Personal Data Processing Policy

  1. General provisions
    1. The present policy of personal data processing is made following the requirements of the Federal Law dated 27.07.2006. No. 152-FL “On Personal Data” and defines the procedure of processing personal data and measures to ensure the security of personal data taken by Pugachev Luxury Car Rental (hereinafter – the Operator).
    2. The Operator sets the respect of human and citizen’s rights and freedoms in the process of personal data processing as its most important goal and condition for carrying out its activity, including the protection of rights to privacy, personal and a family secret.
    3. This policy of the Operator regarding personal data processing (hereinafter referred to as the Policy) applies to all information that the Operator can obtain about visitors of the website
  2. The main definitions used in the Policy
    1. Automated processing of personal data – processing using computer technology.
    2. Personal data blocking – temporary cessation of personal data processing (except for cases when processing is necessary to clarify personal data).
    3. Website – a set of graphic and information materials, as well as computer programs and databases that ensure their availability on the Internet at
    4. Personal data information system – a complex of personal data contained in databases and ensuring their processing of information technologies and technical means.
    5. Personal data depersonalization – actions that make it impossible to determine the belonging of personal data to a specific User or other personal data subjects without using additional information.
    6. Personal data processing – any action (operation) or set of actions (operations) performed with or without the use of automation means with personal data, including collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
    7. Operator – a state authority, a municipal authority, a legal entity or an individual, which independently or together with other persons organize and (or) carry out the processing of personal data, as well as determine the purposes of personal data processing, the composition of personal data to be processed, actions (operations) performed with personal data.
    8. Personal data – any information related directly or indirectly to the User of the website
    9. User – any visitor of the website.
    10. Provision of personal data – actions aimed at disclosing personal data to a certain person or a certain group of persons.
    11. Dissemination of personal data – any actions aimed at disclosure of personal data to an indefinite group of persons (transfer of personal data) or at familiarization with personal data of an unlimited number of people, including personal data publication in mass media, placement in the information, and telecommunication networks or providing access to them in any other way.
    12. Transboundary transfer of personal data – transmission of personal data on the territory of a foreign state to a foreign authority, foreign individual, or foreign legal entity.
    13. Destruction of personal data – any actions that lead to the data deletion with the impossibility of further restoration of personal content in the information system of personal data and (or) destruction of material personal data carriers.
  3. The Operator may process the following personal data of the User
    1. Surname, first name, patronymic;
    2. E-mail address;
    3. Phone numbers;
    4. The site also collects and processes impersonal data about visitors (including “cookies”) using Internet statistics services (Yandex Metrica, Google Analytics, and others).
    5. The above-mentioned data further in the text of the Policy are united in the general concept of Personal Data.
  4. Purposes of personal data processing
    1. The purpose of processing the User’s data is to inform him or her by sending emails; provide the User with access to the services, information, and/or materials contained on the website.
    2. The Operator is also entitled to send notifications to the User about new products and services, special offers, and various events. The User can always refuse to receive information messages, by sending a letter to the Operator at [email protected] with a text “Refusal to notify about new products, services, and special offers”.
    3. Impersonalized data of the Users, collected using the Internet-statistics services, are used to get information about the Users’ actions at the website, improve the quality of the site and its content.
  5. Legal grounds for personal data processing
    1. The Operator processes User’s data only in case of filling in and\or sending them by the User himself or via special companies on the site Filling in the corresponding forms and\or sending personal data to the Operator, the User agrees to the given policy.
    2. The Operator handles impersonal data about the User only if it is stipulated in the settings of the User’s browser (it is switched on saving “cookie” files and using the JavaScript technology).
  6. The order of collecting, saving, transmitting information, and other ways of personal data processing
    1. Personal data security handled by the Operator is provided by the implementation of legal, organizational, and technical measures necessary for meeting the requirements of the current legislation in the field of personal data protection.
    2. The Operator keeps the personal data safe and takes all means to avoid the access of unauthorized persons to them.
    3. User’s data will never, under no circumstances, be transferred to third parties, except for the cases according to the current legislation.
    4. In case of finding some drawbacks in the personal data, the User can update them independently, by sending a letter to the Operator’s email address [email protected] with the note “Updating of personal data“.
    5. The term of personal data processing is unlimited. The User can withdraw his consent to the processing of personal data by sending a notice by email to the Operator’s email address [email protected] with the note “Withdrawing the consent to the processing of personal data” at any moment.
  7. Cross-border transfer of personal data
    1. Before cross-border transferring personal data, the Operator must be convinced that the foreign country where the data are transmitted ensures the reliable protection of the personal data subjects’ rights.
    2. Transborder transfer of personal data on the territory of foreign states which do not meet the above-mentioned requirements can be carried out only if the personal data subject has consented in writing to the transboundary transfer of his data and/or execution of the contract where the personal data subject is one of the parties.
  8. Concluding provisions
    1. The User can get any explanations on any questions concerning the processing of his data by contacting the Operator by email [email protected].
    2. This document will reflect any changes in the policy of personal data processing by the Operator. The policy is valid indefinitely until it is replaced by a new version.
    3. The current version of the Policy with free access is available on the Internet at

Mark Pugachev

contact ico pugachev service contact ico pugachev service contact ico pugachev service contact ico pugachev service