Privacy Policy on Personal Data Processing

1. General Provisions This Privacy Policy on Personal Data Processing is drawn up in accordance with the requirements of Federal Law No. 152-FZ of 27.07.2006 “On Personal Data” (hereinafter referred to as the “Personal Data Law”) and defines the procedure for processing personal data and the measures taken by Faguri Prod OÜ (hereinafter referred to as the “Operator”) to ensure the security of personal data. 1.1. The Operator’s primary goal and a fundamental condition of its activities is to respect the rights and freedoms of individuals and citizens in the processing of their personal data, including the protection of the right to privacy, personal and family secrets. 1.2. This Privacy 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 http://fuelopti.com.
2. Key Definitions Used in the Policy
2.1. Automated processing of personal data — processing of personal data using computing equipment.
2.2. Blocking of personal data — temporary suspension of processing of personal data (except where processing is necessary to clarify the personal data).
2.3. Website — a set of graphic and informational materials, as well as computer programs and databases, providing their availability on the Internet at the network address http://fuelopti.com.
2.4. Personal data information system — a set of personal data contained in databases and the information technologies and technical means that ensure their processing.
2.5. Anonymization of personal data — actions as a result of which it is impossible to determine, without using additional information, to which specific user or other data subject the personal data belong.
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, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
2.7. Operator — a state body, municipal body, legal entity or individual who, alone or jointly with others, organizes and/or carries out the processing of personal data, and who determines the purposes of processing personal data, the composition of 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 http://fuelopti.com. 2.9. Personal data permitted for dissemination by the data subject — personal data to which an unlimited circle of persons has been granted access by the data subject by giving consent to the processing of personal data permitted for dissemination, in the manner prescribed by the Personal Data Law (hereinafter referred to as “personal data permitted for dissemination”).
2.10. User — any visitor of the website http://fuelopti.com.
2.11. Disclosure of personal data — actions aimed at revealing personal data to a specific person or a specific group of persons.
2.12. Dissemination of personal data — any actions aimed at revealing personal data to an indefinite circle of persons (transfer of personal data) or making personal data available to an unlimited circle of persons, including publication of personal data in mass 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, foreign individual, or foreign legal entity.
2.14. Destruction of personal data — any actions as a result of which personal data are irreversibly destroyed, with no possibility of further recovery of the content of personal data in the personal data information system and/or destruction of physical media containing personal data.

3. Main Rights and Obligations of the Operator

3.1. The Operator has the right: — to obtain from the data subject reliable information and/or documents containing personal data; — in the event that the data subject revokes consent to the processing of personal data, or sends a request to cease processing of personal data, the Operator may continue processing personal data without the data subject’s 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 the obligations established by the Personal Data Law and the regulatory legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.
3.2. The Operator is obliged to: — provide the data subject, upon request, with information concerning the processing of his or her personal data; — organize the processing of personal data in the manner established by the current legislation of the Russian Federation; — respond to requests and inquiries from data subjects and their lawful representatives in accordance with the requirements of the Personal Data Law; — provide the authorized body for the protection of data subjects’ rights, upon its request, with the necessary information within 10 days from the date of receipt of such request; — publish or otherwise ensure unlimited access to this Privacy Policy on Personal Data Processing; — take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, alteration, blocking, copying, disclosure, dissemination, and other unlawful actions in relation to personal data; — cease the transfer (dissemination, provision, access) of personal data, cease processing, and destroy personal data in the manner and cases provided by the Personal Data Law; — fulfill other obligations established by the Personal Data Law.

4. Main Rights and Obligations of Data Subjects

4.1. Data subjects have the right: — to obtain information concerning the processing of their personal data, except in cases provided by federal laws. Information shall be provided to the data subject by the Operator in an accessible form and must not contain personal data relating to other data subjects, except where there are lawful grounds for disclosure of such personal data. The list of information and the procedure for its receipt are established by the Personal Data Law; — to require the Operator to clarify their personal data, block or destroy them if the personal data are incomplete, outdated, inaccurate, unlawfully obtained, or are not necessary for the declared purpose of processing, as well as to take legal measures to protect their rights; — to require prior consent for the processing of personal data for the purposes of promoting goods, works, and services in the market; — to withdraw consent to the processing of personal data, as well as to send a request to cease processing of personal data; — to appeal in the authorized body for the protection of data subjects’ rights or in court against unlawful actions or inaction of the Operator in the processing of their personal data; — to exercise other rights provided by the legislation of the Russian Federation.
4.2. Data subjects are obliged to: — provide the Operator with accurate information about themselves; — inform the Operator of any clarification (updating, modification) of their personal data.
4.3. Individuals who provide the Operator with false information about themselves, or information about another data subject without that person’s consent, shall bear responsibility in accordance with the legislation of the Russian Federation.

5. Principles of Personal Data Processing

5.1. Personal data processing is carried out on a lawful and fair basis.
5.2. Personal data processing is limited to achieving specific, pre-determined, and lawful purposes. Processing of personal data incompatible with the purposes of collection is not permitted.
5.3. Merging of databases containing personal data processed for purposes incompatible with each other is not permitted.
5.4. Only personal data that correspond to the purposes of their processing are subject to processing.
5.5. The content and volume of processed personal data correspond to the declared purposes of processing. Excessive personal data in relation to the declared purposes of processing are not permitted.
5.6. During processing, the accuracy of personal data is ensured, their sufficiency, and, where necessary, their relevance to the purposes of processing personal data. The Operator takes necessary measures and/or ensures that such measures are taken to remove or clarify incomplete or inaccurate data.
5.7. Personal data are stored in a form that allows identification of the data subject, no longer than required for the purposes of processing, unless the storage period is established by federal law, contract, or by a contract to which the data subject is a party, beneficiary, or guarantor. Processed personal data are destroyed or anonymized upon achievement of the purposes of processing or when the necessity to achieve these purposes is lost, unless otherwise provided by federal law.

6. Purposes of Personal Data Processing Purpose of Processing:

Informing the User by sending electronic messages. Personal Data: - Surname, first name, patronymic - Email address - Phone numbers - Company name Legal Basis: - Charter (constitutive) documents of the Operator Types of Personal Data Processing: - Collection, recording, systematization, accumulation, storage, destruction, and anonymization of personal data - Sending informational emails to the email address

7. Conditions for Processing Personal Data

7.1. Personal data processing is carried out with the consent of the data subject to the processing of his or her personal data.

7.2. Processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, to carry out functions, powers, and duties imposed on the Operator by the legislation of the Russian Federation.
7.3. Processing of personal data is necessary for the administration of justice, enforcement of a court decision, decision of another body or official, which must be enforced in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. 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. Processing of personal data is necessary for the exercise of rights and legitimate interests of the Operator or third parties, or for achieving socially significant purposes, provided that the rights and freedoms of the data subject are not violated.
7.6. Processing is carried out of personal data whose access by an unlimited circle of persons has been provided by the data subject or at his or her request (hereinafter referred to as “publicly available personal data”).
7.7. Processing is carried out of personal data that must be published or disclosed in accordance with federal law.

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 by implementing legal, organizational, and technical measures necessary to fully comply with the requirements of the current legislation on personal data protection.

8.1. The Operator ensures the security 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 compliance with current legislation or if the data subject has given the Operator consent to transfer data to a third party for the performance of obligations under a civil law contract.
8.3. In the event of inaccuracies in personal data, the User may update them independently by sending the Operator a notification to the Operator’s email address juri@faguri.com with the subject line “Updating personal data”.
8.4. The period of personal data processing is determined by the achievement of the purposes for which the personal data were collected, unless otherwise provided by a contract or current legislation. The User may at any time withdraw his or her consent to the processing of personal data by sending the Operator a notification via email to the Operator’s email address juri@faguri.com with the subject line “Withdrawal of consent to personal data processing”.
8.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by these parties (operators) in accordance with their Terms of Service and Privacy Policy. The data subject is responsible for familiarizing him- or herself with these documents. The Operator is not liable for the actions of third parties, including the service providers mentioned in this clause.
8.6. Restrictions set by the data subject on the transfer (except for granting access), as well as on processing or conditions of processing (except for granting access) of personal data permitted for dissemination, 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 when processing personal data.
8.8. The Operator stores personal data in a form that allows identification of the data subject, no longer than required for the purposes of processing, unless the storage period is established by federal law, contract, or by a contract to which the data subject is a party, beneficiary, or guarantor.
8.9. Grounds for termination of personal data processing may include: achievement of the purposes of processing, expiration of the consent term, withdrawal of consent by the data subject, a request to cease processing of personal data, or detection of unlawful processing of personal data.
9. List of Actions Performed by the Operator with the Obtained Personal Data
9.1. The Operator carries out collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
9.2. The Operator carries out automated processing of personal data with receipt and/or transmission of the obtained information via information and telecommunications networks or without such transmission.

10. Cross-Border Transfer of Personal Data

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

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

12. Final Provisions

12.1. The User may obtain any clarifications on questions of interest regarding the processing of his or her personal data by contacting the Operator via email at juri@faguri.com.
12.2. Any changes to the Operator’s personal data processing policy will be reflected in this document. The Policy is effective indefinitely until it is replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet at http://fuelopti.com/pd.