Regulations on the processing of personal data of candidates and clients

This Regulation on the processing of personal data of candidates (hereinafter referred to as the “Regulation”) is intended to inform candidates for vacant positions (hereinafter referred to as the “Candidates”) about how Protega Insurance LLC and/or its affiliates, including included in the same group with Protega Insurance LLC and registered in Germany (hereinafter referred to as "Protega Insurance"), processes their personal data.

The provision is based on data protection legislation, including the Federal Law "On Personal Data" dated July 27, 2006 No. 152-FZ (“FZ-152”) and the by-laws adopted in accordance with it.

The terms used in the Regulations have the meaning established by law. In particular:

Personal data operator - is a legal entity that, independently or jointly with other persons, organizes and (or) carries out the processing of personal data, as well as determining the purposes of processing personal data, the composition of personal data to be processed, and actions (operations) performed with personal data.

Personal data - any information relating directly or indirectly to a specific or identifiable individual (subject of personal data). The subject of personal data is a candidate for a vacant position.

Processing of personal data - any action (operation) or set of actions (operations) performed in relation to personal data using automation tools or without the use of such means, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction , use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.

1. Operator

The operator of personal data processed under this Regulation is the legal entity of the Protega Insurance group for which you are applying for an open vacancy. In particular, the controller in relation to your personal data may be:

• Limited Liability Company "Protega Insurance", registered at the address: Tucholskystraße 2, 10117 Berlin, Germany; and


• Other branches included in the Protega Insurance group.

You can always get additional information about the operator by studying the job description, asking a question to the hiring manager, or using the contact information provided in section 10 of the Regulations.

2. Purposes and legal grounds for processing personal data

Protega Insurance processes your personal data to (1) discuss employment prospects with you; (2) consideration of your candidacy for an open position; (3) testing your skills, qualifications and business acumen; (4) making a final employment decision; (5) preparation for concluding an employment contract in the event of successful selection for an open vacant position; (6) informing you about vacancies that are suitable for your experience and specialization; (7) compliance with applicable laws; (8) conducting analytics to improve the efficiency of hiring processes; (9) checking for conflicts of interest; (10) sending invitations to events held by Protega Insurance; (11) sending information and other materials related to the activities of Protega Insurance; (12) collecting feedback on the employment process; (13) within the limits established by law - to protect the rights and legitimate interests of the Protega Insurance group. Protega Insurance processes personal data on the basis of your specific, informed and conscious consent to the processing of personal data. In cases provided for by law, Protega Insurance has the right to rely on other legal grounds, including:

• Compliance with the duties and functions provided for by current legislation (clause 2, part 1, article 6 of Federal Law-152);


• Necessity for the execution of an agreement with the subject of personal data or for concluding an agreement on the initiative of the subject of personal data (clause 5, part 1, article 6 of Federal Law-152);


• Processing of personal data in connection with participation in legal proceedings or for the execution of a judicial act, an act of another body or official (clause 3, part 1, article 6 of the Federal Law-152, clause 3.1, part 1, article 6 of the Federal Law-152);


• Exercise of the rights and legitimate interests of Protega Insurance or third parties (clause 7, part 1, article 6 of Federal Law No. 152);


• Processing of personal data for statistical or other research purposes, subject to mandatory anonymization of personal data (clause 9, part 1, article 6 of Federal Law No. 152);


• Other legal grounds provided for by applicable law.

3. Categories of personal data and actions (operations) performed with them

To achieve the goals specified in section 2 of the Regulations, Protega Insurance processes the personal data you provided when applying for a vacancy and during the further selection process, including, if applicable:

• FULL NAME;


• Date of Birth;


• Place of Birth;


• Address;


• Citizenship/residence permit;


• Gender;


• Family status;


• Work permit;


• Passport details;


• Contact information (email, phone number, postal address);


• Profiles on social networks;


• Information about education and specialization;


• Information about length of service and work experience;


• Characteristics from previous places of work


• Information about the expected salary;


• Information about skills and business qualities;


• Health information (if required to participate in a competition for an open vacant position);


• Photo;


• Test task results;


• Information required to pass the conflict of interest check;


• Other information specified by you in your resume or otherwise provided to Protega Insurance for the purposes listed in section 2 of the Regulations.

Protega Insurance performs the following actions (operations) with and without the use of automation tools in relation to the above personal data: collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (provision, access) , depersonalization, blocking, deletion, destruction of personal data. When collecting your personal data, Protega Insurance ensures their recording, systematization, accumulation, storage, clarification (updating, changing), and retrieval using databases located on the territory of Germany/USA/UK.