Privacy Policy on Personal Data Processing

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 Roskomnadzor Order No. 996 of 24.02.2021, and defines the procedure for processing personal data and the measures taken to ensure the security of personal data by Individual Entrepreneur Isaeva Yu. A. (hereinafter — the Operator).

1.1. The Operator considers respect for human and civil rights and freedoms during the processing of personal data, including protection of the rights to privacy, personal and family secrets, to be the most important goal and condition of its activity.

1.2. This Operator's policy on personal data processing (hereinafter — the Policy) applies to all information the Operator may obtain about visitors to the website https://edriveexpo.ru.

2. Basic Concepts Used in the Policy

2.1. Automated processing of personal data — processing of personal data using computing equipment.

2.2. Blocking of personal data — temporary suspension of personal data processing (except when processing is necessary to clarify the personal data).

2.3. Website — the collection of graphic and informational materials, as well as computer programs and databases, ensuring their availability on the internet at the network address https://edriveexpo.ru.

2.4. Personal data information system — a collection of personal data contained in databases, along with the information technologies and technical means ensuring their processing.

2.5. Depersonalization of personal data — actions as a result of which it becomes impossible to determine, without using additional information, which personal data belongs 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 with personal data, whether or not using automation tools, 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 body, municipal body, legal entity, or individual that independently or jointly with other persons organizes and/or carries out the processing of personal data, and determines the purposes of processing, the composition of personal data to be processed, 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://edriveexpo.ru.

2.9. Personal data permitted by the subject of personal data for distribution — personal data to which an unlimited number of persons has been granted access by the subject of personal data through consent to the processing of personal data permitted by the subject for distribution, in the manner prescribed by the Personal Data Law (hereinafter — personal data permitted for distribution).

2.10. User — any visitor to the website https://edriveexpo.ru.

2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or specific group of persons.

2.12. Distribution of personal data — any actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or at making personal data known to an unlimited number of persons, including publication of personal data in the media, posting on information and telecommunications networks, or otherwise providing access to personal data.

2.13. Cross-border transfer of personal data — transfer of personal data to the territory of a foreign state to an authority of a foreign state, a foreign individual, or a foreign legal entity.

2.14. Destruction of personal data — any actions as a result of which personal data are irrevocably destroyed with no possibility of further restoring the content of the personal data in the personal data information system and/or the physical media containing personal data are destroyed.

3. Basic Rights and Obligations of the Operator

3.1. The Operator has the right to:

— receive from the subject of personal data reliable information and/or documents containing personal data;

— in the event the subject of personal data withdraws consent to the processing of personal data, or submits a request to cease processing, continue processing the personal data without the subject's consent where grounds exist under the Personal Data Law;

— independently determine the composition and list of measures necessary and sufficient to ensure compliance with the obligations under the Personal Data Law and the regulatory legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.

3.2. The Operator is obliged to:

— provide the subject of personal data, at their request, with information relating to the processing of their personal data;

— organize the processing of personal data in accordance with the procedure established by current Russian legislation;

— respond to requests and inquiries from subjects of personal data and their legal representatives in accordance with the requirements of the Personal Data Law;

— provide the authorized body for the protection of the rights of personal data subjects with the necessary information within 10 days of receiving such a request;

— publish or otherwise ensure unrestricted access to this Policy on personal data processing;

— take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, distribution, and other unlawful actions with respect to personal data;

— cease transfer (distribution, provision, access) of personal data, cease processing, and destroy personal data in the manner and cases prescribed by the Personal Data Law;

— fulfill other obligations provided for by the Personal Data Law.

4. Basic Rights and Obligations of Personal Data Subjects

4.1. Subjects of personal data have the right to:

— receive information relating to the processing of their personal data, except in cases provided for by federal laws. Such information is provided to the subject by the Operator in an accessible form and must not contain personal data relating to other subjects, except where there are lawful grounds for disclosing such data. The list of information and the procedure for obtaining it is established by the Personal Data Law;

— require the Operator to clarify their personal data, block it, or destroy it if the personal data is incomplete, outdated, inaccurate, unlawfully obtained, or is not necessary for the stated purpose of processing, and to take measures provided by law to protect their rights;

— set a condition of prior consent for processing personal data for purposes of promoting goods, works, and services on the market;

— withdraw consent to the processing of personal data and submit a request to cease processing;

— appeal to the authorized body for the protection of the rights of personal data subjects or to the courts against unlawful actions or inaction of the Operator in processing their personal data;

— establish prohibitions on the transfer (other than granting access) of personal data permitted by the subject for distribution to an unlimited number of persons, as well as conditions and prohibitions on the processing (other than gaining access) of such personal data;

— demand that the transfer (distribution, provision, access) of personal data previously permitted for distribution be stopped at any time (consent is deemed terminated from the moment the Operator receives such a request);

— exercise other rights provided for by Russian legislation.

4.2. Subjects of personal data are obliged to:

— provide the Operator with reliable information about themselves;

— inform the Operator of any clarification (updating, modification) of their personal data.

4.3. Persons who have provided the Operator with unreliable information about themselves, or information about another subject of personal data without that subject's consent, bear liability in accordance with Russian legislation.

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 the achievement of specific, predetermined, and legitimate purposes. Processing of personal data that is incompatible with the purposes of its collection is not permitted.

5.3. The merging of databases containing personal data processed for mutually incompatible purposes is not permitted.

5.4. Only personal data that meets the purposes of its processing is subject to processing.

5.5. The content and scope of personal data processed correspond to the stated purposes of processing. Excessive personal data in relation to the stated purposes of processing is not permitted.

5.6. When processing personal data, the accuracy, sufficiency, and, where necessary, relevance of the data in relation to the purposes of processing are ensured. The Operator takes the necessary measures and/or ensures they are taken to delete or clarify incomplete or inaccurate data.

5.7. Personal data is stored in a form allowing the subject to be identified for no longer than required by the purposes of processing, unless a different storage period is established by federal law or by an agreement to which the subject of personal data is a party, beneficiary, or guarantor. Processed personal data is destroyed or depersonalized upon achievement of the purposes of processing or if the need to achieve those purposes is no longer relevant, unless otherwise provided by federal law.

6. Purposes of Personal Data Processing

Purpose of processing: informing the User by sending electronic messages.

Categories of data:

- Last name, first name, patronymic
- Email address
- Phone numbers
- Year, month, date, and place of birth

Legal basis: the Operator's founding (constituent) documents.

Types of personal data processing:

- Collection, recording, systematization, accumulation, storage, destruction, and depersonalization of personal data
- Sending informational emails to the email address

7. Conditions of Personal Data Processing

7.1. Personal data processing is carried out with the consent of the subject of personal data to the processing of their personal data.

7.2. Personal data processing is necessary for achieving purposes provided for by an international treaty of the Russian Federation or by law, for the exercise of functions, powers, and duties assigned to the Operator by Russian legislation.

7.3. Personal data processing is necessary for the administration of justice, the execution of a judicial act, an act of another body or official, subject to execution in accordance with Russian enforcement proceedings legislation.

7.4. Personal data processing is necessary for the performance of an agreement to which the subject of personal data is a party, beneficiary, or guarantor, as well as for concluding an agreement at the initiative of the subject of personal data or an agreement under which the subject of personal data will be a beneficiary or guarantor.

7.5. Personal data processing is necessary for exercising the rights and legitimate interests of the Operator or third parties, or for achieving socially significant purposes, provided the rights and freedoms of the subject of personal data are not violated.

7.6. Processing is carried out of personal data to which an unlimited number of persons has been granted access by the subject of personal data 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 the Collection, Storage, Transfer, and Other Types of Processing of Personal Data

The security of personal data processed by the Operator is ensured through the implementation of legal, organizational, and technical measures necessary to fully comply with the requirements of current legislation in the field of personal data protection.

8.1. The Operator ensures the safety of personal data and takes all possible measures to prevent access to personal data by unauthorized 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 current legislation, or where the subject of personal data has given the Operator consent to transfer data to a third party for the performance of obligations under a civil-law agreement.

8.3. If inaccuracies are found in the personal data, the User may update it independently by sending the Operator a notice to the Operator's email address isaeva.jam@mail.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 an agreement or current legislation.
The User may withdraw their consent to the processing of personal data at any time by sending the Operator a notice via email to isaeva.jam@mail.ru marked "Withdrawal of Consent to 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 those persons (Operators) in accordance with their own User Agreement and Privacy Policy. The subject of personal data must independently review these documents. The Operator is not liable for the actions of third parties, including the service providers referred to in this clause.

8.6. Prohibitions established by the subject of personal data on the transfer (other than granting access), processing, or conditions of processing (other than gaining access) of personal data permitted for distribution do not apply in cases where personal data is processed in the state, public, or other public interests defined by Russian legislation.

8.7. The Operator ensures the confidentiality of personal data during processing.

8.8. The Operator stores personal data in a form allowing the subject to be identified for no longer than required by the purposes of processing, unless a different storage period is established by federal law or by an agreement to which the subject of personal data is a party, beneficiary, or guarantor.

8.9. Grounds for terminating personal data processing may include: achievement of the purposes of processing, expiration of the subject's consent, withdrawal of consent by the subject, a request to cease processing, or the discovery of unlawful processing of personal data.

9. List of Actions Performed by the Operator with the Personal Data Received

9.1. The Operator carries out the collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, 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 the information obtained via information and telecommunications networks.

10. Cross-Border Transfer of Personal Data

10.1. Before beginning cross-border transfer of personal data, the Operator must notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out such a transfer (this notice is sent separately from the notice of intent to process personal data).

10.2. Before submitting the above-mentioned notice, the Operator must obtain relevant information from the foreign state authorities, foreign individuals, or foreign legal entities to whom the cross-border transfer of personal data is planned.

11. Use of Cookies and Web Analytics Tools

11.1. In order to improve the operation of the Website https://edriveexpo.ru, enhance its usability, and collect statistical information, the Operator uses cookies and third-party web analytics services (including "Yandex.Metrica" and similar automated systems).

11.2. Cookies are small pieces of data sent by a web server and stored on the User's device (computer, mobile phone, tablet) when visiting the Website.

11.3. The Operator processes the following information obtained through cookies and web analytics systems:

- IP address of the User's device;
- Data on the User's equipment (device type, model, screen resolution, operating system version);
- Web browser data (type, version, installed plugins);
- Date, time, and duration of the session;
- Addresses of requested pages and sources of referral to the Website;
- Geographic location (at the country and city level);
- Behavioral factors (clicks, cursor movements, page views).

11.4. The purposes of processing this data are to ensure the correct functioning of the Website, protect against unauthorized actions, analyze user activity, optimize the interface, and improve the quality of the Website's operation.

11.5. The User may at any time change their browser settings and block the storage of cookies or configure notifications about their transmission. Disabling cookies may cause certain features of the Website to malfunction or become unavailable.

11.6. By continuing to use the Website without changing browser settings, the User expresses consent to the processing of the above-mentioned data using cookies and web analytics systems under the conditions described in this Policy.

12. Confidentiality of Personal Data

The Operator and other persons who have gained access to personal data are obliged not to disclose it to third parties and not to distribute personal data without the consent of the subject of personal data, unless otherwise provided by federal law.

13. Final Provisions

13.1. The User may obtain any clarifications on matters of interest regarding the processing of their personal data by contacting the Operator via email at isaeva.jam@mail.ru.

13.2. This document will reflect any changes to the Operator's personal data processing policy. The Policy is valid indefinitely until replaced by a new version.

13.3. The current version of the Policy is freely available on the internet at https://edriveexpo.ru/personaldata_en.

Operator's Details
Individual Entrepreneur Isaeva Yulia Aleksandrovna
TIN (INN): 773273794979
PSRNIE (OGRNIP): 317774600014908
Address: 119634, Moscow, intra-city municipal district Khoroshyovo-Mnyovniki, Karamyshevskaya Embankment, bldg. 56, block 1, apt. 36