Policy on the Processing and Protection of Personal Data

This Policy on the Processing and Protection of Personal Data (hereinafter, the "Policy") has been adopted and is in effect at LLC "PB", TIN (INN) 7448265179, KPP 744801001, OGRN 1257400032284, registered address: 454014, Chelyabinsk Region, Chelyabinsk (hereinafter, the "Administration").

We collect, use and protect personal data (information relating directly or indirectly to you) that you provide to us when using our websites at https://puzzlebot.top, https://puzzle.bot, https://labo.top, including subdomains (hereinafter, the "Site"), from any device and when communicating with us in any form, in accordance with this Policy on the Processing and Protection of Personal Data, the Consent to the Processing of Personal Data, the User Agreement and the Cookie Policy, and other documents on the Site.

By using our Site and providing us with your personal data, you give your consent to the processing of your personal data, available at https://puzzle.bot/privacy-agree (hereinafter, the "Consent"), in accordance with this Policy and the other documents specified above.

On what basis do we process data?

The Administration processes your personal data on the basis of the Constitution of the Russian Federation, the Convention for the Protection of Individuals with regard to Automatic Processing of Personal Data (ETS No. 108, concluded in Strasbourg on 28.01.1981), Federal Law No. 152-FZ "On Personal Data" of 27.07.2006, other federal laws and regulations of the Russian Federation that determine the cases and specifics of processing personal data and ensuring the security and confidentiality of such information, as well as your Consent given during registration on the Site and/or use of the Site.

What data do we collect? What are the purposes of processing?

Through the Site, we collect the following personal data of unregistered and registered users of the Site:

Purposes of personal data processing	List of personal data processed (if provided)
Providing you with information about the Administration, our services and events, organizing your participation in the events and surveys we hold, sending you our news materials, communicating with you.	Personal data that you provide to us when filling in the information fields on the Site, filling out the contact form, subscribing to the newsletter or registering for events, such as your name, phone number, email address, data from your Telegram account and other data.
Performance of agreements between you and the Administration, such as the User Agreement and other agreements, and of the terms of provision of individual services of the Administration on the Site and beyond it; exercise of the powers and performance of the duties imposed on the Administration by the legislation of the Russian Federation; registering you on the Site to give you access to certain sections of it, including creating an account.	Personal data that you provide to us when filling in the information fields on the Site during registration for the purpose of concluding an agreement, or accepting an offer, such as your first name, last name, patronymic, date of birth, email address, mobile phone number, address, TIN (INN), details of your passport or other identity document, your payment card details and other payment information, and other information provided by you.
Recruiting and selecting candidates for employment with the Administration.	Personal data contained in messages and files that you send us, including when responding to our vacancies, such as your name, phone number, email address, age, education details, work experience, address and other personal data provided by you.
Organizing your participation in the Administration's External Candidate Referral Program.	Personal data that you provide to us when filling in the information fields on the Site, such as your first name, last name, patronymic, phone number, email address, as well as the personal data of the candidate you recommend for a vacant position: first name, last name, patronymic, phone number, email address, information contained in the recommended candidate's resume, including age, education and work experience details, address and other personal data specified in the candidate's resume.
Generating visit statistics; ensuring the operation and security of the Site, improving the Administration's services.	Technical data automatically transmitted by the device you use to access the Site, including technical characteristics of the device, IP address, information stored in cookies sent to your device, browser information, date and time of access to the site, addresses of requested pages and other similar information, HTTP headers, web beacons/pixel tags, browser identifier data, geolocation information, hardware and software information; information about your activity while using the Site (for example, search history, files stored in the Site systems) and other similar information.

What methods of data processing do we use?

We process your personal data with and without the use of automation tools by collecting, recording, systematizing, accumulating, storing, clarifying (updating, changing), extracting, using, transferring (providing, granting access to), depersonalizing, blocking, deleting and destroying personal data.

We do not place your personal data in publicly available sources. We do not make decisions that give rise to legal consequences for you or otherwise affect your rights and legitimate interests based solely on automated processing of personal data.

The Administration records, systematizes, accumulates, stores, clarifies (updates, changes) and extracts personal data of citizens of the Russian Federation using databases located in the territory of the Russian Federation.

For how long do we process the data?

We process your personal data until the purposes of their processing are achieved. We store your personal data:

— until we receive your request to stop processing your personal data or to destroy it, if the personal data processed has been obtained unlawfully or is not necessary for the stated purpose of processing, unless there are other legal grounds for processing the personal data provided for by the legislation of the Russian Federation;

— or until the purposes of processing such data are achieved;

— or until unlawful processing of personal data is detected, if it is impossible to ensure the lawfulness of processing.

Upon expiry of the storage periods, personal data shall be destroyed or blocked.

Do we use cookies?

We invite you to read the Cookie Policy.

What are your rights?

To ensure the protection of your rights and freedoms, at your request we will:

— confirm whether we process your personal data and provide your personal data within 10 business days from the date of your request or our receipt of an inquiry from you or your representative; this period may be extended by no more than 5 business days if we send you a reasoned notice stating the reasons for extending the period for providing the requested information;

— inform you of the source and composition of your personal data that we process;

— inform you of the legal grounds, purposes, periods and methods of processing your personal data, as well as of the measures aimed at ensuring that the Administration fulfills its obligations with respect to your personal data as provided for by law;

— clarify, block or destroy your personal data if it is incomplete, outdated, inaccurate, obtained unlawfully or not necessary for the stated purpose of processing, and notify you of the measures taken;

— inform you of the name and location of organizations that have access to your personal data and to which your personal data may be disclosed with your Consent;

— inform you of the name, or the last name, first name and patronymic, and the address of persons who, with your Consent, may be entrusted with the processing of your personal data;

— unsubscribe you from our news mailings upon your request;

— stop processing your personal data within 30 days from the date of receipt of the withdrawal of Consent, unless there are other legal grounds for processing the personal data provided for by the legislation of the Russian Federation.

How do we ensure the security of your data?

To ensure the security of your personal data during their processing, we take the necessary and sufficient legal, organizational and technical measures provided for by Russian legislation.

To ensure adequate protection of your personal data, we assess the effectiveness of the measures taken to ensure the security of personal data and identify current threats to the security of your personal data during their processing in personal data information systems.

We detect instances of unauthorized access to personal data and take measures, including measures to detect, prevent and eliminate the consequences of computer attacks on personal data information systems and to respond to computer incidents in them.

The Administration has adopted local regulations on personal data security. Employees of the Administration who have access to personal data have been familiarized with this Policy and the local regulations on personal data security.

Cross-border transfer of personal data

The Administration does not carry out cross-border transfer of personal data. All data is stored in the territory of the Russian Federation in accordance with the requirements of Federal Law No. 152-FZ "On Personal Data" of 27.07.2006.

Is the data available to third parties?

The Site may transfer your personal data to third parties with your consent, unless otherwise provided by law.

Links to third-party websites

The Site may contain links to third-party websites and services that we do not control. We are not responsible for the security and/or confidentiality of any information collected by third-party websites and/or services.

Changes to the Policy

We may update the Policy as necessary. We recommend that you periodically check this Policy for updates. By continuing to use the Site after the Policy has been changed, you confirm your consent to the changes made.

How can you contact us?

You can contact us with a question about this Policy or a request regarding the processing of your personal data by sending an email to: support@puzzlebot.top or a letter to: 454014, Russia, Chelyabinsk Region, Chelyabinsk Urban District, Chelyabinsk, Komsomolsky Prospekt, Building 84, Apt. 62

This document is a translation of the Russian original. In case of any discrepancy between the English and Russian versions, the Russian version shall prevail.