1. Terms, definitions and references
For the purposes hereof, the following terms and their definitions shall apply:
Personal data means any information related to directly or indirectly identified or identifiable individual (subject of personal data).
Personal data also includes data that can be automatically transferred to the Company when using its information systems through software installed on the device by personal data subject, including: IP address, identification files information (Cookies), information about the personal data subject’s browser (or other application through providing access to the Company’s services).
Processing of personal data means any action (operation) or set of actions (operations) performed via automation tools or without such means on personal data, including collection, record, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), depersonalization, block, deletion, destruction of personal data.
Confidentiality of information means an obligatory requirement for a person got access to certain information not to transfer such information to third parties without the consent of its owner.
Clients of the Company mean for the purposes hereof: policyholders, insured persons, beneficiaries, representatives of policyholders, representatives of legal entities under insurance policies.
The Company's websites mean software products (web applications) hosted in the renins.com or renins.ru domains.
MV means motor vehicle.
MVT means motor vehicle title.
Accident means depending on the context: accidents\accident and illness insurance.
2. General provisions
The Guidelines for confidentiality and security of personal data when processed at the Renaissance Insurance Group, PJSC (PAO), (hereinafter referred to as the Guidelines) are developed in accordance with the requirements of the Federal Law No. 152-FZ 'On Personal Data' as of July 27, 2006 and aimed at ensuring protection of the rights and freedoms of man and citizen when processing his/her personal data, and apply to all personal data processed at the Renaissance Insurance Group, PJSC (PAO) (hereinafter - the Company).
The Guidelines’ purpose is to provide subjects of personal data (users of websites and software products, persons who wish using the Company's products and services, clients, employees, potential employees (applicants), agents (including agents as individual entrepreneurs), representatives of the Company's partners) with information required to realize the structure of processed personal data, the purposes and methods of the Company’s processing, and the Company’s measures to ensure personal data security.
2.1. The subject of personal data has the right to receive the following information from the Company:
- Confirmation of the fact of personal data processing;
- Legal grounds and purposes of personal data processing;
- Purposes and applied methods of personal data processing;
- Name and location of the Company, information about persons (except for the Company’s employees) who have access to their personal data or to whom personal data may be disclosed;
- Certain types of data processed, the source of their receipt;
- Processing terms, including period for storage of personal data;
- Information about completed or planned cross-border data transfer;
- Name or surname, first name, homeland and address of the person processing personal data on behalf of the Company, if the processing has been or will be assigned to such a person;
- Other information provided for by the laws of the Russian Federation.
2.2. The subject of personal data has the right to:
- demand from the Company clarification of their personal data, their blocking or destruction (if the personal data is incomplete, outdated, unreliable, illegally obtained or is not required for the stated purpose of processing);
- require the Company to ensure updating, blocking or destruction of personal data if third parties process personal data is carried on behalf of the Company
- withdraw consent to the processing of his personal data by sending the Company a written notice of withdrawal of relevant consent. In this case, the Company ceases processing the personal data of the subject of personal data and, within a period not exceeding thirty days as of the date of receipt of the above withdrawal, destroys the personal data of the subject, except for those personal data which keeping is required for the purposes of processing personal data under the laws;
-demand the exclusion of his personal data from publicly available sources (directories). The Company is obliged to immediately exclude the subject’s data from such directories from the date of receipt of the relevant request;
- demand to terminate processing of his personal data to promote goods and services through direct contacts via means of communication. The Company is obliged to immediately stop processing such data from the date of receipt of the relevant request.
- The subject of personal data may at any time change (update, add) the personal data provided by him or its part by sending a request to the Company.
2.3. If the personal data owner believes that the Company is processing their personal data in violation of federal law or otherwise violates their rights and freedoms, the personal data owner shall be entitled to appeal against the actions or inactions of the Company by contacting the authorized body for protection of the rights of personal data owners, or through a judicial procedure.
2.4. Personal data owner shall be entitled to protect their rights and legitimate interests including for indemnification and (or) compensation for moral injury in a court.
3. Purposes and terms of personal data processing
3.1. Providing insurance products and services to the Company's clients requires collecting and further processing of personal data enabling to identify the Company's policyholders and (or) insured persons, their representatives and (or) beneficiaries and provide their services. The structure and the scope of the required information shall be established by the current legislation of the Russian Federation and the internal regulatory documents of the Renaissance Insurance Group, PJSC (PAO). If these persons do not provide the required information, the Company shall be entitled to deny provision of services.
3.2. Acting in their own interests, clients of the Renaissance Insurance Group, PJSC (PAO) have the right to involve third parties in their relations with the Company. In this case, they are obliged to ensure the provision of the required information by the specified persons or provide it themselves with notification of the specified persons of the fact of providing such information for its processing at the Renaissance Insurance Group, PJSC (PAO) and get them acquainted with the provisions hereof.
3.3. Using the insurance products and services provided by the Company, and informing the Company, including through third parties, about your personal data means the subject’s consent to the processing of his personal data in accordance with the Guidelines. If disagreement with these terms, subjects of personal data shall refuse from using insurance products and services and providing their personal data to the Company.
3.4. Potential employees (applicants) of the Renaissance Insurance Group, PJSC (PAO) shall oblige to provide personal data for further employment in Renaissance Insurance Group, PJSC (PAO), for the possibility of signing employment agreement/contract between the potential employee (applicant) and the Renaissance Insurance Group, PJSC (PAO). The content and scope of required information are determined by the current laws of the Russian Federation and internal regulatory documents of the Renaissance Insurance Group, PJSC (PAO). If a potential employee (applicant) fails to provide the required information, the Renaissance Insurance Group, PJSC (PAO) may refuse to give them a job at the Company.
3.5. The employees of the Company shall oblige to provide personal data to arrange personnel records of the Renaissance Insurance Group PJSC (PAO), ensure compliance with the legislation of the Russian Federation and other regulations, conclude and execute liabilities under employment and civil contracts, and conduct personnel records, help employees in employment, training and promotion, use different types of benefits, comply with the requirements of the tax legislation of the Russian Federation on calculation and payment of personal income tax, as well as the unified social tax, pension legislation of the Russian Federation for making and providing personalized data on each recipient of income regarded for calculating insurance premiums for obligatory pension insurance and benefits, filling primary statistical documentation under the Labor Code of the Russian Federation, the Tax Code of the Russian Federation, Federal laws of the Russian Federation, the Articles of the Association and internal regulations of the Renaissance Insurance Group PJSC, (PAO). The content and volume of required information are determined by the current laws of the Russian Federation and internal regulatory documents of the Renaissance Insurance Group, PJSC (PAO). If potential employee (applicant) fails to provide the required information, the Renaissance Insurance Group, PJSC (PAO) may refuse to give them a job at the Company.
3.6. Agents, agents (individual entrepreneurs), representatives of the partners shall oblige to provide personal data to comply with the laws of the Russian Federation, signing and executing the liabilities under civil law contracts and comply with the Tax Code of the Russian Federation. The content and volume of required information are determined by the current laws of the Russian Federation and internal regulatory documents of the Renaissance Insurance Group, PJSC (PAO).
4. Legal basis for personal data processing
The Company effects personal data processing under the principles and conditions for the personal data processing established by the Federal Law of July 27, 2006 No. 152-FZ “On Personal Data” to get predetermined certain goals meet the interests of the subjects of personal data and the Company itself, and only with sufficient legal grounds for such processing.
Processing of personal data in the Company is available if at least one of the following conditions is met:
- Consent of the subject to the personal data processing;
- Processing is required to achieve the goals under the law, to implement the functions the laws of the Russian Federation assigned to the Company;
- Processing is required to execute or sign a contract with the subject of personal data as a party;
- Personal data became public subject of personal data;
- Other terms and conditions that allow personal data processing under the laws of the Russian Federation.
If a visitor of the Site or mobile application user does not agree with the terms hereof, he shall stop using the Site or refuse to install the Mobile Application. If he continues using the Site, as well as installing the Mobile Application, he as the subject of personal data confirms the complete and unconditional acceptance hereof. Such personal data processing is terminated as provided herefor for other categories of personal data and subjects.
The Company's clients (policyholders, insured persons, beneficiaries) shall oblige to provide their personal data, so the Company performs the liabilities to such persons and is determined by the requirements of such regulatory legal acts as: Federal Law No. 4015-1-FZ 'On the Organization Of Insurance Business in the Russian Federation' as of November 27, 1992 ; Federal Law No. No. 115-FZ “On Counter-Acting the Legalization (Laundering) of Proceeds from Crime and Financing of Terrorism' as of August 07, 2001; Federal Law No. 40-FZ 'On Compulsory Insurance of Civil Liability of Vehicle Owners’ as of April, 25, 2002; Federal Law No. 326-FZ 'On Compulsory Medical Insurance in the Russian Federation' as of November 29, 2010; Federal Law No. 102-FZ 'On Mortgage (Pledge of Real Estate)' as of July 16, 1998; Federal Law No. 122-FZ ' On State Registration of Rights to Immovable Property and Transactions Involving Such Property' as of July 21, 1997; Federal Law No. 132-FZ 'On the Basics of Tourist Activities' as of November 24, 1996; Federal Law No. 161-FZ 'On the National Payment System' as of June 27, 2011, and other internal regulatory documents of the Renaissance Insurance Group, PJSC (PAO).
Potential employees (applicants) of the Renaissance Insurance Group, PJSC (PAO) shall oblige to provide personal data for further employment, for the possibility of signing employment agreement/contract between the potential employee (applicant) and the Renaissance Insurance Group, PJSC (PAO). The content and scope of required information are determined by the current laws of the Russian Federation and internal regulatory documents of the Renaissance Insurance Group, PJSC (PAO), that do not contradict the current laws and do not contain provisions limiting the rights of potential employees (applicants). If a potential employee (applicant) fails to provide the required information, the Renaissance Insurance Group, PJSC (PAO) may refuse to give him a job at the Company.
The employees of the Company shall oblige to provide personal data to conclude and execute liabilities under employment and civil contracts, conduct personnel records, arrange personnel records, ensure compliance with the "Labor Code of the Russian Federation" dated December 30, 2001 No. 197-FZ, Federal Law dated March 28, 1998 No. 53-FZ "On Military Duty and Military Service", Federal Law dated February 26, 1997 No. 31-FZ "On mobilization preparation and mobilization in the Russian Federation" and other regulations, as well as to manage personnel records, help employees in employment, training and promotion, use different types of benefits, comply with the requirements of the tax legislation of the Russian Federation on calculation and payment of personal income tax, as well as the unified social tax, pension legislation of the Russian Federation for making and providing personalized data on each recipient of income regarded for calculating insurance premiums for obligatory pension insurance and benefits, filling primary statistical documentation under the Labor Code of the Russian Federation, the Tax Code of the Russian Federation, the Family Code of the Russian Federation, other Federal laws of the Russian Federation, the Articles of the Association and internal regulations of the Renaissance Insurance Group PJSC, (PAO). The content and scope of required information are determined by the current laws of the Russian Federation and internal regulatory documents of the Renaissance Insurance Group, PJSC (PAO), that do not contradict the current laws and do not contain provisions limiting the rights of employees. If an employee fails to provide the required information, the Renaissance Insurance Group, PJSC (PAO) may refuse to give him a job at the Company.
Agents, agents (individual entrepreneurs), representatives of the Company's partners, as well as executors under civil law contracts shall oblige to provide personal data required for the signing and executing the liabilities under civil law contracts with such persons and compliance with the Civil Code of the Russian Federation and other legal regulations acts. The structure and scope of required information are set by the current laws of the Russian Federation and the Company’s non-contradictory internal regulatory documents.
The Company also processes personal data for the purpose of insurance business within the framework of exercising its rights and legal interests, and the arising requirements provided for by the current laws of the Russian Federation.
5. Scope and types of processed personal data, categories of personal data subjects
The Company ensures that content and volume of processed personal data corresponds to the purposes of their processing.
The Company may process personal data of the following categories of personal data subjects:
5.1. Clients signed insurance policies with the Company, as well as users of insurance products and services, including contracts with the subject of personal data being a beneficiary or guarantor: at the structure and terms necessary for the execution of the contract with a party being either a beneficiary or guarantor where the last mentioned are the subject of personal data. The structure and scope of required information are determined by the current laws of the Russian Federation and internal regulatory documents of the Company. If these persons do not provide the required information, the Company shall be entitled to deny provision of services.
Personal data of Clients is also used for the purpose of identifying the parties to the contract, providing the Client with insurance products and services and other additional services, sending Clients notifications, requests, information on contracts signed with the Client, processing Client applications and requests, updating software, analyzing consumer qualities of the Client and the services provided to the Client to optimize offers to the Client, researches for improving products and services, developing quality of services provided to Clients and upgrading the convenience of their use, for marketing and advertising purposes, performing statistical and other researches, including on anonymized personal data;
5.2. Visitors to the Company's Sites: at the structure and terms required to identify a Site visitor, provide site visitor with information about the Company and the services provided, products sold, provide services/provide the corresponding service, for research and analysis of trends, study of behavior of site visitors, site administration and similar goals.
The website of the Company applies cookie technology to track the preferences of website visitors and improve products and services, while cookies mean a small piece of text transmitted to the web browser from the website.
When visiting the website of the Renaissance Insurance Group, JSC (AO), the data is automatically collected, including: IP address, date and time of a visit to the website, type of a browser and operating system, model and type of a device and other similar information.
The collected information shall be used for the following purposes:
- to collect statistical data which allows to improve the functionality and the website management;
- for effective advertising management;
- to temporarily track the activities at the website;
- to improve the level of service;
- for processing by metric systems as Yandex.Metrica and other similar services;
- to ensure the information security of users, as well as the Company’s information resources, to prevent malicious mailings, fraud and abuse.
A website visitor can independently disable the function of using cookies in a web browser, therewith some sections of the Company’s website, may be inaccessible or incorrect. To manage cookies using your web browser, you can use the instructions provided by the web browser developer.
5.3. Users of Mobile Application: at the structure and terms required for installing, using Mobile Application, identifying user of Mobile Application, informing user and processing his requests, researching and analyzing the behavior of users of Mobile Application, improving dealing with Mobile Application and eliminating its faults.
5.4. Applicants for vacant positions: at the structure and terms required for the Company to make a decision on hire or refusal to hire, with the consent by personal data subjects, as well as for the creation of personnel reserve with the consent by personal data subjects.
5.5. The employees having or had labor relations with the Company: at the structure and terms required to achieve the goals provided for by the laws of the Russian Federation, to execute the functions, powers and responsibilities assigned to the Company under the laws of the Russian Federation, to sign and execute an employment contract. The employees of the Company shall oblige to provide personal data to arrange personnel records of the Renaissance Insurance Group PJSC (PAO), ensure compliance with the legislation of the Russian Federation and other regulations, conclude and execute liabilities under employment contracts, help employees in employment, training and promotion, use different types of benefits, comply with the requirements of the tax, pension legislation of the Russian Federation and filling primary statistical documentation under the Labor Code of the Russian Federation, Federal laws of the Russian Federation, the Articles of the Association and internal regulations of the Renaissance Insurance Group PJSC, (PAO).
5.6. Close relatives of the Company's employees: at the structure and terms required for the performing the functions, powers and liabilities assigned by the laws of the Russian Federation to the Company, realizing the rights and legitimate interests of the Company;
5.7. Representatives of the Company's counterparty/partner: at the structure and terms required for interaction with counterparties and execution of liabilities under civil contracts with the consent by the subjects of personal data;
5.8. Agents (including agents who are individual entrepreneurs): at the structure and terms required to comply with the laws of the Russian Federation, sing and execute liabilities under civil contracts, as well as fulfill the requirements of the tax legislation of the Russian Federation. The content and volume of required information are determined by the current laws of the Russian Federation and internal regulatory documents of the Renaissance Insurance Group, PJSC (PAO).
5.9. Visitors of the Company's offices and other premises where the Company's employees or property are located: in the structure and terms necessary to make access regime to ensure the personal safety for the employees.
Acting in their own interests, the Company's clients have the right to involve third parties (beneficiaries, insured persons, co-borrowers and other persons) to participate in their relations with the Company (in this case acting as a Representative). It means before transferring personal data of third parties, the Representative after informing them on the provisions hereof, shall oblige to ensure that these persons provide consent to the processing of their personal data by the Company or provide it independently with confirmation of their authority to give consent on behalf of the involved personal data subject.
Depending on the purposes of processing and categories of personal data subjects, the Company may process the following personal data of different categories of personal data subjects:
- last name, first name, patronymic (if available);
- date of birth;
- place of birth;
- former last name, first name, patronymic;
- passport data or data of another identity document (series, number, date of issue, name of the authority that issued the document);
- last name, first name in Latin letters;
- citizenship;
- picture;
- registration address at the place of residence;
- registration address at the place of residence;
- date of registration at the place of residence;
- date of registration at the place of stay;
- contact phone numbers;
- e-mail;
- information about education, qualifications and special knowledge or special training (series, number, date of issue of the document on graduation from educational facility, name and location of educational facility, date of start and completion, faculty or department, qualification and specialty upon graduation from the educational facility, academic degree, academic title, knowledge of foreign languages);
- information on advanced training and retraining (series, number, date of issue of the document on advanced training or retraining, name and location of educational facility, date of start and completion of training, qualification and specialty upon graduation from educational facility);
- information on labor activity (data on employment at the current time with a complete details for the position, division, name, address and telephone number of organization, as well as details of other organizations with full name of positions previously held in them and the period of employment in these organizations);
- information about the number, series and date of issue of employment record (supplementary sheets in it) and relevant entries;
- contents and details of employment contract;
- information about salary at the previous job;
- information about salary (account numbers, data on salary, premiums, taxes);
- information on military registration of persons liable for military service and persons with conscription for military service (series, number, date of issue, name of the body that issued military ID, military registration specialty, military rank, data on registration/deregistration));
- information about number and series of state pension insurance certificate;
- information about taxpayer identification number;
- driver’s license data (date of issue of license, expiration date of license, name or seal of the authority that issued license, license number, categories (subcategories) of vehicles covered by the license, additional information or restrictions as code per each category (subcategories) of vehicles);
- information about temporary disability or care for a dependent;
- information about social benefits and social status (series, number, date of issue, name of the body that issued the document being basis for the provision of benefits and status);
- information about marital status;
- information about dependents for providing tax deductions;
- data on employment at the current time with a complete details for the position, department, name, address and telephone number of the organization;
- contents and details of the insurance policy;
- information about salary at the current job;
- bank details;
- information from medical survey;
- information about health status;
- degree of relationship with the insured person in the insurance policy;
- data on the Certificate of State Registration of Title (series, number, date of issue, name of the authority that issued the document, subjects of law, type of law, object of law, cadastral (conditional number), existing restrictions on the right);
- contents and details of the insurance policy;
- citizenship in Latin letters;
- registration address at the place of residence in Latin letters;
- data of the international passport (series, number, date of issue, name of the authority that issued the document);
- information about health status;
- list of medical services;
- weight;
- growth;
- driving experience;
- vehicle brand;
- individual registration plate (number);
- region;
- data on vehicle registration certificate (registration plate, identification number, brand, model, vehicle type, vehicle category, vehicle year of manufacture, engine model, engine No., weight No., body No., color, engine power, engine displacement, passport series, permissible maximum weight, unladen weight);
- title data (identification number, brand, model of the vehicle, name (type) of the vehicle, category of the vehicle, year of manufacture of the vehicle, engine model, weight No., body No., body color, engine power, engine displacement, engine type, permissible maximum weight, unladen weight, vehicle manufacturer, vehicle export country, series, number, name of the authority that issued the document);
- data on the Certificate of State Registration of Title (series, number, date of issue, name of the authority that issued the document);
- cookies, IP address of computer or mobile device, date and time of visiting the site, browser type, operating system type, mobile device model, type of mobile device for visiting the site
www.renins.ru.
Lists of personal data for certain purposes and categories of personal data subjects shall be set by the current laws of the Russian Federation and fixed in the List of personal data information systems and personal data processed in them, approved by order of the CEO of the Company.
6. Procedure and conditions for processing personal data
To comply with the requirements of the current laws of the Russian Federation and its contractual obligations, the Company executes both automated processing of personal data and non-automated processing through paper work. In total, the processing operations include collection, record, systematization, accumulation, storage, clarification (update, change), extraction, application, transfer (distribution, provision, access), depersonalization, block, deletion, destruction of personal data.
In connection with the specific character of insurance activity, the personal data processing in the information systems of the Company is inextricably linked with the insurance secret protected by law. All employees of the Renaissance Insurance Group, PJSC (PAO) admitted to personal data processing shall sign an obligation to not disclose personal data that became known to them in the performance of their employment duties, shall keep secret about insurance contracts, personal data of such owners, as well as other information established by the Company, if this does not contradict the current laws of the Russian Federation.
The Company's employees due to their job responsibilities have access to the processed personal data. Other persons get access to personal data processed by the Company only in cases provided for law (such as transfer to bodies of inquiry and investigation, other authorized bodies on the grounds provided for the current laws of the Russian Federation) or with the consent of the personal data subject. To keep confidentiality and ensure the security of personal data during their processing is key terms of contract between the Company and the person who is granted access to personal data.
When processing personal data in the Company’s information systems, the security of personal data is ensured by protection system of restricted access information, that includes arrangement measures and information security facilities (including encryption (cryptographic) means, means of prevention for unauthorized access, software and hardware impacts on technical means of processing personal data), as well as information technologies applied in information system. The Company improves continuously and constantly information security system according to the requirements of international and national information security standards.
Personal data exchange during their processing in information systems is performed through communication channels. Implemented appropriate organizational measures and applied technical means of information security ensure protection for such exchange.
Placement of information systems, special equipment and security of premises for activities with personal data, arrangement of security regime in these premises ensure personal data protection and information security tools, and exclude the possibility of uncontrolled entry or stay of unauthorized persons in these premises as well.
When Company’s information systems process personal data, the following is provided:
- Taking measures aimed at preventing unauthorized access to personal data and (or) their transfer to persons have no right to access such information;
- due detection of facts of unauthorized access to personal data;
- preventing the impact on technical means of personal data automated processing, with disrupted functioning as a result;
- permanent monitoring of security level of personal data;
- ability to restore personal data modified or destroyed due to unauthorized access to it;
- taking measures aimed at guaranteed destruction/depersonalization of personal data by written request of the subject of personal data if not contradicting the current laws.
Periods of storage and processing of personal data in framework of specific purposes and categories of personal data subjects shall be determined under the current laws of the Russian Federation, They shall be given in the List of personal data information systems and personal data processed in them, approved by order of the CEO of the Company, as well as contracts with the parties, the beneficiaries or guarantors being personal data subjects.
Personal data processing is terminated upon achievement of the purposes of their processing, expiry or withdrawal of consent by the personal data subject to his data personal processing, as well as if detection of unlawful personal data processing.
Personal data is stored in a manner to identify the personal data subject no longer than required by the purposes of personal data processing, except for the cases with the terms for data storage established by federal law, contract with personal data subject being a party, beneficiary or guarantor.
According to the part 5 of clause 18 of the Federal Law of July 27, 2006 No. 152-FZ “On Personal Data”, the Company shall use databases located on the territory of the Russian Federation for personal data storage.
7. Update, correction, deletion and destruction of personal data, responses to requests from subjects for access to personal data, and rights of personal data subjects
If personal data is inaccurate or illegally processed, for the period of verification the Company blocks inaccurate or illegally processed personal data (if such blocking does not violate the rights and legitimate interests of the subject of personal data or third parties).
If confirmed fact of inaccuracy of personal data, within seven business days from the date of receipt of correct data the Company corrects it and stops blocking the updated personal data.
If illegal processing of personal data is detected within a period not exceeding three business days from the date of such detection, the Company stops processing it and takes measures to ensure the legality of processing such data, and if it is impossible to ensure legality, it destroys it within a period not exceeding ten business days from the date of detection of unlawful processing.
Personal data is subject to destruction as the purposes of their processing are achieved, as well as in case the subject of personal data withdraws the consent to their processing, if:
- otherwise not provided for the contract with the subject of personal data being a party, beneficiary or guarantor;
- The Company shall not process without the consent by the subject of personal data under the grounds provided for the Federal Law “On Personal Data” or other federal laws;
- otherwise not provided for in another agreement between the Company and the subject of personal data.
The Company informs the subject of personal data or his representative about the ongoing processing of the personal data upon his request.
The terms for personal data processing specified in section 3 hereof shall be determined regarding the purposes of personal data processing, under the requirements of federal laws, regulations, including Order of the Federal Archive of December 20, 2019 N 236 “On approval of the List of standard management archival documents generated in course of the activities of state bodies, local governments and facilities, providing the storage terms", Resolution of the Federal Commission for Securities Market of the Russian Federation dated July 16, 2003 No. 03-33/ps "On approval of the "Regulations on the procedure and storage terms for documents of joint-stock companies", as well as the statute of limitations.
8. Final provisions
The Company shall be entitled to make amend the Guidelines as the current laws of the Russian Federation and the terms of the activities change. The Guidelines and all changes hereto are approved and inacted by the Order of the CEO of the Company.
The Guidelines’ current version is to be placed in service offices and on the Company’s official website on the Internet:
www.renins.com.
Persons whose personal data is processed in the Company may refer at the email address -
itsecurity@renins.com concerning the issues of their interest as well as enforcement of their rights.