Pilot Telematics has developed the Policy on Processing and Protection of Personal Data (hereinafter, the "Policy").

1. Basic concepts used in this Policy:
2. Website - the Operator's website containing the Base at: https://garm24.com/, including all subdomains.
3. Personal Data Operator (Operator) Kvadrat Systems L.L.S, which independently organizes and (or) carries out the processing of Personal Data, defines the purpose of the Processing, and the composition, actions (operations) performed with Personal Data.
4. User - a natural person, the subject of Personal Data.
5. Personal Data - any information relating to a directly or indirectly defined or identifiable User.
6. Processing of Personal Data (Processing) - any action (operation) or a set of actions (operations) with Personal Data, performed with or without the use of automation tools. Processing includes, but is not limited to: collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction.
7. Automated Processing - processing of Personal Data by means of computer technology.
8. Dissemination of Personal Data - actions aimed at disclosure of Personal Data to an indefinite circle of persons.
9. Provision of Personal Data - actions aimed at disclosure of Personal Data to a certain person or a certain circle of persons.
10. Blocking of Personal Data means temporary termination of processing of Personal Data (unless processing is necessary for their clarification).
11. Destruction of Personal Data means actions as a result of which it becomes impossible to restore the content of Personal Data in the Database and (or) as a result of which tangible carriers of Personal Data are destroyed.
12. Depersonalization of Personal Data - actions, as a result of which it becomes impossible, without the use of additional information, to determine whether Personal Data belongs to a particular User.
13. Cross-border transfer of Personal Data means transfer of Personal Data to the territory of a foreign country to a foreign authority, a foreign individual or a foreign legal entity.

1. General Provisions
2. This policy is a local document of the Operator, which defines the order of processing and protection of Personal data, Users, using the Site (including sub-domains).
3. This Policy has been developed in accordance with the laws and other laws and regulations governing the handling of Personal Data and its security requirements.
4. The purpose of the Policy is to ensure protection of human and civil rights and freedoms in the processing of their Personal Data, including protection of the rights to privacy, personal and family secrets, clear and strict compliance with the requirements of Russian legislation in the field of Personal Data.
5. This Policy applies to all Personal Data processed by the Operator with and without the use of automated means.
6. The Policy applies to all Personal Data processed by the Operator with and without the use of automated means.
7. The Operator publishes the Policy on the Internet at: https://garm24.com/ , and provides unrestricted access to it to anyone who applies in person.
8. The operator has the right to make changes to the Policy. The current revision specifies the date of the last update. The new version of the Policy becomes effective as soon as it is posted on the Website.
9. The User agrees to the terms of the Policy by registering on the Site or by clicking the "Submit" button on the page of the Site on which the form that the User fills out is located.

1. Legal basis for processing of Personal Data
2. The legal basis for the processing of Personal Data is the User's consent to the processing of Personal Data.

1. Purposes of Personal Data collection
2. The purpose of processing Personal Data is to fulfill the Operator's obligations to the User under the relevant contracts, including:
3. Registration and identification on the Site;
4. Establishing and maintaining contact with the User;
5. Sending messages of informational and other nature, including by subscription;
6. Prevention of fraud and other abuses, as well as for investigation of such cases;
7. Statistical and other research, as well as for targeting (selecting the target audience) of advertisements placed on the Site on the basis of the Depersonalized Data;
8. Resolving disputes, collecting feedback and identifying faults;
9. Improving the quality of the Site, its usability and development of new functionality.
10. Compliance with the requirements of Russian legislation.

1. Composition of Processed Personal Data
2. In order to register and identify the User, the Operator processes the following Personal Data: last name, first name, patronymic, cell phone number, email address. In order to establish and maintain contact with the User and to send him messages, the following Personal Data is processed: last name, first name, phone numbers and email address.
3. For other purposes specified in Section 5 of the Policy, any User data entered by the User in the web forms of the Site may be used.
4. Other information processed by Operator:
5. data about technical means (devices): IP address, type of operating system, browser type, geographic location, Internet service provider.
6. information about the use of the Site (including information about pages visited, transfers from other resources).
7. information automatically obtained when you access the Site, including through the use of cookies;
8. information received as a result of the User's actions, including the following information: about the sent requests, feedback and questions.

Principles of Personal Data Processing
The Operator processes Personal Data on the basis of the following principles:

1. The lawful and fair basis for Processing Personal Data.
2. Processing of Personal Data in accordance with specific, predetermined and legitimate purposes.
3. Avoid combining databases containing Personal Data whose Processing is incompatible with each other.
4. Compliance of the content and scope of Personal Data with the stated purposes of Processing.
5. Accuracy, adequacy, relevance and reliability of Personal Data.
6. Legality of technical measures aimed at the Processing of Personal Data.
7. The reasonableness and expediency of the processing of Personal Data.
8. Storage of Personal Data no longer than required by the purposes of its Processing or during the period of the User's consent.
9. Processed Personal Data is subject to Destruction or Depersonalization: after 12 (twelve) months after the goals of processing, if it is no longer necessary to achieve them, or upon withdrawal of consent to the processing of Personal Data.

1. Procedure and conditions of Personal Data Processing
2. Personal Data is collected in the following ways:
3. Submission by Users when filling out web forms on the Site;
4. Automatic collection of information about the User using technologies and services: web-protocols, cookies, web-tags, which run only when you enter data.
5. Storage of Personal Data
6. Personal Data is stored only on electronic media and automated processing is applied, except when non-automated processing of Personal Data is necessary
7. Storage of Personal Data shall be in a form that makes it possible to identify the subject, no longer than required by the purposes of Processing, unless the period of storage is established by federal law, the contract, to which the User is a party.
8. The period of placement of Personal Data in the Resume or personal account on the Site is unlimited and is determined by the User.
9. Transfer of Personal Data
10. The Operator shall not distribute and provide Personal Data to third parties without the written consent of the User, except when they are publicly available or it is necessary to prevent threats to life and health, prevent, stop illegal actions of the User and protect the legitimate interests of the Operator and third parties.
11. Upon reasonable request, Personal Data may be provided without the consent of the User:

• To judicial authorities in connection with the administration of justice;
• to state security bodies;
• to prosecution authorities;
• to police authorities;
• Investigative authorities;
• other bodies and organizations in the cases established by normative legal acts, mandatory for execution

1. If Personal Data is provided, the Operator warns the recipients that this data may be used only for the purposes for which it is communicated.
2. Updating, correction, destruction of Personal Data.
3. If it is confirmed that Personal Data is inaccurate, it must be updated by the Operator.
4. Destruction shall be performed in the following cases:

• existence of a threat to the security of the Site;
• expiration of the storage period of Personal Data;
• at the request of a user

1. Blocking of Personal Data. The Operator reserves the right to temporarily discontinue Processing (unless Processing is necessary to clarify Personal Data).
2. User's rights
3. The User has the right to receive information about the Processing, including
4. confirmation of the fact of the Processing;
5. The legal grounds for the Processing;
6. The objectives and methods of Processing used by the Operator;
7. Processed Personal Data pertaining to the relevant User, the source of their receipt, unless another procedure for presentation of such data is stipulated by law
8. the terms of Processing, including the terms of storage of Personal Data;
9. information about the cross-border data transfer that has taken place or is expected to take place;
10. the name or full name and address of the person performing the Processing on behalf of the Operator, if the Processing is or will be assigned to such person;
11. The User may receive the information specified in this section of the Policy an unlimited number of times by submitting a corresponding request to the Operator.

Operator Duties

1. The operator is obliged:
2. Provide, at the request of the User, the information about the processing of his Personal Data specified in clause 9.1. Policy, or a reasonable refusal to do so;
3. Take the measures necessary and sufficient to ensure the fulfillment of obligations stipulated by law
4. At the request of the User, clarify the processed Personal Data, block or delete it if it is incomplete, outdated, inaccurate, illegally obtained or unnecessary for the stated purpose of processing;
5. Ensure the lawfulness of the Processing of Personal Data. If it is impossible to ensure the legitimacy of Processing, the Operator shall destroy or ensure the destruction of the Personal Data within 10 (ten) business days from the date of detection of unlawful Processing;
6. In case of revocation of the User's consent to processing of Personal Data, to stop processing and destroy them within a period not exceeding 30 (thirty) days from the date of receipt of the said revocation, except when the Processing may be continued in accordance with the legislation

1. Measures to ensure the protection of Personal Data
2. Legal measures include:
3. Development by the Operator of local documents implementing the requirements of the Russian legislation, including - the Policy with regard to processing and protection of personal data, and its placement in the relevant section of the Website;
4. Refusal from any ways of Processing that do not correspond to the purposes predetermined by the Operator.
5. Organizational measures include:
6. appointment of a person responsible for the organization of the Processing;
7. Restricting the composition of the Operator's employees, who have access to Personal Data, and organizing a permissive system of access to it;
8. Instruction and familiarization of the Operator's employees engaged in the Processing with normative legal acts, with the Operator's local acts regulating the procedure of work and protection of Personal Data;
9. Conducting periodic inspections in order to carry out internal control over the compliance of the Processing with the established legal requirements
10. Measures of a technical nature aimed at:
11. prevention of unauthorized access to the systems in which Personal Data are stored;
12. Backup and recovery of Personal Data, operability of technical means and software, information protection means in information systems of Personal Data;
13. other necessary security measures.

1. Limitation of this Policy
2. This Policy applies only to the Site and does not apply to other Internet resources.
3. The User must be reasonable and responsible in placing his or her own Personal Data on the Site in the public domain.

1. Limitations of liability
2. The Operator doesn't bear responsibility for the confidentiality preservation and/or usage of the Personal information which was independently distributed or presented by the User to the third parties with which the Operator doesn't have any contracts concluded.
3. The Operator doesn't bear responsibility for the actions of the third parties who have got access to the Personal information of the User through the fault of the latter.
4. The Operator doesn't bear responsibility for the possible non-purposeful use of the Users' personal data which took place because of the technical malfunction in the software, servers or computer networks which are out of the Operator's control.

1. Procedure for consideration of the User's appeals
2. The User shall be entitled to send his appeals/requests to the Operator, including requests regarding the Processing: in the form of an electronic document to the e-mail address: info@pilot-telematics.com
3. The request must contain the following information:
4. information about the User's identity document;
5. Information confirming the User's participation in the relationship with the Operator;
6. the User's signature.
7. The Operator undertakes to consider and reply to the received request within 5 (five) working days from the moment of receipt of the request.