Privacy
Policy

General Provisions

1.1. This Privacy Policy (hereinafter — the Policy) defines the purposes, conditions and procedures for processing personal data of users of the mobile application "OTK Personal Account" (hereinafter — the Application).

1.2. The personal data operator is OTK LLC (hereinafter — the Operator).

1.3. Use of the Application constitutes the User's unconditional acceptance of this Policy and the personal data processing conditions specified herein.

1.4. The Policy applies to all information that the Operator may obtain about the User during use of the Application.

1.5. In compliance with Part 2, Article 18.1 of Federal Law No. 152-FZ of 27.07.2006 "On Personal Data", this Policy is published in open access on the Operator's website at: https://otk.pw.

Purposes of Personal Data Processing

The Operator processes the User's personal data for the following purposes:

• Identifying the User to grant access to Application features (personal account).
• Processing requests for vehicle access, employee/visitor passes, and work permits.
• Generating access documents (including with use of a photograph).
• Technical support and troubleshooting.
• Establishing feedback (sending notifications, processing requests).
• Compliance with the requirements of the legislation of the Russian Federation.

Categories and Scope of Data Processed

3.1. The following categories of personal data are processed under this Policy:

• User data: last name, first name, patronymic (if applicable).
• Contact data: email address, phone number.
• Pass data: full names of employees/visitors, vehicle data (licence plate, make, model), photograph (for pass).
• Technical data: device information (model, OS), session identifiers, error logs.

3.2. Processing of biometric and special categories of personal data (information on race, nationality, political views, religious beliefs, etc.) is not carried out.

3.3. By providing the above information, the User warrants that it is complete and accurate, and agrees to compensate in full any damage that may arise from the provision of incorrect or inaccurate data.

Legal Grounds for Processing

4.1. The legal grounds for processing personal data are:

• The Constitution of the Russian Federation and the Civil Code of the Russian Federation.
• Federal Law No. 152-FZ of 27.07.2006 "On Personal Data".
• The User's consent to personal data processing, given upon registration or when using the Application's features.

Processing Procedure and Conditions

5.1. Processing is carried out by automated and non-automated means.

5.2. Actions performed with data include: collection, recording, systematisation, accumulation, storage, clarification (updating, modification), retrieval, use, blocking, deletion, and destruction.

5.3. Data is stored for the period necessary to achieve the purposes of processing, unless a different period is established by law or contract.

5.4. Procedure for working with photographs and the camera:

• For the pass generation feature, the Application may request access to the device's camera and gallery solely for the purpose of uploading a photograph.
• Access is granted only upon the User's explicit action (by tapping the relevant button).
• The photograph is used exclusively for generating a pass document and displaying in the profile.
• Photographs are stored on the Operator's servers in encrypted form.

Rights and Obligations of the Parties

The Operator's actions are carried out in strict compliance with the requirements of Article 18 of Federal Law No. 152-FZ of 27.07.2006 "On Personal Data".

Blocking, Rectification and Erasure of Personal Data

7.1. If inaccuracies in personal data or unlawful processing are identified, the Operator shall, upon request by the User or a competent authority, block such data for the duration of the verification.

7.2. If inaccuracy of personal data is confirmed, the Operator shall rectify (update, modify) it within 7 business days of receipt of the relevant supporting information.

7.3. If unlawful processing is identified, the Operator shall cease such processing within 3 business days. If lawful processing cannot be ensured, the data shall be destroyed within 10 business days.

7.4. Upon achievement of the processing purposes or withdrawal of the User's consent, the Operator shall destroy personal data within 30 days, unless a different period is established by law or contract.

Liability of the Parties

8.1. The Operator shall be liable for violations of the requirements of the legislation of the Russian Federation in the field of personal data in accordance with applicable law.

8.2. The User has the right to claim compensation for damages and/or moral harm through judicial proceedings. Compensation for moral harm is independent of compensation for material damages and losses incurred by the User.

Dispute Resolution

9.1. All disputes and disagreements arising between the User and the Operator in connection with personal data processing shall be resolved through negotiations.

9.2. If agreement cannot be reached, disputes shall be resolved through judicial proceedings in accordance with the legislation of the Russian Federation.

Final Provisions

10.1. This Policy enters into force upon approval and remains in effect until replaced by a new version.

10.2. The Operator reserves the right to amend this Policy without prior notice to or consent of the User. Amendments take effect upon their publication in the Application or on the Operator's website.

10.3. The new version of the Policy applies to relations arising after its entry into force. The User is responsible for independently monitoring changes to this Policy.