Cookie Processing Policy

1. GENERAL PROVISIONS

1.1. This Cookie Processing Policy is developed in compliance with the requirements of the Law of the Republic of Belarus of May 7, 2021, No. 99-Z "On Personal Data Protection" and is one of the measures to protect the personal data of users of the carlux.by information resource (hereinafter referred to as the Site), owned by LLC "ELVILEMAR" (Minsk, Mayakovskogo St., 111-509).
1.2. Cookies are small data fragments that are transmitted and stored on the user's device (computer, smartphone, tablet, or smartwatch) when visiting the Site. With these files, the Site remembers information about the user and his device, including storing personal preferences and settings, and also "recognizes" the user and his device during subsequent visits to the Site.
1.3. Cookies are processed by LLC "ELVILEMAR" for the purposes of:
1.3.1. proper functioning of the Site (including allowing the user not to re-enter previously filled access parameters to the Site);
1.3.2. ensuring the security of Site users (for example, recognizing malicious users (bots));
1.3.3. collecting analytical information in aggregate form to assess and further improve the Site's performance;
1.3.4. creating and providing personalized marketing and advertising materials.
1.4. LLC "ELVILEMAR" does not use cookies to identify a specific Site user.

2. WHAT INFORMATION ABOUT SITE USERS WE COLLECT

2.1. Information obtained using cookies may include:
the date and time of the Site visit;
the duration of the session when visiting the Site;
information about the Site pages visited by the user;
the number of visits by the user to the Site during the month;
the URL file viewed by the user, as well as information related to it;
information about the information resource from which the user came to the Site;
information about the operating system and browser used by the user's device.

3. WHAT COOKIES WE USE

3.1. The following types of cookies are used on the Site:
technical (mandatory);
analytical;
advertising (marketing).
3.2. Technical (mandatory) cookies are required to ensure the proper functioning of the Site, including the correct use of the features offered on it, as well as to remember individual user settings (language, etc.). These cookies do not store any information about the user that can be used for advertising (marketing) purposes or to assess their behavior on the Site. Such data is not transmitted to third-party analytical systems.
3.3. Analytical cookies allow assessing how users interact with the Site, including counting the number and duration of visits to the Site, understanding how users arrived at the Site, which pages of the Site they visited, etc., which helps improve the Site's performance and make it more user-friendly.
3.4. Advertising (marketing) cookies are used to provide users with personalized marketing and advertising materials based on their interests, as well as information about the pages visited by users, including on other information resources.
3.5. Depending on the storage periods, LLC "ELVILEMAR" uses session and persistent cookies. Session cookies are stored only during the browser session. Persistent cookies are stored for the time specified in the cookie settings or until they are deleted by the user.
3.6. Depending on who sets (generates) the cookies, they are divided into own, which are set (generated) by LLC "ELVILEMAR", and third-party, which are formed by third parties and used by us as a tool for analyzing user interaction with the Site, as well as setting relevant to the user's interests marketing and advertising materials.
3.7. The list of used cookies with an indication of their functional purpose and storage periods is provided in the appendix to this Policy.

4. WHO WE SHARE SITE USERS' INFORMATION COLLECTED USING COOKIES WITH

4.1. To achieve the objectives specified in sub-items 1.3.3 and 1.3.4 of item 1.3 of this Policy, LLC "ELVILEMAR" transfers information collected using analytical and advertising (marketing) cookies to the following third parties, who are engaged by us for cookie processing and who implement sufficient measures to protect personal data:

LLC "Yandex". Address: Russian Federation, 119021, Moscow, Lev Tolstoy St., 16.
Privacy Policy.
Terms of Use of Yandex.Metrica and AppMetrica services.
Yandex.Metrica Data Processing Agreement (DPA).

Google, Inc. Address: 1600 Amphitheatre Parkway Mountain View, California 94043, USA.
Privacy Policy.
Terms of Use of Google services.
Google Ads Data Protection Terms: Service Information.
Google Ads Data Processing Terms.

LLC "Mindbox". Address: Russian Federation, 125124, Moscow, Pravdy St., 26.
Personal Data Processing Policy.
Terms of Use of Mindbox service.

Meta Payments Inc. Address: 1601 Willow Road, Menlo Park, California 94025, USA.
Privacy Policy.
Data Processing Terms.
Data Security Terms.

JSC "1C-Bitrix". Address: Republic of Belarus, 220035, Minsk, Pobediteley Ave., 59, office 202.
Personal Data Processing Policy.
Order for Personal Data Processing.

5. DO WE CONDUCT CROSS-BORDER TRANSFER OF INFORMATION COLLECTED USING COOKIES

5.1. LLC "ELVILEMAR", using third-party cookies provided by third parties mentioned in section 4 of this Policy, conducts cross-border data transfer not related to the identification of a specific user.
5.2. Cross-border transfer of information from cookies is carried out to countries that ensure an adequate level of protection of personal data subjects' rights.
5.3. Within the framework of the Google Analytics web analytics service, LLC "ELVILEMAR" may conduct cross-border transfer of aggregated (combined into a general array of data about users based on their behavioral characteristics) data, not related to the identification of a specific user, to Google, Inc. servers located in countries that do not ensure an adequate level of protection of personal data subjects' rights.
5.4. In this regard, LLC "ELVILEMAR" informs users about the existence of risks arising in connection with the absence of an adequate level of personal data protection in such foreign countries:
absence (fragmentation) of personal data legislation;
absence (limitation) of personal data subjects' rights, the operator's obligation to respond to the subject's requests;
absence of an authorized body for the protection of personal data subjects' rights;
absence (limitation) of liability measures for violations of personal data subjects' rights;
risk of wide access to personal data by law enforcement agencies of various countries;
risk of using illegal methods of access to personal data and their illegal use.

6. ON WHAT LEGAL BASIS DO WE PROCESS COOKIES

6.1. Since LLC "ELVILEMAR" can ensure full and correct functioning of the Site, including the security of its use, only with the use of technical (mandatory) cookies, this type of cookies cannot be disabled using the Site's functionality and is processed regardless of the user's consent.
In case of disabling such cookies using browser settings, LLC "ELVILEMAR" cannot guarantee the correct operation of the Site.
6.2. Regarding analytical and advertising (marketing) cookies, LLC "ELVILEMAR" offers the user to give consent to the use of cookies or to refuse their use by clicking the "Accept" or "Reject" buttons on the pop-up information banner during the first visit to the Site.
By clicking the "Accept" button, the user consents to the processing of analytical and advertising (marketing) cookies. By clicking the "Reject" button, the user refuses their use. The user can also choose to use a specific type of cookies by following the "Settings" link on the pop-up information banner.
6.3. The Site saves user cookie settings for 1 (one) year. At the end of this period, the Site will again request the user's consent through a pop-up information banner.
The Site user can change their choice, as well as refuse the use of cookies before the expiration of the term specified in this item, by clicking the "Cookie settings" button at the bottom of the main page of the Site.

7. DISABLING COOKIES IN BROWSER SETTINGS

7.1. Most browsers are initially set to accept cookies. Users can delete previously saved cookies by selecting the appropriate option in the browser history. Additionally, some browsers allow visiting websites in "incognito" mode to limit the amount of information stored on the computer and automatically delete certain types of cookies.
7.2. Users can also disable the use of cookies by changing their browser settings. More details on managing cookie settings can be found by following the links to the websites of major browsers:
Microsoft Internet Explorer;
Microsoft Edge;
Google Chrome;
Firefox;
Yandex Browser;
Opera;
Opera (mobile);
Safari;
Safari (mobile);
Android Browser;
Information on managing settings of other browsers can be obtained from the documentation of their developers.
7.3. Users can prohibit the storage and use of data collected using Google Analytics cookies by using a plugin, the download of which is available at the link: https://tools.google.com/dlpage/gaoptout.
7.4. Users can prohibit the storage and use of data collected using Yandex Metrica cookies by using a plugin, the download of which is available at the link: https://yandex.com/support/metrica/general/opt-out.html.
7.5. Since the cookies used by LLC "ELVILEMAR" allow the user to effectively use the Site's functionality, personalize its content by recording user preferences, and customize advertising and marketing materials relevant to the user's interests, it is recommended to keep cookies enabled.

8. ASSISTANCE IN EXERCISING RIGHTS RELATED TO COOKIE PROCESSING

8.1. Users have the right to seek assistance in exercising their rights related to cookie processing by contacting the person responsible for internal control over personal data processing at LLC "ELVILEMAR", by sending an email to elvilemar@yandex.by.
8.2. Users can learn about other issues related to personal data protection at LLC "ELVILEMAR", including information about rights related to personal data processing and the mechanisms for their implementation, within the framework of the Personal Data Processing Policy.

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