Privacy policy
Personal Data Processing Policy
1. **General Provisions**
This Personal Data Processing Policy is drafted in accordance with the requirements of Federal Law No. 152-FZ dated July 27, 2006, "On Personal Data" (hereinafter referred to as the Personal Data Law) and defines the procedures for processing personal data and the measures to ensure the security of personal data taken by LETBUYCAR LTD (hereinafter referred to as the Operator).
1.1. The Operator's primary goal and condition for conducting its activities is to ensure the rights and freedoms of individuals and citizens during the processing of their personal data, including the protection of the right to privacy and personal and family secrets.
1.2. This policy of the Operator 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://letbuycar.com.
2. **Key Concepts 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 cessation of the processing of personal data (except when processing is necessary for clarifying 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 the network address https://letbuycar.com.
2.4. Personal Data Information System - a collection of personal data contained in databases and the information technologies and technical means ensuring their processing.
2.5. De-identification of personal data - actions that result in the inability to identify personal data without additional information related to a specific User or another personal data subject.
2.6. Processing of personal data - any action (operation) or set of actions (operations) performed with or without automation tools on personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), de-identification, blocking, deletion, destruction of personal data.
2.7. Operator - a state body, municipal body, legal entity, or individual that independently or jointly with other persons 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 the actions (operations) performed with personal data.
2.8. Personal Data - any information related directly or indirectly to a specific or identifiable User of the website https://letbuycar.com.
2.9. Personal Data Allowed by the Data Subject for Distribution - personal data to which the data subject has granted access to an indefinite number of persons by consenting to the processing of personal data allowed for distribution in accordance with the Personal Data Law (hereinafter referred to as personal data allowed for distribution).
2.10. User - any visitor to the website https://letbuycar.com.
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 indefinite number of persons (transfer of personal data) or at making personal data accessible to an unlimited number of persons, including publicizing personal data in the media, placing it in information and telecommunication 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 to the authority of a foreign state, a foreign individual, or a foreign legal entity.
2.14. Destruction of Personal Data - any actions resulting in the irrevocable destruction of personal data with the impossibility of further restoration of the content of personal data in the personal data information system and/or destruction of physical media containing personal data.
3. **Operator's Basic Rights and Obligations**
3.1. The Operator has the right to:
- Obtain accurate information and/or documents containing personal data from the data subject.
- Continue processing personal data without the data subject's consent if the consent is withdrawn or if the data subject sends a request to stop processing personal data, provided there are grounds specified in the Personal Data Law.
- Independently determine the composition and list of measures necessary and sufficient to ensure compliance with the obligations established by the Personal Data Law and related normative legal acts unless otherwise provided by the Personal Data Law or other federal laws.
3.2. The Operator is obligated to:
- Provide the data subject with information regarding the processing of their personal data upon request.
- Organize the processing of personal data in accordance with the current legislation of the Russian Federation.
- Respond to inquiries and requests from data subjects and their legal representatives in accordance with the requirements of the Personal Data Law.
- Provide the authorized body for the protection of data subjects' rights with the necessary information within 10 days from the date of receipt of such a request.
- Publish or otherwise ensure unrestricted access to this Personal Data Processing Policy.
- Take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, alteration, blocking, copying, provision, distribution, as well as from other unlawful actions regarding personal data.
- Stop the transfer (distribution, provision, access) of personal data, cease processing, and destroy personal data in accordance with the Personal Data Law.
- Fulfill other obligations specified by the Personal Data Law.
4. **Basic Rights and Obligations of Personal Data Subjects**
4.1. Data subjects have the right to:
- Obtain information regarding the processing of their personal data, except as provided by federal laws. The information is provided by the Operator in an accessible form, and it should not contain personal data related to other data subjects unless there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law.
- Request the Operator to clarify their personal data, block or delete it if the personal data is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, as well as to take legal measures to protect their rights.
- Condition their consent prior to the processing of personal data for marketing purposes related to goods, works, and services.
- Withdraw consent for the processing of personal data, as well as request to stop the processing of personal data.
- Appeal to the authorized body for the protection of data subjects' rights or to the court regarding unlawful actions or omissions of the Operator in processing their personal data.
- Exercise other rights provided by the legislation of the Russian Federation.
4.2. Data subjects are obligated to:
- Provide the Operator with accurate data about themselves.
- Notify the Operator about any clarifications (updates, changes) to their personal data.
4.3. Persons who have provided the Operator with false information about themselves or about another data subject without their consent are liable in accordance with the legislation of the Russian Federation.
5. **Principles of Personal Data Processing**
5.1. Personal data processing is carried out on a lawful and fair basis.
5.2. Personal data processing is limited to achieving specific, predetermined, and lawful purposes. Processing of personal data incompatible with the purposes of data collection is not permitted.
5.3. Combining databases containing personal data for incompatible processing purposes is not allowed.
5.4. Only personal data that meets the processing purposes is subject to processing.
5.5. The content and volume of processed personal data correspond to the stated processing purposes. The processing of excessive personal data relative to the stated purposes is not permitted.
5.6. The accuracy, adequacy, and, if necessary, relevance of personal data to the processing purposes are ensured. The Operator takes necessary measures and/or ensures their implementation for the removal or clarification of incomplete or inaccurate data.
5.7. Personal data is stored in a form that allows identifying the data subject for no longer than necessary for the purposes of processing personal data, unless otherwise established by federal law, contract, or by the party, beneficiary, or guarantor of which the data subject is a party. Processed personal data is destroyed or de-identified once the processing goals are achieved or if the need to achieve these goals ceases, unless otherwise provided by federal law.
6. **Purposes of Personal Data Processing**
| Purpose of Processing | Informing the User through sending emails |
|-----------------------|--------------------------------------------|
| Personal Data | Email address, phone numbers, date of birth, photographs |
| Legal Basis | Charter (founding) documents of the Operator |
| Types of Personal Data Processing | Collection, recording, systematization, accumulation, storage, destruction, and de-identification of personal data; sending informational emails |
7. **Conditions for Processing Personal Data**
7.1. Processing of personal data is carried out with the consent of the data subject.
7.2. Processing of personal data is necessary to achieve the goals provided by international treaties of the Russian Federation or laws, to fulfill the functions, powers, and duties imposed on the Operator by the legislation of the Russian Federation.
7.3. Processing of personal data is necessary for justice, execution of a court order, or act of another authority or official subject to enforcement in accordance with the Russian Federation's legislation on enforcement proceedings.
7.4. Processing of personal data is necessary for the performance of a contract where the data subject is a party, beneficiary, or guarantor, as well as for entering into a contract at the data subject's initiative or a contract where the data subject will be a beneficiary or guarantor.
7.5. Processing of personal data is necessary for the fulfillment of the rights and lawful interests of the Operator or third parties or for achieving socially significant goals provided that the rights and freedoms of the data subject are not violated.
7.6. Processing of personal data, which is accessible to an indefinite number of
persons by the data subject's consent, is carried out within the framework of this consent.
7.7. Processing of personal data is carried out for statistical or other research purposes, with due consideration of the data subject's confidentiality.
8. **Cross-Border Transfer of Personal Data**
8.1. The Operator's cross-border transfer of personal data to the territory of foreign states is carried out if the foreign state provides adequate protection of the rights of data subjects.
8.2. The Operator is obligated to ensure that adequate protection of personal data rights is provided in accordance with the legislation of the Russian Federation in cases where cross-border transfer is carried out to the territories of foreign states that do not ensure adequate protection.
8.3. The cross-border transfer of personal data to the territories of foreign states that do not ensure adequate protection of personal data rights is carried out only with the data subject's consent and/or the presence of other legal grounds.
9. **Final Provisions**
9.1. This Policy is subject to review and updates as needed.
9.2. The Policy becomes effective upon approval by the Operator and is valid indefinitely until replaced by a new version.
9.3. The Operator reserves the right to make changes to the Policy. All changes will be posted on the website https://letbuycar.com.