Personal Data Processing Policy
1. General Provisions
This personal data processing policy has been drawn up in accordance with the requirements of Federal Law No. 152-FZ of 27.07.2006 "On Personal Data" (hereinafter — the Personal Data Law) and defines the procedure for processing personal data and the measures taken to ensure the security of personal data by LLC "AVTOZHIZN" (hereinafter — the Operator).
1.1. The Operator considers the observance of the rights and freedoms of individuals in the processing of their personal data, including the protection of the right to privacy, personal and family confidentiality, to be its primary goal and condition for carrying out its activities.
1.2. This Operator policy on personal data processing (hereinafter — the Policy) applies to all information that the Operator may obtain about visitors to the website https://carlifecare.en.
2. Key Terms Used in the Policy
2.1. Automated processing of personal data — processing of personal data using computer technology.
2.2. Blocking of personal data — temporary suspension of personal data processing (except where processing is necessary to clarify personal data).
2.3. Website — a set of graphic and informational materials, as well as computer programs and databases ensuring their availability on the internet at https://carlifecare.en.
2.4. Personal data information system — a set of personal data contained in databases and the information technologies and technical means ensuring their processing.
2.5. Depersonalisation of personal data — actions as a result of which it is impossible to determine, without the use of additional information, whether personal data belongs to a specific User or other personal data subject.
2.6. Processing of personal data — any action (operation) or set of actions (operations) performed with or without the use of automation tools on personal data, including collection, recording, systematisation, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalisation, blocking, deletion, and destruction of personal data.
2.7. Operator — a state authority, municipal authority, legal entity or individual that independently or jointly with others organises and/or carries out the processing of personal data, and also determines the purposes of personal data processing, the composition of personal data subject to processing, and the actions (operations) performed with personal data.
2.8. Personal data — any information relating directly or indirectly to a specific or identifiable User of the website https://carlifecare.en.
2.9. Personal data authorised by the data subject for distribution — personal data to which unlimited access has been granted by the data subject by giving consent to the processing of personal data authorised for distribution in the manner provided for by the Personal Data Law (hereinafter — personal data authorised for distribution).
2.10. User — any visitor to the website https://carlifecare.en.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Distribution of personal data — any actions aimed at disclosing personal data to an unspecified group of persons (transfer of personal data) or at making personal data available to an unlimited group of persons, including publication of personal data in the media, placement in information and telecommunication networks, or provision of access to personal data by any other means.
2.13. Cross-border transfer of personal data — transfer of personal data to the territory of a foreign state to a foreign state authority, a foreign individual, or a foreign legal entity.
2.14. Destruction of personal data — any actions as a result of which personal data is irreversibly destroyed with no possibility of further restoration of the content of personal data in the personal data information system and/or the physical carriers of personal data are destroyed.
3. Basic Rights and Obligations of the Operator
3.1. The Operator has the right to: — receive reliable information and/or documents containing personal data from the personal data subject; — in the event that the personal data subject withdraws consent to the processing of personal data, or submits a request to cease processing of personal data, the Operator has the right to continue processing personal data without the consent of the personal data subject where grounds specified in the Personal Data Law exist; — independently determine the composition and list of measures necessary and sufficient to fulfil the obligations provided for by the Personal Data Law and the regulatory legal acts adopted in accordance therewith, unless otherwise provided by the Personal Data Law or other federal laws.
3.2. The Operator is obliged to: — provide the personal data subject, upon their request, with information relating to the processing of their personal data; — organise the processing of personal data in the manner established by the current legislation of the Russian Federation; — respond to requests and enquiries from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law; — communicate to the authorised body for the protection of the rights of personal data subjects, upon request, the necessary information within 10 days from the date of receipt of such request; — publish or otherwise ensure unrestricted access to this personal data processing Policy; — take legal, organisational and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision, distribution, and other unlawful actions with respect to personal data; — cease the transfer (distribution, provision, access) of personal data, cease processing and destroy personal data in the manner and cases provided for by the Personal Data Law; — fulfil other obligations provided for by the Personal Data Law.
4. Basic Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects have the right to: — receive information relating to the processing of their personal data, except in cases provided for by federal laws. 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 lawful grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law; — require the Operator to clarify, block or destroy their personal data if the personal data is incomplete, outdated, inaccurate, unlawfully obtained or not necessary for the stated purpose of processing, and also to take measures prescribed by law to protect their rights; — stipulate a precondition of prior consent when personal data is processed for the purposes of market promotion of goods, works and services; — withdraw consent to the processing of personal data, and also submit a request to cease the processing of personal data; — appeal to the authorised body for the protection of the rights of personal data subjects, or through judicial proceedings, against unlawful actions or inaction of the Operator in the processing of their personal data; — exercise other rights provided for by the legislation of the Russian Federation.
4.2. Personal data subjects are obliged to: — provide the Operator with accurate information about themselves; — notify the Operator of any updates (changes) to their personal data.
4.3. Persons who have provided the Operator with inaccurate information about themselves, or information about another personal data subject without the latter's consent, shall be liable in accordance with the legislation of the Russian Federation.
5. Principles of Personal Data Processing
5.1. Personal data is processed on a lawful and fair basis.
5.2. Processing of personal data is limited to achieving specific, predetermined and lawful purposes. Processing of personal data that is incompatible with the purposes of personal data collection is not permitted.
5.3. The merging of databases containing personal data whose processing is carried out for purposes that are incompatible with each other is not permitted.
5.4. Only personal data that meets the purposes of its processing shall be processed.
5.5. The content and volume of personal data processed correspond to the stated purposes of processing. Excessive processing of personal data in relation to the stated purposes of its processing is not permitted.
5.6. When processing personal data, the accuracy, sufficiency and, where necessary, relevance of personal data in relation to the purposes of personal data processing is ensured. The Operator takes the necessary measures and/or ensures that measures are taken to delete or clarify incomplete or inaccurate data.
5.7. Personal data is stored in a form that allows the identification of the personal data subject for no longer than required by the purposes of personal data processing, unless the storage period of personal data is established by federal law or by a contract to which the personal data subject is a party, beneficiary or guarantor. Processed personal data is destroyed or depersonalised upon achievement of the processing purposes or in the event that the need to achieve those purposes is lost, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing
Purpose of processing: providing the User with access to the services, information and/or materials contained on the website. Personal data: last name, first name, patronymic; email address; telephone numbers. Legal basis: Federal Law "On Information, Information Technologies and Information Protection" No. 149-FZ of 27.07.2006. Types of personal data processing: collection, recording, systematisation, accumulation, storage, destruction and depersonalisation of personal data; sending of informational emails to the email address.
7. Conditions for Personal Data Processing
7.1. Personal data is processed with the consent of the personal data subject to the processing of their personal data.
7.2. Processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, and to carry out the functions, powers and obligations imposed on the Operator by the legislation of the Russian Federation.
7.3. Processing of personal data is necessary for the administration of justice, the execution of a court order, or an act of another authority or official subject to enforcement in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. Processing of personal data is necessary for the performance of a contract to which the personal data subject is a party, beneficiary or guarantor, as well as for the conclusion of a contract at the initiative of the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor.
7.5. Processing of personal data is necessary to exercise the rights and legitimate interests of the Operator or third parties, or to achieve socially significant goals, provided that the rights and freedoms of the personal data subject are not violated.
7.6. Processing is carried out of personal data to which unrestricted access has been granted by the personal data subject or at their request (hereinafter — publicly available personal data).
7.7. Processing is carried out of personal data subject to publication or mandatory disclosure in accordance with federal law.
8. Procedure for Collection, Storage, Transfer and Other Types of Personal Data Processing
The security of personal data processed by the Operator is ensured through the implementation of legal, organisational and technical measures necessary to fully meet the requirements of current legislation in the field of personal data protection.
8.1. The Operator ensures the security of personal data and takes all possible measures to prevent access to personal data by unauthorised persons.
8.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to compliance with applicable law or where the personal data subject has given the Operator consent to transfer data to a third party for the performance of obligations under a civil law contract.
8.3. If inaccuracies are identified in personal data, the User may update it independently by sending the Operator a notification to the Operator's email address adambrakk@yandex.ru marked "Personal Data Update".
8.4. The period of personal data processing is determined by the achievement of the purposes for which the personal data was collected, unless a different period is provided for by contract or applicable law. The User may at any time withdraw their consent to the processing of personal data by sending the Operator a notification by email to adambrakk@yandex.ru marked "Withdrawal of Consent to Personal Data Processing".
8.5. All information collected by third-party services, including payment systems, communication services and other service providers, is stored and processed by those persons (Operators) in accordance with their User Agreement and Privacy Policy. The Operator is not responsible for the actions of third parties, including the service providers referred to in this clause.
8.6. Restrictions established by the personal data subject on the transfer (other than access provision), processing or conditions of processing of personal data authorised for distribution do not apply in cases of processing of personal data in state, public and other public interests determined by the legislation of the Russian Federation.
8.7. The Operator ensures the confidentiality of personal data when processing it.
8.8. The Operator stores personal data in a form that allows the identification of the personal data subject for no longer than required by the purposes of personal data processing, unless the storage period is established by federal law or by a contract to which the personal data subject is a party, beneficiary or guarantor.
8.9. The grounds for terminating the processing of personal data may include the achievement of the purposes of processing, the expiry of the personal data subject's consent, the withdrawal of consent by the personal data subject or a request to cease processing, as well as the identification of unlawful processing of personal data.
9. List of Actions Performed by the Operator with Received Personal Data
9.1. The Operator carries out collection, recording, systematisation, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalisation, blocking, deletion and destruction of personal data.
9.2. The Operator carries out automated processing of personal data with or without the receipt and/or transfer of information obtained via information and telecommunication networks.
10. Cross-Border Transfer of Personal Data
10.1. Prior to commencing cross-border transfer of personal data, the Operator is obliged to notify the authorised body for the protection of the rights of personal data subjects of its intention to carry out cross-border transfer of personal data (such notification is sent separately from the notification of the intention to process personal data).
10.2. Prior to submitting the above notification, the Operator is obliged to obtain the relevant information from the foreign state authorities, foreign individuals, and foreign legal entities to whom the cross-border transfer of personal data is planned.
11. Confidentiality of Personal Data
The Operator and other persons who have obtained access to personal data are obliged not to disclose personal data to third parties and not to distribute personal data without the consent of the personal data subject, unless otherwise provided by federal law.
12. Final Provisions
12.1. The User may obtain any clarification on matters of interest relating to the processing of their personal data by contacting the Operator by email at adambrakk@yandex.ru.
12.2. Any changes to the Operator's personal data processing policy will be reflected in this document. The Policy is valid indefinitely until replaced by a new version.
12.3. The current version of the Policy is freely available on the internet at https://carlifecare.en.