Personal Data Processing Policy

1. General provisions

1.1. This Personal Data Processing Policy (the Policy) sets out the procedures for processing and protecting the personal data of individuals who use the TruckPart website, contact the company by phone or email, or interact with the company under contractual arrangements.

1.2. This Policy has been developed in accordance with the Constitution of the Russian Federation, Federal Law No. 152-FZ of 27.07.2006 On Personal Data, and other Russian legislation governing personal data.

1.3. This Policy applies to all information that the controller may obtain about website visitors and other data subjects in the course of its activities.

1.4. By using the website and submitting your data through contact forms, you confirm that you have read this Policy and accept its terms.

2. Terms and definitions

• Personal data — any information relating directly or indirectly to an identified or identifiable individual (data subject).
• Controller — a legal entity that, independently or jointly with others, organises and/or carries out personal data processing and determines its purposes, the data to be processed and the operations performed on them.
• Personal data processing — any operation or set of operations involving personal data, performed by automated or non-automated means: collection, recording, organisation, accumulation, storage, updating (amendment, modification), retrieval, use, transfer (disclosure, access), anonymisation, blocking, deletion and destruction.
• Data subject — the individual to whom the personal data relate.
• Automated processing — processing of personal data using computing equipment.
• Anonymisation — operations that make it impossible to attribute personal data to a specific data subject without additional information.
• Destruction of personal data — operations that make it impossible to restore the contents of personal data and/or destroy physical media containing personal data.
• Website — a collection of pages published on the Internet under the domain name of the TruckPart website.

3. The controller and its details

The personal data controller is:

Details of the person responsible for organising personal data processing at the controller are available upon request using the contact details above.

4. Purposes of personal data processing

The controller processes personal data solely for predetermined and lawful purposes:

• handling and responding to enquiries and requests received through website forms, by phone or by email;
• advising on products and selecting filters by part number, cross-reference number and equipment model;
• providing information about nearby dealers and product suppliers;
• preparing, entering into and performing contracts, and settling payments under them;
• fulfilling the controller's obligations under the laws of the Russian Federation;
• collecting anonymised website visitor statistics to improve its operation and usability, subject to your consent to analytics cookies.

The controller does not process personal data for purposes incompatible with those listed above.

5. Legal bases for processing

The legal bases for personal data processing are:

• the data subject's consent to personal data processing (Clause 1, Part 1, Article 6 of Federal Law No. 152-FZ) — the consent form is available on the page «Consent to Personal Data Processing»;
• the need to perform a contract to which the data subject is a party, or to take steps to enter into a contract at the data subject's initiative (Clause 5, Part 1, Article 6 of Federal Law No. 152-FZ);
• the need to fulfil obligations imposed on the controller by the laws of the Russian Federation (Clause 2, Part 1, Article 6 of Federal Law No. 152-FZ);
• the controller's constituent documents and contracts entered into with counterparties.

6. Categories of personal data processed

6.1. Data you provide yourself

• surname, first name and patronymic (or how you prefer to be addressed);
• contact phone number;
• email address;
• organisation name and position, if you provide them voluntarily;
• the contents of your enquiry and any information you choose to include in your message.

6.2. Data collected automatically

• information sent by the browser: IP address, browser type and version, device type and operating system, interface language and screen resolution;
• date and time of access to the website, addresses of visited pages and the referring page address;
• cookie identifiers — their use is described in the Cookie Policy.

Automatically collected data are processed in anonymised form and used to compile visitor statistics. Analytics cookies are enabled only after you click Accept in the website consent banner.

6.3. Data the controller does not process

The controller does not process special categories of personal data concerning race, ethnicity, political opinions, religious or philosophical beliefs, health or intimate life, or biometric personal data.

The controller does not process the personal data of minors. The website is not intended for persons under 18 years of age.

7. Processing procedures, conditions and periods

7.1. Personal data are processed both by automated and non-automated means. Processing includes collection, recording, organisation, accumulation, storage, updating, retrieval, use, transfer, anonymisation, blocking, deletion and destruction of personal data.

7.2. Personal data processing is limited to achieving specific, predetermined and lawful purposes. Only data relevant to the stated purposes are processed, and the volume of data is not excessive in relation to those purposes.

7.3. The controller ensures that personal data of citizens of the Russian Federation are recorded, organised, accumulated, stored, updated and retrieved using databases located within the Russian Federation, in accordance with Part 5 of Article 18 of Federal Law No. 152-FZ.

7.4. Personal data are retained in a form that identifies the data subject for no longer than required by the purposes of processing, unless a retention period is prescribed by federal law or contract.

7.5. Personal data must be destroyed or anonymised once the purposes of processing have been achieved, when those purposes are no longer relevant, or when consent is withdrawn, unless the controller is entitled to continue processing on another legal basis.

Specific retention periods for individual categories of personal data are determined by the controller's internal documents and Russian legal requirements, and are provided upon a data subject's request.

8. Transfer of personal data

8.1. The controller does not sell or disclose personal data to third parties, except as expressly provided in this Policy and the laws of the Russian Federation.

8.2. Personal data may be transferred to:

• authorised government bodies, on the grounds and under the procedures prescribed by the laws of the Russian Federation;
• parties engaged by the controller to process personal data on its behalf, under a contract requiring confidentiality and security of personal data during processing;
• the controller's dealers and partners, only to the extent needed to respond to your enquiry about purchasing products and only with your consent.

8.3. This Policy does not govern cross-border transfers of personal data.

9. Personal data protection measures

The controller takes the necessary legal, organisational and technical measures to protect personal data against unlawful or accidental access, destruction, alteration, blocking, copying, disclosure, dissemination and other unlawful actions, including:

• appoints a person responsible for organising personal data processing;
• adopts internal policies governing the processing and protection of personal data;
• restricts access to personal data to employees who need it to perform their duties;
• uses information security and access control measures, including a secure connection when transmitting data from the website;
• carries out internal checks to ensure that personal data processing complies with legal requirements.

10. Rights of the data subject

You have the right to:

• receive information about the processing of your personal data, including confirmation of processing, its legal bases and purposes, the data processed, processing and retention periods, and the persons to whom data may be transferred;
• request that your personal data be updated, blocked or destroyed if they are incomplete, outdated, inaccurate, unlawfully obtained or unnecessary for the stated purpose of processing;
• withdraw previously given consent to personal data processing;
• object to processing of your personal data for promoting goods and services;
• appeal the controller's actions or omissions to the authorised data protection authority (Roskomnadzor) or through the courts;
• protect your rights and legitimate interests, including claiming damages and compensation for non-material harm through the courts.

To exercise your rights, send a request to office@truckpart.info. Your request must include information identifying you as the data subject or their representative, as well as the signature of the data subject or representative.

11. Withdrawing consent

11.1. Consent to personal data processing may be withdrawn at any time.

11.2. To withdraw your consent, send a written notice in any format:

• to the email address office@truckpart.info;
• or by post to: Rostov Region, Chaltyr, Industrial Zone 1, Plot 28.

11.3. In your notice, include your surname, first name, patronymic, the contact details you previously provided to the controller, and a request to stop processing your personal data.

11.4. Upon receiving a withdrawal notice, the controller stops processing personal data and ensures their destruction within the period specified in Part 5 of Article 21 of Federal Law No. 152-FZ, unless retention is required for purposes prescribed by law or for performance of an existing contract.

11.5. Consent to analytics cookies can be withdrawn on the website — see How to change your choice in the Cookie Policy.

12. Requests and contact details

For any questions about personal data processing, you can contact the controller:

• by email: office@truckpart.info;
• by phone: 8-800-333-24-30 (toll-free within Russia), 8 (863) 333-42-10;
• by post: Rostov Region, Chaltyr, Industrial Zone 1, Plot 28.

A response is sent in a format corresponding to that of the request, within the periods prescribed by Federal Law No. 152-FZ.

13. Final provisions

13.1. This Policy is a public document available freely on the controller's website.

13.2. The controller may amend this Policy. The current version is always published on this page. We recommend reviewing it periodically.

13.3. This Policy and the relationship between you and the controller are governed by the laws of the Russian Federation.