Personal Data Processing Policy
This Personal Data Processing Policy (hereinafter referred to as the "Policy") applies to all information that GREENDIVISION LLC (hereinafter referred to as the "Company") and/or its affiliates, including all entities belonging to the same group as GREENDIVISION LLC, may obtain about the User while using any of the websites, services, programs, and products of GREENDIVISION LLC during the process of registration, authorization, and other use, as well as in the course of GREENDIVISION LLC / its affiliates fulfilling any agreements and contracts concluded with the User in connection with the use of the services.
The consent of the User to the processing of personal data and other information provided by him to the Company, expressed in accordance with the Policy, is considered, at the same time, to be provided by the User to the third parties specified in the Policy, engaged by the Company to assist in the execution of the User Agreement, the Accession Agreement, the License Agreement.
The use of the website https://electro.cars (hereinafter referred to as the "Website"), the electro.cars Application (hereinafter referred to as the "Application"), and the electro.cars Service (hereinafter referred to as the "Service"), including the User's registration and authorization, signifies the User's unconditional consent to this Policy and all the conditions specified therein for the processing of their personal data and other information, namely the performance of actions provided for in Paragraph 3, Part 1, Article 3 of the Federal Law of July 27, 2006, No. 152-FZ "On Personal Data" both with and without the use of automation tools, and confirms that, by giving such consent, they are acting voluntarily, of their own will, and in their own interest. In case of disagreement with this Policy and all its conditions, the User must refrain from using the Website, Application, and Service.
By using our Website, Service, Application, and providing your consent to the use of personal data, you also give your consent to the recording of conversations with Company employees or call center operators, and to the sending of information, individual offers, and promotional materials about the products and services provided by the Company, related to the Website, Service, Application, and the Company's business activities, including messages about existing or developing goods and services of the Company and its partners, via any communication channels, including: SMS notifications, push notifications, messages via WhatsApp, phone calls, voice messages, and emails. You acknowledge that you have read the terms of this Policy and agree to the processing of your personal data under the terms specified below. If you do not agree with these terms, please do not provide your personal data.
You independently decide to provide us with your personal data through special interactive forms posted on the Website, Service, and Application. You give your consent to the processing of personal data voluntarily, of your own will, and in your own interest. By providing your consent and continuing to use the Website, you express your agreement that your consent to the processing of personal data is specific, informed, and conscious. Consent is considered granted if you check the "box" in the interactive personal data collection form to confirm that you agree with this Policy.
Terms and Definitions
This Policy uses the following terms:
1. Personal Data and Other User Information Received and Processed by the Company
1.1. During User registration, authorization, as well as when using the Website, Application, Services, making payments, conducting surveys, sending informational and promotional messages, and in all other cases provided for by the User Agreement, the Accession Agreement, and the License Agreement, the Company may request from the User (clause 1.1.1 of the Policy) and/or receive automatically (clause 1.1.2 of the Policy) the following information about the User:
1.1.1. Last name, first name, patronymic, year, month, date, and place of birth, gender, passport details, mobile phone number, email address, registration address/actual (mailing) address, login and password information for accessing certain functions of the Website, Application, Service, driver's license data, data on the presence (absence) of medical contraindications to using a vehicle, biometric data (photographs), data on place of work, position, control information, service usage history (information on the number, cost, time, and order of User orders for Service services and their payment, including bank account and/or bank card details), information on participation in promotions, information on subscription to informational newsletters or support service materials), bank details for refunds, as well as other personal data and information;
1.1.2. Information automatically transmitted to the Company during the use of the Website, Application, Service using software installed on the User's device, including IP address, information from cookies and tracking bugs, information about the User's country and/or city of location, information about the User's Internet browser (or other program used to access the Website, Application, Service), access time, address of the requested page, information about the User's devices used to access the Website, Application, Service.
1.2. This Policy applies only to the Website, Application, and Service. The Company does not control and is not responsible for third-party websites and software that the User may access via links available on the Website, Application, or Service. On such third-party websites, other information may be collected or requested from the User, and other actions may be taken, for which the Company is not responsible.
1.3. The Company generally does not verify the accuracy of personal information provided by Users and does not monitor their legal capacity. The Company assumes that the User is an adult with full legal capacity, meets the requirements of the User Agreement, the Accession Agreement, and the License Agreement, provides reliable and sufficient information, and keeps this information up to date. The risk of providing inaccurate information is borne by the User who provided it.
1.4. The Company has the right to verify the information provided by the User in accordance with the provisions of the User Agreement, the Accession Agreement, and the License Agreement. If the User provides inaccurate information, the Company has the right to suspend or cancel registration and/or deny the User access to the Website, Application, and Service. The Company and/or other third parties are not liable for providing inaccurate information and the resulting negative consequences. If the Website, Application, or Service is used by a minor and/or incapacitated person, the parents, adoptive parents, and other legal representatives of the minor and/or incapacitated person are responsible for such use not authorized by the Company.
1.5. The User's consent to the processing of personal data is valid indefinitely from the moment of the User's registration on the Website and/or Service and/or Application and does not require periodic confirmation. The Company will store personal information for as long as necessary to achieve the purpose for which it was collected or to comply with legal and regulatory requirements.
2. Purposes of Collecting and Processing Users' Personal Information
2.1. The Company collects, processes, and stores only those personal data that are necessary for providing the Service and rendering services (performing agreements and contracts with the User), in strict accordance with applicable law.
2.2. The Company uses the User's personal data and other information for the purposes of concluding and performing the User Agreement, concluding and performing the Accession Agreement, the License Agreement, providing additional services, improving service quality, User participation in promotions, surveys, and research conducted by the Company (including, but not limited to, conducting surveys and research via electronic, telephone, and mobile communication), making decisions or performing other actions that have legal consequences for the User or other persons, providing the User with information about the services provided by the Company, and providing consulting services by the Company. These purposes of using personal data apply to all information specified in clause 1.1 of the Policy.
2.3. The purposes of collecting and processing personal data include, without limitation, the following: registration, identification, and authorization of the User within the Service, conclusion and performance of the User Agreement, the Accession Agreement, the License Agreement, providing the User with the Service, as well as any additional functionality within the Service; processing User requests by the Company within the Service; analysis and research to improve the Service; sending news and information about products, services, special offers related to the Service; sending service messages (e.g., to inform about the status of car rental, recovery/changes of User login and password, etc.); prevention and detection of fraud and illegal use of the Service; conducting statistical and other research based on anonymized data, targeted advertising; communication with the User, including sending notifications, requests, and information related to the use of the Services, provision of services, as well as processing User requests and applications.
3. Conditions for Processing User's Personal Information
3.1. The confidentiality of the User's personal information is maintained, except in cases where the User voluntarily provides information about themselves for general access to an unlimited number of persons.
3.2. The Company uses the User's personal data and other information only for the purposes specified in this Policy and in accordance with this Policy.
3.3. The Company will not disclose to third parties, distribute, sell, or otherwise dispose of the received personal data and other information, except for the purposes, methods, and within the limits provided for by this Policy.
3.4. The processing of the User's personal and other data is carried out by the Company to the extent necessary to achieve each of the purposes specified in Section 2 of this Policy, by the following possible methods: collection, recording (including on electronic media), systematization, accumulation, storage, compilation of lists, labeling, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction, cross-border transfer of personal data, obtaining images through photography, as well as performing any other actions with the User's personal data, taking into account applicable law. The Company has the right to process the User's personal and other data both with and without the use of automation tools.
3.5. The Company has the right to transfer the personal data provided by the User for processing (issue an instruction for processing) (to the extent necessary for the Company to fulfill its obligations) to third parties, including organizations engaged by the Company for sending messages via email/mobile operators, debiting/crediting funds from/to bank cards/current accounts – to credit institutions (banks), payment systems, mobile operators, courier services, postal organizations, including cross-border transfer of the User's personal data in written or electronic form, in the cases and manner provided for by the relevant agreements with said third parties, the Company's rules, and applicable law.
3.6. The Company also has the right to transfer the personal data provided by the User to state authorities, courts, other authorized bodies and organizations, in cases and in the manner required by the law applicable to this Policy.
3.7. The Company guarantees the fair and lawful processing of the User's personal and other data in accordance with the purposes provided for in Section 2 of this Policy.
3.8. The Company guarantees the prompt updating of the User's data upon their provision of updated data.
3.9. Consent to the processing of personal data and other data is given by the User on an indefinite basis, or until the expiration of the storage periods for the relevant information or documents containing the aforementioned information, determined in accordance with the law applicable to this Policy. After this period, the personal data are subject to destruction by the Company.
3.10. The Company processes personal data based on the following principles: legality and fair basis; limiting the processing of personal data to achieving specific, predetermined, and lawful purposes; not allowing processing of personal data incompatible with the purposes of collecting personal data; not combining databases containing personal data processed for incompatible purposes; processing only those personal data that meet the purposes of their processing; compliance of the content and volume of processed personal data with the stated processing purposes; not allowing the processing of personal data excessive in relation to the stated purposes of their processing; ensuring the accuracy, sufficiency, and relevance of personal data in relation to the purposes of processing personal data; destruction or depersonalization of personal data upon achieving the purposes of their processing or in case of loss of the necessity to achieve these purposes, if the Operator cannot eliminate the violations of personal data, unless otherwise provided by federal law.
3.11. Ensuring the Security of Personal Data.
3.11.1. The security of personal data processed by the Company is ensured by the implementation of legal, organizational, and technical measures necessary to meet the requirements of federal legislation in the field of personal data protection. To prevent unauthorized access to personal data, the Company applies the following organizational and technical measures: appointment of officials responsible for the organization of processing and protection of personal data; limiting the number of persons with access to personal data; familiarizing subjects with the requirements of federal legislation and the Company's regulatory documents on the processing and protection of personal data; organization of accounting, storage, and handling of information carriers; identification of threats to the security of personal data during their processing, formation of threat models based on them, including during automated data processing; development of a personal data protection system based on the threat model, including during automated data processing; checking the readiness and effectiveness of information protection means, including during automated data processing; differentiation of User access to information resources, personalization and accounting of Company employees' access to software and hardware for information processing; registration and accounting of actions of Users of personal data information systems; use of antivirus tools and system recovery tools for personal data protection; application, where necessary, of firewalls, intrusion detection systems, security analysis tools, and cryptographic information protection tools; organization of access control to the Company's territory, protection of premises with technical means for processing personal data.
4. Changes to Personal Information by the User
4.1. The User can at any time change (update, supplement) the personal data and other information they provided by contacting the Company, for example, through the support service or using the contacts indicated on the Website or in the Application, with a request to change (update, supplement) the information previously provided by them (the Company changes (updates, supplements) the information provided by the User only after conducting the User identification procedure applied by the Company at the time of the relevant request).
4.2. The User has the right to withdraw their consent to the processing of personal data by sending a corresponding written notification to the Company at least 30 (thirty calendar) days before the withdrawal of consent, whereby the User acknowledges and understands that access to the use of the Website and Application Services, and the Service will not be provided by the Company from the moment the Company loses the ability to process the User's personal data.
5. Measures Taken to Protect Users' Personal Information
5.1. The Company takes necessary and sufficient organizational and technical measures to protect the User's personal information from unlawful or accidental access, destruction, modification, blocking, copying, distribution, as well as from other unlawful actions by third parties.
6. Use of Cookies
6.1. To improve the quality of the Service provided, the Company may use (temporary and permanent) cookies, tracking bugs, and/or other technologies for collecting non-personal data (e.g., IP address, browser type, and Internet Service Provider (ISP) data, as well as (for Users who use the Company's services through a mobile device) a unique device identifier, operating system data, and coordinates for the purpose of accounting for the number of Users and their behavior when using the Service. For the convenience of Users, the Company has the right to collect and process information about the total number of operations, pages viewed by the User, referring/exit pages, platform type, date/time of information recording, number and location of views of a given page, page views, and used (search) words.
6.2. The Company may use cookies and tracking bugs to monitor the use of the Service, collect non-personal information about the User, save preferences and other information on the User's device to save the User time required for repeatedly entering the same information in the forms on the Website and Application, as well as to display content during subsequent visits by the User to the Website and Application. Information obtained through cookies and tracking bugs may also be used by the Company for statistical research aimed at adjusting the content of the Website and Application according to the User's preferences.
6.3. The Company may provide the User with the ability to change the settings for accepting cookies and tracking bugs in their browser settings or disable them completely; however, in this case, some functions of the Service may work incorrectly.
7. Changes to the Privacy Policy. Applicable Law.
7.1. The Company has the right, at its sole discretion, to change and/or supplement this Policy at any time without prior and/or subsequent notice to the User. When changes are made, the date of the last update is indicated in the current version. The current version of the Policy is always available on the Website, Service, or in the Application.
7.2. The User's continued use of the Service, Application, and Website after any changes and/or additions to the Policy signifies their consent to such changes and/or additions.
7.3. The User undertakes to regularly review the content of the Policy to timely familiarize themselves with its changes/additions.
7.4. This Policy and the relations between the User and the Company arising in connection with the application of the Policy shall be governed by the law of the Russian Federation.
7.5. This Policy has been developed in accordance with the provisions of the Federal Law of the Russian Federation of July 27, 2006, No. 152-FZ "On Personal Data" as well as other regulatory legal acts of the Russian Federation establishing requirements for the processing of personal data. If any obligation or any rights, conditions, or principles of processing are not mentioned in this Policy, they are determined in accordance with the legislation of the Russian Federation.
7.6. In case of loss or disclosure of Confidential Information, the Site Administration is not responsible if this confidential information:
7.6.1. Became public domain before its loss or disclosure.
7.6.2. Was received from a third party before it was received by the Site Administration.
7.6.3. Was disclosed with the User's consent.
7.7. Before going to court with a claim for disputes arising from the relations between the User and the Company, it is mandatory to submit a claim (a written proposal for a voluntary settlement of the dispute).
7.8. The recipient of the claim, within 30 calendar days from the date of receipt of the claim, shall notify the claimant in writing of the results of the consideration of the claim.
7.9. If no agreement is reached, the dispute will be referred to a judicial authority for consideration in accordance with the current legislation of the Russian Federation.
Appendix No.1 to the Personal Data Processing Policy
Consent to the processing of the personal data
By using the Website, Services, Application, filling out and sending the registration form, authorizing on the Website, Service, Application, and/or calling the Company's phone number indicated on the website, I voluntarily, of my own will, and in my own interest, express to GREENDIVISION LLC (registered address: 129626, Moscow, Alekseevsky Municipal district, Mira Avenue, house 102, building 12, office 12A, PSRN 1217700250404, TIN 9710089850, TRRC 771701001) and/or an operator engaged at the discretion or desire of GREENDIVISION LLC, consent to the processing of personal data, implying collection (directly from the applicant, from third parties, by sending requests to state authorities, local self-government bodies, legal entities and individuals, from other publicly available information resources, from archives), recording, systematization, accumulation, storage, clarification (updating, modification), verification, extraction, use, transfer (distribution, provision, access), in full or in part to third parties acting on the basis of agreements concluded by them with the Company, depersonalization, blocking, deletion, and destruction of the following my personal data:
Last name, first name, patronymic, year, month, date, and place of birth, gender, passport details, mobile phone number, email address, registration address/actual (mailing) address, login and password information for accessing certain functions of the Website, Application, Service, driver's license data, data on the presence (absence) of medical contraindications to using a vehicle, biometric data (photographs), data on place of work, position, control information, Service usage history (information on the number, cost, time, and order of User orders for Service services and their payment, including bank account and/or bank card details), information on participation in promotions, information on subscription to informational newsletters or support service materials), bank details for refunds, as well as other personal data and information;
Information automatically transmitted to the Company during the use of the Website, Application, Service using software installed on the User's device, including IP address, information from cookies and tracking bugs, information about the User's country and/or city of location, information about the User's Internet browser (or other program used to access the Website, Application, Service), access time, address of the requested page, information about the User's devices used to access the Website, Application, Service.
For the purposes of providing access to the Website/ to the account on the Website, Service, Application, providing consulting support in connection with the use of the Website, Service, Application, sending calculations and commercial offers for the sale of goods and services of the Company and/or the Company's partners, obtaining statistical and analytical data to improve the functioning of the Website and/or Services and/or Application, expanding the range of Services provided, receiving informational and/or promotional messages from the Company or third parties, preventing or suppressing illegal and/or unauthorized actions of Users or third parties, ensuring compliance with the requirements of the current legislation of the Russian Federation.
The processing of personal data is carried out both with the use of automation tools, including in information and telecommunication networks, and without the use of such tools.
The User, hereby, gives their consent to the specified processing of Users' personal data, as well as to sending them, via any communication channels, including: SMS notifications, push notifications, messages via WhatsApp, phone calls, voice messages, and emails, information, individual offers, and promotional materials about the products and services provided by the Company, related to the Website, Service, Application, and the Company's business activities, including messages about existing or developing goods and services of the Company.
Consent is granted from the moment I sign this Application and for my entire lifetime.
GREENDIVISION LLC, in accordance with this consent and to achieve the above purposes, has the right to entrust the processing of personal data to third parties, as well as in case of involving third parties to provide services and/or in case of transfer by GREENDIVISION LLC of its rights of claim to a third party, has the right to disclose/transfer information to such third parties, their agents, and other persons authorized by them to the necessary extent, as well as provide such persons with relevant documents containing such information.
Consent may be withdrawn by the User at any time by sending a corresponding signed written notification to GREENDIVISION LLC at the address: 129626, Moscow, Alekseevsky Municipal district, Mira Avenue, house 102, building 12, office 12A, at least 30 (thirty) calendar days in advance.
In case of withdrawal of this consent, GREENDIVISION LLC has the right to continue processing personal data in the cases and manner provided for by the legislation of the Russian Federation.
I, hereby, acknowledge that I have received all necessary information regarding the processing of my personal data. I confirm that all personal data provided during registration, submission of the Application form on the Website, Application, or Service, or communicated during a call to an operator, are my own. I declare that all information about my identity stated during registration is accurate and complete. I have carefully read this consent in its entirety, fully understand the terms of processing of my personal data, and accept them without any reservations or limitations.
This Personal Data Processing Policy (hereinafter referred to as the "Policy") applies to all information that GREENDIVISION LLC (hereinafter referred to as the "Company") and/or its affiliates, including all entities belonging to the same group as GREENDIVISION LLC, may obtain about the User while using any of the websites, services, programs, and products of GREENDIVISION LLC during the process of registration, authorization, and other use, as well as in the course of GREENDIVISION LLC / its affiliates fulfilling any agreements and contracts concluded with the User in connection with the use of the services.
The consent of the User to the processing of personal data and other information provided by him to the Company, expressed in accordance with the Policy, is considered, at the same time, to be provided by the User to the third parties specified in the Policy, engaged by the Company to assist in the execution of the User Agreement, the Accession Agreement, the License Agreement.
The use of the website https://electro.cars (hereinafter referred to as the "Website"), the electro.cars Application (hereinafter referred to as the "Application"), and the electro.cars Service (hereinafter referred to as the "Service"), including the User's registration and authorization, signifies the User's unconditional consent to this Policy and all the conditions specified therein for the processing of their personal data and other information, namely the performance of actions provided for in Paragraph 3, Part 1, Article 3 of the Federal Law of July 27, 2006, No. 152-FZ "On Personal Data" both with and without the use of automation tools, and confirms that, by giving such consent, they are acting voluntarily, of their own will, and in their own interest. In case of disagreement with this Policy and all its conditions, the User must refrain from using the Website, Application, and Service.
By using our Website, Service, Application, and providing your consent to the use of personal data, you also give your consent to the recording of conversations with Company employees or call center operators, and to the sending of information, individual offers, and promotional materials about the products and services provided by the Company, related to the Website, Service, Application, and the Company's business activities, including messages about existing or developing goods and services of the Company and its partners, via any communication channels, including: SMS notifications, push notifications, messages via WhatsApp, phone calls, voice messages, and emails. You acknowledge that you have read the terms of this Policy and agree to the processing of your personal data under the terms specified below. If you do not agree with these terms, please do not provide your personal data.
You independently decide to provide us with your personal data through special interactive forms posted on the Website, Service, and Application. You give your consent to the processing of personal data voluntarily, of your own will, and in your own interest. By providing your consent and continuing to use the Website, you express your agreement that your consent to the processing of personal data is specific, informed, and conscious. Consent is considered granted if you check the "box" in the interactive personal data collection form to confirm that you agree with this Policy.
Terms and Definitions
This Policy uses the following terms:
- "Personal Data" – any information relating directly or indirectly to a specific or identifiable person (subject of personal data).
- "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, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
- "Confidentiality of Personal Data" – a mandatory requirement for the Company or any other person who has gained access to personal data to prevent their distribution without the consent of the subject of personal data or the existence of another legal basis.
- "User" – a person with access to the Website, Service, Application via the Internet.
- "Cookies" – a small piece of data sent by a web server and stored on the User's computer, which the web client or web browser sends to the web server each time in an HTTP request when trying to open a page of the corresponding site.
- "IP address" – a unique network address of a node in a computer network built using the IP protocol.
1. Personal Data and Other User Information Received and Processed by the Company
1.1. During User registration, authorization, as well as when using the Website, Application, Services, making payments, conducting surveys, sending informational and promotional messages, and in all other cases provided for by the User Agreement, the Accession Agreement, and the License Agreement, the Company may request from the User (clause 1.1.1 of the Policy) and/or receive automatically (clause 1.1.2 of the Policy) the following information about the User:
1.1.1. Last name, first name, patronymic, year, month, date, and place of birth, gender, passport details, mobile phone number, email address, registration address/actual (mailing) address, login and password information for accessing certain functions of the Website, Application, Service, driver's license data, data on the presence (absence) of medical contraindications to using a vehicle, biometric data (photographs), data on place of work, position, control information, service usage history (information on the number, cost, time, and order of User orders for Service services and their payment, including bank account and/or bank card details), information on participation in promotions, information on subscription to informational newsletters or support service materials), bank details for refunds, as well as other personal data and information;
1.1.2. Information automatically transmitted to the Company during the use of the Website, Application, Service using software installed on the User's device, including IP address, information from cookies and tracking bugs, information about the User's country and/or city of location, information about the User's Internet browser (or other program used to access the Website, Application, Service), access time, address of the requested page, information about the User's devices used to access the Website, Application, Service.
1.2. This Policy applies only to the Website, Application, and Service. The Company does not control and is not responsible for third-party websites and software that the User may access via links available on the Website, Application, or Service. On such third-party websites, other information may be collected or requested from the User, and other actions may be taken, for which the Company is not responsible.
1.3. The Company generally does not verify the accuracy of personal information provided by Users and does not monitor their legal capacity. The Company assumes that the User is an adult with full legal capacity, meets the requirements of the User Agreement, the Accession Agreement, and the License Agreement, provides reliable and sufficient information, and keeps this information up to date. The risk of providing inaccurate information is borne by the User who provided it.
1.4. The Company has the right to verify the information provided by the User in accordance with the provisions of the User Agreement, the Accession Agreement, and the License Agreement. If the User provides inaccurate information, the Company has the right to suspend or cancel registration and/or deny the User access to the Website, Application, and Service. The Company and/or other third parties are not liable for providing inaccurate information and the resulting negative consequences. If the Website, Application, or Service is used by a minor and/or incapacitated person, the parents, adoptive parents, and other legal representatives of the minor and/or incapacitated person are responsible for such use not authorized by the Company.
1.5. The User's consent to the processing of personal data is valid indefinitely from the moment of the User's registration on the Website and/or Service and/or Application and does not require periodic confirmation. The Company will store personal information for as long as necessary to achieve the purpose for which it was collected or to comply with legal and regulatory requirements.
2. Purposes of Collecting and Processing Users' Personal Information
2.1. The Company collects, processes, and stores only those personal data that are necessary for providing the Service and rendering services (performing agreements and contracts with the User), in strict accordance with applicable law.
2.2. The Company uses the User's personal data and other information for the purposes of concluding and performing the User Agreement, concluding and performing the Accession Agreement, the License Agreement, providing additional services, improving service quality, User participation in promotions, surveys, and research conducted by the Company (including, but not limited to, conducting surveys and research via electronic, telephone, and mobile communication), making decisions or performing other actions that have legal consequences for the User or other persons, providing the User with information about the services provided by the Company, and providing consulting services by the Company. These purposes of using personal data apply to all information specified in clause 1.1 of the Policy.
2.3. The purposes of collecting and processing personal data include, without limitation, the following: registration, identification, and authorization of the User within the Service, conclusion and performance of the User Agreement, the Accession Agreement, the License Agreement, providing the User with the Service, as well as any additional functionality within the Service; processing User requests by the Company within the Service; analysis and research to improve the Service; sending news and information about products, services, special offers related to the Service; sending service messages (e.g., to inform about the status of car rental, recovery/changes of User login and password, etc.); prevention and detection of fraud and illegal use of the Service; conducting statistical and other research based on anonymized data, targeted advertising; communication with the User, including sending notifications, requests, and information related to the use of the Services, provision of services, as well as processing User requests and applications.
3. Conditions for Processing User's Personal Information
3.1. The confidentiality of the User's personal information is maintained, except in cases where the User voluntarily provides information about themselves for general access to an unlimited number of persons.
3.2. The Company uses the User's personal data and other information only for the purposes specified in this Policy and in accordance with this Policy.
3.3. The Company will not disclose to third parties, distribute, sell, or otherwise dispose of the received personal data and other information, except for the purposes, methods, and within the limits provided for by this Policy.
3.4. The processing of the User's personal and other data is carried out by the Company to the extent necessary to achieve each of the purposes specified in Section 2 of this Policy, by the following possible methods: collection, recording (including on electronic media), systematization, accumulation, storage, compilation of lists, labeling, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction, cross-border transfer of personal data, obtaining images through photography, as well as performing any other actions with the User's personal data, taking into account applicable law. The Company has the right to process the User's personal and other data both with and without the use of automation tools.
3.5. The Company has the right to transfer the personal data provided by the User for processing (issue an instruction for processing) (to the extent necessary for the Company to fulfill its obligations) to third parties, including organizations engaged by the Company for sending messages via email/mobile operators, debiting/crediting funds from/to bank cards/current accounts – to credit institutions (banks), payment systems, mobile operators, courier services, postal organizations, including cross-border transfer of the User's personal data in written or electronic form, in the cases and manner provided for by the relevant agreements with said third parties, the Company's rules, and applicable law.
3.6. The Company also has the right to transfer the personal data provided by the User to state authorities, courts, other authorized bodies and organizations, in cases and in the manner required by the law applicable to this Policy.
3.7. The Company guarantees the fair and lawful processing of the User's personal and other data in accordance with the purposes provided for in Section 2 of this Policy.
3.8. The Company guarantees the prompt updating of the User's data upon their provision of updated data.
3.9. Consent to the processing of personal data and other data is given by the User on an indefinite basis, or until the expiration of the storage periods for the relevant information or documents containing the aforementioned information, determined in accordance with the law applicable to this Policy. After this period, the personal data are subject to destruction by the Company.
3.10. The Company processes personal data based on the following principles: legality and fair basis; limiting the processing of personal data to achieving specific, predetermined, and lawful purposes; not allowing processing of personal data incompatible with the purposes of collecting personal data; not combining databases containing personal data processed for incompatible purposes; processing only those personal data that meet the purposes of their processing; compliance of the content and volume of processed personal data with the stated processing purposes; not allowing the processing of personal data excessive in relation to the stated purposes of their processing; ensuring the accuracy, sufficiency, and relevance of personal data in relation to the purposes of processing personal data; destruction or depersonalization of personal data upon achieving the purposes of their processing or in case of loss of the necessity to achieve these purposes, if the Operator cannot eliminate the violations of personal data, unless otherwise provided by federal law.
3.11. Ensuring the Security of Personal Data.
3.11.1. The security of personal data processed by the Company is ensured by the implementation of legal, organizational, and technical measures necessary to meet the requirements of federal legislation in the field of personal data protection. To prevent unauthorized access to personal data, the Company applies the following organizational and technical measures: appointment of officials responsible for the organization of processing and protection of personal data; limiting the number of persons with access to personal data; familiarizing subjects with the requirements of federal legislation and the Company's regulatory documents on the processing and protection of personal data; organization of accounting, storage, and handling of information carriers; identification of threats to the security of personal data during their processing, formation of threat models based on them, including during automated data processing; development of a personal data protection system based on the threat model, including during automated data processing; checking the readiness and effectiveness of information protection means, including during automated data processing; differentiation of User access to information resources, personalization and accounting of Company employees' access to software and hardware for information processing; registration and accounting of actions of Users of personal data information systems; use of antivirus tools and system recovery tools for personal data protection; application, where necessary, of firewalls, intrusion detection systems, security analysis tools, and cryptographic information protection tools; organization of access control to the Company's territory, protection of premises with technical means for processing personal data.
4. Changes to Personal Information by the User
4.1. The User can at any time change (update, supplement) the personal data and other information they provided by contacting the Company, for example, through the support service or using the contacts indicated on the Website or in the Application, with a request to change (update, supplement) the information previously provided by them (the Company changes (updates, supplements) the information provided by the User only after conducting the User identification procedure applied by the Company at the time of the relevant request).
4.2. The User has the right to withdraw their consent to the processing of personal data by sending a corresponding written notification to the Company at least 30 (thirty calendar) days before the withdrawal of consent, whereby the User acknowledges and understands that access to the use of the Website and Application Services, and the Service will not be provided by the Company from the moment the Company loses the ability to process the User's personal data.
5. Measures Taken to Protect Users' Personal Information
5.1. The Company takes necessary and sufficient organizational and technical measures to protect the User's personal information from unlawful or accidental access, destruction, modification, blocking, copying, distribution, as well as from other unlawful actions by third parties.
6. Use of Cookies
6.1. To improve the quality of the Service provided, the Company may use (temporary and permanent) cookies, tracking bugs, and/or other technologies for collecting non-personal data (e.g., IP address, browser type, and Internet Service Provider (ISP) data, as well as (for Users who use the Company's services through a mobile device) a unique device identifier, operating system data, and coordinates for the purpose of accounting for the number of Users and their behavior when using the Service. For the convenience of Users, the Company has the right to collect and process information about the total number of operations, pages viewed by the User, referring/exit pages, platform type, date/time of information recording, number and location of views of a given page, page views, and used (search) words.
6.2. The Company may use cookies and tracking bugs to monitor the use of the Service, collect non-personal information about the User, save preferences and other information on the User's device to save the User time required for repeatedly entering the same information in the forms on the Website and Application, as well as to display content during subsequent visits by the User to the Website and Application. Information obtained through cookies and tracking bugs may also be used by the Company for statistical research aimed at adjusting the content of the Website and Application according to the User's preferences.
6.3. The Company may provide the User with the ability to change the settings for accepting cookies and tracking bugs in their browser settings or disable them completely; however, in this case, some functions of the Service may work incorrectly.
7. Changes to the Privacy Policy. Applicable Law.
7.1. The Company has the right, at its sole discretion, to change and/or supplement this Policy at any time without prior and/or subsequent notice to the User. When changes are made, the date of the last update is indicated in the current version. The current version of the Policy is always available on the Website, Service, or in the Application.
7.2. The User's continued use of the Service, Application, and Website after any changes and/or additions to the Policy signifies their consent to such changes and/or additions.
7.3. The User undertakes to regularly review the content of the Policy to timely familiarize themselves with its changes/additions.
7.4. This Policy and the relations between the User and the Company arising in connection with the application of the Policy shall be governed by the law of the Russian Federation.
7.5. This Policy has been developed in accordance with the provisions of the Federal Law of the Russian Federation of July 27, 2006, No. 152-FZ "On Personal Data" as well as other regulatory legal acts of the Russian Federation establishing requirements for the processing of personal data. If any obligation or any rights, conditions, or principles of processing are not mentioned in this Policy, they are determined in accordance with the legislation of the Russian Federation.
7.6. In case of loss or disclosure of Confidential Information, the Site Administration is not responsible if this confidential information:
7.6.1. Became public domain before its loss or disclosure.
7.6.2. Was received from a third party before it was received by the Site Administration.
7.6.3. Was disclosed with the User's consent.
7.7. Before going to court with a claim for disputes arising from the relations between the User and the Company, it is mandatory to submit a claim (a written proposal for a voluntary settlement of the dispute).
7.8. The recipient of the claim, within 30 calendar days from the date of receipt of the claim, shall notify the claimant in writing of the results of the consideration of the claim.
7.9. If no agreement is reached, the dispute will be referred to a judicial authority for consideration in accordance with the current legislation of the Russian Federation.
Appendix No.1 to the Personal Data Processing Policy
Consent to the processing of the personal data
By using the Website, Services, Application, filling out and sending the registration form, authorizing on the Website, Service, Application, and/or calling the Company's phone number indicated on the website, I voluntarily, of my own will, and in my own interest, express to GREENDIVISION LLC (registered address: 129626, Moscow, Alekseevsky Municipal district, Mira Avenue, house 102, building 12, office 12A, PSRN 1217700250404, TIN 9710089850, TRRC 771701001) and/or an operator engaged at the discretion or desire of GREENDIVISION LLC, consent to the processing of personal data, implying collection (directly from the applicant, from third parties, by sending requests to state authorities, local self-government bodies, legal entities and individuals, from other publicly available information resources, from archives), recording, systematization, accumulation, storage, clarification (updating, modification), verification, extraction, use, transfer (distribution, provision, access), in full or in part to third parties acting on the basis of agreements concluded by them with the Company, depersonalization, blocking, deletion, and destruction of the following my personal data:
Last name, first name, patronymic, year, month, date, and place of birth, gender, passport details, mobile phone number, email address, registration address/actual (mailing) address, login and password information for accessing certain functions of the Website, Application, Service, driver's license data, data on the presence (absence) of medical contraindications to using a vehicle, biometric data (photographs), data on place of work, position, control information, Service usage history (information on the number, cost, time, and order of User orders for Service services and their payment, including bank account and/or bank card details), information on participation in promotions, information on subscription to informational newsletters or support service materials), bank details for refunds, as well as other personal data and information;
Information automatically transmitted to the Company during the use of the Website, Application, Service using software installed on the User's device, including IP address, information from cookies and tracking bugs, information about the User's country and/or city of location, information about the User's Internet browser (or other program used to access the Website, Application, Service), access time, address of the requested page, information about the User's devices used to access the Website, Application, Service.
For the purposes of providing access to the Website/ to the account on the Website, Service, Application, providing consulting support in connection with the use of the Website, Service, Application, sending calculations and commercial offers for the sale of goods and services of the Company and/or the Company's partners, obtaining statistical and analytical data to improve the functioning of the Website and/or Services and/or Application, expanding the range of Services provided, receiving informational and/or promotional messages from the Company or third parties, preventing or suppressing illegal and/or unauthorized actions of Users or third parties, ensuring compliance with the requirements of the current legislation of the Russian Federation.
The processing of personal data is carried out both with the use of automation tools, including in information and telecommunication networks, and without the use of such tools.
The User, hereby, gives their consent to the specified processing of Users' personal data, as well as to sending them, via any communication channels, including: SMS notifications, push notifications, messages via WhatsApp, phone calls, voice messages, and emails, information, individual offers, and promotional materials about the products and services provided by the Company, related to the Website, Service, Application, and the Company's business activities, including messages about existing or developing goods and services of the Company.
Consent is granted from the moment I sign this Application and for my entire lifetime.
GREENDIVISION LLC, in accordance with this consent and to achieve the above purposes, has the right to entrust the processing of personal data to third parties, as well as in case of involving third parties to provide services and/or in case of transfer by GREENDIVISION LLC of its rights of claim to a third party, has the right to disclose/transfer information to such third parties, their agents, and other persons authorized by them to the necessary extent, as well as provide such persons with relevant documents containing such information.
Consent may be withdrawn by the User at any time by sending a corresponding signed written notification to GREENDIVISION LLC at the address: 129626, Moscow, Alekseevsky Municipal district, Mira Avenue, house 102, building 12, office 12A, at least 30 (thirty) calendar days in advance.
In case of withdrawal of this consent, GREENDIVISION LLC has the right to continue processing personal data in the cases and manner provided for by the legislation of the Russian Federation.
I, hereby, acknowledge that I have received all necessary information regarding the processing of my personal data. I confirm that all personal data provided during registration, submission of the Application form on the Website, Application, or Service, or communicated during a call to an operator, are my own. I declare that all information about my identity stated during registration is accurate and complete. I have carefully read this consent in its entirety, fully understand the terms of processing of my personal data, and accept them without any reservations or limitations.
GREENDIVISION LLC
PSRN 1217700250404
TIN 9710089850
TRRC 771701001
PSRN 1217700250404
TIN 9710089850
TRRC 771701001
© All Rights Reserved. The information on this site is for informational purposes only and does not constitute a public offer.
129626, Moscow
Alekseevsky municipal district,
Mira avenue, house 102,
Building 12, Office 12A
Alekseevsky municipal district,
Mira avenue, house 102,
Building 12, Office 12A
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