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LLC “Sperasoft Studio” Personal Data Processing Policy

  1. General Provisions
    The following Personal Data Processing Policy of the Limited Liability Company “Sperasoft Studio” (hereinafter – the Operator), Tax Identification Number (INN) 7801498077, located at 5A Kievskaya St, St.Petersburg, Russia, is prepared in keeping with the Constitution of the Russian Federation, the Russian Federation Labor Law, the Russian Federation Civil Code, Federal Act #149-FZ of July 27, 2006 “On information, Information Technology and information protection”, Federal Act #152-FZ of July 27, 2006 “On personal data”, the Russian Federation Government Regulation #1119 of November 1, 2012 “On Approval of requirements to protect personal data during its processing in the informational personal data systems”, by other federal acts, laws and regulations.

    1. Personal data processing policy is designed to protect human rights and freedoms of citizens in the processing of his/her personal data;
    2. Policy Provisions serve as a platform for development of local legal acts which regulate issues related to personal data processing of “Sperasoft Studio” employees and other entities.
  2. The following general terms are used in this Provision
    1. Personal data –any information directly or indirectly concerning identified or defined individual (personal data subject);
    2. Operator – a state body, a municipal authority, a legal entity or an individual that individually or in cooperation with other entities provides organization and/or processing of personal data, and determines purposes of data processing, composition of personal data to be processed, actions (operations) performed with personal data;
    3. personal data processing – any action (operation) or a complex of actions (operations) with personal data performed with or without automation equipment, including collection, recording, systematization, accumulation, storage, specification (updating, modification),extraction, use, transfer (distribution, provision, access), depersonalization, blocking, removal, destruction of personal data;
    4. automated personal data processing – personal data processing by means of computational tools;
    5. personal data distribution – actions designed to disclose personal data to any number of unspecified persons;
    6. personal data provision – actions designed to disclose personal data to a specific person or a specific group of persons;
    7. personal data blocking – temporary suspension of personal data processing (unless processing is necessary to re-confirm personal data);
    8. personal data destruction – actions as a result of which it is impossible to recover personal data in the information system and (or) which result in destruction of tangible mediums with personal data;
    9. personal data depersonalization – actions as a result of which additional information is required to determine an individual to whom the personal data belongs;
    10. personal data information system – a combination of personal data database and IT and technical means which process it;
    11. personal data cross-border transfer – personal data transfer to the Authority of a foreign state, a foreign individual and a foreign legal entity.
  3. Operator can process the following personal data
    1. Last name, first name, patronymic (middle name);
    2. Email address;
    3. Telephone numbers;
    4. Date and place of birth;
    5. Identification document data;
    6. Residence and registration address;
    7. Education, profession, qualification information, academic credentials details.
  4. The purposes of personal data processing
    Operator processes personal data in order to:

    1. Implement and deliver functions, powers and responsibilities prescribed by the Russian legislation, in particular:
      • To comply with the requirements of the legislation regarding labor standards and taxation;
      • To manage current bookkeeping and tax accounting, to prepare and submit accounting, tax and statistical reports in a timely fashion;
      • To comply with the requirements of the legislation regarding processing and protection procedures of the “Sperasoft Studio” employees’ personal data or to assist job seeing candidates (hereinafter – personal data subjects).
    2. To exercise rights and legitimate interests by exercising types of activities provided by the Charter and other local legal acts of LLC “Sperasoft Studio”;
    3. For other legitimate purposes.
  5. Legal Grounds for Personal Data Processing
    Personal data processing is performed on the basis of the following federal acts, laws and regulations:

    1. Constitution of the Russian Federation;
    2. The Russian Federation Labor Law
    3. Federal Act #152-FZ of July 27, 2006 “On personal data”;
    4. Federal Act #149-FZ of July 27, 2006 “On information, Information Technology and information protection”;
    5. The Russian Federation Government Resolution # 687 of September 15, 2008 “On the approval of the Provision on the special features of the personal data processing performed without automation facilities”;
    6. The Russian Federation Government Resolution # 1119 of November , 2012 “On the approval of the personal data protection during its processing in the personal data information system”;
    7. Order # 21 of February 18, 2012 of the FSTEK of Russia “On the approval of the composition and content of the organizational and technical security measures during personal data processing in the personal data information systems”;
    8. Roskomnadzor Order # 996 of September 5, 2013 “On the approval of the requirements and methods of personal data depersonalization”;
    9. Other laws and regulations of the Russian Federation and regulatory instruments of the authorized state agencies.
  6. List of Actions with Personal Data
    1. The Operator will perform the following actions during personal data processing: collection, recording, systematization, accumulation, storage, specification (updating, modification),extraction, use, transfer (distribution, provision, access), depersonalization, blocking, removal, destruction of personal data;
    2. Job applicants’ personal data is processed only when it is filled out and/or sent in using special forms on the website: https://sperasoft.com/career/. Filling out these forms and/or providing operator with his/her personal data, the candidate agrees to the given Policy.
  7. Processed Data Composition
    1. The following personal data subjects are subject to personal data processing by the Operator:
      • The Operator’s employees;
      • Job applicants;
      • Individuals addressing the Operator in concordance with the procedure established by the Federal Act “On the procedure of the consideration of applications from citizens of the Russian Federation”.
    2. The composition of personal data of each category of subjects listed in paragraph 7.1. of this Provision is determined by regulatory instruments listed in section 3 of this Provision;
    3. Personal data subject decides to provide the Operator with personal data and agrees to its processing of his/her own free will and volition and his/her own interest as prescribed by effective legislation;
    4. The Operator ensures that the processed data content and volume complies with stated goals and, if needed, takes measures to eliminate excessive data.
    5. Certain categories of personal data concerning race, nationality, political affiliation and views, religious and philosophical beliefs and convictions, private life are not processed by LLC “Sperasoft Studio”.
  8. Personal Data Processing
    1. LLC “Sperasoft Studio” performs personal data processing in the following ways:
      • Non-automated personal data processing;
      • Automated personal data processing with or without transfer of the information obtained using information telecommunication networks;
      • Mixed personal data processing.
  9. Personal Data Protection during its Processing by the Operator
    1. The Operator takes necessary and sufficient actions to ensure performance of duties under the Federal Act #152-FZ of July 27, 2006 “On personal data” and the laws and regulations adopted pursuant to that Act. The Operator determines the list of measures necessary and sufficient to ensure performance of duties under the Federal Act #152-FZ of July 27, 2006 “On personal data”, the Russian Federation Government Resolution # 687 of September 15, 2008 “On the approval of the Provision on the features of the personal data processing performed without automation facilities”, the Russian Federation Government Resolution # 1119 of November 1, 2012 “On the approval of the personal data protection during its processing in the personal data information system”, order # 21 of February 18, 2012 of the FSTEK of Russia “On the approval of the composition and content of the organizational and technical security measures during personal data processing in the personal data information systems”, and other regulatory legal instruments unless otherwise specified by federal acts. Such measures include:
      • The nomination of an individual responsible for personal data processing;
      • Publication of documents which define the Operator’s policy concerning personal data processing, pieces of local legislation concerning personal data processing, as well as pieces of local legislation establishing procedures to prevent and reveal violations of Russian law, the measures taken to address such violations;
      • Application of legal, organizational and technical measures to provide personal data security;
      • Implementation of internal control and(or) personal data processing audit to check compliance with the Federal Act “On personal data” and the legislative acts adopted pursuant to it, the requirements to protect personal data, the Operator’s policy with regard to personal data processing, the Operator’s local acts;
      • Estimating the risk of harm to personal data subjects which can be caused in the event of violation of the Federal Act “On personal data”, correlation of the caused harm and the actions ta ken by the operator intended to ensure performance of duties defined in the Federal Act “On personal data”;
      • Familiarizing the Operator’s staff members processing personal data with the provisions on personal data legislation, including personal data protection, documents determining the Operator’s policy regarding personal data processing, local regulations on personal data processing, and (or) training of staff members concerned.
    2. Processing personal data, the Operator takes necessary legal, organizational and technical measures and ensures their implementation to protect personal data from illegal or accidental access, destruction, modification, blocking, copying, provision, distribution, as well as other illegal actions.
  10. Cross-border Personal Data Transfer
    1. Prior to personal data cross-border transfer, the Operator has to make sure that a receiving foreign state provides a strong protection of rights to personal data subjects;
    2. Cross-border personal data transfer in foreign states which do not provide adequate protection of subject’s rights can be carried out only when subject’s written consent has been submitted.
  11. Personal Data Subject’s Right to Access his/her Personal Data
    1. Personal data subject has the right to demand that the Operator clarify personal data, block or delete it if personal data is incomplete, outdated, inaccurate, obtained illegally or is not required for the stated processing goal, as well as take appropriate measures to protect their rights established by the law
    2. The Operator provides personal data subject (or his/her representative) with information upon subject’s (or his/her representative’s) request. The request should contain subject’s (or representative’s) identification document data (number of the document, the date and place of issue, the issuing authority), information which proves subject’s relations with the Operator (contract number, contract date, conventional verbal mark and (or) other information) or information which otherwise confirms the Operator’s personal data processing, signature of personal data subject (or his/her representative). By the Russian Federation law the request can be filed and signed electronically.
    3. The Operator has the right to refuse a second request. Reasons must be provided for such refusal. The Operator is responsible for providing grounds for any refusals.
    4. Personal data subject has the right to information concerning his/her personal data processing, including information containing:
      • The Operator’s personal data processing confirmation;
      • Legal grounds for personal data processing;
      • Goals and applicable ways of personal data processing by the Operator;
      • The Operator’s name and location, information on any person (except for the Operator’s staff members) who has access to personal data or to whom personal data may be disclosed on the grounds of agreement with the Operator, or on the basis of the federal law;
      • Processed personal data concerning relevant personal data subject , and data source unless otherwise specified by the federal law;
      • Timeframes for personal data processing and storage;
      • Procedures for exercising personal data subject’s rights specified by the Federal Act “On personal data”;
      • Information on performed or anticipated cross-border personal data transfer;
      • Title or last name, first name, middle name (patronymic) and address of any person conducting personal data processing under the Operator’s instructions, given such person is entrusted or will be entrusted with data processing;
    5. If personal data subject believes that the Operator processes his/her personal data in violation of the requirements of the Federal Act “On personal data” or otherwise violates his/her rights and freedoms, personal data subject is entitled to appeal the Operator’s activity or inactivity to the authorized body responsible for protection of rights of personal data subjects.
    6. Personal data subject is entitled to protection of his/her rights and legal interests including compensation for damages and (or) reparation for moral damage in accordance with judicial procedures.
  12. Final Provisions
    1. Personal data subject can receive an answer to any question concerning personal data processing at security@sperasoft.com;
    2. Any changes to the personal data processing Policy will be reflected in this document. This Policy is valid for an indefinite period until replaced by a new version.

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Hiring Workflow

Sperasoft provides a challenging and exciting career path to help you learn, grow and contribute.

The quality and commitment of our professionals create a conducive working environment and enhance our growth and success. We are always glad to welcome talented individuals in our offices in St. Petersburg, Volgograd and Krakow.

There are many great applicants for our openings so here are some tips on how to succeed in hiring process and become a part of #sperasoftteam

  • We review a CV within 5 days. The Recruiter will get back to you if we have any positive feedback
  • We usually have a phone or Skype interview before the onsite one
  • Depending on the role you’re applying for you might have 2 to 4 interviews
  • For non-local candidates most of interviews are made remotely by Skype, although Sperasoft might organize a visit to the studio to which you’re applying
  • After the interview we might need time to review more candidates and make a decision. Don’t hesitate to contact your Recruiter to get feedback
  • In our company we communicate in English, so please submit your CV in English and be prepared for the interview to be held in English as well
  • If you’re an Artist please submit your portfolio along with your CV
  • If applying for Designer roles please support your application by sending us examples of your design documentation
  • Please list the names of projects you’ve previously worked on