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 "On Personal Data" dated July 27, 2006 (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 undertaken by Baltic Bears Rent Car (hereinafter referred to as the "Operator").
1.1. The Operator considers compliance with human and civil rights and freedoms when processing personal data, including the protection of the right to privacy, personal, and family secrecy, to be its most important goal and condition for carrying out its activities. 1.2. This Operator's policy on personal data processing (hereinafter referred to as the "Policy") applies to all information that the Operator may obtain about visitors to the website http://balticbearsrentcar.com.
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 suspension of personal data processing (except in cases where processing is necessary for the clarification of personal data). 2.3. Website – a set of graphic and informational materials, as well as computer programs and databases that ensure their availability on the Internet at http://balticbearsrentcar.com. 2.4. Personal data information system – a set of personal data contained in databases and ensuring their processing using information technologies and technical means. 2.5. Anonymization of personal data – actions that make it impossible to determine, without the use of additional information, the ownership of personal data by a specific User or another subject of personal data. 2.6. Processing of personal data – any action (operation) or a set of actions (operations) performed with or without the use of automation tools concerning personal data, including collection, recording, systematization, accumulation, storage, updating (modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data. 2.7. Operator – a state authority, municipal authority, legal or physical entity that 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 subject to processing, and actions (operations) performed with personal data. 2.8. Personal data – any information related directly or indirectly to a specific or identifiable User of the website http://balticbearsrentcar.com. 2.9. Personal data permitted for distribution – personal data, access to which an unlimited number of persons is provided by the subject of personal data by giving consent to the processing of personal data permitted for distribution in the manner prescribed by the Personal Data Law (hereinafter referred to as "personal data permitted for distribution"). 2.10. User – any visitor to the website http://balticbearsrentcar.com. 2.11. Provision of personal data – actions aimed at disclosing personal data to a specific person or a specific group of persons. 2.12. Distribution of personal data – any actions aimed at disclosing personal data to an indefinite number of persons (transferring personal data) or at making personal data known to an unlimited number of persons, including the publication of personal data in the media, placement in information and telecommunication networks, or providing access to personal data in any other way. 2.13. Cross-border transfer of personal data – the transfer of personal data to the territory of a foreign state, to a foreign state authority, a foreign individual, or a foreign legal entity. 2.14. Destruction of personal data – any actions that result in the irreversible destruction of personal data, making it impossible to further restore the content of personal data in the personal data information system and/or the destruction of physical media containing personal data.
3. Basic Rights and Responsibilities of the Operator
3.1. The Operator has the right to:

• receive from the subject of personal data reliable information and/or documents containing personal data;
• in case of withdrawal by the subject of personal data of consent to the processing of personal data, as well as submission of a request for termination of personal data processing, the Operator has the right to continue processing personal data without the consent of the subject if there are grounds specified in the Personal Data Law;
• independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations provided by the Personal Data Law and adopted in accordance with it regulatory legal acts, 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, upon request, with information regarding the processing of their personal data;
• organize the processing of personal data in accordance with the current legislation of the Russian Federation;
• respond to requests and inquiries from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
• notify the authorized body for the protection of personal data subjects’ rights upon request of this body of the necessary information within 10 days from the date of receipt of such a request;
• publish or otherwise ensure unrestricted access to this Policy on personal data processing;
• take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision, distribution of personal data, as well as other unlawful actions in relation to personal data;
• cease the transfer (distribution, provision, access) of personal data, cease processing, and destroy personal data in the manner and cases provided for by the Personal Data Law;
• fulfill other obligations provided by the Personal Data Law.

4. Main 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 laws. The information is provided to the personal data subject by the Operator in an accessible form and must not contain personal data related to other personal data subjects, except in cases where 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; — request the Operator to clarify, block, or destroy their personal data if the personal data is incomplete, outdated, inaccurate, illegally obtained, or unnecessary for the declared purpose of processing, as well as take legally prescribed measures to protect their rights; — set a condition of prior consent when processing personal data for the purpose of marketing goods, works, and services; — withdraw consent to the processing of personal data and submit a request to terminate the processing of personal data; — file complaints with the authorized body for the protection of personal data subjects' rights or in court against unlawful actions or inactions of the Operator in the processing of their personal data; — exercise other rights provided by Russian legislation.
4.2. Personal data subjects are obliged to: — provide the Operator with accurate information about themselves; — notify the Operator of updates (modifications, changes) to their personal data.
4.3. Persons who provide the Operator with inaccurate information about themselves or information about another personal data subject without their consent bear responsibility in accordance with Russian legislation.

5. Principles of Personal Data Processing
5.1. Personal data processing is carried out on a lawful and fair basis. 5.2. The processing of personal data is limited to achieving specific, predetermined, and lawful purposes. Processing of personal data that is incompatible with the purposes of data collection is not allowed. 5.3. It is not allowed to combine databases containing personal data whose processing is carried out for purposes that are incompatible with each other. 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 must correspond to the declared purposes of processing. The processing of excessive personal data in relation to the declared purposes is not allowed. 5.6. The accuracy, sufficiency, and, where necessary, relevance of personal data must be ensured concerning the purposes of processing. The Operator takes necessary measures and/or ensures that incomplete or inaccurate data is deleted or clarified. 5.7. Personal data is stored in a form that allows identifying the personal data subject no longer than required for the purposes of processing unless the storage period is established by federal law, a contract, or another legal obligation. Processed personal data is destroyed or anonymized upon achieving the processing purposes or if the need to achieve these purposes is lost, unless otherwise provided by federal law.

6. Purposes of Personal Data Processing

7. Conditions for Personal Data Processing
7.1. Processing of personal data is carried out with the consent of the personal data subject. 7.2. Processing of personal data is necessary for achieving goals stipulated by international treaties of the Russian Federation or laws, for fulfilling functions, powers, and duties assigned to the Operator by Russian legislation. 7.3. Processing of personal data is necessary for the administration of justice, execution of judicial acts, or acts of other authorities or officials in accordance with Russian legislation on enforcement proceedings. 7.4. Processing of personal data is necessary for the execution of a contract in which the personal data subject is a party, beneficiary, or guarantor, as well as for concluding a contract initiated by the personal data subject or a contract under which the personal data subject will act as a beneficiary 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 this does not violate the rights and freedoms of the personal data subject. 7.6. Processing of personal data is carried out when the personal data subject has granted access to an unlimited number of persons or at their request (publicly available personal data). 7.7. Processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.

8. Collection, Storage, Transfer, and Other Types of Personal Data Processing
8.1. The Operator ensures the security of processed personal data through legal, organizational, and technical measures necessary for full compliance with applicable legislation in the field of personal data protection. 8.2. The Operator guarantees the confidentiality of personal data and takes all possible measures to prevent unauthorized access. 8.3. The User may update personal data by sending an email to the Operator at balticbearsrentalcar@gmail.com with the subject "Personal Data Update." 8.4. The duration of personal data processing is determined by the achievement of the purposes for which the personal data was collected unless otherwise stipulated by a contract or applicable legislation. 8.5. The User may withdraw consent for personal data processing at any time by sending an email to the Operator at balticbearsrentalcar@gmail.com with the subject "Withdrawal of Consent for Personal Data Processing."

9. Actions Performed by the Operator with Received Personal Data
9.1. The Operator performs the collection, recording, systematization, accumulation, storage, updating (modification, change), retrieval, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data. 9.2. The Operator performs automated processing of personal data with the receipt and/or transmission of the obtained information via information and telecommunication networks or without them.

10. Cross-Border Transfer of Personal Data
10.1. Before commencing cross-border transfer of personal data, the Operator must notify the authorized body for the protection of personal data subjects' rights of its intention (this notification is sent separately from the notification of intent to process personal data). 10.2. Prior to submitting the above notification, the Operator must obtain relevant information from foreign authorities, individuals, and legal entities to whom personal data is planned to be transferred.

11. Confidentiality of Personal Data
The Operator and other persons who have access to personal data must not disclose it to third parties or distribute it without the consent of the personal data subject, unless otherwise provided by federal law.

12. Final Provisions
12.1. The User may obtain any clarifications regarding the processing of their personal data by contacting the Operator via email at balticbearsrentalcar@gmail.com. 12.2. Any changes to this personal data processing policy will be reflected in this document. The policy remains in effect indefinitely until replaced by a new version. 12.3. The current version of the Policy is publicly available online at http://balticbearsrentcar.com/privacy.