1. General provisions
1.1. This Policy for the Processing of Personal Data on Websites (the ‘Policy’) determines, in accordance with the provisions of Federal Law No. 152-FZ ‘On personal data’ dated 27 July 2006, the procedure and terms and conditions for the processing of personal data by the personal data operator, LLC Volvo Cars, located at: building 5, 39 Leningradskaya Street, Khimki, Moscow Region, 141402 Russia (the ‘Company’), in relation to personal data collected using the websites https://www.volvocars.com/ru,https://www.privilegeclub.ru/, https://volvocardrive.ru/, volvoselekt.ru, cars.volvocars.ru/new (the “Sites” or a “Site”), as well as the requirements for their security.
2. Personal data subjects
2.1. The Company processes the personal data of the following categories of data subjects whose personal data was provided using the Sites:
- representatives of dealership centres,
- clients (individuals and their representatives),
- subscribers for newsletters, and
- website users.
2.2. If you are browsing the Sites as a client (an individual or his/her representative), or if you are interested in buying a car, your personal data will additionally be processed in accordance with the Policy for the Processing of Clients’ Personal Data and the Terms and Conditions for Consent to the Processing of Clients’ Personal Data published on the website at the following link.
3. Purposes of processing personal data
3.1. The Company processes personal data that has been provided using the Sites, for the following purposes:
- to exercise and perform functions, powers and obligations imposed on the Company by Russian legislation and international treaties to which Russia is a party,
- to agree, conclude and perform contracts and other transactions,
- to give information about new products, services and events of the Company and of dealership centre,
- to identify a user as a multiple visitor of the websites of Volvo Car Group,
- to analyse the conduct of visitors of the websites of Volvo Car Group in order to optimise communication with website users and the structure of the websites of Volvo Car Group,
- to create a profile of a website user's interests in order to be able to display on other websites advertisements of Volvo products and services that are important for the website user,
- to personalise offers for website users as part of the promotion of goods, work and services of the Company, its partners and dealership centres.
3.2. The processing of the personal data of clients (individuals and their representatives) may be also performed for the purposes set out in the Policy for the Processing of Clients’ Personal Data and the Terms and Conditions for Consent to the Processing of Clients’ Personal Data (as provided for by clause 2.2 of this Policy).
3.3. Personal data may be processed for other purposes if required in order to ensure statutory compliance.
4. The volume and content of personal data to be processed
4.1. The personal data to be processed includes all information provided to the Company using a Site, including by uploading individual files or by filling in the relevant fields of the Site.
4.2. The volume of personal data of the data subjects is determined according to the need to achieve specific goals related to the processing of such data.
5. The general procedure and conditions for processing personal data
5.1. The Company collects personal data that data subjects enter into the relevant data fields on the Sites during sign-up, sign-in and when using the functions of the Sites, and also that they upload using the Sites.
5.2. The personal data is processed by using and/or without using automated tools by collecting, recording, systematising, accumulating, storing, updating (renewing or modifying), extracting, using, transferring (providing or accessing to), blocking, deleting and destroying the personal data.
5.3. The legal grounds for the processing of data subjects’ personal data are the following:
- the consent of the personal data subjects to their personal data being processed, including pursuant to the conditions of this Policy;
- the need to achieve the goals provided for by an international treaty of the Russian Federation or the law, and the need for the functions, powers and obligations imposed on or granted to the Company by Russian legislation need to be exercised and performed;
- performing an agreement to which the data subject is a party or a beneficiary or a guarantor, as well as concluding an agreement initiated by the data subject or an agreement under which the data subject will be a beneficiary or a guarantor.
5.4. The Company may engage third parties to process personal data, transfer personal data to third parties or instruct third parties to process personal data if this is required for the purposes of the processing of such data in accordance with this Policy, as well as in the cases for which current legislation provides.
5.5. The timeframes for processing personal data are determined in line with the purpose for which such data has been collected. The personal data to be processed shall be destroyed when the purposes for the processing of it have been achieved or when the need for such processing has discontinued, unless Russian legislation provides otherwise.
5.6. The Company may also collect information concerning the visiting of the Site without the data subject directly providing such information. This information can be obtained by different methods, such as cookie-files and the like, as well as Internet statistics tools. The conditions of, and procedure for, cookie files to be processed and Internet statistics tools to be used are determined by an Information Notification – volvocars.com, which is located under the link https://www.volvocars.com/ru/v/legal/cookies.
6. Consent of the data subject and applicable stipulations
6.1. A data subject, acting of his/her own free will and volition and on his/her own behalf, provides his/her personal data to the Company.
6.2. By filling in the forms available on the Sites (including by signing up on the Sites, ticking the field denoting the consent to personal data being processed, and by performing other actions relating to the submission of personal data), the data subject gives his/her consent to personal data being processed on the conditions set out in this Policy.
6.3. If the data subject enters third-party personal data into the forms available on the Sites and uploads files with third-party personal data, the data subject warrants that such third parties have given their consent to their personal data being processed in accordance with the procedure and on the conditions set out in this Policy. The data subject shall notify such third parties that their personal data has been transferred to the Company for the relevant purpose of the personal data processing. The data subject warrants that such notification will be sent.
6.4. If the data subject does not intend to provide personal data to the Company in accordance with this Policy, including situations when the data subject does not agree with this Policy, this may hinder or make impossible the exercise or performance of the mutual rights and obligations of the data subject and the Company.
7. Security of personal data
7.1. When processing personal data the Company takes organisational and technical measures that are necessary and sufficient for ensuring security of personal data in the event of accidental and unauthorised access, destruction, alteration, access to such data being blocked and other unauthorised activities.
7.2. The measures to protect and ensure the security of personal data are determined in the Policy for the Processing and Protection of Personal Data located here.
7.3. Taking into account the specifics of the Internet environment, the Company cannot guarantee that any unauthorised third parties will not be able to circumvent the security measures implemented by the Company or use the data of a data subject for improper purposes since such actions do not entirely depend on the measures taken by the Company.
7.4. The Company is not liable for third parties obtaining the personal data of data subjects by gaining access to their accounts. A data subject must independently ensure the security of the data pertaining to his/her account.
8. Rights and obligations of data subjects
8.1. By accepting these Policy, a data subject confirms that he/she knows his/her rights and obligations set out in Federal Law No. 152-FZ ‘On personal data’ dated 27 July 2006, in particular the right to access his/her personal data and to revoke his/her consent.
8.2. A data subject may revoke his/her consent to the processing of personal data by using the Sites as well as by sending a written declaration via registered mail to the Company’s postal address or an email to: email@example.com. If a data subject provides incorrect data, the Company will be entitled to continue processing his/her personal data.
8.3. A data subject has the right:
- to file inquiries about the processing of his/her personal data;
- to demand that his/her personal data should be adjusted, blocked or destroyed if such personal data is incomplete, obsolete, inaccurate, was received unlawfully or is not necessary for the declared purpose of processing; and to take any measures provided for by legislation to protect his/her rights;
- to demand the list of his/her personal data that the Company is processing and the source of such data;
- to be advised of the timeframes of processing his/her personal data, including storage timeframes;
- to demand that all persons to whom incorrect or incomplete personal data was previously provided should be notified to that effect, such notification specifying all exclusions, adjustments and additions made to such data;
- to appeal to a body authorised to protect the rights of personal data subjects or a court against unlawful acts or omissions committed when his/her personal data was being processed;
- to protect his/her rights and lawful interests, including having recourse to the court to seek compensation of losses and/or moral harm.
8.4. A data subject is obliged to:
- provide the Company with accurate personal data;
- inform the Company of any changes and additions to his/her personal data in a timely manner;
8.5. By accepting the terms and conditions of this Policy, the data subject hereby confirms that the personal data he/she has provided is accurate. The Company proceeds on the assumption that the data subject submits accurate and sufficient personal data and keeps such data up-to-date.
8.6. By using the Sites, the data subject agrees with the above procedure for, and conditions of, personal data to be processed.
9. Final provisions
9.1. Contact details for data subjects to file a request concerning the Company’s processing of personal data:
- mailing address: building 5, 39 Leningradskaya Street, Khimki, Moscow Region, 141402 Russia,
- email address: firstname.lastname@example.org.
9.2. The current version of the Policy is published on the Internet and is available to any data subject at the address: https://www.volvocars.com/ru/legal/privacy.