1. General Provisions
This personal data processing policy is drawn up in accordance with the requirements of Federal Law No. 152-FZ “On Personal Data” dated July 27, 2006 (hereinafter referred to as the Personal Data Law) and defines the procedure for processing personal data and measures to ensure the security of personal data taken by the Administration of the CarVOG online resource (hereinafter referred to as the Operator).
1.1. The Operator considers compliance with human and civil rights and freedoms in the processing of personal data, including the protection of the right to privacy, personal and family secrets, as its primary objective and condition for conducting its activities.
1.2. This Operator’s policy regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator may obtain about visitors to the website https://carvog.ru.
2. Basic 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).
— A collection of graphical and informational materials, as well as computer programs and databases that ensure their availability on the internet at the network address https://carvog.ru.
2.4. Information System of Personal Data — A collection of personal data contained in databases and the information technology and technical means ensuring their processing.
2.5. Depersonalization of Personal Data — Actions resulting in the inability to determine, without additional information, the affiliation of personal data to a specific User or other subject of personal data.
2.6. Processing of Personal Data — Any action (operation) or set of actions (operations) performed using automation tools or without them concerning personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
2.7. Operator — A state authority, municipal authority, legal or physical entity that independently or jointly with others organizes and/or performs the processing of personal data, as well as determines the purposes of processing personal data, the composition of personal data to be processed, and actions (operations) performed with personal data.
2.8. Personal Data — Any information directly or indirectly related to a specific or identifiable User of the website https://carvog.ru.
2.9. Personal Data Allowed for Distribution — Personal data to which an unlimited number of persons have been granted access by the subject of personal data through consent to the processing of personal data allowed for distribution, in accordance with the procedure established by the Personal Data Law (hereinafter referred to as personal data allowed for distribution).
2.10. User — Any visitor to the website https://carvog.ru.
2.11. Provision of Personal Data — Actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Dissemination of Personal Data — Any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or making personal data available to an indefinite number of persons, including publishing personal data in the media, placing it in information and telecommunications networks, or providing access to personal data in any other way.
2.13. Cross-Border Transfer of Personal Data — Transfer of personal data to the territory of a foreign state, a foreign state authority, a foreign individual, or a foreign legal entity.
2.14. Destruction of Personal Data — Any actions resulting in the irreversible destruction of personal data with the inability to further restore the content of personal data in the personal data information system and/or the destruction of personal data’s physical carriers.
3. Main Rights and Obligations of the Operator
3.1. The Operator has the right to:
— Receive accurate information and/or documents containing personal data from the subject of personal data;
— Continue processing personal data without the consent of the data subject in cases specified by the Personal Data Law;
— Independently determine the composition and list of necessary measures to ensure compliance with legal requirements regarding the protection of personal data.
3.2. The Operator is obliged to:
— Provide the subject of personal data, upon request, with information regarding the processing of their personal data;
— Organize the processing of personal data in accordance with applicable Russian Federation legislation;
— Respond to requests and inquiries from data subjects and their legal representatives;
— Report necessary information to the authorized body for the protection of personal data subjects’ rights within ten days of receiving a request;
— Publish or otherwise provide unrestricted access to this Privacy Policy;
— Implement legal, organizational, and technical measures to protect personal data;
— Cease the processing and destroy personal data upon achieving processing objectives or in cases of unlawful processing.
4. Main Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects have the right to:
— Receive information regarding the processing of their personal data, except in cases specified by law;
— Request the Operator to clarify, block, or delete their personal data if it is incomplete, outdated, inaccurate, illegally obtained, or not necessary for the declared purpose of processing;
— Require prior consent for the processing of personal data for marketing purposes;
— Withdraw consent for the processing of personal data;
— File complaints regarding unlawful data processing with the authorized body or in court.
4.2. Personal data subjects are obliged to:
— Provide the Operator with accurate personal data;
— Notify the Operator of updates (modifications) to their personal data.
5. Principles of Personal Data Processing
5.1. The processing of personal data is carried out on a lawful and fair basis.
5.2. The processing of personal data is limited to achieving specific, predetermined, and lawful purposes. The processing of personal data that is incompatible with the purposes of collecting personal data is not allowed.
5.3. The merging of databases containing personal data, which are processed for purposes incompatible with each other, is not allowed.
5.4. Only personal data that meet the purposes of their processing are subject to processing.
5.5. The content and volume of the processed personal data must correspond to the stated purposes of processing. The processing of excessive personal data in relation to the declared purposes of their processing is not allowed.
5.6. When processing personal data, the accuracy, sufficiency, and, when necessary, relevance of personal data in relation to the purposes of processing must be ensured. The Operator takes necessary measures and/or ensures their implementation to delete or clarify incomplete or inaccurate data.
5.7. Personal data is stored in a form that allows for the identification of the personal data subject no longer than required for the purposes of personal data processing, unless a storage period for personal data is established by federal law, a contract to which the personal data subject is a party, beneficiary, or guarantor. The processed personal data is destroyed or depersonalized upon achieving the purposes of processing or if the need to achieve these purposes is lost, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing
Purpose of processing: Informing the User by sending emails and/or phone calls.
Personal data: Surname, first name, patronymic, email address, phone numbers.
Legal grounds: The Operator’s charter (founding) documents.
Types of personal data processing: Collection, recording, systematization, accumulation, storage, destruction, and depersonalization of personal data.
– Distribution of information requested by the User by the Operator, conducting informational mailings by the Operator to the Users’ email addresses, providing access to the functionality and information available on the website, and other purposes in accordance with the website’s functionality.
7. Conditions for Personal Data Processing
7.1. Personal data processing is carried out with the consent of the personal data subject for the processing of their personal data.
7.2. The processing of personal data is necessary for achieving purposes provided for by an international treaty of the Russian Federation or law, for carrying out the functions, powers, and obligations imposed on the Operator by the legislation of the Russian Federation.
7.3. The processing of personal data is necessary for the administration of justice, execution of a court ruling, or an act of another body or official subject to execution under the legislation of the Russian Federation on enforcement proceedings.
7.4. The 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. The processing of personal data is necessary for the exercise of the rights and legitimate interests of the Operator or third parties or for achieving socially significant goals, provided that this does not violate the rights and freedoms of the personal data subject.
7.6. The processing of personal data that has been made publicly available by the personal data subject or at their request (hereinafter referred to as “publicly available personal data”) is carried out.
7.7. The processing of personal data that is subject to publication or mandatory disclosure in accordance with federal law is carried out.
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, organizational, and technical measures necessary for full compliance with the current legislation on personal data protection.
8.1. The Operator ensures the security of personal data and takes all possible measures to prevent unauthorized access to personal data.
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 legislation or when the personal data subject has given the Operator consent to transfer data to a third party for the fulfillment of obligations under a civil law contract.
8.3. If inaccuracies in personal data are identified, the User can update them independently by sending a notification to the Operator’s email address at arenda@carvog.ru with the subject “Personal Data Update.”
8.4. The duration of personal data processing is determined by the achievement of the purposes for which the personal data was collected, unless another period is specified by contract or applicable legislation.
The User may withdraw their consent to personal data processing at any time by sending a notification to the Operator via email at arenda@carvog.ru with the subject “Withdrawal of Consent for Personal Data Processing.”
8.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by these entities (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject should familiarize themselves with these documents. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this section.
8.6. Restrictions imposed by the personal data subject on the transfer (except for granting access), as well as on processing or conditions of processing (except for access) of personal data authorized for dissemination, do not apply in cases where personal data is processed in the interest of the state, society, or other public interests as defined by Russian law.
8.7. The Operator ensures the confidentiality of personal data during its processing.
8.8. The Operator stores personal data in a form that allows identifying the personal data subject for no longer than required to achieve the purposes of personal data processing, unless a longer retention period is established by federal law or a contract to which the personal data subject is a party, beneficiary, or guarantor.
8.9. The processing of personal data may be terminated upon achieving the purposes of processing, expiration of the personal data subject’s consent, withdrawal of consent by the personal data subject, a request to cease processing, or the detection of unlawful personal data processing.
9. List of Actions Performed by the Operator with Collected Personal Data
9.1. The Operator carries out the collection, recording, systematization, accumulation, storage, updating (modification, correction), retrieval, usage, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
9.2. The Operator conducts automated processing of personal data, including receiving and/or transferring the obtained information via information and telecommunication networks or without such transmission.
10. Cross-Border Transfer of Personal Data
10.1. Before commencing activities related to the cross-border transfer of personal data, the Operator must notify the authorized body for the protection of personal data subjects’ rights about its intention to conduct a cross-border transfer of personal data. This notification is sent separately from the notification of intent to process personal data.
10.2. Before submitting the above notification, the Operator must obtain the necessary information from foreign government 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 parties who have gained access to personal data are obligated not to disclose or distribute personal data to third parties without the consent of the personal data subject, unless otherwise provided by federal law.
12. Final Provisions
12.1. The User may obtain any clarifications regarding questions related to their personal data processing by contacting the Operator via email at arenda@carvog.ru.
12.2. Any changes to the Operator’s personal data processing policy will be reflected in this document. The policy remains in effect indefinitely until it is replaced with a new version.
12.3. The current version of the Policy is publicly available on the Internet at https://en.carvog.ru/privacy/.