Privacy Policy for Processing of Personal Data
1. Terms and Definitions
1.1. Organizer – Limited Liability Company "Royal Capital" (Tax ID: 4025428684, OGRN: 1114025001309, KPP: 402501001, registered address: 249031, Kaluga Region, Obninsk, Pobedy St., 14-37).
1.2. Personal Data – any information related to an identified or identifiable individual (data subject).
1.3. Processing of Personal Data – any action (operation) or set of actions (operations) performed on personal data, with or without the use of automated means, including the collection, recording, systematization, accumulation, storage, updating (modification), retrieval, usage, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
1.4. Automated Processing of Personal Data – processing of personal data by means of computer technology.
1.5. Dissemination of Personal Data – actions aimed at disclosing personal data to an undefined group of persons.
1.6. Provision of Personal Data – actions aimed at disclosing personal data to a specific person or a defined group of persons.
1.7. Blocking of Personal Data – temporary cessation of personal data processing (except in cases where processing is necessary for the clarification of personal data).
1.8. Destruction of Personal Data – actions resulting in the irreversible removal of personal data from information systems and/or the destruction of physical data carriers.
1.9. Anonymization of Personal Data – actions making it impossible to identify the data subject without additional information.
1.10. Organizer's Website – an internet resource containing information and software, accessible at normax-auto.com, owned by the Organizer, along with rights to use domain names normax-auto.com.
1.11. User – an individual of at least 18 years of age, with full legal capacity, who has a personal email address at their disposal; a data subject providing their personal data to the Organizer in connection with the use of the Organizer's Website within its functional capabilities.
2. General Provisions
2.1. The Organizer, LLC "Royal Capital", prioritizes information security in its activities. The Organizer implements a set of legal, organizational, and technical measures aimed at protecting Users' Personal Data.
2.2. This Privacy Policy for the Processing of Personal Data (hereinafter referred to as the "Privacy Policy") defines the main principles of processing Users' Personal Data by the Organizer.
2.3. The purpose of adopting the Privacy Policy is to comply with data protection laws (Clause 2, Part 1, Article 18.1 of Federal Law No. 152-FZ of July 27, 2006 "On Personal Data").
2.4. This Privacy Policy is developed in accordance with data protection laws based on the Constitution of the Russian Federation, including Federal Law No. 152-FZ of July 27, 2006 "On Personal Data," and other federal laws and regulations.
2.5. The scope of this Privacy Policy applies to personal data processed by the Organizer using both automated and non-automated means.
2.6. The purpose of ensuring the protection of Personal Data is to safeguard the rights and freedoms of the data subject, including minimizing harm from potential security threats to personal data.
2.7. The purposes for processing Users' Personal Data include:
- User identification (individuals), including in the Organizer's information database;
- Providing services to Users as per the User Agreement between the User and the Organizer;
- Informing Users about services provided by the Organizer.
2.8. Use of the Website or providing the Organizer with Personal Data by any other means signifies the User's unconditional consent to this Privacy Policy and its terms for processing their Personal Data. By deciding to provide their Personal Data to the Organizer, the User consents to its processing voluntarily, on their own will and in their own interest. In case of disagreement with these terms, the User should refrain from using the Website and providing their Personal Data to the Organizer in any way.
3. Principles of Personal Data Processing
3.1. The Organizer processes Personal Data based on the following principles:
3.1.1. Processing is carried out on a lawful and fair basis.
3.1.2. Processing is limited to achieving specific, predetermined, and legitimate goals.
3.1.3. The content and volume of Personal Data correspond to the declared processing purposes.
3.1.4. The Organizer ensures the accuracy, sufficiency, and, where necessary, relevance of Personal Data in relation to the purposes of processing. The Organizer takes necessary measures to delete or update incomplete or inaccurate data.
3.2. Personal Data is stored in a form that allows the identification of the data subject (User) no longer than required by the purposes of processing, unless a longer storage period is mandated by applicable law. Processed Personal Data is destroyed or anonymized upon achieving the processing goals or when the necessity for these goals ceases, unless otherwise required by applicable law.
3.3. The Organizer and other persons with access to Personal Data must not disclose or distribute it to third parties without the User's consent, unless otherwise required by Russian Federation law.
4. Conditions for Processing Personal Data
4.1. Personal Data is processed with the User's consent. Consent to process Personal Data may be given by the User or their representative in any form that allows confirming the fact of its receipt, unless otherwise stipulated by Federal Law No. 152-FZ of July 27, 2006 "On Personal Data" or other laws.
4.2. Personal Data may be obtained by the Organizer from a person other than the User, provided that the Organizer receives confirmation of the grounds specified in Clauses 2-11, Part 1, Article 6, Part 2, Article 10, and Part 2, Article 11 of Federal Law No. 152-FZ of July 27, 2006 "On Personal Data," or other grounds provided by Russian law.
4.3. Employees of LLC "Royal Capital" have the right to access Users' Personal Data on paper and electronic media in accordance with their job responsibilities.
4.4. The Organizer transfers the User's Personal Data to third parties strictly in accordance with the applicable laws of the Russian Federation.
4.5. The Organizer may entrust the processing of the User's Personal Data to a third party with the User's consent and in other cases stipulated by the applicable laws of the Russian Federation, based on a contract with this third party. The third party processing the User's Personal Data on behalf of the Organizer must comply with the principles and rules of Personal Data processing stipulated by Federal Law No. 152-FZ of July 27, 2006 "On Personal Data," ensuring the confidentiality and security of Personal Data during processing.
5. Description of Personal Data Processing
5.1. The Organizer processes Personal Data using the following methods:
- Non-automated processing of Personal Data;
- Automated processing of Personal Data.
6. Personal Data Processing Period
6.1. The period for processing Personal Data is determined in accordance with the applicable laws of the Russian Federation and other regulatory legal acts.
7. User Rights
7.1. Users' rights (data subjects) are regulated by applicable laws, particularly Articles 14-17 of Federal Law No. 152-FZ of July 27, 2006 "On Personal Data."
7.2. The User has the right to obtain information regarding the processing of their Personal Data.
7.3. The information specified in Clause 7.2 is provided to the User or their legal representative by the Organizer upon request. The request can be sent by letter or statement in any form to the Organizer's address.
7.4. The User has the right to demand clarification of their Personal Data if it is incomplete, outdated, or inaccurate. The User has the right to withdraw their consent to the processing of Personal Data by sending a letter or statement to the Organizer's address.
7.5. If the User believes that the Organizer processes their Personal Data in violation of federal law or otherwise violates their rights and freedoms, the User may file a claim/statement with the Organizer before taking legal action. A pre-trial complaint (written offer for voluntary dispute resolution) is mandatory before filing a lawsuit in court.
The Organizer shall notify the User in writing of the results of the claim/statement review. If no agreement is reached, the dispute will be referred to the court in accordance with the applicable laws of the Russian Federation.
8. Measures to Ensure the Security of Personal Data During Processing
8.1. The Organizer takes necessary and sufficient organizational and technical measures, as required by data protection laws, to protect Personal Data that requires confidentiality from unlawful or accidental access, destruction, alteration, blocking, copying, dissemination, as well as from other illegal actions by third parties.
8.2. The measures to ensure the security of Personal Data during processing, applied by the Organizer, are planned and implemented to ensure compliance with data protection legislation.
8.3. Security of Personal Data is achieved, in particular, by:
8.3.1. Development and implementation of internal regulations on Personal Data processing;
8.3.2. Identifying threats to the security and confidentiality of Personal Data during processing;
8.3.3. Applying organizational and technical measures to ensure the security and confidentiality of Personal Data;
8.3.4. Restricting third-party access to premises where technical means processing Personal Data are located and where data carriers are stored;
8.3.5. Familiarizing LLC "Royal Capital" employees directly involved in Personal Data processing with the provisions of Russian data protection legislation, including Personal Data protection
1.1. Organizer – Limited Liability Company "Royal Capital" (Tax ID: 4025428684, OGRN: 1114025001309, KPP: 402501001, registered address: 249031, Kaluga Region, Obninsk, Pobedy St., 14-37).
1.2. Personal Data – any information related to an identified or identifiable individual (data subject).
1.3. Processing of Personal Data – any action (operation) or set of actions (operations) performed on personal data, with or without the use of automated means, including the collection, recording, systematization, accumulation, storage, updating (modification), retrieval, usage, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
1.4. Automated Processing of Personal Data – processing of personal data by means of computer technology.
1.5. Dissemination of Personal Data – actions aimed at disclosing personal data to an undefined group of persons.
1.6. Provision of Personal Data – actions aimed at disclosing personal data to a specific person or a defined group of persons.
1.7. Blocking of Personal Data – temporary cessation of personal data processing (except in cases where processing is necessary for the clarification of personal data).
1.8. Destruction of Personal Data – actions resulting in the irreversible removal of personal data from information systems and/or the destruction of physical data carriers.
1.9. Anonymization of Personal Data – actions making it impossible to identify the data subject without additional information.
1.10. Organizer's Website – an internet resource containing information and software, accessible at normax-auto.com, owned by the Organizer, along with rights to use domain names normax-auto.com.
1.11. User – an individual of at least 18 years of age, with full legal capacity, who has a personal email address at their disposal; a data subject providing their personal data to the Organizer in connection with the use of the Organizer's Website within its functional capabilities.
2. General Provisions
2.1. The Organizer, LLC "Royal Capital", prioritizes information security in its activities. The Organizer implements a set of legal, organizational, and technical measures aimed at protecting Users' Personal Data.
2.2. This Privacy Policy for the Processing of Personal Data (hereinafter referred to as the "Privacy Policy") defines the main principles of processing Users' Personal Data by the Organizer.
2.3. The purpose of adopting the Privacy Policy is to comply with data protection laws (Clause 2, Part 1, Article 18.1 of Federal Law No. 152-FZ of July 27, 2006 "On Personal Data").
2.4. This Privacy Policy is developed in accordance with data protection laws based on the Constitution of the Russian Federation, including Federal Law No. 152-FZ of July 27, 2006 "On Personal Data," and other federal laws and regulations.
2.5. The scope of this Privacy Policy applies to personal data processed by the Organizer using both automated and non-automated means.
2.6. The purpose of ensuring the protection of Personal Data is to safeguard the rights and freedoms of the data subject, including minimizing harm from potential security threats to personal data.
2.7. The purposes for processing Users' Personal Data include:
- User identification (individuals), including in the Organizer's information database;
- Providing services to Users as per the User Agreement between the User and the Organizer;
- Informing Users about services provided by the Organizer.
2.8. Use of the Website or providing the Organizer with Personal Data by any other means signifies the User's unconditional consent to this Privacy Policy and its terms for processing their Personal Data. By deciding to provide their Personal Data to the Organizer, the User consents to its processing voluntarily, on their own will and in their own interest. In case of disagreement with these terms, the User should refrain from using the Website and providing their Personal Data to the Organizer in any way.
3. Principles of Personal Data Processing
3.1. The Organizer processes Personal Data based on the following principles:
3.1.1. Processing is carried out on a lawful and fair basis.
3.1.2. Processing is limited to achieving specific, predetermined, and legitimate goals.
3.1.3. The content and volume of Personal Data correspond to the declared processing purposes.
3.1.4. The Organizer ensures the accuracy, sufficiency, and, where necessary, relevance of Personal Data in relation to the purposes of processing. The Organizer takes necessary measures to delete or update incomplete or inaccurate data.
3.2. Personal Data is stored in a form that allows the identification of the data subject (User) no longer than required by the purposes of processing, unless a longer storage period is mandated by applicable law. Processed Personal Data is destroyed or anonymized upon achieving the processing goals or when the necessity for these goals ceases, unless otherwise required by applicable law.
3.3. The Organizer and other persons with access to Personal Data must not disclose or distribute it to third parties without the User's consent, unless otherwise required by Russian Federation law.
4. Conditions for Processing Personal Data
4.1. Personal Data is processed with the User's consent. Consent to process Personal Data may be given by the User or their representative in any form that allows confirming the fact of its receipt, unless otherwise stipulated by Federal Law No. 152-FZ of July 27, 2006 "On Personal Data" or other laws.
4.2. Personal Data may be obtained by the Organizer from a person other than the User, provided that the Organizer receives confirmation of the grounds specified in Clauses 2-11, Part 1, Article 6, Part 2, Article 10, and Part 2, Article 11 of Federal Law No. 152-FZ of July 27, 2006 "On Personal Data," or other grounds provided by Russian law.
4.3. Employees of LLC "Royal Capital" have the right to access Users' Personal Data on paper and electronic media in accordance with their job responsibilities.
4.4. The Organizer transfers the User's Personal Data to third parties strictly in accordance with the applicable laws of the Russian Federation.
4.5. The Organizer may entrust the processing of the User's Personal Data to a third party with the User's consent and in other cases stipulated by the applicable laws of the Russian Federation, based on a contract with this third party. The third party processing the User's Personal Data on behalf of the Organizer must comply with the principles and rules of Personal Data processing stipulated by Federal Law No. 152-FZ of July 27, 2006 "On Personal Data," ensuring the confidentiality and security of Personal Data during processing.
5. Description of Personal Data Processing
5.1. The Organizer processes Personal Data using the following methods:
- Non-automated processing of Personal Data;
- Automated processing of Personal Data.
6. Personal Data Processing Period
6.1. The period for processing Personal Data is determined in accordance with the applicable laws of the Russian Federation and other regulatory legal acts.
7. User Rights
7.1. Users' rights (data subjects) are regulated by applicable laws, particularly Articles 14-17 of Federal Law No. 152-FZ of July 27, 2006 "On Personal Data."
7.2. The User has the right to obtain information regarding the processing of their Personal Data.
7.3. The information specified in Clause 7.2 is provided to the User or their legal representative by the Organizer upon request. The request can be sent by letter or statement in any form to the Organizer's address.
7.4. The User has the right to demand clarification of their Personal Data if it is incomplete, outdated, or inaccurate. The User has the right to withdraw their consent to the processing of Personal Data by sending a letter or statement to the Organizer's address.
7.5. If the User believes that the Organizer processes their Personal Data in violation of federal law or otherwise violates their rights and freedoms, the User may file a claim/statement with the Organizer before taking legal action. A pre-trial complaint (written offer for voluntary dispute resolution) is mandatory before filing a lawsuit in court.
The Organizer shall notify the User in writing of the results of the claim/statement review. If no agreement is reached, the dispute will be referred to the court in accordance with the applicable laws of the Russian Federation.
8. Measures to Ensure the Security of Personal Data During Processing
8.1. The Organizer takes necessary and sufficient organizational and technical measures, as required by data protection laws, to protect Personal Data that requires confidentiality from unlawful or accidental access, destruction, alteration, blocking, copying, dissemination, as well as from other illegal actions by third parties.
8.2. The measures to ensure the security of Personal Data during processing, applied by the Organizer, are planned and implemented to ensure compliance with data protection legislation.
8.3. Security of Personal Data is achieved, in particular, by:
8.3.1. Development and implementation of internal regulations on Personal Data processing;
8.3.2. Identifying threats to the security and confidentiality of Personal Data during processing;
8.3.3. Applying organizational and technical measures to ensure the security and confidentiality of Personal Data;
8.3.4. Restricting third-party access to premises where technical means processing Personal Data are located and where data carriers are stored;
8.3.5. Familiarizing LLC "Royal Capital" employees directly involved in Personal Data processing with the provisions of Russian data protection legislation, including Personal Data protection