Appendix No. 1
to the Order of LLC “WIZOIL-LUBRICANTS”
dated December 18, 2025 No. 6/25
Personal Data Processing Policy
in the Limited Liability Company
“WIZOIL-LUBRICANTS”
Date of publication: December 18, 2025
Last updated: December 18, 2025
1. General Provisions
1.1. This Personal Data Processing Policy (hereinafter referred to as the “Policy”) defines the main purposes, principles, conditions, and procedures for the processing and protection of personal data of Users submitted to LLC “WIZOIL-LUBRICANTS” (hereinafter referred to as the “Operator”) when using the website www.wizoil.ru (hereinafter referred to as the “Website”).
1.2. This Policy is developed in accordance with the legislation of the Russian Federation, including Federal Law No. 152-FZ of July 27, 2006 “On Personal Data,” and is intended to ensure unrestricted access to information regarding the processing of personal data.
1.3. This Policy is publicly available on the website of LLC “WIZOIL-LUBRICANTS” at https://wizoil.ru. Use of the Website by the User constitutes acceptance of this Policy and the terms of personal data processing.
2. Terms and Definitions
2.1. User — an individual using the Website and providing their personal data.
2.2. Operator — a legal entity that independently or jointly with other persons organizes and/or carries out the processing of personal data.
2.3. Personal Data — any information relating directly or indirectly to an identified or identifiable individual.
2.4. Processing of Personal Data — any action (operation) or set of actions performed with or without the use of automation tools on personal data.
2.5. Cookies — small text files stored on a user’s device (computer, smartphone, tablet) when visiting websites. They enable websites to remember user actions and preferences, improving convenience and functionality of interaction with the website.
3. Categories of Personal Data
3.1. The Operator processes Users’ personal data only to the extent necessary to achieve specific purposes defined in this Policy and does not allow processing of excessive or irrelevant data.
3.2. Personal data are divided into several categories depending on their nature and level of sensitivity:
3.2.2. General Personal Data.
This category includes information allowing identification of the User:
• Last name, first name, and patronymic (if applicable);
• Contact details (phone number, email address, postal address);
• Organization and position (for corporate clients);
• History of inquiries, orders, applications, and correspondence with the company;
• Data provided through feedback forms, registration, and surveys.
3.2.3. Technical Data Collected Automatically.
The Operator uses such data solely for analytics, website optimization, and content personalization. These data do not directly identify the User but are used to improve the quality of services.
They include:
• IP address, browser type and version, interface language;
• Device information (model, operating system, screen resolution);
• Information on visited website pages, date and time of access;
• Click history, navigation paths, and on-site user actions;
• Cookies and other similar technologies;
• Geolocation data (if permission is granted).
3.2.4. Anonymized (Depersonalized) Data.
The Operator may use anonymized User data for statistical, analytical, and marketing purposes. Such data do not allow identification of a specific person and are not considered personal data in the legal sense.
3.3. Principles of Minimization and Accuracy of Data:
3.3.1. Only data necessary for achieving declared purposes are processed;
3.3.2. All personal data are regularly updated, clarified, and deleted when necessary;
3.3.3. The User has the right to request an update or deletion of their data by sending a request to: info@wizoil.ru.
4. Purposes of Personal Data Processing
4.1. The Operator processes Users’ personal data exclusively for specific, predetermined, and lawful purposes. Processing is carried out only to the extent necessary to achieve defined objectives, without excessive collection or use of data for purposes incompatible with the original intent.
4.2. Main purposes of data processing:
4.2.1. Providing access to the Website and its functionality:
1. Ensuring the proper operation of the Website services, including feedback forms;
2. Personalizing the interface and improving user experience.
4.2.2. Execution and fulfillment of contracts, including the following:
• Processing Users’ requests;
• Performing contractual obligations, including possible product delivery, warranty services, and technical support;
• Maintaining the client database, issuing invoices, and preparing documentation;
• Communicating with clients regarding orders, deliveries, and payments.
4.2.3. User feedback and support:
• Responding to Users’ inquiries, requests, and feedback;
• Providing information on order status, services, and updates;
• Improving service quality and reducing response times.
4.2.4. Improving product and service quality:
• Conducting customer satisfaction surveys and questionnaires;
• Analyzing feedback and suggestions to optimize product range and services;
• Utilizing the WIZOIL AI Expert system to analyze oil performance characteristics and provide product improvement recommendations.
4.2.5. Marketing and informational communications:
• Sending newsletters, notifications about new products, promotions, and offers (with User consent);
• Personalizing marketing communications and offers;
• Analyzing User behavior on the Website to enhance advertising effectiveness.
4.2.6. Ensuring security and preventing violations:
• Protecting the Website from fraudulent activities, unauthorized access, and cyberattacks;
• Monitoring system integrity and preventing security incidents;
• Identifying and resolving technical issues.
4.2.7. Compliance with legal requirements:
• Maintaining accounting, tax, and HR records;
• Providing information upon requests of governmental or authorized bodies;
• Ensuring compliance with regulatory acts of the Russian Federation and international data protection agreements.
4.2.8. Statistics and analytics:
• Collecting depersonalized website traffic statistics (via Yandex.Metrica, Google Analytics, and other analytical systems);
• Analyzing user trends and content effectiveness;
• Enhancing Website stability and performance.
4.3. Additional purposes:
• Conducting research in the field of lubricants development and application;
• Improving company digital systems and algorithms;
• Enabling interaction among clients, dealers, and partners of LLC “WIZOIL-LUBRICANTS” via specialized services.
4.4. Purpose limitation principle:
Personal data are processed solely for the purposes specified in this section.
The Operator does not use personal data for automated decision-making that could have legal consequences for the User without their explicit consent.
5. Legal Grounds for Data Processing
5.1. The processing of personal data on the website of LLC “WIZOIL-LUBRICANTS” is carried out strictly in accordance with the provisions of Federal Law No. 152-FZ “On Personal Data.” The Operator processes Users’ personal data only if there are legal grounds, which include:
5.1.1. Consent of the data subject.
Personal data processing is based on the User’s consent provided when completing website forms through the feedback section.
Consent is voluntary, specific, informed, and deliberate.
The User may withdraw consent at any time by sending a notice to: info@wizoil.ru.
5.1.2. Execution of a contract or User request.
Data processing is necessary for fulfilling a contract to which the User is a party, or for concluding a contract at the User’s initiative.
This includes providing access to Website services, processing orders, product delivery, invoicing, and customer service communication.
5.1.3. Fulfillment of legal obligations.
The Operator processes personal data when required to comply with the laws of the Russian Federation, including:
• Tax and accounting legislation;
• Labor legislation;
• Obligations to government authorities (upon official request or legal requirement).
5.1.4. Protection of vital interests of the User.
In exceptional cases, personal data may be processed without User consent if necessary to protect the life, health, or other vital interests of the User or others.
5.1.5. Processing of publicly disclosed data.
If the User independently makes their personal data publicly available (for example, in reviews, comments, or profiles), such processing is permitted within the purposes defined by the User.
5.1.6. Processing of anonymized data for statistical and research purposes.
The Operator may use anonymized data for analysis, statistics, service quality improvement, and product development. Such data do not allow identification of the User.
6. Conditions of Data Processing and Storage
6.1. Personal data processing is performed by the Operator in accordance with the laws of the Russian Federation.
6.2. Processing is carried out with the consent of data subjects, as well as without it in cases established by law.
6.3. The organization performs personal data processing as a data operator.
6.4. The Operator may process personal data upon the User’s consent obtained through the Website’s feedback section.
6.5. The Operator ensures the security and confidentiality of personal data using modern technical and organizational measures. Processing may be performed both automatically and manually.
6.6. Personal data are stored in secure data centers located within the territory of the Russian Federation and are kept confidential. Data are retained in a form allowing identification of the data subject only for as long as necessary to achieve processing purposes.
6.7. Upon achieving the purposes of processing (or when no longer required), personal data must be destroyed or anonymized.
7. Disclosure of Personal Data to Third Parties
7.1. The Operator guarantees that Users’ personal data are not transferred to third parties, except in cases expressly provided for by the legislation of the Russian Federation, by the provisions of this Policy, or with the explicit consent of the data subject. Any transfer to third parties is carried out only to the extent necessary to fulfill the specific purposes of processing and in strict compliance with confidentiality and data protection requirements.
7.2. The Operator may disclose personal data in the following cases:
7.2.1. With the User’s consent — when the User explicitly authorizes such transfer (e.g., during registration, placing an order, or participating in promotions or loyalty programs).
7.2.2. Contract execution — when disclosure is necessary to fulfill obligations to the User (e.g., product delivery, payment processing, or provision of service support).
7.2.3. Legal requirements — upon official requests from government authorities (courts, law enforcement, or tax authorities) in accordance with the law.
7.2.4. Protection of the Operator’s rights and interests — when data transfer is required to protect the rights, property, or safety of LLC “WIZOIL-LUBRICANTS,” its employees, or clients.
7.2.5. Within partnerships and contractors — when data processing is entrusted to third-party service providers (e.g., hosting providers, courier services, banks, advertising agencies, or analytics systems). Such parties process data solely under the company’s instruction and in accordance with confidentiality and data protection agreements.
7.3. Categories of third parties that may receive information, provided that all such parties must ensure confidentiality, use data strictly for established purposes, and apply protection measures not lower than those ensured by the Operator:
7.3.1. Courier and logistics services — for the delivery of orders and products;
7.3.2. Analytics and advertising services (e.g., Yandex.Metrica, Google Analytics) — to analyze user behavior and optimize the Website;
7.3.3. Technical contractors — ensuring server operation, email services, hosting, and IT infrastructure;
7.3.4. Marketing and CRM partners — participating in customer engagement programs.
7.4. Security guarantees and responsibility of parties.
The Operator takes all necessary technical and organizational measures to protect personal data during transfer to third parties, including:
1. use of secure communication channels (TLS/SSL);
2. access and authorization control;
3. regular partner security audits;
4. inclusion of confidentiality and data protection clauses in contracts.
7.5. Each third party receiving personal data from the Operator bears responsibility for its use in accordance with the contract terms and the laws of the Russian Federation. The Operator, in turn, monitors compliance with established data protection rules by its partners.
8. User Rights
8.1. The Operator respects the rights and freedoms of every User and ensures their protection in accordance with the legislation of the Russian Federation.
Each User who has provided personal data through the Website possesses all rights of a data subject established by Federal Law No. 152-FZ, as well as those defined in this Policy.
8.2. The User has the following rights:
8.2.1. Right to information:
1. To obtain details regarding the fact, legal basis, and purposes of personal data processing;
2. To know the persons who have access to their data or to whom data may be disclosed;
3. To obtain information about the storage duration and data deletion procedures.
8.2.2. Right of access to personal data:
1. To request from the Operator a copy of all personal data being processed;
2. To obtain information on the methods and purposes of processing.
8.2.3. Right to rectification:
1. To make changes or additions to personal data if they are inaccurate, outdated, or incomplete;
2. To request updates to data previously submitted through feedback or registration forms.
8.2.4. Right to erasure (“right to be forgotten”):
1. To request deletion of personal data when they are no longer required for the stated purposes;
2. To withdraw previously granted consent to processing;
3. To demand cessation of dissemination or deletion of data from public sources.
8.2.5. Right to restriction of processing or withdrawal of consent:
1. To temporarily suspend data processing in case of a dispute regarding accuracy, legality, or necessity;
2. To restrict use of data for marketing or advertising purposes;
3. To withdraw consent to processing at any time by sending notice to: info@wizoil.ru.
8.2.6. Right to protection and appeal:
1. The User may file a complaint regarding the Operator’s actions or inactions with Roskomnadzor (Federal Service for Supervision of Communications, Information Technology, and Mass Media) or in court;
2. The Operator undertakes to review User inquiries and complaints within 30 days from the date of receipt.
9. Use of Cookies and Analytics
9.1. The Operator obtains personal data from Website visitors when they complete the Feedback form on the Website. The Website uses technologies such as cookies to simplify and improve user experience. Cookies are processed to enhance the Website’s functionality and improve the Operator’s products.
9.2. The Website uses cookies and web analytics tools (e.g., Yandex.Metrica, Google Analytics) to collect statistics, analyze user behavior, and enhance the interface and content.
9.3. The User may disable cookies in their browser settings; however, this may limit certain functionalities of the Website.
10. Personal Data Protection Measures
10.1. The Operator recognizes the protection of personal data as one of its top priorities and takes all necessary legal, organizational, and technical measures to ensure their security.
All data processing procedures are performed in accordance with the principles of confidentiality, integrity, and availability of information, in order to prevent unauthorized access, alteration, dissemination, blocking, destruction, or other unlawful use of data.
10.2. Main principles of data security:
1. Personal data processing is carried out on a lawful and fair basis;
2. Data are protected at all stages of processing — from the moment of collection to destruction;
3. Security measures are selected based on the nature of the data, processing purposes, risk level, and applied technologies;
4. Access to personal data is granted only to employees specifically authorized to perform such processing;
5. All persons with access to data are required to maintain confidentiality and sign nondisclosure agreements.
10.3. Organizational and technical protection measures
10.3.1. Organizational measures:
To ensure the protection of personal data, the Operator applies the following organizational measures:
1. Appointment of a person responsible for organizing personal data processing and protection;
2. Regular staff training and instruction on information security and confidentiality;
3. Monitoring and auditing compliance with legislative requirements and the company’s internal policies;
4. Conducting risk assessments and testing the effectiveness of protection measures at least once a year.
10.3.2. Technical measures:
To safeguard personal data, the Operator implements a variety of technological solutions aimed at preventing unauthorized access, including:
1. Data encryption during Internet transmission (TLS/SSL protocols);
2. Use of firewalls and antivirus systems;
3. Regular updates of operating systems, antivirus databases, and software;
4. Use of backup and data recovery systems;
5. Protection of information systems through multi-level authentication and complex passwords;
6. Access control to databases;
7. Network activity monitoring to detect suspicious operations and attacks (DDoS, brute-force, phishing, etc.);
8. Hosting servers in secure data centers meeting Tier III or higher security standards.
10.4. Personal data processing is carried out strictly in accordance with the legislation of the Russian Federation, including Federal Law No. 152-FZ, the Civil Code of the Russian Federation, the Labor Code of the Russian Federation, and other applicable regulatory acts.
10.5. In the event of unauthorized access to personal data or other security incidents, the company shall:
• Immediately take measures to eliminate the threat;
• Conduct an internal investigation;
• Notify the data subject and, if necessary, Roskomnadzor;
• Restore the integrity and confidentiality of the information.
11. Policy Updates
11.1. The Operator reserves the right to amend this Policy at any time. The new version takes effect upon publication on the Website.
11.2. Users are encouraged to regularly review the “Personal Data Processing” section for the most recent updates.
12. Contact Information
Personal Data Operator:
LLC “WIZOIL-LUBRICANTS”
Email: info@wizoil.ru