1. GENERAL PROVISIONS
1.1. This Policy of Mikhail Pavlov, an individual entrepreneur, regarding the processing of personal data (hereinafter referred to as 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 27.07.2006 “On Personal Data” (hereinafter referred to as the Law on Personal Data) in order to ensure the protection of human and civil rights and freedoms when processing his 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 Mikhail Pavlov, an Individual Entrepreneur (hereinafter referred to as the Operator), namely: the Site, all subdomains of the Site, and all products and services offered by the Site and the Operator.
1.3. The Policy applies to the 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 of Article 18.1 of the Law on Personal Data, this Policy is published freely on the Internet on the Operator’s website. https://arendaminivanspb.ru / (hereinafter referred to as the Site), VK page https://vk.com/arendaminivanspb /, Avito’s website https://www.avito.ru/brands/i4017305/all?sellerId=668be1fbdd9cb84997f3fa3277ad0428 (next is the Page).
1.5. The use of the Site’s services means the User’s unconditional consent to this Policy and the conditions for processing his personal information specified therein; in case of disagreement with these conditions, the User must refrain from using the Site.
1.6. Basic concepts used in the Policy:
personal data is any information related directly or indirectly to a specific or identifiable natural person (personal data subject);
the personal data operator (operator) is an individual entrepreneur Mikhail Pavlov, address: 197372, Saint Petersburg, Aviakonstruktorov ave., 1, sq.286, TIN 781429344850, OGRNIP 323784700083683, independently or jointly with other persons organizing and (or) processing personal data, as well as determining the purposes of processing personal data, the composition of personal data to be processed, actions (operations) performed with personal data;
personal data processing is any action (operation) or set of actions (operations) with personal data performed with or without automation tools. The processing of personal data includes, but is not limited to:
• collection;
• Recording;
• systematization;
• accumulation;
• Storage;
• clarification (update, change);
• Usage;
• transfer (provision, access);
• deletion;
• Destruction;
automated personal data processing is the processing of personal data using computer technology;
mixed processing of personal data is the processing of personal data carried out both by those engaged in employment and recruitment activities, and with the direct participation of a person;
providing personal data is an action aimed at disclosing personal data to a specific person or a specific group of people.;
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 material carriers of personal data are destroyed;
personal data information system is a set of personal data contained in databases and information technologies and technical means that process them.;
confidentiality of personal data is a mandatory requirement for the Operator or other person who has access to personal data to prevent their dissemination without the consent of the personal data subject or other legitimate grounds.;
Cookies are a small piece of data sent by a web server and stored on the user’s computer, which the web client or web browser sends each time to the web server in an HTTP request when trying to open the page of the corresponding site.;
An IP address is a unique network address of a node in a computer network built using the IP protocol.
a user is any visitor to a website https://arendaminivanspb.ru /, VK pages https://vk.com/arendaminivanspb ?from=groups, including the application acceptance page https://vk.com/arendaminivanspb ?from=groups&w=app6013442_-207555846%2523form_id%253D1, Avito website https://www.avito.ru/brands/i4017305/all?sellerId=668be1fbdd9cb84997f3fa3277ad0428 , which provides a transfer service, passenger transportation.
1.7. Basic rights and obligations of the Operator.
1.7.1. The Operator has the right to:
1) independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations stipulated by the Law on Personal Data and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Law on Personal Data or other federal laws;
2) 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 this person. The person who processes personal data on behalf of the Operator is obliged to comply with the principles and rules of personal data processing provided for by the Law on Personal Data;
3) 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.
1.7.2. The Operator is obliged to:
1) organize the processing of personal data in accordance with the requirements of the Law on Personal Data;
2) respond to requests and requests from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Act;
3) notify the authorized body for the protection of the rights of personal data subjects (the Federal Service for Supervision of Communications, Information Technology and Mass Communications (Roskomnadzor) upon request of this body of the necessary information within 30 days from the date of receipt of such request.
1.8. The basic rights of the personal data subject. The personal data subject has the right to:
1) to receive information concerning the processing of his 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 it should not contain personal data related to other personal data subjects, except in cases where there are legitimate grounds for the disclosure of such personal data. The list of information and the procedure for obtaining it are established by the Law on Personal Data;
2) require the operator to clarify his personal data, block or destroy them if the personal data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated purpose of processing, as well as to take measures provided by law to protect their rights.;
3) to put forward a condition of prior consent when processing personal data in order to promote goods, works and services on the market;
4) appeal to Roskomnadzor or in court against illegal actions or omissions of the Operator during the processing of his personal data.
1.9. Control over the fulfillment of the requirements of this Policy is carried out by an authorized person responsible for organizing the processing of personal data by the Operator.
1.10. Responsibility for violation of the requirements of the legislation of the Russian Federation and regulatory acts of the Operator in the field of personal data processing and protection is determined in accordance with the legislation of the Russian Federation.
1.11. This Privacy Policy applies to the Website, the VK application page, products and services offered by the Operator, as well as to the Operator’s legal relations with its contractors and employees. The Site does not control and is not responsible for third-party sites to which the User can click on the links available on the Site.
1.12. This Policy and its amendments are approved by the order of the head of the Operator.
2. Purposes of personal data collection
2.1. The processing of personal data is limited to the achievement of specific, predetermined and legitimate purposes. Processing of personal data incompatible with the purposes of personal data collection is not allowed.
2.2. Only personal data that meets the purposes of their processing is subject to processing.
2.3. The processing of personal data by the Operator is carried out for the following purposes::
• Ensuring the protection of human and civil rights and freedoms when processing personal data, including the protection of the rights to privacy, personal and family secrets;
• promotion of the Operator’s goods, works, and services on the market by making direct contacts with potential consumers using communication tools;
• Identification of the User, for placing an order and (or) concluding a Contract of Carriage;
• Providing the User with access to personalized website resources;
• Establishing feedback with the User, including sending notifications, requests regarding the use of the Site, provision of services, processing requests and requests from the User;
• Determining the User’s location to ensure security and fraud prevention;
• Confirmation of the accuracy and completeness of the personal data provided by the User;
• Processing and receiving payments;
• Providing the User with effective customer and technical support in case of problems related to the use of the website;
• Providing the User with his consent, product updates, special offers, pricing information, newsletters and other information on behalf of the Online Store or on behalf of the partners of the website.
• Carrying out advertising activities with the User’s consent.
• Conclusion of civil law (agency, service provision) contracts within the framework of the Operator’s activities.
The Operator also processes technical data (cookies) to:
a) ensure the functioning and security of the Website;
b) improving the quality of the Website.
3. Legal grounds for personal data processing
3.1. The legal basis for the processing of personal data is a set of regulatory legal acts, in compliance with 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;
• other regulatory legal acts regulating relations related to the Operator’s activities.
3.2. The legal basis for the processing of personal data is also:
• contracts concluded between the Operator and the subjects of personal data;
• consent of personal data subjects to the processing of their personal data.
4. Scope and categories of personal data processed,
categories of personal data subjects
4.1. The content and scope of the personal data being processed must comply with the stated purposes of processing provided for in sec. 2 of this Policy. The personal data being processed should not be redundant 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. Job seekers who are provided with employment assistance services:
• last name, first name, patronymic;
• gender;
• Date of birth;
• Contact information;
• information about education, work experience, qualifications;
• other personal information provided by candidates in resumes and cover letters.
4.2.2. Users of the Website who receive transfer and passenger transportation services:
• last name, first name;
• Contact information;
• other personal data provided by clients and counterparties (individuals) necessary for the conclusion and execution of contracts.
4.2.3. Users of the VK or Avito Page who receive transfers or passenger transportation:
• last name, first name;
• Contact information (phone number);
• other personal data provided by representatives (employees) of clients and counterparties necessary for the conclusion and execution of contracts.
4.2.4. Website Users:
• User’s IP address;
• User Cookie data;
• User location information;
• information about the Site pages that the User visited, as well as the time and duration of their visit;
• information about User behavior on the site: clicks, scrolling, keystrokes, cursor movement;
• information about the User’s browser or other program that the User uses to access the Site;
• information about the device from which the site is accessed;
• information about the operating system that is installed on this device and other software that is used to access the Site;
• information about the page, resource, or application from which the User accessed the Operator’s Website;
• other information that the User transmits to the Operator with his informed consent, including by sending messages through the Website, by e-mail, filling in the appropriate fields or marking the appropriate fields in the forms posted on the Website.
4.3. Processing by the Operator of biometric personal data (information that characterizes the physiological and biological characteristics of a person, on the basis of which his identity can be established) It is not carried out by the operator.
4.4. The Operator does not process special categories of personal data related to race, nationality, political views, religious or philosophical beliefs, health status, intimate life, except in cases provided for by the legislation of the Russian Federation.
5. Procedure and conditions of personal data processing
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 the subjects of personal data to the processing of their personal data, as well as without it in cases provided for by the legislation of the Russian Federation.
5.3. The Operator performs both automated, non-automated, and mixed processing of personal data.
5.4. The Operator’s employees, whose job responsibilities include processing personal data, are allowed to process personal data.
5.5. Personal data is processed by:
• receiving personal data in oral and written form directly from personal data subjects;
• obtaining personal data from publicly available sources;
• entering personal data into the logs, registers and information systems of the Operator;
• using other methods of personal data processing.
5.6. Disclosure and dissemination of personal data to third parties is prohibited without the consent of the personal data subject, unless otherwise provided by federal law.
5.7. Consent to the processing of personal data authorized by the personal data subject for dissemination is issued separately from other consents of the personal data subject to the processing of his personal data.
The requirements for the content of consent to the processing of personal data authorized by the personal data subject for distribution were approved by Roskomnadzor Order No. 18 dated 02/24/2021.
A simple written form or a note in the highlighted field by the personal data subject stating consent to the processing of personal data in accordance with the Terms of Data Processing and familiarization with the Privacy Policy is sufficient for consent.
5.8. With respect to the User’s personal information, its confidentiality is maintained, except in cases where the User voluntarily provides information about himself for general access to an unlimited number of persons. When using certain services, the User agrees that a certain part of his personal information becomes publicly available.
5.9. The Operator has the right to transfer the User’s personal information to third parties in the following cases::
• The user has consented to such actions;
• The transfer is necessary to fulfill a specific agreement or contract with the User.
• The transfer is provided for by Russian or other applicable legislation within the framework of the procedure established by law.
• In case of sale of the Site, all obligations to comply with the terms of this Policy in relation to the personal information received by the buyer are transferred to the buyer.
5.10. The transfer of personal data to the bodies of inquiry and investigation and other authorized executive authorities and organizations is carried out in accordance with the requirements of the legislation of the Russian Federation.
5.11. The Operator takes the necessary legal, organizational and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, distribution and other unauthorized actions, including:
• identifies threats to the security of personal data during their processing;
• adopts local regulations and other documents regulating relations in the field of personal data processing and protection;
• appoints persons responsible for ensuring the security of personal data in the structural divisions and information systems of the Operator;
• creates the necessary conditions for working with personal data;
• organizes the accounting of documents containing personal data;
• organizes work with information systems in which personal data is processed;
• stores personal data in conditions that ensure their safety and prevent unauthorized access to them;
• organizes training for the Operator’s employees who process personal data.
5.12. The Operator stores personal data in a form that allows determining the subject of personal data for no longer than the purposes of personal data processing require, unless the period of personal data storage is established by federal law or contract.
5.13. The conditions for termination of personal data processing are:
• achieving the goals of personal data processing;
• expiration of the consent of the personal data subject to the processing of his personal data;
• revocation of the consent of the personal data subject to the processing of his personal data;
• identification of unlawful processing of personal data;
• termination of an individual’s activity as an individual entrepreneur in connection with his decision to terminate this activity.
5.14. When collecting personal data, including through the Internet information and telecommunications network, the Operator ensures the recording, systematization, accumulation, storage, clarification (updating, modification) of personal data of citizens of the Russian Federation using databases located on the territory of the Russian Federation, except for the cases specified in the Law on Personal Data.
6. Updating, correction, deletion and destruction of personal data, responding to requests from subjects for access to personal data
6.1. Confirmation of the fact of personal data processing by the Operator, the legal grounds and purposes of personal data processing, as well as other information specified in Part 7 of Article 14 of the Law on Personal Data, are provided by the Operator to the personal data subject or his representative when contacting or receiving a request from the personal data subject or his representative.
The information provided does not include personal data related to other subjects of personal data, except in cases where there are legitimate grounds for the disclosure of such personal data.
The request must contain:
• the number of the main identity document of the personal data subject or his representative, information about the date of issue of the specified document and the issuing authority.;
• information confirming the personal data subject’s participation in the relationship with the Operator (contract number, date of conclusion of the contract, conditional designation and (or) other information), or information otherwise confirming the fact of personal data processing by the Operator;
• signature of the personal data subject or his representative.
The request can be sent in the form of an electronic document using the following official e-mail address of the Operator: arendaminivanspb@yandex.ru .
If the 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 access rights to the requested information, a reasoned refusal is sent to him.
The right of a personal data subject to access his personal data may be restricted in accordance with Part 8 of Article 14 of the Law on Personal Data, including if the access of a personal data subject to his personal data violates the rights and legitimate interests of third parties.
6.2. In case of detection of inaccurate personal data when contacting a personal data subject or his representative, or at their request or at the request of Roskomnadzor, the Operator blocks personal data related to this personal data subject from the moment of such request or receipt of the specified request for the verification period, if blocking personal data does not violate the rights and legitimate interests of the subject personal data or third parties.
In case of confirmation of the inaccuracy of personal data, the Operator, based on information provided by the personal data subject or his representative or Roskomnadzor, or other necessary documents, clarifies the personal data within seven working days from the date of submission of such information and removes the blocking of personal data.
6.3. In case of detection of unlawful processing of personal data when contacting (requesting) a personal data subject or his representative or Roskomnadzor, the Operator shall block unlawfully processed personal data related to this personal data subject from the moment of such request or receipt of the request.
6.4. Upon achievement of the purposes of personal data processing, as well as in the case of withdrawal by the personal data subject of consent to their processing, personal data is subject to destruction if:
• nothing else is provided for by the contract to which the personal data subject is a party, beneficiary or guarantor.;
• the operator does not have the right to process personal data without the consent of the personal data subject on the grounds provided for by the Law on Personal Data or other federal laws.;
• unless otherwise provided by another agreement between the Operator and the subject of personal data.