1. This policy regarding the processing of personal data of the website https://d2prive.com/ (hereinafter - the “Policy”) is developed in accordance with the requirements of the legislation of the Russian Federation and in fulfillment of the requirements of paragraph 2, part 1, Article 18.1 of the Federal Law of 27.07.2006 № 152-FZ “On Personal Data” (hereinafter - the “Personal Data Law”) in order to ensure the protection of human and civil rights and freedoms in the processing of personal data, including the protection of the right to privacy, personal and family secrecy.
2. This Policy applies to all Users of https://d2prive.com/.
3. Users expressly consent to the processing of their personal data as described in the Policy.
4. Basic concepts used in the Policy:

• Personal data - any information relating to directly or indirectly defined or determined natural person (subject of personal data) - User of the site https://d2prive.com/;
• Personal Data Subject / User of the website https://d2prive.com/ / User - a natural person who has performed (passed) the registration (authorization) procedure on the website https://d2prive.com/;
• Operator of personal data (hereinafter - “Operator” / “Company”) - Individual Entrepreneur Dudinsky Dmitry Andreyevich, OGRN 315774600237712 from 15.07.2015, TIN: 7727626403;
• Address (location): 115191, RUSSIA, MOSCOW, VN.TER.G. MUNICIPALITY DISTRICT DONSKOY, DUKHOVSKAYA PER. 17, P. 15, ROOM. 12H/2, independently or jointly with other persons organizing and (or) carrying out the processing of personal data, as well as determining the purposes of personal data processing, the composition of personal data subject to processing, actions (operations) performed with personal data;
• Processing of personal data means any action (operation) or set of actions (operations) with personal data performed with or without the use of automation tools. Processing of personal data includes, but is not limited to: collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction;
• Automated processing of personal data - processing of personal data by means of computer equipment;
• Dissemination of personal data - actions aimed at disclosure of personal data to an indefinite number of persons;
• Provision of personal data - actions aimed at disclosure of personal data to a certain person or a certain circle of persons;
• Blocking of personal data - temporary cessation of personal data processing (except for cases when processing is necessary to clarify personal data);
• Destruction of personal data - actions as a result of which it becomes impossible to restore the content of personal data in the information system of personal data and (or) as a result of which material carriers of personal data are destroyed;
• Personal data depersonalization - actions, as a result of which it becomes impossible to determine the belonging of personal data to a particular subject of personal data without using additional information;
• Personal data information system - a set of personal data contained in databases and information technologies and technical means ensuring their processing.

5 The website https://d2prive.com/ is provided by the Company, its subsidiaries, contractors and licensees (related companies). The Company is a data controller, responsible for the purposes of processing Users' personal data and may transfer personal data or entrust their processing to any of the related companies in accordance with the procedure stipulated by the Policy and the legislation of the Russian Federation.
6 Principles of personal data processing
6.1 Processing of personal data is carried out by the Company in accordance with the requirements of the legislation of the Russian Federation and on the basis of the following principles:

• legality and fair basis;
• limiting the processing of personal data to the achievement of specific, predetermined and legitimate purposes;
• prevention of personal data processing incompatible with the purposes of personal data collection;
• preventing the merging of databases containing personal data processed for incompatible purposes;
• processing only those personal data that meet the purposes of their processing;
• compliance of the content and scope of processed personal data with the stated processing purposes;
• preventing the processing of redundant personal data in relation to the stated purposes of their processing;
• ensuring accuracy, sufficiency and relevance of personal data in relation to the purposes of personal data processing;
• destruction or depersonalization of personal data upon achievement of the purposes of their processing or in case of loss of necessity in achievement of these purposes, in case of impossibility of elimination by the Company of the admitted violations of personal data, unless otherwise provided for by the legislation of the Russian Federation.

7 Legal basis for processing personal data
7.1 The legal basis for processing personal data is a set of regulatory legal acts, pursuant to which and in accordance with which the Company processes personal data, including:

• Constitution of the Russian Federation;
• Civil Code of the Russian Federation;
• Labor Code of the Russian Federation;
• Tax Code of the Russian Federation;
• Federal Law of 27.07.2006 No. 152-FZ “On Personal Data”;
• Federal Law No. 402-FZ “On Accounting” dated December 6, 2011;
• Company's Charter;
• local normative acts of the Company;
• contracts concluded with the User;
• User's consent to the processing of personal data.
• other normative legal acts regulating relations related to the activities of the Company.

8 Purposes and conditions of personal data processing
8.1 The processing of personal data is limited to the achievement of specific, predetermined and legitimate purposes
8.2 Processing of personal data incompatible with the purposes of personal data collection is not allowed
8.3 Only personal data that meet the purposes of their processing shall be processed
8.4 The Company processes personal data of Personal Data Subjects for such purpose(s) as:

• providing access to the services and products of https://d2prive.com/;
• conclusion and execution of contracts with the Personal Data Subject;
• organization of the Personal Data Subject's participation in the Company's loyalty program;
• sending of advertising information about goods and services to the Personal Data Subject.

8.5 The content and scope of the processed personal data shall comply with the stated purposes of processing provided for in this section of the Policy.
8.6 Processed personal data shall not be redundant in relation to the stated purposes of their processing.
9 This Policy applies to the following categories of Personal Data Subjects processed by the Company:

• Users of the website https://d2prive.com/.
• Company's contractors (individuals).
• Personal data subjects (individuals) who are representatives of the Company's counterparties (legal entities and individual entrepreneurs).

10 Collection and storage of personal data
10.1 The Company, offering its services and products, periodically needs information about the communication details of Users.
10.2 The Company requests a minimum amount of this information from the User in order to keep in touch with the User. For the purposes provided for in the Policy, the Company processes the following categories of personal data of the Users of the https://d2prive.com/ website:
- User's name;
- contact (cell) phone number
-users account in messengers (WhatsApp, Telegram)
- e-mail address;
- credentials for logging into the personal account: login and password.
- gender / age (if necessary).
10.3 In the course of processing orders from Users, the Company may collect and store the following personal information, including personal data:
- address and other contact information (depending on the Products used), if paying through the service - financial information such as credit card and bank account numbers;
- messages sent using the Products and messages sent to the Company;
- other information about User's interaction with information systems of the Company and its partners, results of collection of statistics of visits to https://d2prive.com/ and publicly available information about programs and devices used for such access, including data on geolocation or IP-address of the User;
- additional information that the Company requests from Users to verify their identity.
10.4The Company does not process biometric personal data of Users (information that characterizes physiological and biological features of a person, on the basis of which his/her identity can be established).
10.5 The Company does not process special categories of Users' personal data.
10.6 The Company does not carry out cross-border transfer of Users' personal data.
10.7 The User transfers personal data when concluding a contract. Personal data of Users are subject to storage during the period of fulfillment of contractual obligations and (or) during the terms established by the legislation of the Russian Federation.
10.8 The list of actions performed by the Company with personal data of Users / Personal Data Subjects: collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, blocking, deletion, destruction.
10.9 The Company collects and stores personal data of Users / Personal Data Subjects using databases located in the territory of the Russian Federation.
10.10 The Company carries out mixed processing of personal data of Users / Personal Data Subjects with transmission via internal network, with transmission via Internet.
10.11 It is not allowed to disclose to third parties and distribute personal data without the consent of the User / Personal Data Subject, unless otherwise provided for by the legislation of the Russian Federation.
10.12 Processing of personal data of Personal Data Subjects does not require additional consent, in the case of processing of personal data in accordance with paragraph 5, part 1, article 6 of the Law on Personal Data. 1 part 1 of Article 6 of the Law on Personal Data.
10.13 Persons who transferred to the Company information about another Personal Data Subject, including via https://d2prive.com/, without the consent of the subject whose personal data were transferred, shall be liable in accordance with the laws of the Russian Federation.
10.14 The Company shall store personal data in a form that allows identification of the Personal Data Subject for no longer than required for the purposes of personal data processing, unless the period of personal data storage is established by the legislation of the Russian Federation, the contract to which the Personal Data Subject is a party, beneficiary or guarantor.

11 Processed personal data shall be destroyed in case of:
- when the period of personal data processing has been reached;
- achievement of the purposes of personal data processing;
- no longer necessary to achieve the purposes of personal data processing;
- withdrawal of consent to the processing of personal data;
- exclusion of the Company from the Unified State Register of Legal Entities.
12 Use of personal data:

- The Company's primary purpose in collecting personal data is to provide Users with a safe and efficient use of https://d2prive.com/.

13 Users agree that the Company may also use their personal data to:

- providing services and customer support at the request of Users;
- fulfillment of agreements with Users;
- resolving disputes, collecting feedback and troubleshooting;
- customization, analysis and improvement of services, information content and advertising of the website https://d2prive.com/;
- informing Users about https://d2prive.com/, targeted marketing, service updates and promotional offers based on Users' information preferences;
- sending individual marketing messages via e-mail and SMS (which Users can refuse at any time by changing their information preferences);
- comparison of personal data to confirm its accuracy and verification by third parties in cases stipulated by law.
14 Marketing:
14.1 The Company does not sell or provide Users' personal data to third parties for marketing purposes other than those provided for in these Terms and Conditions of Use of https://d2prive.com/ without Users' express consent.
14.2 The Company may combine anonymized data with other information received from third parties and use it to improve and personalize services, information content and advertising.
14.3 The Company may also provide personal data of Users:
- to service providers who provide the assistance provided for in the agreements for the provision of the Products (e.g., fraud investigation, payment collection, customer service, consultant services);
- to third parties to whom Users expressly request the Company to send their personal data (or to whom Users are otherwise expressly notified and agree when using specific services);
- to law enforcement agencies, other government agencies or third parties in response to requests for information in connection with criminal investigations, other unlawful activity or any activity that could subject the Company or Users to liability.
14.4 Without limiting the foregoing, in an effort to respect Users' personal information, the Company will not provide personal data to any person, including authorized government agencies, without a request made in strict compliance with the laws of the Russian Federation.
15 Metrics
15.1 The Company may use the metric to help analyze the flow of information, customize services, content and advertising, as well as to measure the effectiveness of https://d2prive.com/ and ensure reliability and security, for market research purposes, to track revenue, as well as to improve the functionality of https://d2prive.com/, to monitor compliance with these terms and conditions, and to protect legal rights and interests.
15.2 The metric is depersonalized.

16 Personal data protection. Security.
16.1 The Company takes the necessary legal, organizational and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, distribution and other unauthorized actions, including:
- determines threats to the security of personal data during their processing;
- adopts local normative acts and other documents regulating relations in the field of personal data processing and protection;
- appoints persons responsible for ensuring the security of personal data in the Company's structural subdivisions and information systems;
- creates the necessary conditions for working with personal data;
- organizes accounting of documents containing personal data;
- organizes work with information systems in which personal data is processed;
- stores personal data in conditions that ensure their safety and prevent unauthorized access to them;
- organizes training of the Company's employees who process personal data.
16.2 Users' personal data are stored in the Company's information systems and stored in various ways (encryption, passwords, restriction of access of related companies, employees and contractors, physical security, etc.) to protect Users' personal data from unauthorized access and disclosure.
16.3 The information systems of https://d2prive.com/ that collect, record, systematize, accumulate, store, clarify, update, change and retrieve Users' personal data are located in Russia; during the initial registration of Users and updating of personal data, cross-border transfer of personal data is not carried out, in exceptional cases it is replaced by means of remote access for non-automated processing or, if such transfer is necessary due to the laws of the respective countries where Users are located.
16.4 The use, transfer, distribution, provision, access, depersonalization, blocking, deletion and destruction of Users' personal data are carried out only on the basis of decisions of the Company's authorized representatives in accordance with the requirements of applicable law and the legitimate interests of Users.
16.5 The Company does not make decisions affecting the rights and legitimate interests of Users on the basis of exclusively automated processing of personal data, except for cases of providing information based on the results of a request made by the User using the interface of automated systems.
16.6 When making legally significant decisions, interacting with Users of third parties at the request of the Company, in fulfillment of agreements with Users or at the request of Users, non-automated processing of personal data is carried out to the extent required for the purposes of such interaction and in compliance with the requirements for the security of other data not affected by the processing.
17 Third parties
17.1 Unless otherwise expressly stated in this Policy, this document relates only to the Company's use of personal data provided by Users / Personal Data Subjects.
17.2 If Users disclose their personal data to other parties, different rules may apply to such use and disclosure of personal data. The Company advises Users to clarify the purposes of use before disclosing their personal data to other parties.
18 Changes
18.1 The Company is constantly improving the methods of data collection, storage and processing, including security measures. In this regard, as well as in cases of changes in legislation on personal data, the Company may change this Policy at any time by notifying the Users of https://d2prive.com/.
18.2 Continued use of https://d2prive.com/ after making such changes confirms the User's consent to such changes, unless obtaining a separate consent is required by law.
19 Updating, correction, deletion and destruction of personal data, responses to requests of Users / Personal Data Subjects for access to personal data
19.1 Confirmation of the fact of personal data processing by the Company, legal grounds and purposes of personal data processing, as well as other information specified in Part 7, Article 14 of the Law on Personal Data, shall be provided by the Company to the User or his/her representative upon application or upon receipt of a request from the User or his/her representative within 10 (Ten) working days from the date of receipt of the application or request.
The information provided does not include personal data related to other Users, unless there are legitimate grounds for disclosure of such personal data.
19.2 The request shall contain:
- number of the main identity document of the User or its representative, information about the date of issue of the said document and the issuing authority;
- information confirming the User's participation in relations with the Company (contract number, date of the contract, conventional word designation and (or) other information), or information otherwise confirming the fact of personal data processing by the Company;
- the signature of the User or his/her representative.
19.3 The request may be sent in the form of an electronic document and signed with an electronic signature in accordance with the laws of the Russian Federation.
19.4 If the User's application (request) does not reflect all the necessary information in accordance with the requirements of the Law on Personal Data or the User / Personal Data Subject does not have access rights to the requested information, a reasoned refusal is sent to the User.
19.5 The User's / Personal Data Subject's right to access his/her personal data may be restricted in accordance with part 8 of Article 14 of the Personal Data Law, including if the User's access to his/her personal data violates the rights and legitimate interests of third parties.
19.6 If inaccurate personal data is detected upon application of the User or its representative or at their request or at the request of Roskomnadzor, the Company blocks personal data related to this User from the moment of such application or receipt of the said request for the period of verification, if the blocking of personal data does not violate the rights and legitimate interests of the User or third parties.
19.7 In case of confirmation of the fact of inaccuracy of personal data, the Company, based on the information provided by the User of personal data or its representative or Roskomnadzor, or other necessary documents, clarifies personal data within 7 (Seven) working days from the date of submission of such information and removes the blocking of personal data.
19.8 In case of detection of unlawful processing of personal data upon application (request) of the User or its representative or Roskomnadzor, the Company blocks unlawfully processed personal data related to this User from the moment of such application or request.
19.9 When the purposes of personal data processing are achieved, as well as in case the User withdraws consent to their processing, the personal data shall be destroyed, unless:

• Other is not provided for in the contract to which the User is a party;
• The Company may not carry out processing without the User's consent on the grounds provided for by the Personal Data Law or other federal laws;
• Otherwise is not provided for by another agreement between the Company and the User.

20 Main rights and obligations of the Company.

20.1 The Company shall have the right to:

• independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations stipulated by the Law on Personal Data and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Law on Personal Data or other federal laws;
• to entrust the processing of personal data to another person with the consent of the User (subject of personal data), unless otherwise provided for by federal law, on the basis of a contract concluded with this person. The person processing personal data on behalf of the Company is obliged to comply with the principles and rules of personal data processing stipulated by the Law on Personal Data;
• In case the User revokes his/her consent to the processing of personal data, the Company has the right to continue processing personal data without the User's consent if there are grounds specified in the Personal Data Law.

20.2 The Company is obliged to:

• Organize the processing of personal data in accordance with the requirements of the Personal Data Law;
• respond to appeals and requests of Personal Data Subjects and their legal representatives in accordance with the requirements of the Law on Personal Data;
• to inform the authorized body for the protection of the rights of Personal Data Subjects (hereinafter referred to as Roskomnadzor) at the request of this body the necessary information within 10 (Ten) working days from the date of receipt of such request.

21 Basic rights of the User.

21.1 The User has the right to:

• To receive information regarding the processing of his/her personal data, except in cases provided for by federal laws. Information is provided to the User by the Company in an accessible form, and it should not contain personal data relating to other Users, except in cases where there are legal grounds for disclosure of such personal data.
• The list of information and the procedure for obtaining it is established by the Law on Personal Data.
• demand from the Company to clarify his/her personal data, block or destroy it 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 by law to protect his/her rights;
• to appeal to Roskomnadzor or in court against unlawful acts or omissions of the Company in the processing of his/her personal data.

21.2 The User may exercise the rights to obtain information regarding the processing of his/her personal data, as well as the rights to clarify his/her personal data, block or destroy them:
- by contacting the Company with a relevant request at the Company's address.
- by contacting the Company with a relevant request by e-mail at d2@d2ms.agency, subject to the requirements of this Policy.
22 Final provisions
22.1 Additional rules on personal data protection may be applied to certain categories of Users in accordance with the laws of the Russian Federation.
22.2 The Company has the right to send advertising and information messages to the User via e-mail, SMS and push notifications only on condition of prior consent to receive advertising in accordance with Part 1 of Article 18 of Federal Law No. 38-FZ “On Advertising” dated 13.03.2006.
22.3 Consent to receive advertising messages from the Company via e-mail, SMS and push notifications is provided by the User in writing or in electronic form by ticking (ticking) the appropriate box (check box) on https://d2prive.com/
22.4 The User has the right to opt-out of receiving promotional messages by clicking on the appropriate link in the emails received from the Company, sending a notice of opt-out of receiving promotional messages:
- by contacting the Company with a corresponding request to the Company's address
- by contacting the Company with a corresponding request by e-mail at d2@d2ms.agency.
22.5 Control over compliance with the requirements of this Policy shall be exercised by the authorized person responsible for the organization of personal data processing at the Company.
22.6 Responsibility for violation of the requirements of the legislation of the Russian Federation and local acts of the Company in the field of processing and protection of personal data shall be determined in accordance with the legislation of the Russian Federation.
22.7 The User may obtain any clarifications on issues of interest regarding the processing of his/her personal data by contacting the Operator via e-mail at d2@d2ms.agency.
22.8 This document will reflect any changes to the Policy by the Operator. The Policy is valid indefinitely until it is replaced by a new version.
22.9 Pursuant to the requirements of the legislation of the Russian Federation (part 2 of Article 18.1 of the Law on Personal Data), this Policy is placed in free access at: https://d2prive.com/.
23 Contact Information:
Right holder of the site https://d2prive.com/:
Individual entrepreneur Dudinsky Dmitry Andreevich,
OGRN 315774600237712 from 15.07.2015, TIN: 7727626403;
Address (location): 119121, Moscow, Novokonyushenny per., 11, sq. 28.

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