PERSONAL DATA PROCESSING POLICY (online service)
Edition 1.0
Publication date: December 22, 2025
The document is posted on the website: https://etuners.ru/
This Policy defines the procedure for processing and protecting personal data when using the Contractor's online service.
1. General provisions
1.1. This Policy has been developed in accordance with the Federal Law of the Russian Federation No. 152-FZ "On Personal Data". 1.2. The Policy applies exclusively to the processing of personal data when using the online service, access to which is provided by login and password.
1.3. The use of the online service means the user's consent to this Policy.
2. Personal data operator Operator: Individual entrepreneur Basov Ruslan Alexandrovich INN 772023977720/ OGRNIP 320774600190363 Address: Moscow, Nikolaya Starostina St., d11kv12 Email for inquiries: support@etunersrussia.ru
3. Categories of personal data subjects Within the online service, personal data of the following categories of individuals is processed:
3.1. Dealers – individuals, individual entrepreneurs, representatives of legal entities registered in the system.
3.2. End clients of dealers, whose personal data is transmitted by dealers when processing applications.
4. Categories of processed personal data
4.1. Dealer data • Full name • phone number • email address • account data (login, password hash) • IP address, date and time of login
4.2. Data of end clients of dealers • name / designation of the client • VIN and other vehicle identifiers • contact details (if provided by the dealer) ⚠ Passport data and special categories of personal data are not processed.
5. Purposes of processing personal data Personal data is processed exclusively for the purposes of:
• registration and identification of dealers;
• providing access to the online service;
• receiving and processing applications;
• fulfilling contractual obligations;
• generating documents;
• ensuring the security of the service.
6. Legal grounds for processing
6.1. Personal data of dealers is processed on the basis of: • a contract with the dealer; • consent to the processing of personal data.
6.2. Personal data of end clients of dealers is processed on behalf of the dealer.
6.3. The dealer guarantees the presence of all necessary consents of personal data subjects for their transfer and processing.
7. Procedure and conditions for processing personal data
7.1. The processing of personal data is carried out using automation tools.
7.2. Personal data is stored exclusively on the servers of the online service.
7.3. Access to personal data is provided: • only by authorized users; • by individual login and password.
7.4. Transfer of personal data to third parties is not carried out, except in cases provided for by the legislation of the Russian Federation.
8. Measures to protect personal data The operator applies the necessary organizational and technical measures of protection, including: • access rights differentiation; • account protection by passwords; • access control to data; • prevention of unauthorized access.
9. Storage periods for personal data
9.1. Personal data is stored for the duration of the contractual relationship, as well as for the periods established by the legislation of the Russian Federation.
9.2. Upon achieving the purposes of processing, personal data is subject to deletion or anonymization.
10. Rights of personal data subjects The personal data subject has the right to:
• receive information about the processing of their data;
• require clarification or deletion of data;
• withdraw consent to the processing of personal data.
Requests are sent to the email address specified in section 2.
11. Final provisions
11.1. This Policy applies in the edition in force at the time of using the online service.
11.2. The operator has the right to make changes to the Policy. The new edition is subject to posting on the website.