PRIVACY POLICY
of LLC "Tri Tochki"
Regarding the Processing of Personal Data
1. General Provisions
This Policy on Personal Data Processing has been developed in accordance with the requirements of the Federal Law of July 27, 2006 No. 152-FZ "On Personal Data" (hereinafter referred to as the Personal Data Law) and defines the procedures for processing personal data and measures to ensure their security taken by LLC "TRI TOCHKI" (hereinafter referred to as the Operator).
1.1
The Operator considers the protection of human rights and freedoms during the processing of personal data — including the right to privacy and the secrecy of personal and family life — as one of the most important goals and conditions of its activities.
1.2
This Policy applies to all information that the Operator may receive about visitors to the website https://ttri.ru/ and users of the Mobile Application «KAIYI CONNECT».
2. Key Terms 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 cessation of processing of personal data (except where such processing is necessary for clarifying personal data).
2.3 Website — a collection of graphic and informational materials, along with software programs and databases, making them available via the Internet at the address https://ttri.ru/ .
2.4 Mobile Application «KAIYI CONNECT» — software for mobile electronic devices; the latest version of which is available in the AppStore and Google Play online services, accessible via the public information and telecommunications network "Internet" at the addresses: itunes.apple.com and play.google.com respectively. The Mobile Application also represents an information system operated by the Company. It is used for monitoring and determining vehicle parameters through data transmission via a monitoring device (telematics equipment), as well as for providing Users with information services. System requirements for installing the Mobile Application: iOS 14.0 or higher, Android 10.0 or higher.
2.5 Information System of Personal Data — a set of personal data stored in databases, along with the information technologies and technical tools ensuring their processing.
2.6 Anonymization of Personal Data — actions resulting in the inability to determine, without additional information, to which specific User or other subject of personal data the data belongs.
2.7 Processing of Personal Data — any action (operation) or a set of actions (operations) performed with personal data using automated means or without such means, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
2.8 Operator — a state authority, municipal authority, legal entity, or individual who organizes and/or carries out the processing of personal data, either independently or jointly with others,
and determines the purposes of processing, the scope of personal data to be processed, and the actions (operations) performed with personal data.
2.9 Personal Data — any information directly or indirectly relating to an identified or identifiable visitor of the website https://ttri.ru/ .
2.10 Personal Data Permitted for Distribution by the Subject of Personal Data — personal data to which an unlimited number of individuals have access, granted by the subject of personal data through consent to process such data for distribution in accordance with the Personal Data Law (hereinafter referred to as personal data permitted for distribution).
2.11 User — any visitor of the website https://ttri.ru/ .
2.12 Providing Personal Data — actions aimed at disclosing personal data to a specific person or group of persons.
2.13 Distribution of Personal Data — any actions aimed at disclosing personal data to an undefined group of persons (transfer of personal data) or enabling access to personal data for an unlimited number of persons, including publishing personal data in mass media, placing them in information and telecommunication networks, or otherwise granting access to personal data.
2.14 Cross-Border Transfer of Personal Data — transferring personal data to the territory of a foreign state to a government body, foreign individual, or foreign legal entity.
2.15 Destruction of Personal Data — any actions resulting in the irreversible destruction of personal data with no possibility of further restoration of their content in the personal data information system and/or the destruction of physical carriers of personal data.
3. Main Rights and Obligations of the Operator
3.1 The Operator has the right:
● To obtain accurate information and/or documents containing personal data from the subject of personal data;
● In the event the subject of personal data revokes their consent for processing or sends a request for termination of processing, the Operator has the right to continue processing the personal data without consent if there are grounds specified in the Personal Data Law;
● To independently determine the composition and list of measures necessary and sufficient to fulfill obligations under the Personal Data Law and related normative legal acts, unless otherwise stipulated by the Personal Data Law or other federal laws.
3.2 The Operator is obligated:
● To provide the subject of personal data with information regarding the processing of their personal data upon request;
● To organize the processing of personal data in compliance with current Russian legislation;
● To respond to requests and inquiries from subjects of personal data and their legal representatives in accordance with the requirements of the Personal Data Law;
● To provide the authorized body responsible for protecting the rights of personal data subjects with the necessary information within 10 days from the date of receiving a request;
● To publish or otherwise ensure unrestricted access to this Policy on the processing of personal data;
● To take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, disclosure, distribution, and any other unlawful actions;
● To terminate the transfer (distribution, provision, access) of personal data, cease processing, and destroy personal data in cases and procedures established by the Personal Data Law;
● To comply with other obligations set forth in the Personal Data Law.
4. Main Rights and Obligations of Subjects of Personal Data
4.1 Subjects of personal data have the right:
● To obtain information concerning the processing of their personal data, except in cases specified by federal laws. Information must be provided to the subject of personal data in an accessible form, and should not include personal data relating to other subjects of personal data, unless there are legal grounds for disclosing such data. The scope of information and procedure for obtaining it are established by the Personal Data Law;
● To require the Operator to clarify, block, or destroy their personal data if the data is incomplete, outdated, inaccurate, obtained unlawfully, or not necessary for the stated purpose of processing, and to take legally prescribed measures to protect their rights;
● To require prior consent when processing personal data for marketing goods, works, and services;
● To withdraw consent for the processing of personal data, as well as to send a request for termination of processing;
● To file a complaint with the authorized body for the protection of personal data subjects' rights or through judicial proceedings against unlawful actions or inaction by the Operator in relation to the processing of their personal data;
● To exercise other rights provided for under Russian law.
4.2 Subjects of personal data are obligated:
● To provide the Operator with accurate data about themselves;
● To inform the Operator about updates (modifications) to their personal data.
4.3 Individuals who submit false information about themselves to the Operator, or about another subject of personal data without their consent, shall bear responsibility in accordance with Russian legislation.
5. Principles of Personal Data Processing
5.1
Personal data is processed on a legal and fair basis.
5.2
Processing of personal data is limited to achieving specific, pre-defined, and lawful purposes. Processing of personal data that is incompatible with the purposes for which it was collected is prohibited.
5.3
It is not allowed to combine databases containing personal data if such processing serves incompatible purposes.
5.4 Only personal data relevant to the declared processing purposes are subject to processing.
5.5 The content and scope of the processed personal data must correspond to the declared purposes. Excessive collection or processing of personal data relative to the stated purposes is not permitted.
5.6 When processing personal data, its accuracy, sufficiency, and in necessary cases, relevance to the processing purposes must be ensured. The Operator takes necessary measures or ensures their adoption to delete or clarify incomplete or inaccurate data.
5.7 Personal data is stored in a form that allows identification of the data subject no longer than required by the purpose of the processing, unless a storage period is established by federal law, a contract where the subject is a party, assignee, or guarantor. Processed personal data is destroyed or anonymized upon achievement of the processing goals or when the necessity for those goals is lost, unless otherwise stipulated by federal law.
6. Purposes of Personal Data Processing
Purpose of processing:
6.1 Providing access to services, information, or materials available on the website or within the Mobile Application «KAIYI CONNECT».
Personal data:
● Surname, first name, patronymic
● Details of identity document
● Email address
● Phone numbers
● Location data, user's IP address, activity information on the site
Legal grounds: Article 24 of the Constitution of the Russian Federation, Charter of LLC "TRI TOCHKI", consent for processing personal data.
Types of personal data processing: Collection, recording, systematization, accumulation, storage, destruction, and anonymization of personal data.
6.2 Sending informational emails to the email address or via instant messaging services using the mobile phone number.
Purpose of processing: Conclusion, performance, and termination of civil contracts.
Personal data:
● Surname, first name, patronymic
● Email address
● Phone numbers
● Year, month, date, and place of birth
● Citizenship details
● Identity document details
● Taxpayer identification number (INN), registration date, tax office registration certificate details
● Actual residence address and registered address of residence/temporary stay
Legal grounds: Article 24 of the Constitution of the Russian Federation, Charter of LLC "TRI TOCHKI", consent for processing personal data.
Types of personal data processing: Collection, recording, systematization, accumulation, storage, destruction, and anonymization of personal data.
6.3 Sending informational emails to an email address or as push notifications in the Mobile Application «KAIYI CONNECT».
Purpose of processing: Collecting information about user activity on the company’s websites.
Personal data:
● Surname, first name, patronymic
● Email address
● Phone numbers
● Source from which the user came to the site (from which site), IP address, active time on the site, traffic volume on the site, pages visited and buttons clicked by the user, browser type and version
Legal grounds: Article 24 of the Constitution of the Russian Federation, Charter of LLC "TRI TOCHKI", consent for processing personal data.
Types of personal data processing: Collection, recording, systematization, accumulation, storage, destruction, and anonymization of personal data.
7. Conditions for Processing Personal Data
7.1 Processing of personal data is carried out with the consent of the data subject.
7.2 Processing of personal data is necessary to achieve the purposes set out in an international treaty of the Russian Federation or by law, to perform functions, powers, and obligations imposed by legislation on the operator.
7.3 Processing of personal data is necessary for carrying out judicial proceedings, executing court decisions, or decisions of other authorities or officials that must be executed under the laws of the Russian Federation on enforcement proceedings.
7.4 Processing of personal data is necessary to fulfill a contract where the data subject is a party, assignee, or guarantor, as well as to conclude a contract at the initiative of the data subject or a contract where the data subject will be an assignee or guarantor.
7.5 Processing of personal data is necessary to exercise the rights and legitimate interests of the operator or third parties, or to achieve socially significant goals, provided that the rights and freedoms of the data subject are not violated.
7.6 Processing of personal data accessible to an unlimited number of individuals is conducted if such access is granted by the data subject or at their request (hereinafter referred to as publicly accessible personal data).
7.7 Processing of personal data intended for publication or mandatory disclosure in accordance with federal law is conducted.
8. Procedure for Collection, Storage, Transfer, and Other Types of Processing of Personal Data
The security of personal data processed by the Operator is ensured through the implementation of legal, organizational, and technical measures necessary to fully comply with current legislation on the protection of personal data.
8.1 The Operator ensures the safety of personal data and takes all possible measures to prevent unauthorized access to such data.
8.2 The User’s personal data will never be transferred to third parties under any circumstances, except in cases required by applicable law or if the data subject has given the Operator permission to transfer data to a third party for fulfilling obligations under a civil contract.
8.3 In the event inaccuracies are identified in the personal data, the User may update them independently by sending a notification to the Operator at info@ttri.ru , marked “Update of Personal Data.”
8.4 The duration of processing personal data is determined by the achievement of the objectives for which the data was collected, unless another period is specified by contract or applicable law. The User may revoke their consent to the processing of personal data at any time by
sending a notification via email to the Operator at info@ttri.ru , marked “Revocation of Consent for Processing 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 entities (Operators) in accordance with their own User Agreements and Privacy Policies. The data subject is responsible for reviewing these documents. The Operator is not liable for the actions of third parties, including the service providers mentioned in this section.
8.6 Restrictions placed by the data subject on the transfer (excluding granting access) and/or processing (excluding granting access) of personal data permitted for distribution do not apply in cases where the processing serves public, state, or other public interests defined by Russian legislation.
8.7 The Operator ensures the confidentiality of personal data during processing.
8.8 The Operator stores personal data in a form allowing identification of the data subject no longer than required by the purpose of the processing, unless a storage period is established by federal law, a contract where the subject is a party, assignee, or guarantor.
8.9 Circumstances for ceasing processing of personal data include:
● Achievement of the processing goal;
● Expiry of the validity period of the data subject’s consent;
● Revocation of consent by the data subject;
● A request from the data subject to cease processing;
● Detection of unlawful processing of personal data.
9. List of Actions Performed by the Operator with the Collected Personal Data
9.1 The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, modifies), extracts, uses, transfers (distributes, provides, grants access to), anonymizes, blocks, deletes, and destroys personal data.
9.2 The Operator performs automated processing of personal data, including the receipt and/or transmission of the collected information through information and telecommunication networks or without such transmission.
10. Cross-Border Transfer of Personal Data
10.1 Before commencing any activities involving the cross-border transfer of personal data, the Operator must notify the authorized body for the protection of personal data subjects of its intention to perform such a transfer (this notification is submitted separately from the notification about the intention to process personal data).
10.2 Prior to submitting the above notification, the Operator must obtain from the foreign state authorities, foreign individuals, or foreign legal entities to which the cross-border transfer is planned, the relevant information.
11. Confidentiality of Personal Data
The Operator and any other persons who have gained access to personal data are obligated not to disclose them to third parties or distribute them without the consent of the personal data subject, unless otherwise provided for by federal law.
12. Final Provisions
12.1 The User may obtain any clarifications on questions concerning the processing of their personal data by contacting the Operator via email at info@ttri.ru .
12.2 Any changes to the Operator’s policy on personal data processing 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 publicly available on the Internet at: https://ttri.ru/kaiyiconnect/privacy-policy