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Personal Data Processing Policy

1. General Provisions

This personal data processing policy has been compiled in accordance with the requirements of Federal Law No. 152-FZ dated July 27, 2006 "On Personal Data" (hereinafter - the Personal Data Law) and defines the procedure for processing personal data and measures to ensure the security of personal data taken by Rowerco Western Balkans DOO (hereinafter - the Operator).
1.1. The Operator considers its most important goal and condition for carrying out its activities to be the observance of human and civil rights and freedoms when processing personal data, including the protection of rights to privacy, personal and family secrets.
1.2. This policy of the Operator regarding the processing of personal data (hereinafter - the Policy) applies to all information that the Operator can receive about visitors to the website https://rowercogroup.com.


2. Basic 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 cessation of processing of personal data (except for cases where processing is necessary to clarify personal data).
2.3. Website - a collection of graphic and information materials, as well as computer programs and databases that ensure their availability on the Internet at the network address https://rowercogroup.com.
2.4. Personal data information system - a combination of personal data contained in databases and ensuring their processing of information technologies and technical means.
2.5. Depersonalization of personal data - actions as a result of which it is impossible to determine, without using additional information, the ownership of personal data to a specific User or other subject of personal data.
2.6. Processing of personal data - any action (operation) or 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), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
2.7. Operator - a state body, municipal body, legal entity or individual who independently or jointly with other persons organizes and/or carries out the processing of personal data, as well as determines the purposes of processing personal data, the composition of personal data to be processed, 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://rowercogroup.com.
2.9. Personal data permitted by the subject of personal data for distribution - personal data, access to which is provided to an unlimited number of persons by the subject of personal data by giving consent to the processing of personal data permitted by the subject of personal data for distribution in the manner prescribed by the Law on Personal Data (hereinafter - personal data permitted for distribution).
2.10. User - any visitor to the website https://rowercogroup.com.
2.11. Provision of personal data - actions aimed at disclosing personal data to a certain person or a certain circle of persons.
2.12. Dissemination of personal data - any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or familiarizing with personal data of an unlimited number of persons, including the publication of personal data in the media, placement in information and telecommunications 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 a foreign state authority, a foreign individual or a foreign legal entity.
2.14. Destruction of personal data - any actions resulting in the permanent destruction of personal data with the impossibility of further restoration of the content of personal data in the personal data information system and/or the destruction of material carriers of personal data.


3. Basic Rights and Obligations of the Operator

3.1. The Operator has the right to:

• receive reliable information and/or documents containing personal data from the subject of personal data;
• in case of withdrawal by the subject of personal data of consent to the processing of personal data, as well as sending a request with a requirement to stop processing personal data, the Operator has the right to continue processing personal data without the consent of the subject of personal data 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 regulations adopted in accordance with it, unless otherwise provided by the Law on Personal Data or other federal laws.

3.2. The Operator is obliged to:

• provide the subject of personal data, at his request, with information regarding the processing of his personal data;
• organize the processing of personal data in the manner 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 Law on Personal Data;
• report to the authorized body for the protection of the rights of subjects of personal data at the request of this body 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 to them, destruction, modification, blocking, copying, provision, dissemination of personal data, as well as from other illegal actions in relation to personal data;
• stop the transfer (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 stipulated by the Law on Personal Data.

4. Basic Rights and Obligations of Subjects of Personal Data

4.1. Subjects of personal data have the right to:

• receive information concerning the processing of his personal data, except in cases provided for by federal laws. Information is provided to the subject of personal data by the Operator in an accessible form, and it should not contain personal data relating to other subjects of personal data, except in cases where there are legitimate grounds for disclosing such personal data. The list of information and the procedure for obtaining it is established by the Law on Personal Data;
• require the operator to clarify his personal data, block or destroy them if the personal data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated purpose of processing, as well as take measures provided for by law to protect his rights;
• put forward the condition of prior consent when processing personal data for the purpose of promoting goods, works and services on the market;
• to withdraw consent to the processing of personal data, as well as to send a requirement to stop the processing of personal data;
• appeal to the authorized body for the protection of the rights of subjects of personal data or in court the illegal actions or inaction of the Operator when processing his personal data;
• to exercise other rights provided for by the legislation of the Russian Federation.

4.2. Subjects of personal data are obliged to:

• provide the Operator with reliable data about themselves;
• inform the Operator about 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, shall be liable 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. Processing of personal data that is incompatible with the purposes of collecting personal data is not allowed.
5.3. The merging of databases containing personal data, the processing of which is carried out for purposes that are incompatible with each other, is not allowed.
5.4. Only personal data that meet the purposes of their processing are subject to processing.
5.5. The content and volume of processed personal data correspond to the stated processing purposes. The redundancy of the processed personal data in relation to the stated purposes of their processing is not allowed.
5.6. When processing personal data, the accuracy of personal data, their sufficiency, and, if necessary, relevance in relation to the purposes of processing personal data, is ensured. The operator takes the necessary measures and/or ensures that they are taken to delete or clarify incomplete or inaccurate data.
5.7. Personal data is stored in a form that allows determining the subject of personal data, no longer than required by the purposes of processing personal data, if the period for storing personal data is not established by federal law, an agreement to which the subject of personal data is a party, beneficiary or guarantor. The processed personal data is destroyed or depersonalized upon achievement of the processing goals or in the case of loss of the need to achieve these goals, unless otherwise provided by federal law.

6. Purposes of Personal Data Processing

The purposes of data processing are:

• processing user requests,
• sending information messages,
• providing services.

Personal data is processed in accordance with Federal Law No. 152-FZ dated 27.07.2006 "On Personal Data" and includes:

• email address;
• name;
• telephone.

The consent is valid indefinitely until it is revoked by the user by sending a written notification by e-mail trading@rowercogroup.com


7. Conditions for Personal Data Processing

7.1. The processing of personal data is carried out with the consent of the subject of personal data to the processing of his personal data.
7.2. The processing of personal data is necessary to achieve the goals provided for by an international treaty of the Russian Federation or law, to carry out the functions, powers and duties assigned by the legislation of the Russian Federation to the operator.
7.3. The processing of personal data is necessary for the administration of justice, the execution of a judicial act, an act of another body or official, 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 the contract, to which the subject of personal data is a party or beneficiary or guarantor, as well as for the conclusion of a contract at the initiative of 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 exercise of 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 subject of personal data.
7.6. The processing of personal data is carried out, to which an unlimited number of persons have access provided by the subject of personal data or at his request (hereinafter - publicly available personal data).
7.7. The processing of personal data is carried out that is subject to publication or mandatory disclosure in accordance with federal law.

8. Procedure for Collection, Storage, Transfer and Other Types of Personal Data Processing

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 the requirements of 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 related to the implementation 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 trading@rowercogroup.com with the note "Personal data update".
8.4. The period for processing personal data is determined by the achievement of the purposes for which the personal data was collected, unless another period is provided for by the contract or current legislation. The User may at any time withdraw his consent to the processing of personal data by sending a notification to the Operator via email to the Operator's email address trading@rowercogroup.com with the note "Withdrawal of consent to the processing of personal data".
8.5. All information that is collected by third-party services, including payment systems, means of communication and other service providers, is stored and processed by these persons (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 clause.
8.6. The prohibitions on the transfer (except for the provision of access), as well as on the processing or conditions of processing (except for obtaining access) of personal data permitted for distribution, established by the subject of personal data, do not apply in cases of processing personal data in state, public and other public interests defined 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 determining the subject of personal data, no longer than required by the purposes of processing personal data, if the period for storing personal data is not established by federal law, an agreement to which the subject of personal data is a party, beneficiary or guarantor.
8.9. The condition for the termination of the processing of personal data may be the achievement of the purposes of processing personal data, the expiration of the consent of the subject of personal data, the withdrawal of consent by the subject of personal data or a requirement to stop the processing of personal data, as well as the identification of illegal processing of personal data.


9. List of Actions Performed by the Operator with the Received Personal Data

9.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), extracts, uses, transfers (distributes, provides, accesses), 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 received via information and telecommunications networks.


10. Cross-border Transfer of Personal Data

10.1. The Operator, before starting activities for the cross-border transfer of personal data, is obliged to notify the authorized body for the protection of the rights of subjects of personal data of its intention to carry out a cross-border transfer of personal data (such notification is sent separately from the notification of the intention to process personal data).
10.2. The Operator, before submitting the above notification, is obliged to obtain from the authorities of a foreign state, foreign individuals, foreign legal entities to which a cross-border transfer of personal data is planned, the relevant information.


11. Confidentiality of Personal Data

The Operator and other persons who have gained access to personal data are obliged not to disclose to third parties and not to 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 get any clarification on issues of interest regarding the processing of his personal data by contacting the Operator via email trading@rowercogroup.com.
12.2. This document will reflect any changes to the Operator's personal data processing policy. The Policy is valid indefinitely until it is replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet at  https://rowercogroup.com/policyen.

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Belgrade, Bulevar Jna 123v

trading@rowercogroup.com

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