1. General provisions
This personal data processing policy has been developed in accordance with the requirements of the "Personal Data Protection" law (hereinafter referred to as the Personal Data Law) and defines the procedure for processing personal data and the measures taken by Mobilochka.ae (hereinafter referred to as the Operator) to ensure the security of personal data.
1.1. The Operator sets compliance with the rights and freedoms of the individual and citizen in processing their personal data, including protecting the right to privacy, personal and family secrets, as its main goal and condition for carrying out 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 httpsː//mobilochka.ae.
2. Main concepts used in the Policy
2.1. Automated processing of personal data - processing of personal data using computer technology.
2.2. Blocking of personal data - temporary suspension of the processing of personal data (except in cases where processing is necessary to clarify personal data).
2.3. Website - a set of graphic and informational materials, as well as computer programs and databases that provide their availability on the Internet at the network address https://mobilochka.ae.
2.4. Personal data information system - a set of personal data contained in databases, and providing their processing with information technology and technical means.
2.5. Depersonalization of personal data - actions that make it impossible to determine the affiliation of personal data to a specific User or other subject of personal data without using additional information.
2.6. Processing of personal data - any action (operation) or set of actions (operations) performed with personal data, using automation tools or without using such tools, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transmission (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
2.7. Operator - a state body, municipal body, legal or natural person, acting independently or jointly with other persons, organizing and (or) carrying out the processing of personal data, as well as determining the purposes of processing personal data, the composition of personal data subject to processing, actions (operations) performed with personal data.
2.8. Personal data - any information directly or indirectly related to a specific or identifiable User of the website https://mobilochka.ae.
2.9. Personal data allowed by the subject of personal data for distribution - personal data, access to which by an unlimited circle of persons is provided by the subject of personal data by giving consent to the processing of personal data allowed by the subject of personal data for distribution in the manner provided by the Law on Personal Data (hereinafter - personal data allowed for distribution).
2.10. User - any visitor to the website https://mobilochka.ae.
2.11. Provision of personal data - actions aimed at disclosing personal data to a specific person or group of persons.
2.12. Dissemination of personal data - any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or acquainting an unlimited number of persons with personal data, including publicizing personal data in mass media, placing in information and telecommunication networks, or providing access to personal data in any other way.
2.13. Cross-border transfer of personal data - transfer of personal data to the territory of a foreign state to the authority of a foreign state, foreign individual or foreign legal entity.
2.14. Destruction of personal data - any actions that result in the irretrievable destruction of personal data with no possibility of further recovery of the content of personal data in the personal data information system and/or the destruction of the material carriers of personal data.
3. Main rights and obligations of the Operator
3.1. The Operator has the right to:
• Receive from the personal data subject accurate information and/or documents containing personal data;
• In the event of revocation by the personal data subject of consent to the processing of personal data, the Operator has the right to continue processing personal data without the consent of the personal data subject if there are grounds specified in the Law on Personal Data;
• Independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations provided for by the Law on Personal Data and adopted in accordance with it regulatory legal acts, unless otherwise provided by the Law on Personal Data or other laws.
3.2. The Operator is obliged to:
• Provide the personal data subject with information upon his request regarding the processing of his personal data;
• Organize the processing of personal data in the manner established by applicable law;
• Respond to requests and inquiries of personal data subjects and their legal representatives in accordance with the requirements of the Law on Personal Data;
• Publish or otherwise provide unlimited access to this Policy regarding the processing of personal data;
• Take legal, organizational and technical measures to protect personal data from unauthorized or accidental access to them, destruction, alteration, blocking, copying, provision, dissemination of personal data, as well as from other illegal actions with respect to personal data;
• Stop the transmission (distribution, provision, access) of personal data, stop processing and destroy personal data in the manner and cases provided for by the Law on Personal Data;
• Fulfill other obligations provided for by the Law on Personal Data.
4. Basic 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 law. The information is provided to the personal data subject by the Operator in an accessible form, and should not contain personal data relating to other personal data subjects, except when there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it is established by the Law on Personal Data;
• demand from the Operator the clarification of their personal data, their blocking or destruction in case the personal data is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing, as well as take legal measures to protect their rights provided for by law;
• impose a preliminary consent requirement for the processing of personal data for the purpose of promoting goods, works and services on the market;
• withdraw consent for the processing of personal data;
• appeal to the authorized body for the protection of personal data subjects' rights or in court against unlawful actions or inaction of the Operator in the processing of their personal data;
• exercise other rights provided for by law.
4.2. Personal data subjects are obliged to:
• provide the Operator with data about themselves;
• inform the Operator about the clarification (updating, changing) of their personal data.
5. The operator may process the following personal data of the User:
5.1. Surname, name, patronymic.
5.2. Email address.
5.3. Phone numbers.
5.4. In addition, the site collects and processes anonymous data about visitors (including "cookie" files) using internet statistics services (Yandex Metrics, Google Analytics, and others).
5.5. The above-mentioned data are collectively referred to as Personal Data in this Policy.
5.6. The Operator does not process special categories of personal data concerning racial or ethnic origin, political views, religious or philosophical beliefs, intimate life, or any other sensitive information.
5.7. Processing of personal data permitted for distribution from special categories of personal data.
5.8. The User's consent to the processing of personal data permitted for distribution is separately obtained from other consents for the processing of personal data.
5.8.1. The User provides the Operator with consent to process personal data permitted for distribution directly.
5.8.2. The transfer (distribution, provision, access) of personal data permitted by the data subject for distribution must be terminated at any time at the request of the data subject. This request must include the data subject's full name, contact information (phone number, email address, or mailing address), and a list of personal data that should be terminated from processing. The specified personal data in this request can only be processed by the Operator to whom it is addressed.
5.8.3. The consent to process personal data permitted for distribution expires upon receipt of the relevant request by the Operator.
6. Principles of Personal Data Processing
6.1. Personal data processing is carried out on a lawful and fair basis.
6.2. Processing of personal data is limited to achieving specific, predetermined, and lawful purposes. Processing of personal data that is incompatible with the purposes of collecting personal data is not allowed.
6.3. The merging of databases containing personal data, which are processed for incompatible purposes, is not allowed.
6.4. Only personal data that corresponds to the purposes of their processing shall be subject to processing.
6.5. The content and scope of processed personal data shall correspond to the declared purposes of processing. The excessive processing of personal data in relation to the declared purposes of processing is not allowed.
6.6. When processing personal data, their accuracy, sufficiency, and, where necessary, relevance to the purposes of processing personal data shall be ensured. The Operator takes necessary measures and/or ensures their adoption to delete or clarify incomplete or inaccurate data.
6.7. Personal data shall be stored in a form that allows identifying the subject of personal data for no longer than necessary to achieve the purposes of processing personal data, unless the storage period for personal data is established by law, a contract, or a party to which the subject of personal data is a beneficiary or guarantor. Processed personal data shall be destroyed or depersonalized upon achieving the purposes of processing or in case the need to achieve these purposes is lost, unless otherwise provided by law.
7. Purposes of processing personal data
7.1. The purposes of processing the User's personal data are:
• informing the User by sending emails;
• conclusion, execution, and termination of civil law contracts;
• providing access to services, information and/or materials contained on the website https://mobilochka.ae to the User.
7.2. The Operator also has the right to send notifications to the User about new products and services, special offers, and various events. The User can always refuse to receive informational messages by sending a letter to the Operator at the email address firstname.lastname@example.org with the subject line "Refusal to receive notifications about new products and services and special offers."
7.3. Anonymous data of the Users, collected using internet statistics services, are used to collect information about the Users' actions on the website, improve the quality of the website and its content.
8. Legal grounds for processing personal data
8.1. The legal grounds for the Operator's processing of personal data are:
• the Operator's constituent documents;
• contracts concluded between the Operator and the data subject;
• laws and other regulatory legal acts in the field of personal data protection;
• consent of Users to the processing of their personal data, to the processing of personal data permitted for distribution.
8.2. The Operator processes the User's personal data only if it is filled in and/or sent by the User himself/herself through special forms located on the website https://mobilochka.ae or sent to the Operator by e-mail. By filling out the appropriate forms and/or sending his/her personal data to the Operator, the User expresses his/her consent to this Policy.
8.4. The data subject independently decides on the provision of his/her personal data and gives consent freely, by his/her own will and in his/her own interest.
9. Conditions for Processing Personal Data
9.1. Processing of personal data is carried out with the consent of the subject of personal data to the processing of their personal data.
9.2. Processing of personal data is necessary for the performance of a contract to which the subject of personal data is a party, or for the execution of a contract where the subject of personal data is a beneficiary or guarantor, or for the conclusion of a contract initiated by the subject of personal data or a contract where the subject of personal data will be a beneficiary or guarantor.
9.3. Processing of personal data is necessary for the exercise of the rights and legitimate interests of the operator or third parties, or for the achievement of socially significant goals, provided that the rights and freedoms of the subject of personal data are not violated.
9.4. Processing of personal data is carried out for personal data that is publicly available, where access to which has been provided by the subject of personal data or at their request (hereinafter referred to as publicly available personal data).
9.5. Processing of personal data is carried out for personal data that must be published or disclosed in accordance with the law.
10. Order of collection, storage, transmission, and other types of processing of personal data.
The security of personal data processed by the Operator is ensured by implementing legal, organizational, and technical measures necessary to fully comply with the requirements of the current legislation in the field of personal data protection.
10.1. The Operator ensures the confidentiality of personal data and takes all possible measures to prevent unauthorized access to personal data.
10.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to the implementation of the current legislation or if the subject of personal data has given consent to the Operator for the transfer of data to a third party to fulfill obligations under a civil contract.
10.3. In case of inaccuracies in personal data, the User may update them independently by sending a notification to the Operator's email address email@example.com with the note "Updating personal data."
10.4. The processing period of personal data is determined by achieving the purposes for which personal data were collected, unless otherwise provided by a contract or current legislation.
The User may withdraw their consent to the processing of personal data at any time by sending a notification to the Operator via email at firstname.lastname@example.org with the note "Withdrawal of consent to the processing of personal data."
The Operator is not responsible for the actions of third parties, including service providers mentioned in this section.
10.6. Prohibitions on the transfer (except for providing access), processing or processing conditions (except for accessing) of personal data that are permitted for distribution do not apply in cases of processing personal data in state, public, and other public interests.
10.7. The operator ensures the confidentiality of personal data during its processing.
10.8. The operator stores personal data in a form that allows the identification of the subject of personal data for no longer than is required for the purposes of processing personal data, unless the storage period of personal data is established by law, contract, or the subject of personal data is a party, beneficiary or guarantor under the contract.
10.9. The termination of the processing of personal data may be due to the achievement of the purposes of processing personal data, expiration of the consent of the subject of personal data, revocation of the consent of the subject of personal data, or identification of unlawful processing of personal data.
11. The list of actions performed by the Operator with the obtained personal data
11.1. The Operator collects, records, systematizes, accumulates, stores, updates (modifies, amends), extracts, uses, transfers (distributes, provides, grants access), depersonalizes, blocks, deletes, and destroys personal data.
11.2. The Operator carries out automated processing of personal data, including obtaining and/or transmitting the received information via information and telecommunication networks or without such networks.
12. Cross-border transfer of personal data
12.1. Before starting the cross-border transfer of personal data, the Operator must ensure that the foreign state, to the territory of which the transfer of personal data is supposed to be carried out, ensures reliable protection of the rights of personal data subjects.
12.2. Cross-border transfer of personal data to the territories of foreign states that do not meet the above-mentioned requirements may be carried out only with the written consent of the personal data subject to such transfer and/or the performance of a contract, the party to which is the personal data subject.
13. Confidentiality of personal data
The Operator and other persons who have access to personal data are obliged not to disclose personal data to third parties and not to distribute personal data without the consent of the personal data subject, unless otherwise provided by law.
14. Final provisions
14.1. The user can obtain any clarification on the issues related to the processing of their personal data by contacting the Operator via email email@example.com
14.2. Any changes to the Operator's personal data processing policy will be reflected in this document. The policy is valid indefinitely until it is replaced by a new version.
14.3. The current version of the Policy is freely available on the Internet at the link to the page of the Mobiloсhka website. https://mobilo4ka.ru/