Privacy and Cookie Policy
Privacy and Cookie Policy
XXXXX (hereinafter referred to as "we" or "our Company") fully recognizes the importance of privacy to you and makes every effort to protect your personal data and privacy of your personal life.
This Privacy Notice (hereinafter referred to as the "Notice" or "Policy") explains how we process your personal data, and it may not cover all data processing activities.
To deliver high-quality products and services to you, we shall collect, use, transmit, store and protect your personal data in compliance with this Policy.
Please carefully read and fully understand this Policy before visiting our official website and related web pages. By continuing to browse the website, you confirm that you acknowledge and agree to our collection, processing and use of your personal data in accordance with this Policy. If you have any questions, complaints or suggestions, please contact us via the methods specified below.
This Policy is designed to help you understand the following matters:
How we collect and use your personal data
Use of Cookies and similar technologies
Transmission, assignment and disclosure of personal data
Storage and protection of personal data
Your rights relating to personal data
Protection of personal data of minors
Contact information
Updates to this Policy
I. How We Collect and Use Your Personal Data
1.1 Scope of Collected Personal Data
We only collect the minimum personal data necessary for the operation of our official website. The main collection scenarios and relevant information are as follows:
User Reservation Scenario:When you submit applications for test drive, consultation, reservation and other services, we collect the information you voluntarily provide, including your name, mobile phone number, email address, postal address, selected vehicle model, preferred dealer center and other related information.
Website Browsing Scenario:To optimize your browsing experience and ensure service security, our servers automatically record your browsing activities, including visited pages, browsing duration, device information (device model, operating system, browser type), IP address, access time and other non-identifiable information.
If you participate in brand activities or fill out questionnaires on our website, we will collect the information you provide voluntarily, such as data for lucky draws, feedback and comments.
1.2 Purposes of Using Personal Data
We use the collected personal data solely for the following legitimate and proper purposes, and shall not exceed the scope stated at the time of collection:
Provide reservation services, assign dedicated account managers or sales specialists to contact you, and respond to your inquiries about vehicles, vehicle purchase and after-sales services;
Send you updates on vehicles, brand events and exclusive offers published on our official website (you may unsubscribe at any time);
Optimize the operation of the website and improve user experience, analyze browsing habits, and enhance vehicle display, page design and other contents;
Ensure the safe and stable operation of the website and prevent fraud and unauthorized access;
Comply with the laws and regulations of the Russian Federation and fulfill statutory obligations.
1.3 Exceptional Circumstances
In the following cases, we do not need to obtain your additional consent for the collection and processing of personal data:
It is necessary for the performance of a service contract concluded between you and us (e.g. reservation and consultation services);
It is necessary to comply with Federal Law No. 152-FZ On Personal Data and other regulatory requirements;
It is necessary to respond to emergencies and protect the life, health and property of natural persons;
Processing of publicly available personal data within reasonable limits for public interests, such as journalistic investigations and public supervision;
Other circumstances stipulated by the laws of the Russian Federation.
II. Use of Cookies and Similar Technologies
To enhance your browsing experience on our official website, we use Cookies and similar technologies, such as web storage and pixel tags:
2.1 Purposes of Cookies:A Cookie is a small text file stored in the browser of your device. Its main functions are as follows:
Save your preferences, maintain login status (if applicable) and avoid repeated information entry;
Analyze website traffic and user behavior to optimize page structure, content and service functions;
Prevent unauthorized access and ensure website security.
2.2 Cookie Management:You may manage the above technologies via your browser settings, including clearing Cookies or disabling the Cookie function. Please note that disabling or clearing Cookies may affect the normal use of some website functions, such as form filling and page loading. We recommend keeping Cookies enabled for the best experience.
III. Transmission, Assignment and Disclosure of Personal Data
We strictly abide by the personal data protection laws of the Russian Federation. We will not transmit, assign or disclose your personal data to unrelated third parties except for the following cases:
3.1 Transmission to Necessary Third Parties:To provide reservation, after-sales support and other services, we transmit necessary personal data to third-party service providers, including:
Partners responsible for reservation arrangement and customer service;
Suppliers providing website technical support and data storage services.
All the aforesaid third parties shall sign a confidentiality agreement with us. They may only use your personal data for agreed purposes and shall not use it for any other intentions.
3.2 Disclosure Required by Law:If judicial or supervisory authorities of the Russian Federation require us to disclose your personal data in accordance with legal procedures, we shall comply with relevant laws. We will notify you of such disclosure where permitted by regulations.
3.3 Change of Company Ownership:In the event of merger, acquisition, reorganization, bankruptcy or other changes of ownership, your personal data will be transferred to the new owner. We will post a notice on the homepage in advance to announce the name and contact information of the new owner, who shall continue to comply with this Policy.
IV. Storage and Protection of Personal Data
4.1 Data Retention Period
We retain your personal data only for the period necessary to achieve the purposes set out in this Policy. The specific retention period is determined by us based on actual circumstances. When the personal data is no longer needed, we will securely delete or anonymize it to ensure it can no longer identify an individual.
4.2 Data Storage Location
All personal data collected through our official website is stored on servers located within the territory of the Russian Federation, fully complying with the data localization requirements of Federal Law No. 152-FZ On Personal Data. We will not transfer data outside the Russian Federation without prior permission.
4.3 Security Protection Measures
We adopt comprehensive security measures to protect your personal data from unauthorized access, alteration, disclosure and destruction:
Apply encryption technologies for the storage and transmission of personal data to ensure data security;
Establish a strict access control system. Only authorized staff can access personal data and shall bear confidentiality obligations;
Conduct regular security inspections on website systems and servers, fix vulnerabilities and prevent network attacks and virus intrusions;
Set up a security incident response mechanism. In case of personal data leakage, we will immediately launch emergency procedures and notify you via website announcements, SMS and other channels.
V. Your Rights in Respect of Personal Data
In accordance with Federal Law No. 152-FZ On Personal Data of the Russian Federation, you are entitled to the following rights. You may exercise these rights at any time by contacting us via the information provided at the end of this document.
Right of Access:Request us to inform you of the ways of personal data processing and provide you with a copy of your personal data;
Right to Rectification:Request us to correct or supplement your personal data if it is incomplete or inaccurate;
Right to Erasure:Request us to delete your personal data when it is no longer needed or when you withdraw your consent to processing;
Right to Withdraw Consent:You may withdraw your consent to personal data processing at any time. After withdrawal, we will terminate relevant processing activities, which may affect your access to corresponding services;
Right to Restriction of Processing:Request us to suspend the processing of your personal data temporarily if there is a dispute over data processing;
Right to Data Portability:Request us to provide your personal data in a structured, machine-readable format to yourself or a designated third party.
How to Exercise Your Rights
Please contact us via the methods below to exercise the above rights. After verifying your identity, we will respond to your request within 15 working days. If you are dissatisfied with our response, you may file a complaint with Roskomnadzor, the Federal Service for Supervision of Communications, Information Technology and Mass Media of the Russian Federation.
VI. Protection of Personal Data of Minors
We attach great importance to the protection of personal data of minors. If you are under the age of 18, please visit our website and submit personal data only under the supervision and guidance of your parents or legal guardians.
If we discover that personal data of a minor has been collected without the consent of their legal representatives, we will delete such data immediately. If you are the legal representative of a minor and have inquiries about data processing, please contact us via the methods specified below.
VII. Contact Information
If you have questions, suggestions or need to exercise your rights relating to personal data, please contact us through the following channels:
Email:XXXXX
Phone:XXXXX
Legal Address:XXXXX
We will respond to your request promptly and provide professional assistance and consultation.
VIII. Updates to This Policy
We may revise this Policy due to website service upgrades, changes in laws and regulations and other reasons. In case of material amendments (such as adjustment of data collection scope, processing purposes or third-party partners), we will post a prominent notice on the homepage to specify the revised contents and effective date.
The revised Policy shall take effect on the date the notice is published. We will not materially reduce your rights stipulated in this Policy without your explicit consent.
