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Personal Data Processing Policy

1. General provisions

This personal data processing policy has been drawn up in accordance with the requirements of Federal Law of 27.07.2006 No. 152-FZ “On Personal Data” (hereinafter — the Personal Data Law) and defines the procedure for processing personal data and the measures taken to ensure the security of personal data by the individual entrepreneur (FOP) Vadym Evgenyevich Averchenkov (hereinafter — the Operator).

1.1. The Operator regards the observance of human and civil rights and freedoms in the processing of personal data, including the protection of the rights to privacy and to personal and family confidentiality, as its most important aim and as a condition of carrying out its activities.

1.2. This Operator’s policy on the processing of personal data (hereinafter — the Policy) applies to all information that the Operator may obtain about visitors to the website https://trafficpro.online.

2. Basic concepts used in the Policy

2.1. Automated processing of personal data — processing of personal data by means of computer technology.

2.2. Blocking of personal data — temporary suspension of the processing of personal data (except where processing is necessary to correct personal data).

2.3. Website — a set of graphic and informational materials, as well as computer programs and databases, ensuring their availability on the internet at the network address https://trafficpro.online.

2.4. Personal data information system — the set of personal data contained in databases, together with the information technologies and technical means that ensure their processing.

2.5. Depersonalization of personal data — actions as a result of which it is impossible, without the use of additional information, to determine whether personal data belong to a specific User or other data subject.

2.6. Processing of personal data — any action (operation) or set of actions (operations) performed with personal data, with or without the use of automation tools, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), retrieval, use, transfer (dissemination, provision, access), depersonalization, blocking, deletion and destruction of personal data.

2.7. Operator — a state body, municipal body, legal entity or individual that, independently or jointly with other persons, organizes and/or carries out the processing of personal data, and also determines the purposes of processing personal data, the composition of the personal data to be processed, and the actions (operations) performed with personal data.

2.8. Personal data — any information relating directly or indirectly to a specific or identifiable User of the website https://trafficpro.online.

2.9. Personal data permitted by the data subject for dissemination — personal data to which the data subject has given an unlimited number of persons access by consenting to the processing of personal data permitted by the data subject for dissemination in the manner provided for by the Personal Data Law (hereinafter — personal data permitted for dissemination).

2.10. User — any visitor to the website https://trafficpro.online.

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

2.12. Dissemination of personal data — any actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or at making personal data available to an unlimited number of persons, including publication of personal data in the 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 — transfer of personal data to the territory of a foreign state to an authority of a foreign state, a foreign individual or a foreign legal entity.

2.14. Destruction of personal data — any actions as a result of which personal data are destroyed irrevocably, making it impossible to restore the content of the personal data in the personal data information system, and/or as a result of which the physical media of personal data are destroyed.

3. Basic rights and obligations of the Operator

3.1. The Operator has the right to:

3.2. The Operator is obliged to:

4. Basic rights and obligations of data subjects

4.1. Data subjects have the right to:

4.2. Data subjects are obliged to:

4.3. Persons who have provided the Operator with false information about themselves, or information about another data subject without that person’s consent, are liable in accordance with the legislation of the Russian Federation.

5. Principles of personal data processing

5.1. Personal data are processed on a lawful and fair basis.

5.2. The processing of personal data is limited to the achievement of specific, predetermined and lawful purposes. Processing of personal data that is incompatible with the purposes for which the personal data were collected is not permitted.

5.3. Merging databases that contain personal data processed for purposes that are incompatible with each other is not permitted.

5.4. Only personal data that meet the purposes of their processing are subject to processing.

5.5. The content and volume of the personal data processed correspond to the stated purposes of processing. Excessiveness of the personal data processed in relation to the stated purposes of their processing is not permitted.

5.6. In the processing of personal data, the accuracy of the personal data, their sufficiency and, where necessary, their relevance in relation to the purposes of processing are ensured. The Operator takes the necessary measures and/or ensures that they are taken to delete or correct incomplete or inaccurate data.

5.7. Personal data are stored in a form that makes it possible to identify the data subject, for no longer than the purposes of processing require, unless the storage period is established by federal law or by a contract to which the data subject is a party, beneficiary or guarantor. The personal data processed are destroyed or depersonalized once the purposes of processing are achieved or the need to achieve those purposes is lost, unless otherwise provided by federal law.

6. Purposes of personal data processing

Purpose of processing
informing the User by sending emails
Personal data
  • email address
  • telephone numbers
  • surname and first name
Legal grounds
Law of Ukraine “On the Protection of Personal Data” No. 2297-VI of 01.06.2010
Types of personal data processing
  • Collection, recording, systematization, accumulation, storage, destruction and depersonalization of personal data
  • Sending informational emails to an email address
  • Sending informational messages to messengers and calling a personal telephone number

7. Conditions of personal data processing

7.1. Personal data are processed with the consent of the data subject to the processing of their personal data.

7.2. The processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, and to carry out the functions, powers and duties assigned to the operator by the legislation of the Russian Federation.

7.3. The processing of personal data is necessary for the administration of justice, the enforcement of a judicial act or of an act of another body or official that is subject to enforcement 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 data subject is a party, beneficiary or guarantor, as well as for concluding a contract at the initiative of the data subject or a contract under which the data subject will be a beneficiary or guarantor.

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

7.6. Personal data are processed to which an unlimited number of persons have been given access by the data subject or at their request (hereinafter — publicly available personal data).

7.7. Personal data are processed that are subject to publication or mandatory disclosure in accordance with federal law.

8. Procedure for collecting, storing, transferring and other types of processing of personal data

The security of the personal data processed by the Operator is ensured by implementing the legal, organizational and technical measures necessary to fully meet the requirements of the current legislation in the field of personal data protection.

8.1. The Operator ensures the safety of personal data and takes all possible measures to exclude access to personal data by unauthorized persons.

8.2. The User’s personal data will never, under any circumstances, be transferred to third parties, except in cases connected with compliance with the current legislation, or where the data subject has given the Operator consent to transfer the data to a third party for the performance of obligations under a civil-law contract.

8.3. If inaccuracies are found in personal data, the User may update them independently by sending the Operator a notice to the Operator’s email address trafficproonline@gmail.com marked “Updating of personal data”.

8.4. The period of processing of personal data is determined by the achievement of the purposes for which the personal data were collected, unless another period is provided by a contract or the current legislation.

The User may withdraw their consent to the processing of personal data at any time by sending the Operator a notice by email to the Operator’s email address trafficproonline@gmail.com marked “Withdrawal of consent to the processing of personal data”.

8.5. All information collected by third-party services, including payment systems, means of communication and other service providers, is stored and processed by those persons (Operators) in accordance with their User Agreement and Privacy Policy. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.

8.6. The prohibitions on transfer (other than granting access), as well as on processing or the conditions of processing (other than obtaining access), of personal data permitted for dissemination, that are established by the data subject, do not apply in cases of processing of personal data in state, public and other public interests defined by the legislation of the Russian Federation.

8.7. In processing personal data, the Operator ensures the confidentiality of personal data.

8.8. The Operator stores personal data in a form that makes it possible to identify the data subject, for no longer than the purposes of processing require, unless the storage period is established by federal law or by a contract to which the data subject is a party, beneficiary or guarantor.

8.9. The condition for terminating the processing of personal data may be the achievement of the purposes of processing, the expiry of the data subject’s consent, withdrawal of consent by the data subject or a request to stop processing personal data, as well as the detection of unlawful processing of personal data.

9. List of actions performed by the Operator with the personal data received

9.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), retrieves, uses, transfers (disseminates, provides, grants access to), depersonalizes, blocks, deletes and destroys personal data.

9.2. The Operator carries out automated processing of personal data, with or without receiving and/or transmitting the information obtained over information and telecommunication networks.

10. Cross-border transfer of personal data

10.1. Before starting any cross-border transfer of personal data, the Operator is obliged to notify the authorized body for the protection of the rights of data subjects of its intention to carry out cross-border transfer of personal data (such a notification is sent separately from the notification of the intention to process personal data).

10.2. Before submitting the above notification, the Operator is obliged to obtain the relevant information from the authorities of the foreign state, foreign individuals and foreign legal entities to which 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 are obliged not to disclose personal data to third parties or disseminate them without the consent of the data subject, unless otherwise provided by federal law.

12. Final provisions

12.1. The User may obtain any clarification on questions of interest concerning the processing of their personal data by contacting the Operator by email at trafficproonline@gmail.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://trafficpro.online/privacy.