PRIVACY POLICY
OF GROUND ENGINEERING LIMITED LIABILITY COMPANY
REGARDING THE PROCESSING OF PERSONAL DATA
1. General Provisions
1.1. This Privacy Policy of Ground Engineering Limited Liability Company regarding the processing of personal data (hereinafter – the “Policy”) has been developed in compliance with the requirements of Clause 2, Part 1, Article 18.1 of Federal Law No. 152-FZ dated July 27, 2006 “On Personal Data” (hereinafter – the “Law on Personal Data”) in order to ensure the protection of human and civil rights and freedoms when processing their personal data, including the protection of the rights to privacy, personal and family secrets.
1.2. The Policy applies to all personal data processed by Ground Engineering Limited Liability Company (hereinafter – the “Operator”).
1.3. The Policy extends to relations in the field of personal data processing that arose with the Operator both before and after the approval of this Policy.
1.4. In compliance with the requirements of Part 2, Article 18.1 of the Law on Personal Data, this Policy is published in the public domain on the Operator's website on the information and telecommunications network Internet.
1.5. Basic terms used in the Policy:
1.6.1. The Operator has the right to:
1.9. Responsibility for violation of the requirements of the legislation of the Russian Federation and regulatory acts of Ground Engineering LLC in the field of processing and protection of personal data is determined in accordance with the legislation of the Russian Federation.
2. Purposes of Collecting Personal Data
2.1. The processing of personal data is limited to achieving specific, predetermined and legitimate purposes. Processing of personal data incompatible with the purposes of collecting personal data is not permitted.
2.2. Only personal data that meets the purposes of their processing are subject to processing.
2.3. The Operator processes personal data for the following purposes:
3. Legal Basis for Processing Personal Data
3.1. The legal basis for processing personal data is a set of regulatory legal acts in execution of which and in accordance with which the Operator processes personal data, including:
4.1. The content and scope of processed personal data must correspond to the stated processing purposes provided for in Section 2 of this Policy. Processed personal data must not be excessive in relation to the stated purposes of their processing.
4.2. The Operator may process personal data of the following categories of personal data subjects.
4.2.1. Candidates for employment with the Operator – for the purposes of fulfilling labor legislation in the framework of labor and other directly related relations, implementing access control:
4.4. The Operator does not process special categories of personal data concerning racial or ethnic origin, political views, religious or philosophical beliefs, health status, or intimate life, except in cases provided for by the legislation of the Russian Federation.
5. Procedure and Conditions for Processing Personal Data
5.1. The processing of personal data is carried out by the Operator in accordance with the requirements of the legislation of the Russian Federation.
5.2. The processing of personal data is carried out with the consent of personal data subjects to the processing of their personal data, as well as without such consent in cases provided for by the legislation of the Russian Federation.
5.3. The Operator processes personal data for each purpose of their processing in the following ways:
5.5. The processing of personal data for each processing purpose specified in clause 2.3 of the Policy is carried out by:
5.7. The transfer of personal data to bodies of inquiry and investigation, the Federal Tax Service, the Social Fund of Russia and other authorized executive bodies and organizations is carried out in accordance with the requirements of the legislation of the Russian Federation.
5.8. The Operator takes necessary legal, organizational and technical measures to protect personal data from unlawful or accidental access, destruction, alteration, blocking, distribution and other unauthorized actions, including:
5.9.1. Personal data on paper is stored by Ground Engineering LLC for the retention periods of documents for which such periods are provided by the legislation on archiving in the Russian Federation (Federal Law No. 125-FZ dated October 22, 2004 “On Archiving in the Russian Federation”, the List of Standard Administrative Archival Documents Generated in the Course of Activities of State Bodies, Local Self-Government Bodies and Organizations, Indicating Their Retention Periods (approved by Order of Rosarkhiv No. 236 dated December 20, 2019)).
5.9.2. The retention period for personal data processed in personal data information systems corresponds to the retention period for personal data on paper.
5.10. The Operator terminates processing of personal data in the following cases:
5.13. When collecting personal data, including via the information and telecommunications network Internet, the Operator ensures the recording, systematization, accumulation, storage, clarification (updating, changing), and extraction of personal data of citizens of the Russian Federation using databases located on the territory of the Russian Federation, except for cases specified in the Law on Personal Data.
6. Updating, Correction, Deletion, Destruction of Personal Data, Responses to Requests from Subjects for Access to Personal Data
6.1. Confirmation of the fact of processing of personal data by the Operator, the legal basis and purposes of processing personal data, as well as other information specified in Part 7 of Article 14 of the Law on Personal Data, shall be provided by the Operator to the personal data subject or their representative within 10 working days from the date of application or receipt of the request from the personal data subject or their representative. This period may be extended, but by no more than five working days. To do this, the Operator must send a reasoned notice to the personal data subject indicating the reasons for extending the period for providing the requested information.
The information provided shall not include personal data relating to other personal data subjects, except where there are legal grounds for disclosing such personal data.
The request must contain:
The Operator provides the information specified in Part 7 of Article 14 of the Law on Personal Data to the personal data subject or their representative in the form in which the corresponding application or request was submitted, unless otherwise specified in the application or request.
If the application (request) of the personal data subject does not reflect all the necessary information in accordance with the requirements of the Law on Personal Data, or the subject does not have the right to access the requested information, a reasoned refusal shall be sent to them.
The right of the personal data subject to access their personal data may be limited in accordance with Part 8 of Article 14 of the Law on Personal Data, including if access by the personal data subject to their personal data violates the rights and legitimate interests of third parties.
6.2. If inaccurate personal data is identified upon application of the personal data subject or their representative, or upon their request, or upon request of Roskomnadzor, the Operator shall block the personal data relating to that personal data subject from the moment of such application or receipt of said request for the period of verification, provided that blocking of personal data does not violate the rights and legitimate interests of the personal data subject or third parties.
If the fact of inaccuracy of personal data is confirmed, the Operator shall clarify the personal data within seven working days from the date of submission of such information based on information provided by the personal data subject or their representative or by Roskomnadzor, or other necessary documents, and shall lift the blocking of personal data.
6.3. If unlawful processing of personal data is identified upon application (request) of the personal data subject or their representative, or of Roskomnadzor, the Operator shall block the unlawfully processed personal data relating to that personal data subject from the moment of such application or receipt of the request.
6.4. If the Operator, Roskomnadzor or another interested person identifies a fact of unlawful or accidental transfer (provision, distribution) of personal data (access to personal data) that has resulted in a violation of the rights of personal data subjects, the Operator shall:
6.5.1. Conditions and terms for destruction of personal data by the Operator:
6.5.4. Methods for destroying personal data are established in the Operator's local regulations.
7. Final Provisions
7.1. The absence in this Policy of any provisions of legislation granting rights and/or guarantees to personal data subjects does not diminish the corresponding rights and/or guarantees of such subjects.
7.2. The absence in this Policy of any provisions of legislation establishing obligations and/or liability of the operator does not relieve the operator of the corresponding obligations and/or liability.
7.3. Relations not regulated by this Policy are governed by the current legislation.
7.4. The current version of this Policy is available on the Website at: http://uretek.ru/
The Website Administration (Operator) has the right to make changes to this Policy. When changes are made, the date of the last update is indicated in the current version. The new version of the Policy comes into force from the moment it is posted, unless otherwise provided by the new version of the Policy.
OF GROUND ENGINEERING LIMITED LIABILITY COMPANY
REGARDING THE PROCESSING OF PERSONAL DATA
1. General Provisions
1.1. This Privacy Policy of Ground Engineering Limited Liability Company regarding the processing of personal data (hereinafter – the “Policy”) has been developed in compliance with the requirements of Clause 2, Part 1, Article 18.1 of Federal Law No. 152-FZ dated July 27, 2006 “On Personal Data” (hereinafter – the “Law on Personal Data”) in order to ensure the protection of human and civil rights and freedoms when processing their personal data, including the protection of the rights to privacy, personal and family secrets.
1.2. The Policy applies to all personal data processed by Ground Engineering Limited Liability Company (hereinafter – the “Operator”).
1.3. The Policy extends to relations in the field of personal data processing that arose with the Operator both before and after the approval of this Policy.
1.4. In compliance with the requirements of Part 2, Article 18.1 of the Law on Personal Data, this Policy is published in the public domain on the Operator's website on the information and telecommunications network Internet.
1.5. Basic terms used in the Policy:
- Website – an informational website on the Internet located at: http://uretek.ru/
- Personal data – any information relating directly or indirectly to a specific or identifiable individual (personal data subject);
- Operator of personal data (Operator) – a state body, municipal body, legal entity or individual, independently or jointly with other persons organizing and/or carrying 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;
- Website User – an individual with full legal capacity and capacity, acting on their own behalf and in their own interests, or an individual acting on behalf and/or in the interests of another person, including organizations, regardless of organizational and ownership forms, state authorities and municipalities, who visits the Website. For the purposes of this Policy, the terms “Website User” and “personal data subject” (as defined in Federal Law No. 152-FZ dated July 27, 2006 “On Personal Data”) are synonymous.
- Website Administration – Ground Engineering Limited Liability Company, INN/KPP 7724875560/772401001, OGRN 1137746407897, legal entity address: 115304, Russian Federation, Moscow, intramunicipal territory Tsaritsyno Municipal District, ul. Kaspiyskaya, 22, building 1, structure 4. For the purposes of this Policy, the term “Website Administration” also means the legal entity acting as the Operator.
- Processing of personal data – any action (operation) or set of actions (operations) performed with personal data using automation means or without using such means. Processing of personal data includes, among others: collection; recording; systematization; accumulation; storage; clarification (updating, changing); extraction; use; transfer, including to third parties if necessary in the course of fulfilling obligations (distribution, provision, access); anonymization; blocking; deletion; destruction;
- Automated processing of personal data – processing of personal data using computer technology;
- Distribution of personal data – actions aimed at disclosing personal data to an indefinite circle of persons;
- Provision of personal data – actions aimed at disclosing personal data to a specific person or a specific circle of persons;
- Blocking of personal data – temporary cessation of processing of personal data (except where processing is necessary to clarify personal data);
- Destruction of personal data – actions as a result of which it becomes impossible to restore the content of personal data in the personal data information system and/or as a result of which the physical media of personal data are destroyed;
- Anonymization of personal data – actions as a result of which it becomes impossible without using additional information to determine the ownership of personal data to a specific personal data subject;
- Personal data information system – a set of personal data contained in databases and information technologies and technical means ensuring their processing.
1.6.1. The Operator has the right to:
- independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations provided for by the Law on Personal Data and regulatory legal acts adopted in accordance therewith, unless otherwise provided by the Law on Personal Data or other federal laws;
- entrust the processing of personal data to another person with the consent of the personal data subject, unless otherwise provided by federal law, on the basis of a contract concluded with that person. The person processing personal data on behalf of the Operator must comply with the principles and rules of processing personal data provided for by the Law on Personal Data, maintain the confidentiality of personal data, and take necessary measures aimed at ensuring compliance with the obligations provided for by the Law on Personal Data;
- if the personal data subject withdraws consent to the processing of personal data, the Operator has the right to continue processing personal data without the consent of the personal data subject if there are grounds specified in the Law on Personal Data.
- organize the processing of personal data in accordance with the requirements of the Law on Personal Data. Personal data is processed by the Operator (Website Administration) in full compliance with Federal Law No. 152-FZ dated July 27, 2006 “On Personal Data”, as well as other laws and regulations of the Russian Federation governing this area of relations;
- respond to requests and inquiries from personal data subjects and their legal representatives in accordance with the requirements of the Law on Personal Data;
- inform the authorized body for the protection of the rights of personal data subjects (the Federal Service for Supervision of Communications, Information Technology and Mass Media (Roskomnadzor)) at the request of this body of the necessary information within 10 working days from the date of receipt of such request. This period may be extended, but by no more than five working days. To do this, the Operator must send a reasoned notice to Roskomnadzor indicating the reasons for extending the period for providing the requested information;
- in accordance with the procedure established by the federal executive body authorized in the field of security, ensure interaction with the state system for detecting, preventing and eliminating the consequences of computer attacks on information resources of the Russian Federation, including informing it about computer incidents that have resulted in unlawful transfer (provision, distribution, access) of personal data.
- receive information concerning the processing of his/her personal data, except in cases provided for by federal laws. The information is provided to the personal data subject by the Operator in an accessible form and must not contain personal data relating to other personal data subjects, except where there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Law on Personal Data;
- require the Operator to clarify his/her personal data, block or destroy them if the personal data are incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing, as well as take measures provided by law to protect his/her rights;
- give prior consent to the processing of personal data for the purpose of promoting goods, works and services on the market;
- by providing personal data to the Operator (Website Administration), including by filling out the relevant forms on the Website, an individual specifically and knowingly agrees to their processing by the Operator (Website Administration) or another person on behalf of the Operator and confirms that he/she provides them lawfully and within his/her authority;
- appeal against unlawful actions or inaction of the Operator in processing his/her personal data to Roskomnadzor or in court.
1.9. Responsibility for violation of the requirements of the legislation of the Russian Federation and regulatory acts of Ground Engineering LLC in the field of processing and protection of personal data is determined in accordance with the legislation of the Russian Federation.
2. Purposes of Collecting Personal Data
2.1. The processing of personal data is limited to achieving specific, predetermined and legitimate purposes. Processing of personal data incompatible with the purposes of collecting personal data is not permitted.
2.2. Only personal data that meets the purposes of their processing are subject to processing.
2.3. The Operator processes personal data for the following purposes:
- carrying out its activities in accordance with the Charter of Ground Engineering LLC, including concluding and executing contracts with counterparties;
- fulfillment of labor legislation in the framework of labor and other directly related relations, including: assisting employees in employment, education and career advancement, attracting and selecting candidates for work with the Operator, ensuring personal safety of employees, monitoring the quantity and quality of work performed, ensuring the safety of property, maintaining personnel and accounting records, completing and submitting required reporting forms to authorized bodies, organizing registration in individual (personalized) accounting systems of employees in the compulsory pension insurance and compulsory social insurance systems;
- implementing access control;
- informing Website Users about services provided by the Operator (Website Administration);
- making direct contacts with Users (personal data subjects), including for the purpose of sending notifications and information related to Users' requests and applications;
- consulting Users on matters related to the activities of Ground Engineering LLC.
3. Legal Basis for Processing Personal Data
3.1. The legal basis for processing personal data is a set of regulatory legal acts in execution of which and in accordance with which the Operator processes personal data, including:
- The Constitution of the Russian Federation;
- The Civil Code of the Russian Federation;
- The Labor Code of the Russian Federation;
- The Tax Code of the Russian Federation;
- Federal Law No. 14-FZ dated February 8, 1998 “On Limited Liability Companies”;
- Federal Law No. 402-FZ dated December 6, 2011 “On Accounting”;
- Federal Law No. 167-FZ dated December 15, 2001 “On Compulsory Pension Insurance in the Russian Federation”;
- other regulatory legal acts regulating relations related to the activities of the Operator.
- the Charter of Ground Engineering LLC;
- contracts concluded between the Operator and personal data subjects;
- consent of personal data subjects to the processing of their personal data.
4.1. The content and scope of processed personal data must correspond to the stated processing purposes provided for in Section 2 of this Policy. Processed personal data must not be excessive in relation to the stated purposes of their processing.
4.2. The Operator may process personal data of the following categories of personal data subjects.
4.2.1. Candidates for employment with the Operator – for the purposes of fulfilling labor legislation in the framework of labor and other directly related relations, implementing access control:
- surname, first name, patronymic (if any);
- gender;
- citizenship;
- date and place of birth;
- contact details;
- information about education, work experience, qualifications;
- other personal data provided by candidates in resumes and cover letters.
- surname, first name, patronymic (if any);
- gender;
- citizenship;
- date and place of birth;
- image (photograph);
- passport data;
- address of registration at place of residence;
- actual residential address;
- contact details;
- taxpayer identification number (INN);
- individual personal account insurance number (SNILS);
- information about education, qualifications, professional training and professional development;
- marital status, presence of children, family ties;
- information about employment, including incentives, awards and/or disciplinary sanctions;
- marriage registration data;
- military registration information;
- disability information;
- alimony deduction information;
- income information from previous place of employment;
- other personal data provided by employees in accordance with the requirements of labor legislation.
- surname, first name, patronymic (if any);
- degree of relationship;
- year of birth;
- other personal data provided by employees in accordance with the requirements of labor legislation.
- surname, first name, patronymic (if any);
- date and place of birth;
- passport data;
- address of registration at place of residence;
- contact details;
- position held;
- taxpayer identification number (INN);
- bank account number;
- other personal data provided by clients and counterparties (individuals) necessary for concluding and executing contracts.
- surname, first name, patronymic (if any);
- passport data;
- contact details;
- position held;
- other personal data provided by representatives (employees) of clients and counterparties necessary for concluding and executing contracts.
- surname, first name, patronymic (if any);
- phone number;
- email address;
- other personal data provided by the User at their discretion using the feedback form.
4.4. The Operator does not process special categories of personal data concerning racial or ethnic origin, political views, religious or philosophical beliefs, health status, or intimate life, except in cases provided for by the legislation of the Russian Federation.
5. Procedure and Conditions for Processing Personal Data
5.1. The processing of personal data is carried out by the Operator in accordance with the requirements of the legislation of the Russian Federation.
5.2. The processing of personal data is carried out with the consent of personal data subjects to the processing of their personal data, as well as without such consent in cases provided for by the legislation of the Russian Federation.
5.3. The Operator processes personal data for each purpose of their processing in the following ways:
- non-automated processing of personal data;
- automated processing of personal data with or without transfer of the information received via information and telecommunications networks;
- mixed processing of personal data.
5.5. The processing of personal data for each processing purpose specified in clause 2.3 of the Policy is carried out by:
- receiving personal data orally and in writing directly from personal data subjects;
- entering personal data into journals, registers and information systems of the Operator;
- using other methods of processing personal data.
5.7. The transfer of personal data to bodies of inquiry and investigation, the Federal Tax Service, the Social Fund of Russia and other authorized executive bodies and organizations is carried out in accordance with the requirements of the legislation of the Russian Federation.
5.8. The Operator takes necessary legal, organizational and technical measures to protect personal data from unlawful or accidental access, destruction, alteration, blocking, distribution and other unauthorized actions, including:
- identifying threats to the security of personal data during their processing;
- adopting local regulations and other documents regulating relations in the field of processing and protection of personal data;
- appointing persons responsible for ensuring the security of personal data in structural units and information systems of the Operator;
- creating the necessary conditions for working with personal data;
- organizing the recording of documents containing personal data;
- organizing work with information systems in which personal data is processed;
- storing personal data under conditions that ensure their safety and preclude unauthorized access;
- organizing training for employees of the Operator who process personal data.
5.9.1. Personal data on paper is stored by Ground Engineering LLC for the retention periods of documents for which such periods are provided by the legislation on archiving in the Russian Federation (Federal Law No. 125-FZ dated October 22, 2004 “On Archiving in the Russian Federation”, the List of Standard Administrative Archival Documents Generated in the Course of Activities of State Bodies, Local Self-Government Bodies and Organizations, Indicating Their Retention Periods (approved by Order of Rosarkhiv No. 236 dated December 20, 2019)).
5.9.2. The retention period for personal data processed in personal data information systems corresponds to the retention period for personal data on paper.
5.10. The Operator terminates processing of personal data in the following cases:
- a fact of unlawful processing is identified – within three working days from the date of identification;
- the purpose of their processing is achieved;
- the consent period expires or the consent of the personal data subject to the processing of such data is withdrawn, when under the Law on Personal Data processing of such data is permitted only with consent.
- otherwise provided by an agreement to which the personal data subject is a party, beneficiary or guarantor;
- the Operator is not entitled to process without the consent of the personal data subject on grounds provided for by the Law on Personal Data or other federal laws;
- otherwise provided by another agreement between the Operator and the personal data subject.
5.13. When collecting personal data, including via the information and telecommunications network Internet, the Operator ensures the recording, systematization, accumulation, storage, clarification (updating, changing), and extraction of personal data of citizens of the Russian Federation using databases located on the territory of the Russian Federation, except for cases specified in the Law on Personal Data.
6. Updating, Correction, Deletion, Destruction of Personal Data, Responses to Requests from Subjects for Access to Personal Data
6.1. Confirmation of the fact of processing of personal data by the Operator, the legal basis and purposes of processing personal data, as well as other information specified in Part 7 of Article 14 of the Law on Personal Data, shall be provided by the Operator to the personal data subject or their representative within 10 working days from the date of application or receipt of the request from the personal data subject or their representative. This period may be extended, but by no more than five working days. To do this, the Operator must send a reasoned notice to the personal data subject indicating the reasons for extending the period for providing the requested information.
The information provided shall not include personal data relating to other personal data subjects, except where there are legal grounds for disclosing such personal data.
The request must contain:
- the number of the main identity document of the personal data subject or their representative, information on the date of issue of said document and the issuing authority;
- information confirming the participation of the personal data subject in relations with the Operator (contract number, contract date, conditional verbal designation and/or other information), or information otherwise confirming the fact that the Operator processes personal data;
- the signature of the personal data subject or their representative.
The Operator provides the information specified in Part 7 of Article 14 of the Law on Personal Data to the personal data subject or their representative in the form in which the corresponding application or request was submitted, unless otherwise specified in the application or request.
If the application (request) of the personal data subject does not reflect all the necessary information in accordance with the requirements of the Law on Personal Data, or the subject does not have the right to access the requested information, a reasoned refusal shall be sent to them.
The right of the personal data subject to access their personal data may be limited in accordance with Part 8 of Article 14 of the Law on Personal Data, including if access by the personal data subject to their personal data violates the rights and legitimate interests of third parties.
6.2. If inaccurate personal data is identified upon application of the personal data subject or their representative, or upon their request, or upon request of Roskomnadzor, the Operator shall block the personal data relating to that personal data subject from the moment of such application or receipt of said request for the period of verification, provided that blocking of personal data does not violate the rights and legitimate interests of the personal data subject or third parties.
If the fact of inaccuracy of personal data is confirmed, the Operator shall clarify the personal data within seven working days from the date of submission of such information based on information provided by the personal data subject or their representative or by Roskomnadzor, or other necessary documents, and shall lift the blocking of personal data.
6.3. If unlawful processing of personal data is identified upon application (request) of the personal data subject or their representative, or of Roskomnadzor, the Operator shall block the unlawfully processed personal data relating to that personal data subject from the moment of such application or receipt of the request.
6.4. If the Operator, Roskomnadzor or another interested person identifies a fact of unlawful or accidental transfer (provision, distribution) of personal data (access to personal data) that has resulted in a violation of the rights of personal data subjects, the Operator shall:
- within 24 hours – notify Roskomnadzor of the incident, the alleged causes that led to the violation of the rights of personal data subjects, the alleged harm caused to the rights of personal data subjects, and the measures taken to eliminate the consequences of the incident, as well as provide information about the person authorized by the Operator to interact with Roskomnadzor on issues related to the incident;
- within 72 hours – notify Roskomnadzor of the results of the internal investigation of the identified incident and provide information about the persons whose actions caused it (if any).
6.5.1. Conditions and terms for destruction of personal data by the Operator:
- achievement of the purpose of processing personal data or loss of the need to achieve this purpose – within 30 days;
- achievement of the maximum retention periods for documents containing personal data – within 30 days;
- submission by the personal data subject (their representative) of confirmation that the personal data was obtained unlawfully or is not necessary for the stated purpose of processing – within seven working days;
- withdrawal by the personal data subject of consent to the processing of their personal data, if their retention for the purpose of processing is no longer required – within 30 days.
- otherwise provided by an agreement to which the personal data subject is a party, beneficiary or guarantor;
- the Operator is not entitled to process without the consent of the personal data subject on grounds provided for by the Law on Personal Data or other federal laws;
- otherwise provided by another agreement between the Operator and the personal data subject.
6.5.4. Methods for destroying personal data are established in the Operator's local regulations.
7. Final Provisions
7.1. The absence in this Policy of any provisions of legislation granting rights and/or guarantees to personal data subjects does not diminish the corresponding rights and/or guarantees of such subjects.
7.2. The absence in this Policy of any provisions of legislation establishing obligations and/or liability of the operator does not relieve the operator of the corresponding obligations and/or liability.
7.3. Relations not regulated by this Policy are governed by the current legislation.
7.4. The current version of this Policy is available on the Website at: http://uretek.ru/
The Website Administration (Operator) has the right to make changes to this Policy. When changes are made, the date of the last update is indicated in the current version. The new version of the Policy comes into force from the moment it is posted, unless otherwise provided by the new version of the Policy.
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