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 procedure for processing personal data and measures to ensure the security of personal data undertaken by PT. PAXTON GARAGE (hereinafter referred to as the “Operator”).
1.1. The Operator considers the observance of human and civil rights and freedoms in the processing of personal data — including the right to privacy, personal and family confidentiality — as one of its most important priorities and essential conditions for conducting its activities.
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 receive about visitors to the website https://lbrental.online/.
2. Key Terms 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 suspension of personal data processing (except when processing is necessary to clarify personal data).
2.3. Website — a set of graphic and informational materials, as well as software and databases, made available on the Internet at the web address https://lbrental.online/.
2.4. Personal data information system — a set of personal data contained in databases and the information technologies and technical means that ensure their processing.
2.5. Depersonalization of personal data — actions that make it impossible to determine the affiliation of personal data with a specific User or other subject of personal data without using additional information.
2.6. Processing of personal data — any action (operation) or set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
2.7. Operator — a public authority, municipal authority, legal or natural person who, independently or jointly with others, organizes and/or carries out the processing of personal data, as well as determines the purposes of personal data processing, the composition of personal data to be processed, and the actions (operations) performed with personal data.
2.8. Personal data — any information that directly or indirectly relates to a specific or identifiable User of the website https://lbrental.online/.
2.9. Personal data authorized by the subject for distribution — personal data to which the data subject has granted access to an unlimited number of persons by giving consent to the processing of such data in accordance with the Personal Data Law (hereinafter referred to as “personal data authorized for distribution”).
2.10. User — any visitor of the website https://lbrental.online/.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Dissemination of personal data — any actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or at familiarizing an unlimited group of persons with personal data, including publication in the media, posting in information and telecommunication networks, or providing access to personal data by any other means.
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, to a foreign individual or foreign legal entity.
2.14. Destruction of personal data — any actions resulting in the permanent destruction of personal data with no possibility of further recovery in the personal data information system and/or the destruction of tangible media containing personal data.
3. Rights and Obligations of the Operator
3.1. The Operator has the right to:
— receive accurate information and/or documents containing personal data from the personal data subject;
— continue processing personal data without the consent of the personal data subject if the subject withdraws consent or submits a request to terminate processing, provided there are legal grounds as specified in the Personal Data Law;
— independently determine the scope and list of measures necessary and sufficient to ensure the fulfillment of obligations under the Personal Data Law and related legal acts, unless otherwise stipulated by the Personal Data Law or other federal laws.
3.2. The Operator is obliged to:
— provide the personal data subject, upon request, with information regarding the processing of their personal data;
— organize the processing of personal data in accordance with current legislation of the Russian Federation;
— respond to inquiries and requests from personal data subjects 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, upon request, with the necessary information within 10 days from the date of receiving such 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, modification, blocking, copying, dissemination, and other unlawful actions;
— cease the transfer (dissemination, provision, access) of personal data, stop processing, and destroy personal data in the manner and in the cases provided for by the Personal Data Law;
— fulfill other obligations stipulated by the Personal Data Law.
4. Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects have the right to:
— receive information regarding the processing of their personal data, except in cases provided by federal laws. Information is provided to the personal data subject by the Operator in an accessible form and must not contain personal data relating to other personal data subjects, except when 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 destroy it if the personal data is incomplete, outdated, inaccurate, illegally obtained, or unnecessary for the stated purpose of processing, as well as take legal measures to protect their rights;
— set a condition of prior consent for the processing of personal data for marketing purposes of goods, works, or services;
— withdraw consent for personal data processing and submit a request to stop the processing of personal data;
— appeal to the authorized body for the protection of personal data subjects’ rights or in court against unlawful actions or inaction of the Operator in the processing of their personal data;
— exercise other rights provided by the legislation of the Russian Federation.
4.2. Personal data subjects are obliged to:
— provide the Operator with accurate information about themselves;
— inform the Operator about clarifications (updates, changes) to their personal data.
**4.3. Persons who provide the Operator with false information about themselves or information about another personal data subject without the latter’s consent bear responsibility 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 allowed.
5.3. The merging of databases containing personal data processed for incompatible purposes is prohibited.
5.4. Only personal data that meets the purposes of their processing are subject to processing.
5.5. The content and scope of the processed personal data correspond to the declared purposes of processing. Excessive processing of personal data relative to the declared purposes is not allowed.
5.6. During personal data processing, accuracy, sufficiency, and, when necessary, relevance of personal data in relation to the processing purposes are ensured. The Operator takes necessary measures and/or ensures their adoption to delete or clarify incomplete or inaccurate data.
5.7. Personal data storage is carried out in a form that allows identification of the personal data subject for no longer than required by the purposes of processing, unless a storage period is established by federal law, a contract to which the personal data subject is a party, beneficiary, or guarantor. Processed personal data is destroyed or depersonalized upon achievement of processing purposes or loss of necessity to achieve these purposes, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing
Purpose of processing:
— providing the User with access to services, information, and/or materials contained on the website
Personal data:
— last name, first name, patronymic
— email address
— phone numbers
Legal basis:
— Federal Law “On Information, Information Technologies, and Information Protection” No. 149-FZ dated 27.07.2006
Types of personal data processing:
— transfer of personal data
7. Conditions for Personal Data Processing
7.1. Personal data processing is carried out with the consent of the personal data subject to the processing of their personal data.
7.2. Personal data processing is necessary to achieve the purposes provided by an international treaty of the Russian Federation or law, for the performance of functions, powers, and duties imposed on the Operator by the legislation of the Russian Federation.
7.3. Personal data processing is necessary for the administration of justice, enforcement of a court decision, act of another authority or official, subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. Personal data processing is necessary for the execution of a contract to which the personal data subject is a party, beneficiary, or guarantor, as well as for the conclusion of a contract at the initiative of the personal data subject or a contract for which the personal data subject will be a beneficiary or guarantor.
7.5. Personal data processing is necessary for the protection of the rights and legitimate interests of the Operator or third parties or for achieving socially significant goals, provided that this does not violate the rights and freedoms of the personal data subject.
7.6. Processing is carried out of personal data that the personal data subject has made publicly available or provided access to an unlimited number of persons upon 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 Collection, Storage, Transfer, and Other Types of Personal Data Processing
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 preservation of personal data and takes all possible measures to prevent unauthorized access to personal data.
8.2. The User’s personal data will never, under any circumstances, be transferred to third parties, except in cases related to compliance with applicable law or if the personal data subject has given consent to the Operator for the transfer of data to a third party to fulfill obligations under a civil law contract.
8.3. In case of inaccuracies in personal data, the User may update them independently by sending a notification to the Operator’s email address garage.paxton@gmail.com with the subject line “Personal Data Update.”
8.4. The personal data processing period is determined by the achievement of the purposes for which the personal data was collected unless a different period is established by contract or current legislation.
The User may withdraw their consent to personal data processing at any time by sending a notification to the Operator via email at garage.paxton@gmail.com with the subject line “Withdrawal of Consent for 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 entities (Operators) in accordance with their User Agreements and Privacy Policies. The personal data subject agrees with these documents. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this clause.
8.6. Restrictions established by the personal data subject on the transfer (except for providing access), processing, or conditions of processing (except for obtaining access) of personal data permitted for dissemination do not apply in cases of processing personal data in the state, public, and other public interests defined by the legislation of the Russian Federation.
8.7. The Operator ensures the confidentiality of personal data during processing.
8.8. The Operator stores personal data in a form that allows identification of the personal data subject for no longer than required by the purposes of personal data processing, unless a storage period is established by federal law, contract, or if the personal data subject is a party, beneficiary, or guarantor of such contract.
8.9. The termination of personal data processing may occur upon achievement of the processing purposes, expiration of the personal data subject’s consent, withdrawal of consent by the personal data subject, a request to stop processing, or detection of unlawful personal data processing.
9. List of Actions Performed by the Operator with the Received Personal Data
9.1. The Operator carries out collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
9.2. The Operator performs automated processing of personal data with receipt and/or transfer of the obtained information via information and telecommunications networks or without them.
10. Cross-Border Transfer of Personal Data
10.1. Before commencing activities related to the cross-border transfer of personal data, the Operator is obliged to notify the authorized body for the protection of personal data subjects' rights of its intention to carry out the cross-border transfer of personal data (such notification is sent separately from the notification of intention to process personal data).
10.2. Before submitting the above notification, the Operator must obtain from the authorities of the foreign state, foreign individuals, or foreign legal entities to whom the cross-border transfer of personal data is planned, the corresponding information.
11. Confidentiality of Personal Data
The Operator and other persons who have gained access to personal data are obliged not to disclose personal data to third parties and not to distribute personal data without the consent of the personal data subject, unless otherwise provided by federal law.
12. Final Provisions
12.1. The User may obtain any clarifications regarding issues related to the processing of their personal data by contacting the Operator via email at garage.paxton@gmail.com.
12.2. Any changes to the Operator’s personal data processing policy will be reflected in this document. The Policy is valid indefinitely until replaced by a new version.
12.3. The current version of the Policy is freely available online at https://lbrental.online/privacy.
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 procedure for processing personal data and measures to ensure the security of personal data undertaken by PT. PAXTON GARAGE (hereinafter referred to as the “Operator”).
1.1. The Operator considers the observance of human and civil rights and freedoms in the processing of personal data — including the right to privacy, personal and family confidentiality — as one of its most important priorities and essential conditions for conducting its activities.
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 receive about visitors to the website https://lbrental.online/.
2. Key Terms 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 suspension of personal data processing (except when processing is necessary to clarify personal data).
2.3. Website — a set of graphic and informational materials, as well as software and databases, made available on the Internet at the web address https://lbrental.online/.
2.4. Personal data information system — a set of personal data contained in databases and the information technologies and technical means that ensure their processing.
2.5. Depersonalization of personal data — actions that make it impossible to determine the affiliation of personal data with a specific User or other subject of personal data without using additional information.
2.6. Processing of personal data — any action (operation) or set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
2.7. Operator — a public authority, municipal authority, legal or natural person who, independently or jointly with others, organizes and/or carries out the processing of personal data, as well as determines the purposes of personal data processing, the composition of personal data to be processed, and the actions (operations) performed with personal data.
2.8. Personal data — any information that directly or indirectly relates to a specific or identifiable User of the website https://lbrental.online/.
2.9. Personal data authorized by the subject for distribution — personal data to which the data subject has granted access to an unlimited number of persons by giving consent to the processing of such data in accordance with the Personal Data Law (hereinafter referred to as “personal data authorized for distribution”).
2.10. User — any visitor of the website https://lbrental.online/.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Dissemination of personal data — any actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or at familiarizing an unlimited group of persons with personal data, including publication in the media, posting in information and telecommunication networks, or providing access to personal data by any other means.
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, to a foreign individual or foreign legal entity.
2.14. Destruction of personal data — any actions resulting in the permanent destruction of personal data with no possibility of further recovery in the personal data information system and/or the destruction of tangible media containing personal data.
3. Rights and Obligations of the Operator
3.1. The Operator has the right to:
— receive accurate information and/or documents containing personal data from the personal data subject;
— continue processing personal data without the consent of the personal data subject if the subject withdraws consent or submits a request to terminate processing, provided there are legal grounds as specified in the Personal Data Law;
— independently determine the scope and list of measures necessary and sufficient to ensure the fulfillment of obligations under the Personal Data Law and related legal acts, unless otherwise stipulated by the Personal Data Law or other federal laws.
3.2. The Operator is obliged to:
— provide the personal data subject, upon request, with information regarding the processing of their personal data;
— organize the processing of personal data in accordance with current legislation of the Russian Federation;
— respond to inquiries and requests from personal data subjects 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, upon request, with the necessary information within 10 days from the date of receiving such 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, modification, blocking, copying, dissemination, and other unlawful actions;
— cease the transfer (dissemination, provision, access) of personal data, stop processing, and destroy personal data in the manner and in the cases provided for by the Personal Data Law;
— fulfill other obligations stipulated by the Personal Data Law.
4. Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects have the right to:
— receive information regarding the processing of their personal data, except in cases provided by federal laws. Information is provided to the personal data subject by the Operator in an accessible form and must not contain personal data relating to other personal data subjects, except when 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 destroy it if the personal data is incomplete, outdated, inaccurate, illegally obtained, or unnecessary for the stated purpose of processing, as well as take legal measures to protect their rights;
— set a condition of prior consent for the processing of personal data for marketing purposes of goods, works, or services;
— withdraw consent for personal data processing and submit a request to stop the processing of personal data;
— appeal to the authorized body for the protection of personal data subjects’ rights or in court against unlawful actions or inaction of the Operator in the processing of their personal data;
— exercise other rights provided by the legislation of the Russian Federation.
4.2. Personal data subjects are obliged to:
— provide the Operator with accurate information about themselves;
— inform the Operator about clarifications (updates, changes) to their personal data.
**4.3. Persons who provide the Operator with false information about themselves or information about another personal data subject without the latter’s consent bear responsibility 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 allowed.
5.3. The merging of databases containing personal data processed for incompatible purposes is prohibited.
5.4. Only personal data that meets the purposes of their processing are subject to processing.
5.5. The content and scope of the processed personal data correspond to the declared purposes of processing. Excessive processing of personal data relative to the declared purposes is not allowed.
5.6. During personal data processing, accuracy, sufficiency, and, when necessary, relevance of personal data in relation to the processing purposes are ensured. The Operator takes necessary measures and/or ensures their adoption to delete or clarify incomplete or inaccurate data.
5.7. Personal data storage is carried out in a form that allows identification of the personal data subject for no longer than required by the purposes of processing, unless a storage period is established by federal law, a contract to which the personal data subject is a party, beneficiary, or guarantor. Processed personal data is destroyed or depersonalized upon achievement of processing purposes or loss of necessity to achieve these purposes, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing
Purpose of processing:
— providing the User with access to services, information, and/or materials contained on the website
Personal data:
— last name, first name, patronymic
— email address
— phone numbers
Legal basis:
— Federal Law “On Information, Information Technologies, and Information Protection” No. 149-FZ dated 27.07.2006
Types of personal data processing:
— transfer of personal data
7. Conditions for Personal Data Processing
7.1. Personal data processing is carried out with the consent of the personal data subject to the processing of their personal data.
7.2. Personal data processing is necessary to achieve the purposes provided by an international treaty of the Russian Federation or law, for the performance of functions, powers, and duties imposed on the Operator by the legislation of the Russian Federation.
7.3. Personal data processing is necessary for the administration of justice, enforcement of a court decision, act of another authority or official, subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. Personal data processing is necessary for the execution of a contract to which the personal data subject is a party, beneficiary, or guarantor, as well as for the conclusion of a contract at the initiative of the personal data subject or a contract for which the personal data subject will be a beneficiary or guarantor.
7.5. Personal data processing is necessary for the protection of the rights and legitimate interests of the Operator or third parties or for achieving socially significant goals, provided that this does not violate the rights and freedoms of the personal data subject.
7.6. Processing is carried out of personal data that the personal data subject has made publicly available or provided access to an unlimited number of persons upon 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 Collection, Storage, Transfer, and Other Types of Personal Data Processing
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 preservation of personal data and takes all possible measures to prevent unauthorized access to personal data.
8.2. The User’s personal data will never, under any circumstances, be transferred to third parties, except in cases related to compliance with applicable law or if the personal data subject has given consent to the Operator for the transfer of data to a third party to fulfill obligations under a civil law contract.
8.3. In case of inaccuracies in personal data, the User may update them independently by sending a notification to the Operator’s email address garage.paxton@gmail.com with the subject line “Personal Data Update.”
8.4. The personal data processing period is determined by the achievement of the purposes for which the personal data was collected unless a different period is established by contract or current legislation.
The User may withdraw their consent to personal data processing at any time by sending a notification to the Operator via email at garage.paxton@gmail.com with the subject line “Withdrawal of Consent for 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 entities (Operators) in accordance with their User Agreements and Privacy Policies. The personal data subject agrees with these documents. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this clause.
8.6. Restrictions established by the personal data subject on the transfer (except for providing access), processing, or conditions of processing (except for obtaining access) of personal data permitted for dissemination do not apply in cases of processing personal data in the state, public, and other public interests defined by the legislation of the Russian Federation.
8.7. The Operator ensures the confidentiality of personal data during processing.
8.8. The Operator stores personal data in a form that allows identification of the personal data subject for no longer than required by the purposes of personal data processing, unless a storage period is established by federal law, contract, or if the personal data subject is a party, beneficiary, or guarantor of such contract.
8.9. The termination of personal data processing may occur upon achievement of the processing purposes, expiration of the personal data subject’s consent, withdrawal of consent by the personal data subject, a request to stop processing, or detection of unlawful personal data processing.
9. List of Actions Performed by the Operator with the Received Personal Data
9.1. The Operator carries out collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
9.2. The Operator performs automated processing of personal data with receipt and/or transfer of the obtained information via information and telecommunications networks or without them.
10. Cross-Border Transfer of Personal Data
10.1. Before commencing activities related to the cross-border transfer of personal data, the Operator is obliged to notify the authorized body for the protection of personal data subjects' rights of its intention to carry out the cross-border transfer of personal data (such notification is sent separately from the notification of intention to process personal data).
10.2. Before submitting the above notification, the Operator must obtain from the authorities of the foreign state, foreign individuals, or foreign legal entities to whom the cross-border transfer of personal data is planned, the corresponding information.
11. Confidentiality of Personal Data
The Operator and other persons who have gained access to personal data are obliged not to disclose personal data to third parties and not to distribute personal data without the consent of the personal data subject, unless otherwise provided by federal law.
12. Final Provisions
12.1. The User may obtain any clarifications regarding issues related to the processing of their personal data by contacting the Operator via email at garage.paxton@gmail.com.
12.2. Any changes to the Operator’s personal data processing policy will be reflected in this document. The Policy is valid indefinitely until replaced by a new version.
12.3. The current version of the Policy is freely available online at https://lbrental.online/privacy.