Privacy policy

Personal Data Processing Policy

1. General Provisions

This personal data processing policy has been drawn up in accordance with the requirements of the Federal Law No. 152-FZ dated July 27, 2006. “On Personal Data” (hereinafter, the “Personal Data Law”) and defines the procedure for processing personal data and measures taken by Tatlift LLC (hereinafter, the “Operator”) to ensure the security of personal data.

1.1 The Operator sets as its foremost goal and responsibility the observance of the rights and freedoms of individuals in the processing of their personal data, including the protection of the rights to privacy, personal secrets, and family secrets.

1.2 This Operator's personal data processing policy (hereinafter, the “Policy”) applies to all information that the Operator may obtain about visitors to the website tatlift.com. tatlift.com.

2. Basic Concepts Used in the Policy

2.1 Automated personal data processing means the processing of personal data using computer technology.

2.2 Blocking of personal data means a temporary suspension of the personal data processing (unless the processing is necessary to correct personal data).

2.3 Website means a set of graphic and communication materials, along with computer programs and databases that support their availability on the Internet at the network address tatlift.com. tatlift.com.

2.4. Personal data information system means a set of personal data contained in databases, along with information technologies and hardware that support the processing of such data.

2.5. Depersonalization of personal data means actions that make it impossible to link, without the use of additional information, the personal data to a specific User or other personal data subject.

2.6. Personal data processing means 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, correction (updates, changes), extraction, use, transfer (dissemination, provision, access), depersonalization, blocking, deletion, or destruction of personal data.

2.7. Operator means a legal entity that organize or carry out, independently or jointly with other persons, the processing of personal data or determine the purposes of personal data processing, the scope of personal data to be processed, and the actions (operations) performed with personal data.

2.8. Personal data means any information relating directly or indirectly to a specific or identifiable User of the website tatlift.com. tatlift.com.

2.9. Personal data authorized by the personal data subject for dissemination means personal data access whereto by the general public has been provided by the personal data subject by granting consent to the processing of personal data permitted by the personal data subject for dissemination in the manner prescribed by the Personal Data Law (hereinafter, "personal data permitted for dissemination").

2.10. User means any visitor to the website tatlift.com. tatlift.com.

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

2.12. Dissemination of personal data means any actions aimed at disclosing personal data to the general public (transfer of personal data) for review by the general public, including the disclosure of personal data in mass media or placement thereof on information and telecommunication networks, or providing access to personal data by any other means.

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

2.14. Personal data destruction means any actions that result in personal data being irretrievably destroyed without the possibility of future restoration of the personal data content in the personal data information system and/or in physical media of personal data being destroyed.

3. Basic Rights and Obligations of the Operator

3.1. The Operator shall have the following rights:
— to receive accurate information and/or documents containing personal data from the personal data subject
— in the event that the personal data subject revokes their consent to the personal data processing, as well as if they submit a request to stop personal data processing, the Operator shall have the right to continue processing the personal data without the consent of the personal data subject if there are grounds provided for by Personal Data Law
— to independently determine the scope and list of measures necessary and sufficient to ensure the performance of the obligations stipulated by the Personal Data Law and the regulatory acts adopted thereunder, unless otherwise stipulated by the Personal Data Law or other federal laws.

3.2. The Operator shall have the following obligations:
— to provide the personal data subject, at their request, with information regarding the processing of their personal data
— to organize the personal data processing in the manner prescribed by the applicable law of the Russian Federation
— to respond to requests and inquiries from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law
— to report to the authorized body for the protection of rights of personal data subjects, at the request of that body, the required information within 10 days from the date of receipt of such request
— to publish or otherwise provide unrestricted access to this Personal Data Processing Policy
— to take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access thereto and from destruction, modification, blocking, copying, provision, dissemination, or other illegal actions in respect of personal data
— to terminate the transfer (dissemination, provision, access) of personal data, terminate the personal data processing, and destroy personal data in the manner and in cases provided for by the Personal Data Law
— to perform other obligations provided for by the Personal Data Law.

4. Basic Rights and Obligations of Personal Data Subjects

4.1. Personal data subjects shall have the following rights:
— to receive information regarding the processing of their personal data, except as otherwise prescribed by federal laws. The information shall be 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, unless there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining the same are stipulated by the Personal Data Law
— to require the Operator to adjust, block, or destroy their personal data if such personal data is incomplete, outdated, inaccurate, illegally obtained, or not necessary for the stated purpose of processing, and to take legal action to protect their rights
— to stipulate the condition of prior consent when personal data is processed to promote goods, works, or services on the market
— to revoke consent to the processing of personal data, as well as to send a claim to stop processing of personal data
— appeal to the authorized body for the protection of rights of personal data subjects or to a court against illegal actions or omissions of the Operator in the processing of their personal data
— to exercise other rights provided by the laws of the Russian Federation.

4.2. Personal data subjects shall have the following obligations:
— to provide the Operator with accurate information about themselves
— to inform the Operator of any corrections (updates, changes) to their personal data.

4.3. Persons who have provided the Operator with inaccurate information about themselves or information about another personal data subject without the consent of the latter shall be liable in accordance with the laws of the Russian Federation

5. Principles of Personal Data Processing

5.1. The processing of personal data shall be carried out on a lawful and fair basis.

5.2. The processing of personal data shall be limited to the achievement of specific, predetermined, and lawful purposes. Personal data processing inconsistent with the purposes of collecting personal data shall not be allowed

5.3. Combining databases containing personal data processed for purposes mutually incompatible shall not be allowed.

5.4. Only personal data that meet their processing purposes shall be subject to processing.

5.5. The content and scope of the personal data shall correspond to the stated purposes of processing. Excessive personal data being processed relative to the stated processing purposes shall not be allowed.

5.6. In the processing of personal data, care shall be taken to ensure the accuracy of the personal data, its sufficiency, and, if necessary, relevance in relation to the processing purposes of the personal data. The Operator shall take the necessary measures and/or ensure that such measures are taken to remove or correct incomplete or inaccurate data.

5.7. Personal data shall be stored in a form that allows to identify the personal data subject no longer than required by the purposes of the personal data processing, unless the period for storing personal data is established by federal law or an agreement whereto the personal data subject is a party or whereunder they are a beneficiary or guarantor. The processed personal data shall be destroyed or depersonalized upon achieving the processing purposes or cessation of the need to achieve these purposes, unless otherwise provided by federal law.

6. Purposes of Personal Data Processing

Purpose of processing	Informing the User by sending e-mails
Personal data	e-mail address e-mail address telephone numbers
Legal grounds	Federal Law N 149-FZ “On Information, Information Technologies and Information Protection” dated July 27, 2006
Types of personal data processing	Sending newsletters to the e-mail address

Purpose of processing	Providing the User with access to services, information and/or materials on the website
Personal data	e-mail address e-mail address telephone numbers
Legal grounds	Operator's statutory (founding) documents
Types of personal data processing	Collection, recording, systematization, accumulation, storage, destruction and depersonalization of personal data

Purpose of processing	Conclusion, execution and termination of civil law contracts
Personal data	e-mail address e-mail address telephone numbers
Legal grounds	Operator's statutory (founding) documents Contracts concluded between the operator and the subject of personal data
Types of personal data processing	Collection, recording, systematization, accumulation, storage, destruction and depersonalization of personal data Sending newsletters to the e-mail address

7. Conditions for the Processing of Personal Data

7.1. The processing of personal data shall be carried out with the personal data subject’s consent to the processing of their personal data.

7.2. The processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law for the Operator to perform its functions and obligations or to exercise its powers under the laws of the Russian Federation.

7.3. The processing of personal data is necessary for the administration of justice, such as enforcement of a court ruling or decision of another body or official to be enforced in accordance with the laws of the Russian Federation on enforcement proceedings.

7.4. The processing of personal data is necessary for the performance of an agreement whereto the personal data subject is a party or whereunder they are a beneficiary or guarantor, or for the execution of an agreement at the initiative of the personal data subject or an agreement whereunder the personal data subject will be a beneficiary or guarantor.

7.5. The processing of personal data is necessary for the exercise of the rights and legitimate interests of the Operator or third parties to achieve socially significant goals, provided that the rights and freedoms of the personal data subject are not violated.

7.6. The processing shall be carried out in respect of personal data the access to which by the general public is provided by the personal data subject or at their request (hereinafter, "publicly available personal data").

7.7. The processing is carried out in respect of personal data subject to publication or mandatory disclosure in accordance with federal law.

8. Procedure for Collecting, Storing, Transferring, and Other Processing of Personal Data

The security of personal data processed by the Operator shall be ensured through the implementation of legal, organizational, and technical measures necessary to fully comply with the requirements of the applicable law related to personal data protection.

8.1. The Operator shall ensure the integrity of personal data and take all possible measures to prevent 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 compliance with applicable law or if the personal data subject has granted consent to the Operator to transfer data to a third party for the performance of obligations under a civil law contract.

8.3. If inaccuracies are found in personal data, the User shall be able to correct them independently by sending a notification to the Operator at the Operator’s e-mail address (info@tatlift.com) info@tatlift.com marked "Personal Data Update".

8.4. The time period for the processing of personal data shall be determined by the achievement of the purposes for which the personal data was collected, unless a different period is stipulated by a contract or applicable law.
The User may at any time revoke their consent to the processing of personal data by sending to the Operator a notification by e-mail at the Operator’s email address (info@tatlift.com) info@tatlift.com marked "Revocation of Consent to Personal Data Processing".

8.5. All information being collected by third-party services, including payment systems, communication providers, and other service providers, shall be stored and processed by these parties (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject and/or the User shall be obliged to independently review the said documents in a timely manner. The Operator shall not be liable for the actions of third parties, including the service providers specified in this clause.

8.6. The prohibitions established by the personal data subject on the transfer (other than granting access) or on the processing or processing conditions (other than obtaining access) of personal data permitted for dissemination shall not apply in cases of processing personal data in state, public, or other such interests defined by laws of the Russian Federation.

8.7. In processing personal data, the Operator shall ensure the confidentiality of personal data.

8.8. The Operator shall store personal data in a form that allows to identify the personal data subject no longer than required by the purposes of the personal data processing, unless the period for storing personal data is established by federal law or an agreement whereto the personal data subject is a party or whereunder they are a beneficiary or guarantor.

8.9. The conditions for terminating personal data processing shall include the achievement of the purposes of the personal data processing, expiration of the personal data subject’s consent, revocation of consent by the personal data subject, and identification of unlawful processing of personal data.

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

9.1. The Operator shall carry out collection, recording, systematization, accumulation, storage, correction (updates, changes), extraction, use, transfer (dissemination, provision, access), depersonalization, blocking, deletion, and destruction of personal data.

9.2. The Operator shall carry out automated processing of personal data with or without the receipt and/or transmission of the information obtained via information and telecommunication networks.

10. Cross-Border Transfer of Personal Data

10.1. Prior to the start of cross-border transfer of personal data, the Operator shall notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out transborder transfer of personal data (such notification shall be sent separately from the notification on the intention to carry out personal data processing).

10.2. Prior to submitting the above-mentioned notification, the Operator shall obtain the following information from foreign authorities, foreign individuals, and foreign legal entities to whom the personal data is planned to be transferred across borders:

1) information on measures taken by foreign authorities, foreign individuals, foreign legal entities, to whom the personal data is planned to be transferred across borders, to protect the transferred personal data and information on the conditions of termination of their processing

2) information on legal regulations in the field of personal data of a foreign state, under the jurisdiction of which the authorities of the foreign authorities, foreign individuals, foreign legal entities are located, to whom the personal data is planned to be transferred across borders (in the event that cross-border transfer of personal data to foreign authorities, foreign individuals, foreign legal entities under the jurisdiction of a foreign state that is not a party to the Council of Europe Convention for the Protection of Individuals with regard to Automatic Processing of Personal Data and is not included in the list of foreign states ensuring adequate protection of the rights of personal data subjects is envisaged)

3) information on the foreign authorities, foreign individuals, foreign legal entities, to whom the personal data is planned to be transferred across borders (their name or individual’s full name, contact telephone numbers, postal addresses and e-mail).

11. Confidentiality of Personal Data

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

12. Final Provisions

12.1. The User can receive any explanations on issues of interest regarding the processing of their personal data by contacting the Operator via e-mail at info@tatlift.com. info@tatlift.com.

12.2. This document will reflect any changes made to the personal data processing policy by the Operator. The Policy shall remain in effect indefinitely until it is replaced by a new version.

12.3. The current version of the Policy is publicly available on the Internet at tatlift.com/privacy/. tatlift.com/privacy/.