Privacy Policy

POLITICS

regarding the processing of personal data and the implementation of requirements for the protection of personal data

1.General provisions and terms used in the Policy

1.1. This document defines the Policy of the motorcycle rental company Rental Bikes (hereinafter referred to as the “Company”) regarding the processing of personal data and the implementation of the requirements for the protection of personal data (hereinafter referred to as the “Policy”) in accordance with the requirements of Art. 18.1. Federal Law of 27.07.2006 No. 152-FZ “On Personal Data”.

1.2. The following basic concepts are used in this Policy:

personal data – any information relating directly or indirectly to a specific or identifiable individual (subject of personal data);

processing of personal data – any action (operation) or a set of actions (operations) performed using automation tools or without using such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data;

automated processing of personal data – processing of personal data using computer technology;

distribution of personal data – actions aimed at disclosing personal data to an indefinite circle of persons;

provision of personal data – actions aimed at disclosing personal data to a certain person or a certain circle of persons;

blocking of personal data – temporary termination of the processing of personal data (except for cases where processing is necessary to clarify personal data);

destruction of personal data – actions as a result of which it becomes impossible to restore the content of personal data in the information system of personal data and (or) as a result of which material

carriers of personal data;

depersonalization of personal data – actions as a result of which it becomes impossible to determine the ownership of personal data to a specific subject of personal data without using additional information;

information system of personal data – a set of personal data contained in databases and information technologies and technical means that ensure their processing.

personal data subject – an individual to whom personal data directly or indirectly relates.

2.Principles of processing personal data in the Company:

2.1. The processing of personal data is carried out on a legal and fair basis;

2.2. The processing of personal data is limited to the achievement of specific, in advance

specific and legitimate purposes. Processing of personal data that is incompatible with the purposes of collecting personal data is not allowed;

2.3. It is not allowed to combine databases containing personal data, the processing of which is carried out for purposes incompatible with each other;

2.4. Only personal data that meet the purposes of their processing is subject to processing;

2.5. The content and volume of processed personal data correspond to the stated purposes of processing and are not redundant in relation to the stated purposes of their processing;

2.6 When processing personal data, the accuracy of personal data, their sufficiency, and, if necessary, relevance in relation to the purposes of processing personal data is ensured. Necessary measures are taken to remove or clarify incomplete or inaccurate data;

2.7. The storage of personal data is carried out in a form that makes it possible to determine the subject of personal data, no longer than the purpose of processing personal data requires, if the storage period for personal data is not established by federal law, an agreement to which the subject of personal data is a party, beneficiary or guarantor. … The processed personal data upon achievement of the processing goals or in case of loss of the need to achieve these goals, unless otherwise provided by federal law, are subject to destruction or depersonalization.

2.8. When collecting personal data, including through the information and telecommunications network “Internet”, recording, systematization, accumulation, storage, clarification (update, change), extraction of personal data of citizens of the Russian Federation using databases located on the territory of the Russian Federation Federation.

3. Legal basis for the processing of personal data:

The processing of personal data in the Company is carried out in accordance with the Federal Law of July 27, 2006 No. 152-FZ “On Personal Data”, art. 53 of the Federal Law of the Russian Federation of 07.07.2003, No. 126-FZ “On Communication”, the Labor Code of the Russian Federation, Decree of the Government of the Russian Federation of 01.11.2012 No. 1119 “On approval of requirements for the protection of personal data when processing them in information systems of personal data ”, Resolution of the Government of the Russian Federation dated September 15, 2008 No. 687“ On approval of the Regulation on the specifics of personal data processing carried out without the use of automation tools ”and other regulatory legal acts in the field of personal data protection.

4. Purposes of personal data processing:

4.1 The Company collects, stores and processes only those personal data that are necessary for the provision of services and for the implementation of its activities, as well as to ensure the rights and legitimate interests of third parties, provided that this does not violate the rights of the subject of personal data.

4.2 Personal data of the personal data subject can be processed by the Company for the following purposes:

4.2.1. To identify the subject of personal data;

4.2.2. To communicate with the subject of personal data, if necessary, including for sending notifications, requests and information related to the provision of services, as well as for processing requests and applications from subjects of personal data;

4.2.3. To carry out statistical and other studies based on anonymized data.

4.3. The Company does not process special categories of personal data concerning

race, nationality, political views, religious beliefs, health conditions, and biometric personal data.

5.Composition of personal data:

5.1. Personal data of the subject of personal data – an employee of the Company – information required by the Company in connection with the registration, change, termination of labor relations.

5.2 Personal data of the subject of personal data – a counterparty under a civil contract – information required by the Company in connection with the execution, modification, termination of a civil contract with this subject of personal data.

5.3. Personal data of the subject of personal data – the client of the Company – information required by the Company to fulfill its obligations under the contractual relationship with the subject of personal data (client of the Company) and to comply with the requirements of the legislation of the Russian Federation in the field of personal data protection.

6.Processing of personal data:

6.1. The processing of personal data of subjects of personal data of the Company is carried out in order to ensure compliance with laws and other regulatory legal acts of the Russian Federation, training of subjects of personal data – employees of the Company, ensuring personal safety of subjects of personal data, monitoring the quantity and quality of work performed and ensuring the safety of the Company’s property.

6.2. The processing of personal data is carried out by the Company with the consent of the subjects of personal data, both using automation tools and without using such tools.

6.3 The Company does not provide or disclose information containing personal data of personal data subjects to a third party without the written consent of the personal data subject, except for cases when it is necessary in order to prevent threats to life and health, as well as in cases established by the current legislation of the Russian Federation in the field of personal data protection.

6.4 At the reasoned request of the authorized body and exclusively within the framework of the implementation of the current legislation, the personal data of the subject without his consent may be transferred:

– to the judicial authorities in connection with the administration of justice;

– federal security service agencies;

– to the prosecutor’s office;

– to the police;

– to other bodies and organizations in cases established by regulatory legal acts that are binding.

6.5 In case of obtaining consent to the processing of personal data from a representative of the subject of personal data, the authority of this representative to give consent on behalf of the subject of personal data is checked by the Company.

6.6 In the event that the subject of personal data withdraws consent to the processing of personal data, the Company has the right to continue processing personal data without the consent of the subject if there are grounds specified in the current legislation.

6.7. Legal regulation of the procedure and terms of storage of documents containing personal data of personal data subjects is carried out on the basis of the List of standard administrative archival documents generated in the course of the activities of state bodies, local authorities and organizations, with indication of storage time “, approved by the Order of the Ministry of Culture of Russia dated 25.08.2010 No. 558.

6.8. Destruction of documents containing personal data is carried out in any way that excludes the possibility of familiarization by unauthorized persons with the destroyed materials and the possibility of restoring their text.

7. Confidentiality of personal data

7.1. Information related to personal data, which became known in connection with the implementation of labor relations, the fulfillment of the provisions of a civil contract, to which the subject of personal data is a party, and in connection with

with the provision of services to the Company is confidential information and is protected by the current legislation of the Russian Federation.

7.2 Persons who have gained access to the processed personal data undertake not to disclose confidential information, and are also warned of possible disciplinary, administrative, civil and criminal liability in case of violation of the norms and requirements of the current legislation of the Russian Federation in the field of personal data protection.

7.3 Persons who have gained access to the processed personal data do not have the right

communicate the personal data of the subject of personal data to a third party without the written consent of such a subject, except for cases when it is necessary in order to prevent a threat to the life and health of the subject of personal data, and

in cases established by the legislation of the Russian Federation.

7.4. Persons who have gained access to personal data undertake not to disclose personal data for commercial purposes without the written consent of the subject of personal data. The processing of personal data of personal data subjects in order to promote goods, works, services on the market by making direct contacts with a potential consumer using communication means is allowed only with his prior consent.

8.Rights of subjects of personal data

8.1 The subject of personal data has the right to receive information regarding the processing of his personal data, including containing:

8.1.1.confirmation of the fact of processing of personal data by the Company;

8.1.2. Legal grounds and purposes of personal data processing;

8.1.3. The purposes and methods of processing personal data used by the Company;

8.1.4. The name and location of the Company, information about persons (with the exception of employees of the Company) who have access to personal data or to whom personal data may be disclosed on the basis of an agreement with the Company or on the basis of federal law of the Russian Federation;

8.1.5. The processed personal data relating to the relevant subject of personal data, the source of their receipt, unless another procedure for submitting such data is provided for by the federal law of the Russian Federation;

8.1.6. Terms of processing personal data, including the terms of their storage;

8.1.7. The procedure for the exercise by the subject of personal data of the rights provided for by the Federal Law of July 27, 2006 No. 152-FZ “On Personal Data”;

8.1.8. Information about the performed or expected cross-border data transfer;

8.1.9. The name or surname, first name, patronymic and address of the person who processes personal data on behalf of the Company, if the processing is entrusted or will be entrusted to such a person;

8.1.10. Other information provided for by the Federal Law of July 27, 2006 No. 152-FZ “On Personal Data” or other federal laws of the Russian Federation.

8.2. The subject of personal data has the right to demand from the Company clarification of his personal data, their blocking or destruction if the personal data is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing, as well as to take legal measures to protect their rights.

8.3. If the subject of personal data believes that the Company is processing his personal data in violation of the requirements of the Federal Law of July 27, 2006 No. 152-FZ “On Personal Data” or otherwise violates his rights and freedoms, the subject of personal data has the right to appeal against the actions or inaction of the Company in the body for the protection of the rights of subjects of personal data (Federal Service for Supervision of Communications, Information Technology and Mass Media – Roskomnadzor) or in court.

8.4 The subject of personal data has the right to protect his rights and legitimate interests, including compensation for damages and (or) compensation for moral damage in court.

8.5. Other rights defined by Chapter 3 of the Federal Law of July 27, 2006 No. 152-FZ “On Personal Data”.

9. Measures aimed at ensuring that the Company fulfills its obligations under Art. 18.1., 19 of the Federal Law of July 27, 2006 No. 152 – FZ “On Personal Data”:

9.1 The legal, organizational and technical measures provided for by the relevant regulatory legal acts are applied to ensure the security of personal data during their processing in the information systems of the Company’s personal data.

9.2. When processing personal data without using automation tools, the requirements established by the Decree of the Government of the Russian Federation dated September 15, 2008 No. 687 “On approval of the Regulation on the specifics of processing personal data carried out without using automation tools” are fulfilled.

9.3 The employees of the Company who are directly involved in the processing of personal data are familiarized with the provisions of the legislation of the Russian Federation on personal data (including requirements for the protection of personal data), local acts on the processing of personal data.

9.4. The Company is responsible for violation of obligations to ensure the security and confidentiality of personal data during their processing in accordance with the legislation of the Russian Federation.

9.5 To ensure unrestricted access to the Company’s Policy regarding the processing of personal data and information on the measures taken to protect personal data, the text of this Policy is published on the official website (RentalBikes.ru).

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