated geographical location Time zone Browser version and language Display resolution Version of the operating system and auxiliary software Records of interactions with the Website Device model Search engines List of downloaded files Visitor's interests List of visited web pages Time spent on the Website and other similar information
Personal Data subjects	Users
Legal basis for processing	Consent, execution of the agreement with the User (Terms of Use), exercise of the Operator's rights and legitimate interests. The Operator processes anonymized User data if the User's web browser settings allow this (if cookies and JavaScript are enabled). If the User does not consent to the automatic processing of cookie files, the User can change their browser settings and disable and delete cookies.
Methods and terms of Personal Data processing and retention	Processing methods: Automated Personal Data Processing using a Personal Data Information System within the Russian Federation. The Operator provides Personal Data (grants access to it) to third party web analytics services (Yandex Metrica). The Operator does not link names, contact details or other data the User may provide for other purposes with their actions on the Website that are tracked by cookies. Processing and retention periods: the cookie files used by the Operator are stored on the User's device for a period that depends on file type: Session cookies become active when the User enters the Website and are used until the current browser session ends. They are automatically deleted after the browser is closed. Persistent cookies are stored on the device across multiple browser sessions and are not deleted after the browser is closed. They can be stored on the device for different periods depending on their type and use, from one day (for example, cookies used for Website optimization purposes) to two years (for example, cookies that remember the User's earlier consent to the processing of cookies).
Procedure for destruction of Personal Data after the fulfillment of its purpose or on other legal grounds	Cookie files are automatically deleted after they have fulfilled their purpose.
Purpose of processing: recruiting and hiring, including the User's applying for vacant positions through the Website, reviewing the application, and placing the candidate in the talent pool
Categories and list of processed Personal Data	General information: Full name E-mail address Phone number Place of employment Position City and country of residence Information provided by the candidate in their CV
Data subjects	Candidates for vacancies
Legal basis for processing	Consent. By sending Personal Data, the User gives consent to the processing of their Personal Data as defined in the Policy.
Methods and terms of Personal Data processing and retention	Processing methods: Automated Personal Data Processing using a Personal Data Information System within the Russian Federation, non-automated processing, and a combination of both. Processing and retention periods: if the Operator is interested in a resume received from the User, but it is not able to offer a suitable vacancy yet, the Operator will include the resume in its talent pool and keep the resume and other Personal Data within 10 years from the date the Operator receives it. The User is free to withdraw their consent for processing and request the removal of their Personal Data from the talent pool at any moment.
Procedure for destruction of Personal Data after the fulfillment of its purpose or on other legal grounds	After the Personal Data has fulfilled its purpose, after the end of its processing period or upon the User's request, the Operator ensures the destruction of Personal Data within 30 days if the Operator is not required by law to retain any Personal Data and if it does not need to continue processing it for any legitimate reason.

4. Procedure for collecting, storing, providing and other processing of Personal Data

4.1. The Operator processes Personal Data by doing the following: collecting, recording, classifying, accumulating, storing, refining (updating, changing), extracting, using, transferring (providing, accessing), blocking, deleting, and destructing Personal Data. The Operator does not disseminate Personal Data. If such dissemination is necessary, the Operator will obtain a separate consent in accordance with Article 10.1 of Federal Law No. 152-FZ "On Personal Data" dated July 27, 2006.

4.2. The security of Personal Data processed by the Operator is ensured by implementing legal, organizational, and technical measures necessary for full compliance with the effective personal data protection laws.

4.3. The Operator ensures the safety of Personal Data and takes all possible measures to prevent unauthorized persons from accessing Personal Data.

4.4. The Operator takes necessary measures to ensure proper protection of the provided Personal Data, as well as to organize the provision of Personal Data in accordance with the current legislative requirements.

4.5. The Operator is entitled to provide Personal Data (entrust their processing) to service providers for Website operation and maintenance (including the provision of data to web analytics services) to achieve the above purposes (for example, to bulk email service providers), as well as in cases where such provision is required by law.

4.6. If the User discovers any inaccuracies in Personal Data, it may be updated independently by sending a notification to the Operator's e-mail address media@yakovpartners.com with a note saying "Personal Data Update".

5. Final provisions

5.1. If the User needs any clarifications regarding the processing of their Personal Data, they can contact the Operator by writing to media@yakovpartners.com.

5.2. This document will reflect any changes to the Operator's Personal Data Policy. The Policy shall remain in force for an indefinite period of time until its most recent version is replaced with a new one.

5.3. The most recent version of the Personal Data Policy is freely available on the Internet at www.yakovpartners.com.

This Personal Data Policy was last revised on March 21, 2024.