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 of 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 implemented by AUTORENT PATTAYA CO. LTD. (hereinafter referred to as the "Operator").
1.1. The Operator considers the protection of human and civil rights and freedoms in the processing of their personal data, including the protection of the right to privacy, personal, and family secrets, as one of its most important objectives and a prerequisite 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 obtain about visitors to the website https://autorentpattaya.com.
2. Key Terms Used in the Policy
2.1. Automated processing of personal data refers to the processing of personal data using computer technology.
2.2. Blocking of personal data refers to the temporary cessation of personal data processing (except when processing is necessary to clarify personal data).
2.3. Website refers to a set of graphic and informational materials, as well as software and databases, ensuring their availability on the internet at the network address https://autorentpattaya.com.
2.4. Information system of personal data refers to a set of personal data contained in databases and information technologies and technical means ensuring their processing.
2.5. Anonymization of personal data refers to actions that result in the impossibility of determining the ownership of personal data to a specific User or another subject of personal data without using additional information.
2.6. Personal data processing refers to 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), retrieval, use, transfer (distribution, provision, access), anonymization, blocking, deletion, destruction of personal data.
2.7. Operator refers to a state body, municipal body, legal entity, or individual 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 actions (operations) performed with personal data.
2.8. Personal data refers to any information related directly or indirectly to a specific or identifiable User of the website https://autorentpattaya.com.
2.9. Personal data allowed by the subject for dissemination refers to personal data to which an unlimited number of persons have access, provided by the subject of personal data by giving consent for the processing of personal data allowed by the subject of personal data for dissemination in the manner prescribed by the Personal Data Law (hereinafter referred to as "personal data allowed for dissemination").
2.10. User refers to any visitor to the website https://autorentpattaya.com.
2.11. Provision of personal data refers to actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Dissemination of personal data refers to any actions aimed at disclosing personal data to an undefined circle of persons (transfer of personal data) or familiarizing oneself with personal data of an unlimited circle of persons, including publishing personal data in mass media, posting in information and telecommunication networks, or providing access to personal data in any other way.
2.13. Cross-border transfer of personal data refers to the transfer of personal data to the territory of a foreign state, to the authority of a foreign state, to a foreign individual, or a foreign legal entity.
2.14. Destruction of personal data refers to any actions resulting in the irrevocable destruction of personal data with the impossibility of further restoration of the content of personal data in the personal data information system and/or resulting in the destruction of physical media containing personal data.
3. Operator’s Rights and Obligations
3.1. The Operator has the right to:
— Receive accurate information and/or documents containing personal data from the subject of personal data.
— In case of withdrawal of the subject’s consent to the processing of personal data, or submission of a request to terminate the processing of personal data, the Operator is entitled to continue processing personal data without the subject’s consent on the grounds specified in the Personal Data Law.
— Independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations stipulated by the Personal Data Law and the regulations 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 subject of personal data with information regarding the processing of their personal data upon request.
— Organize the processing of personal data in accordance with the procedure established by the current legislation of the Russian Federation.
— Respond to inquiries and requests from subjects of personal data and their legal representatives in accordance with the requirements of the Personal Data Law.
— Notify the authorized body for the protection of the rights of subjects of personal data upon request of this body with the necessary information within 10 days from the date of receipt of such a request.
— Publish or otherwise provide unrestricted 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, and other unlawful actions with respect to personal data.
— Terminate the transfer (dissemination, provision, access) of personal data, terminate processing, and destroy personal data in the manner and in 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 for by federal law. The information is provided to the subject of personal data by the Operator in an accessible form and should not contain personal data related to other subjects of personal data, 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.
— Demand from the Operator the clarification of their personal data, blocking, or destruction of personal data if the personal data is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated 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 promotion of goods, works, and services in the market.
— Withdraw consent to the processing of personal data and request the termination of personal data processing.
— Appeal to the authorized body for the protection of the rights of personal data subjects or to a court regarding unlawful actions or inaction of the Operator in processing their personal data.
— Exercise other rights provided for 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 of the clarification (updating, modification) of their personal data.
4.3. Persons who have provided the Operator with inaccurate information about themselves or information about another subject of personal data without the consent of the latter bear responsibility in accordance with the legislation of the Russian Federation.
5. Principles of Personal Data Processing
5.1. The processing of personal data is carried out on a lawful and fair basis.
5.2. The processing of personal data is limited to the achievement of specific, predetermined, and legitimate goals. The processing of personal data incompatible with the purposes of collecting personal data is not allowed.
5.3. The merging of databases containing personal data that is processed for purposes incompatible with each other is not allowed.
5.4. Only personal data that meets the purposes of processing is subject to processing.
5.5. The content and volume of processed personal data correspond to the stated purposes of processing. Excessive personal data in relation to the stated purposes of processing is not allowed.
5.6. The accuracy, sufficiency, and, where necessary, relevance of personal data in relation to the purposes of personal data processing are ensured during processing. The Operator takes the necessary measures and/or ensures their adoption to delete or clarify incomplete or inaccurate data.
5.7. The storage of personal data is carried out in a form that allows identifying the subject of personal data, no longer than the purposes of personal data processing require, unless the period for storing personal data is established by federal law, a contract, a party to which the subject of personal data is a beneficiary or guarantor. Processed personal data is destroyed or anonymized upon achieving the purposes of processing or if the need to achieve these purposes is lost, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing
Purpose of processing:
— Informing the User through email notifications.
Personal data:
— Last name, first name, middle name
— Email address
— Phone numbers
— Photos
Legal grounds:
— Contracts concluded between the Operator and the subject of personal data.
Types of personal data processing:
— Collection, recording, systematization, accumulation, storage, destruction, and anonymization of personal data.
— Sending information emails to the email address.
7. Conditions for Processing Personal Data
7.1. The processing of personal data is carried out with the consent of the subject of personal data to the processing of their personal data.
7.2. The processing of personal data is necessary to achieve the goals stipulated by an international treaty of the Russian Federation or by law, for the exercise of the functions, powers, and obligations imposed on the Operator by the legislation of the Russian Federation.
7.3. The processing of personal data is necessary for the administration of justice, the execution of a court act, the act of another authority or official, which is 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 performance of a contract to which the subject of personal data is a party or a beneficiary or guarantor, as well as for the conclusion of a contract initiated by the subject of personal data or a contract under which the subject of personal data will be a beneficiary or guarantor.
7.5. The processing of personal data is necessary for the implementation 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 subject of personal data.
7.6. The processing of personal data is carried out if access to personal data is provided to an unlimited number of persons by the subject of personal data or at their request (hereinafter referred to as publicly available personal data).
7.7. The processing of personal data is carried out, subject to publication or mandatory disclosure in accordance with federal law.
8. Procedure for Collecting, Storing, Transferring, and Other Types of Personal Data Processing
The security of personal data processed by the Operator is ensured by implementing 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 confidentiality 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 the execution of current legislation or if the subject of personal data has given consent 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@autorentpattaya.com with the note "Update of personal data."
8.4. The period of personal data processing is determined by the achievement of the purposes for which the personal data was collected, unless otherwise provided by the contract or current legislation.
The User may revoke their consent to the processing of personal data at any time by sending a notification to the Operator via email at info@autorentpattaya.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 tools, and other service providers, is stored and processed by these parties (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data and/or with these documents. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this paragraph.
8.6. The prohibitions established by the subject of personal data on the transfer (except for providing access) as well as on the processing or conditions for processing (except for obtaining access) of personal data allowed for dissemination do not apply in cases of processing personal data in state, public, and other public interests determined by the legislation of the Russian Federation.
8.7. The Operator ensures the confidentiality of personal data during the processing of personal data.
8.8. The Operator stores personal data in a form that allows identifying the subject of personal data, no longer than required by the purposes of personal data processing, unless the period for storing personal data is established by federal law, a contract to which the subject of personal data is a beneficiary or guarantor.
8.9. The condition for the termination of personal data processing may be the achievement of the purposes of personal data processing, 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 personal data processing, as well as the detection of unlawful processing of personal data.
9. List of Actions Performed by the Operator with Received Personal Data
9.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, modifies), retrieves, uses, transfers (disseminates, provides, accesses), anonymizes, blocks, deletes, and destroys personal data.
9.2. The Operator carries out the automated processing of personal data with the receipt and/or transfer of the received information via information and telecommunication networks or without such means.
10. Cross-Border Transfer of Personal Data
10.1. Before starting the cross-border transfer of personal data, the Operator must notify the authorized body for the protection of the rights of personal data subjects about its intention to carry out a cross-border transfer of personal data (this notification is sent separately from the notification of the intention to process personal data).
10.2. Before submitting the above notification, the Operator must obtain the relevant information from the foreign state authorities, foreign individuals, or foreign legal entities to whom the cross-border transfer of personal data is planned.
11. Confidentiality of Personal Data
The Operator and other persons who have gained access to personal data must not disclose it to third parties or distribute personal data without the consent of the subject of personal data unless otherwise provided by federal law.
12. Final Provisions
12.1. The User can obtain any clarifications on issues of interest regarding the processing of their personal data by contacting the Operator via email at info@autorentpattaya.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 on the internet at https://autorentpattaya.com/en-privacypolicy.
1. General Provisions
This personal data processing policy is drafted in accordance with the requirements of Federal Law No. 152-FZ of 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 implemented by AUTORENT PATTAYA CO. LTD. (hereinafter referred to as the "Operator").
1.1. The Operator considers the protection of human and civil rights and freedoms in the processing of their personal data, including the protection of the right to privacy, personal, and family secrets, as one of its most important objectives and a prerequisite 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 obtain about visitors to the website https://autorentpattaya.com.
2. Key Terms Used in the Policy
2.1. Automated processing of personal data refers to the processing of personal data using computer technology.
2.2. Blocking of personal data refers to the temporary cessation of personal data processing (except when processing is necessary to clarify personal data).
2.3. Website refers to a set of graphic and informational materials, as well as software and databases, ensuring their availability on the internet at the network address https://autorentpattaya.com.
2.4. Information system of personal data refers to a set of personal data contained in databases and information technologies and technical means ensuring their processing.
2.5. Anonymization of personal data refers to actions that result in the impossibility of determining the ownership of personal data to a specific User or another subject of personal data without using additional information.
2.6. Personal data processing refers to 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), retrieval, use, transfer (distribution, provision, access), anonymization, blocking, deletion, destruction of personal data.
2.7. Operator refers to a state body, municipal body, legal entity, or individual 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 actions (operations) performed with personal data.
2.8. Personal data refers to any information related directly or indirectly to a specific or identifiable User of the website https://autorentpattaya.com.
2.9. Personal data allowed by the subject for dissemination refers to personal data to which an unlimited number of persons have access, provided by the subject of personal data by giving consent for the processing of personal data allowed by the subject of personal data for dissemination in the manner prescribed by the Personal Data Law (hereinafter referred to as "personal data allowed for dissemination").
2.10. User refers to any visitor to the website https://autorentpattaya.com.
2.11. Provision of personal data refers to actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Dissemination of personal data refers to any actions aimed at disclosing personal data to an undefined circle of persons (transfer of personal data) or familiarizing oneself with personal data of an unlimited circle of persons, including publishing personal data in mass media, posting in information and telecommunication networks, or providing access to personal data in any other way.
2.13. Cross-border transfer of personal data refers to the transfer of personal data to the territory of a foreign state, to the authority of a foreign state, to a foreign individual, or a foreign legal entity.
2.14. Destruction of personal data refers to any actions resulting in the irrevocable destruction of personal data with the impossibility of further restoration of the content of personal data in the personal data information system and/or resulting in the destruction of physical media containing personal data.
3. Operator’s Rights and Obligations
3.1. The Operator has the right to:
— Receive accurate information and/or documents containing personal data from the subject of personal data.
— In case of withdrawal of the subject’s consent to the processing of personal data, or submission of a request to terminate the processing of personal data, the Operator is entitled to continue processing personal data without the subject’s consent on the grounds specified in the Personal Data Law.
— Independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations stipulated by the Personal Data Law and the regulations 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 subject of personal data with information regarding the processing of their personal data upon request.
— Organize the processing of personal data in accordance with the procedure established by the current legislation of the Russian Federation.
— Respond to inquiries and requests from subjects of personal data and their legal representatives in accordance with the requirements of the Personal Data Law.
— Notify the authorized body for the protection of the rights of subjects of personal data upon request of this body with the necessary information within 10 days from the date of receipt of such a request.
— Publish or otherwise provide unrestricted 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, and other unlawful actions with respect to personal data.
— Terminate the transfer (dissemination, provision, access) of personal data, terminate processing, and destroy personal data in the manner and in 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 for by federal law. The information is provided to the subject of personal data by the Operator in an accessible form and should not contain personal data related to other subjects of personal data, 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.
— Demand from the Operator the clarification of their personal data, blocking, or destruction of personal data if the personal data is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated 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 promotion of goods, works, and services in the market.
— Withdraw consent to the processing of personal data and request the termination of personal data processing.
— Appeal to the authorized body for the protection of the rights of personal data subjects or to a court regarding unlawful actions or inaction of the Operator in processing their personal data.
— Exercise other rights provided for 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 of the clarification (updating, modification) of their personal data.
4.3. Persons who have provided the Operator with inaccurate information about themselves or information about another subject of personal data without the consent of the latter bear responsibility in accordance with the legislation of the Russian Federation.
5. Principles of Personal Data Processing
5.1. The processing of personal data is carried out on a lawful and fair basis.
5.2. The processing of personal data is limited to the achievement of specific, predetermined, and legitimate goals. The processing of personal data incompatible with the purposes of collecting personal data is not allowed.
5.3. The merging of databases containing personal data that is processed for purposes incompatible with each other is not allowed.
5.4. Only personal data that meets the purposes of processing is subject to processing.
5.5. The content and volume of processed personal data correspond to the stated purposes of processing. Excessive personal data in relation to the stated purposes of processing is not allowed.
5.6. The accuracy, sufficiency, and, where necessary, relevance of personal data in relation to the purposes of personal data processing are ensured during processing. The Operator takes the necessary measures and/or ensures their adoption to delete or clarify incomplete or inaccurate data.
5.7. The storage of personal data is carried out in a form that allows identifying the subject of personal data, no longer than the purposes of personal data processing require, unless the period for storing personal data is established by federal law, a contract, a party to which the subject of personal data is a beneficiary or guarantor. Processed personal data is destroyed or anonymized upon achieving the purposes of processing or if the need to achieve these purposes is lost, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing
Purpose of processing:
— Informing the User through email notifications.
Personal data:
— Last name, first name, middle name
— Email address
— Phone numbers
— Photos
Legal grounds:
— Contracts concluded between the Operator and the subject of personal data.
Types of personal data processing:
— Collection, recording, systematization, accumulation, storage, destruction, and anonymization of personal data.
— Sending information emails to the email address.
7. Conditions for Processing Personal Data
7.1. The processing of personal data is carried out with the consent of the subject of personal data to the processing of their personal data.
7.2. The processing of personal data is necessary to achieve the goals stipulated by an international treaty of the Russian Federation or by law, for the exercise of the functions, powers, and obligations imposed on the Operator by the legislation of the Russian Federation.
7.3. The processing of personal data is necessary for the administration of justice, the execution of a court act, the act of another authority or official, which is 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 performance of a contract to which the subject of personal data is a party or a beneficiary or guarantor, as well as for the conclusion of a contract initiated by the subject of personal data or a contract under which the subject of personal data will be a beneficiary or guarantor.
7.5. The processing of personal data is necessary for the implementation 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 subject of personal data.
7.6. The processing of personal data is carried out if access to personal data is provided to an unlimited number of persons by the subject of personal data or at their request (hereinafter referred to as publicly available personal data).
7.7. The processing of personal data is carried out, subject to publication or mandatory disclosure in accordance with federal law.
8. Procedure for Collecting, Storing, Transferring, and Other Types of Personal Data Processing
The security of personal data processed by the Operator is ensured by implementing 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 confidentiality 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 the execution of current legislation or if the subject of personal data has given consent 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@autorentpattaya.com with the note "Update of personal data."
8.4. The period of personal data processing is determined by the achievement of the purposes for which the personal data was collected, unless otherwise provided by the contract or current legislation.
The User may revoke their consent to the processing of personal data at any time by sending a notification to the Operator via email at info@autorentpattaya.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 tools, and other service providers, is stored and processed by these parties (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data and/or with these documents. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this paragraph.
8.6. The prohibitions established by the subject of personal data on the transfer (except for providing access) as well as on the processing or conditions for processing (except for obtaining access) of personal data allowed for dissemination do not apply in cases of processing personal data in state, public, and other public interests determined by the legislation of the Russian Federation.
8.7. The Operator ensures the confidentiality of personal data during the processing of personal data.
8.8. The Operator stores personal data in a form that allows identifying the subject of personal data, no longer than required by the purposes of personal data processing, unless the period for storing personal data is established by federal law, a contract to which the subject of personal data is a beneficiary or guarantor.
8.9. The condition for the termination of personal data processing may be the achievement of the purposes of personal data processing, 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 personal data processing, as well as the detection of unlawful processing of personal data.
9. List of Actions Performed by the Operator with Received Personal Data
9.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, modifies), retrieves, uses, transfers (disseminates, provides, accesses), anonymizes, blocks, deletes, and destroys personal data.
9.2. The Operator carries out the automated processing of personal data with the receipt and/or transfer of the received information via information and telecommunication networks or without such means.
10. Cross-Border Transfer of Personal Data
10.1. Before starting the cross-border transfer of personal data, the Operator must notify the authorized body for the protection of the rights of personal data subjects about its intention to carry out a cross-border transfer of personal data (this notification is sent separately from the notification of the intention to process personal data).
10.2. Before submitting the above notification, the Operator must obtain the relevant information from the foreign state authorities, foreign individuals, or foreign legal entities to whom the cross-border transfer of personal data is planned.
11. Confidentiality of Personal Data
The Operator and other persons who have gained access to personal data must not disclose it to third parties or distribute personal data without the consent of the subject of personal data unless otherwise provided by federal law.
12. Final Provisions
12.1. The User can obtain any clarifications on issues of interest regarding the processing of their personal data by contacting the Operator via email at info@autorentpattaya.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 on the internet at https://autorentpattaya.com/en-privacypolicy.
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