- General Provisions
- This personal data processing policy has been developed in accordance with the requirements of Federal Law of July 27, 2006, No. 152-FZ "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 XRent (hereinafter referred to as the Operator).
1.1. The Operator’s most important goal and condition for its activities is the observance of human and civil rights and freedoms in the processing of personal data, including the protection of the rights to privacy, personal and family secrets.
1.2. This Operator’s policy regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator can obtain about visitors to the website
https://xrent.tilda.ws/.
- Basic Concepts 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 cessation of personal data processing (except when necessary to clarify personal data).
- 2.3. Website - a collection of graphic and informational materials, as well as computer programs and databases that make them available on the internet at the network address https://xrent.tilda.ws/.
- 2.4. Personal data information system - a set of personal data contained in databases and information technologies and technical means that ensure their processing.
- 2.5. Anonymization of personal data - actions resulting in the inability to determine the ownership of personal data to a specific user or another personal data subject without the use of additional information.
- 2.6. Processing of personal data - any action (operation) or a set of actions (operations), performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, refinement (updating, changing), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, destruction of personal data.
- 2.7. Operator - a state body, municipal body, legal entity, or individual, independently or jointly with other persons organizing and/or carrying out the processing of 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.
- 2.8. Personal data - any information related directly or indirectly to a specific or identifiable user of the website https://xrent.tilda.ws/.
- 2.9. Personal data permitted for distribution by the subject of personal data - personal data access to which is provided to an unlimited number of persons by the subject of personal data by giving consent to the processing of personal data allowed for distribution as provided by the Personal Data Law.
- 2.10. User - any visitor to the website https://xrent.tilda.ws/.
- 2.11. Provision of personal data - actions aimed at disclosing personal data to a certain person or a certain circle of persons.
- 2.12. Dissemination of personal data - any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or on familiarization with personal data of an unlimited number of persons, including the disclosure of personal data in the media, placement in information and telecommunication networks, or providing access to personal data in any other way.
- 2.13. Cross-border transfer of personal data - the transfer of personal data to the territory of a foreign state to an authority of a foreign state, a foreign individual or foreign legal entity.
- 2.14. Destruction of personal data - any actions as a result of which personal data are irretrievably destroyed with the inability to further restore the content of personal data in the personal data information system and/or result in the destruction of physical carriers of personal data.
- Main 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 subject of personal data;
- continue processing personal data without the consent of the personal data subject if the personal data subject withdraws consent to the processing of personal data or submits a request to stop processing personal data, provided there are grounds specified in the Personal Data Law;
- independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of the obligations provided by 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 personal data subject upon his request with information regarding the processing of his personal data;
- organize the processing of personal data in the order established by the current legislation of the Russian Federation;
- respond to inquiries and requests of personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
- report to the authorized body for the protection of the rights of personal data subjects at the request of this body the necessary information within 10 days from the date of receipt of such a request;
- publish or otherwise provide unlimited access to this Policy regarding the processing of personal data;
- take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, dissemination of personal data, and from other unlawful actions in relation to personal data;
- stop transmitting (distributing, providing access) personal data, stop processing and destroy personal data in the manner and cases provided by the Personal Data Law;
- perform other duties provided by the Personal Data Law.
- Main Rights and Obligations of Personal Data Subjects
- 4.1. Personal data subjects have the right to:
- obtain information regarding the processing of their personal data, except as provided by federal laws. Information is provided to the personal data subject by the Operator in an accessible form and should not contain personal data related to other subjects of personal data, except where 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;
- demand the operator clarify his personal data, block or destroy them if the personal data are incomplete, outdated, inaccurate, illegally obtained, or are not necessary for the declared purpose of processing, as well as take measures provided by law to protect their rights;
- set a condition of prior consent when processing personal data for the purpose of promoting goods, works, and services on the market;
- withdraw consent to the processing of personal data, as well as to send a request for the cessation of the processing of personal data;
- appeal against the unlawful actions or inaction of the Operator in processing his personal data to the authorized body for the protection of the rights of personal data subjects or in court;
- exercise other rights provided by the legislation of the Russian Federation.
4.2. Personal data subjects are obliged to:
- provide the Operator with accurate data about themselves;
- inform the Operator about the clarification (update, change) 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 the consent of the latter are liable in accordance with the legislation of the Russian Federation.
- Principles of Personal Data Processing
- 5.1. Personal data processing is carried out on a legal and fair basis.
- 5.2. The processing of personal data is limited to achieving specific, predetermined, and lawful purposes. It is not allowed to process personal data incompatible with the purposes of collecting personal data.
- 5.3. It is not allowed to merge databases containing personal data, the processing of which is carried out for purposes that are incompatible with each other.
- 5.4. Only personal data that meets the purposes of their processing are subject to processing.
- 5.5. The content and volume of processed personal data correspond to the stated processing purposes. Excessive processing of personal data relative to the stated purposes of their processing is not allowed.
- 5.6. When processing personal data, the accuracy of personal data, their sufficiency, and, if necessary, relevance to the purposes of processing personal data are ensured. The Operator takes the necessary measures and/or ensures their adoption for the deletion or clarification of incomplete or inaccurate data.
- 5.7. Storage of personal data is carried out in a form that allows determining the subject of personal data, no longer than required by the purposes of processing personal data, if the storage period of personal data is not established by federal law, a contract, the party of which, the beneficiary, or guarantor under which is the subject of personal data. Personal data being processed is destroyed or anonymized upon achieving the purposes of processing or in case of losing the need to achieve these goals unless otherwise provided by federal law.
- Purposes of Personal Data Processing
- Purpose of processing: informing the User by sending emails
- Personal data:
- surname, name, patronymic
- phone numbers
- Legal basis:
- Federal Law "On Information, Information Technologies and on the Protection of Information" of July 27, 2006 N 149-FZ
- Types of personal data processing:
- collection, recording, systematization, accumulation, storage, destruction, and anonymization of personal data
- Conditions for the Processing of Personal Data
- 7.1. The processing of personal data is carried out with the consent of the subject of personal data for the processing of his personal data.
- 7.2. The processing of personal data is necessary to achieve the purposes provided by an international treaty of the Russian Federation or by law, to perform the functions, powers, and duties imposed by the legislation of the Russian Federation on the operator.
- 7.3. The processing of personal data 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 the legislation of the Russian Federation on enforcement proceedings.
- 7.4. The processing of personal data is necessary for the execution of a contract, the party of which or the beneficiary or guarantor under which is the subject of personal data, as well as for the conclusion of a contract at the initiative of the subject of personal data or a contract under which the subject of personal data will be the beneficiary or guarantor.
- 7.5. The processing of personal data is necessary for the realization of the rights and lawful interests of the operator or third parties or for achieving socially significant goals provided that in doing so the rights and freedoms of the subject of personal data are not violated.
- 7.6. The processing of personal data, access to which is provided to an unlimited number of persons by the subject of personal data or at his request (hereinafter referred to as publicly available personal data), is carried out.
- 7.7. The processing of personal data that is subject to publication or mandatory disclosure in accordance with federal law is carried out.
- 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 by implementing legal, organizational, and technical measures necessary to fully meet 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 excluding access to personal data by unauthorized persons.
- 8.2. The User's personal data shall never, under any circumstances, be transferred to third parties, except in cases related to the implementation of current legislation or if the subject of personal data has consented to the Operator to transfer data to a third party to fulfill obligations under a civil law contract.
- 8.3. In case of inaccuracies in personal data, the User can update them independently by sending a notification to the Operator's email address info@xrent.com with the note "Updating personal data".
- 8.4. The term of processing personal data is determined by the achievement of the purposes for which the personal data were collected, unless another term is provided by the contract or current legislation.
- The User may at any time withdraw his consent to the processing of personal data by sending a notification to the Operator by email to the Operator's email address info@xrent.com with the note "Withdrawal of consent to the processing of personal data".
- 8.5. All information collected by third-party services, including payment systems, communication means, and other service providers, is stored and processed by the specified persons (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data and/or with the specified documents. The Operator is not responsible for the actions of third parties, including the specified service providers in this paragraph.
- 8.6. Prohibitions established by the subject of personal data on the transfer (except for providing access) as well as on the processing or conditions of processing (except for obtaining access) of personal data allowed for distribution, do not apply in cases of processing personal data in state, public, and other public interests defined by the legislation of the Russian Federation.
- 8.7. When processing personal data, the Operator ensures the confidentiality of personal data.
- 8.8. The Operator carries out the storage of personal data in a form that allows determining the subject of personal data, no longer than required by the purposes of processing personal data, if the storage period of personal data is not established by federal law, contract, the party of which, the beneficiary, or guarantor under which is the subject of personal data.
- 8.9. The condition for the termination of the processing of personal data may be the achievement of the purposes of processing personal data, the expiration of the consent of the subject of personal data, the withdrawal of consent by the subject of personal data or the requirement to stop the processing of personal data, as well as the detection of unlawful processing of personal data.
- List of Actions Performed by the Operator with the Obtained Personal Data
- 9.1. The Operator collects, records, systematizes, accumulates, stores, refines (updates, changes), extracts, uses, transfers (distributes, provides, grants access), anonymizes, blocks, deletes, and destroys personal data.
- 9.2. The Operator carries out automated processing of personal data with obtaining and/or transferring the received information via information and telecommunication networks or without such a network.
- Cross-Border Transfer of Personal Data
- 10.1. Before starting the activity related to the cross-border transfer of personal data, the Operator is obliged to notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out the cross-border transfer of personal data (such notification is sent separately from the notification of the intention to process personal data).
- 10.2. Before submitting the above notification, the Operator is required to obtain the relevant information from the authorities of the foreign state, foreign individuals, foreign legal entities to whom the cross-border transfer of personal data is planned.
- Confidentiality of Personal Data
- The Operator and other persons who have gained access to personal data are obliged not to disclose to third parties and not to distribute personal data without the consent of the subject of personal data, unless otherwise provided by federal law.
- Final Provisions
- 12.1. The User can obtain any clarifications on issues of interest concerning the processing of his personal data by contacting the Operator by email at info@xrent.com.
- 12.2. Any changes to the Operator's personal data processing policy will be reflected in this document. The policy is in effect indefinitely until it is replaced with a new version.
- 12.3. The current version of the Policy is freely accessible on the Internet at https://xrent.tilda.ws/policy.