Policy on the Processing of Personal Data
# **Privacy Policy on the Processing of Personal Data**
## **1. General Provisions**
This Privacy Policy on the processing of personal data (hereinafter referred to as the “Policy”) is prepared in accordance with the requirements of Federal Law No. 152-FZ of July 27, 2006 “On Personal Data” (hereinafter referred to as the “Personal Data Law”) and determines the procedure for processing personal data and the measures taken by **LLC “Prestige Cargo Trans”** (hereinafter referred to as the “Operator”) to ensure the security of personal data.
**1.1.** This Policy on the processing of personal data has been developed pursuant to paragraph 2, part 1, article 18.1 of the Personal Data Law in order to ensure the protection of the rights and freedoms of individuals during the processing of their personal data, including the protection of the right to privacy, personal and family confidentiality.
**1.2.** This Policy applies to the following categories of personal data subjects whose data is processed by the Operator:
— Website visitors;
— Clients of the Operator;
— Counterparties of the Operator.
**1.3.** The legal grounds for the processing of personal data include a set of regulatory legal acts under which and in accordance with which **LLC “Prestige Cargo Trans”** carries out personal data processing, including:
— The Constitution of the Russian Federation;
— The Civil Code of the Russian Federation;
— The Tax Code of the Russian Federation;
— Federal Law No. 149-FZ of July 27, 2006 “On Information, Information Technologies, and Information Protection”;
— Federal Law “On Freight Forwarding Activities” of June 30, 2003;
— Federal Law No. 259-FZ of November 8, 2007 “Charter of Road Transport and Urban Land Electric Transport”;
— The Charter of LLC “Prestige Cargo Trans”;
— The Regulation on Personal Data approved by the General Director of LLC “Prestige Cargo Trans”;
— Other regulatory legal acts of the Russian Federation and regulatory documents of authorized government bodies;
— Consent of data subjects to the processing of their personal data.
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## **2. Basic Terms Used in the Policy**
**2.1.** *Automated processing of personal data* — processing of personal data using computer technology.
**2.2.** *Blocking of personal data* — temporary suspension of personal data processing (except where processing is required to clarify personal data).
**2.3.** *Website* — a collection of graphic and informational materials, as well as software and databases, ensuring their availability on the Internet at the address [https://prestige-cargo.ru/](https://prestige-cargo.ru/).
**2.4.** *Personal data information system* — a set of personal data contained in databases, along with information technologies and technical means ensuring their processing.
**2.5.** *Anonymization of personal data* — actions that make it impossible, without additional information, to determine whether personal data belongs to a specific User or another personal data subject.
**2.6.** *Processing of personal data* — any action (operation) or set of actions (operations), performed with or without the use of automation tools, on personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), anonymization, blocking, deletion, or destruction of personal data.
**2.7.** *Operator* — a state or municipal authority, legal entity, or individual that independently or jointly with other persons organizes and/or performs the processing of personal data, as well as determines the purposes of personal data processing, the composition of personal data to be processed, and the actions (operations) performed on personal data.
**2.8.** *Personal data* — any information that relates directly or indirectly to a specific or identifiable User of the website [https://prestige-cargo.ru/](https://prestige-cargo.ru/).
**2.9.** *Personal data permitted by the data subject for distribution* — personal data to which the data subject has granted access to an unlimited number of persons by providing consent for their processing in accordance with the procedure established by the Personal Data Law (hereinafter referred to as “personal data permitted for distribution”).
**2.10.** *User* — any visitor to the website [https://prestige-cargo.ru/](https://prestige-cargo.ru/).
**2.11.** *Provision of personal data* — actions aimed at disclosing personal data to a specific person or a specific group of persons.
**2.12.** *Distribution of personal data* — any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or making personal data known to an unlimited number of persons, including publication in mass media, placement on information and telecommunication networks, or providing access in any other way.
**2.13.** *Cross-border transfer of personal data* — transfer of personal data to the territory of a foreign state to a foreign government authority, a foreign individual, or a foreign legal entity.
**2.14.** *Destruction of personal data* — any actions resulting in the irreversible destruction of personal data, making it impossible to restore the content of personal data within the personal data information system and/or leading to the destruction of physical media containing personal data.
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## **3. Main Rights and Obligations of the Operator**
**3.1.** The Operator has the right to:
— receive from the data subject accurate information and/or documents containing personal data;
— continue processing personal data without the consent of the data subject in cases provided for by the Personal Data Law, including where the subject withdraws consent or requests termination of processing;
— independently determine the composition and list of measures necessary and sufficient to fulfill the obligations provided by the Personal Data Law and other legal acts, unless otherwise stipulated by federal law.
**3.2.** The Operator is obliged to:
— provide the data subject, upon request, with information regarding the processing of their personal data;
— organize personal data processing in accordance with the applicable legislation of the Russian Federation;
— respond to inquiries and requests from data subjects or their legal representatives in compliance with the requirements of the Personal Data Law;
— submit, within ten (10) days from receipt of a request, the required information to the authorized body for the protection of personal data subjects’ rights;
— publish or otherwise ensure unrestricted access to this Policy on the processing of personal data;
— implement legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, alteration, blocking, copying, provision, distribution, and other unlawful actions;
— cease transfer (distribution, provision, access) and processing of personal data and destroy such data in the cases and in the manner prescribed by the Personal Data Law;
— perform other duties as required by the Personal Data Law.
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## **4. Main Rights and Obligations of Personal Data Subjects**
**4.1.** Personal data subjects include clients and counterparties of the Operator (individuals), as well as representatives of clients and counterparties (legal entities).
Personal data subjects have the right to:
— obtain information regarding the processing of their personal data, except as provided by federal laws. Such information must be provided in an accessible form and must not include personal data of other individuals unless there are legal grounds for disclosure;
— demand the Operator to clarify, block, or destroy their personal data if it is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, as well as take legal measures to protect their rights;
— request prior consent for the processing of personal data for marketing or promotional purposes;
— withdraw consent to the processing of personal data or demand termination of such processing;
— appeal unlawful actions or inactions of the Operator in the authorized body for the protection of personal data subjects’ rights or in court;
— exercise other rights provided by the legislation of the Russian Federation.
**4.2.** Personal data subjects are obliged to:
— provide the Operator with accurate information about themselves;
— inform the Operator of any updates (changes) to their personal data.
**4.3.** Individuals who provide inaccurate information about themselves or information about another personal data subject without that person’s consent bear responsibility in accordance with the legislation of the Russian Federation.
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## **5. Principles of Personal Data Processing**
**5.1.** Processing of personal data shall be carried out on a lawful and fair basis.
**5.2.** Processing of personal data shall be limited to achieving specific, predetermined, and legitimate purposes. Processing of personal data incompatible with the purposes of its collection is not permitted.
**5.3.** It is not allowed to combine databases containing personal data that are processed for purposes that are incompatible with each other.
**5.4.** Only personal data that meet the purposes of their processing shall be subject to processing.
**5.5.** The content and scope of processed personal data must correspond to the stated purposes of processing. Excessive processing of personal data in relation to the stated purposes is not permitted.
**5.6.** The Operator shall ensure the accuracy, sufficiency, and, where necessary, relevance of personal data in relation to the purposes of its processing. The Operator shall take necessary measures to delete or clarify incomplete or inaccurate data.
**5.7.** Personal data shall be stored in a form that allows identifying the personal data subject no longer than required for the purposes of processing, unless a longer retention period is provided by federal law or contract. Processed personal data shall be destroyed or anonymized once the purposes of processing have been achieved or when they are no longer needed, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing
| Purpose of Processing | For initial consultation on transportation services or cargo documentation. |
|---|---|
| Personal Data |
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| Legal Basis |
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| Types of Personal Data Processing |
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### 7. Conditions for the Processing of Personal Data
7.1. Personal data is processed with the consent of the personal data subject to the processing of their personal data.
7.2. The processing of personal data is necessary to achieve the purposes stipulated by an international treaty of the Russian Federation or by law, as well as for the exercise of the functions, powers, and duties assigned to the Operator by the legislation of the Russian Federation.
7.3. The processing of personal data is necessary for the administration of justice, execution of a court judgment, or an act of another authority or official, subject to enforcement under the legislation of the Russian Federation on enforcement proceedings.
7.4. The processing of personal data is necessary for the performance of a contract to which the personal data subject is a party, beneficiary, or guarantor, as well as for the conclusion of a contract at the initiative of the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor.
7.5. The processing of personal data is necessary for the exercise of the Operator’s or third parties’ rights and legitimate interests, or for achieving socially significant purposes, provided that this does not violate the rights and freedoms of the personal data subject.
7.6. Personal data made publicly available by the personal data subject or at their request (hereinafter referred to as “publicly available personal data”) may be processed.
7.7. The processing of personal data subject to publication or mandatory disclosure under federal law is carried out.
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### 8. Procedure for Collection, Storage, Transfer, and Other Types of Personal Data Processing
The security of personal data processed by the Operator is ensured through the implementation of legal, organizational, and technical measures necessary to fully comply with the requirements of applicable personal data protection legislation.
8.1. The Operator ensures the safety of personal data and takes all possible measures to prevent unauthorized access to it.
8.2. The User’s personal data will never, under any circumstances, be transferred to third parties, except as required by applicable law or when the personal data subject has provided consent to the Operator for such transfer to a third party for the fulfillment of obligations under a civil contract.
8.3. In case of inaccuracies in personal data, the User may independently update them by sending a notification to the Operator’s email address: **[sales@prestige-cargo.ru](mailto:sales@prestige-cargo.ru)** marked “Update of personal data.”
8.4. The period of personal data processing is determined by the achievement of the purposes for which the personal data was collected, unless otherwise specified by a contract or applicable legislation. The User may withdraw their consent to the processing of personal data at any time by sending a notice to the Operator via email at **[sales@prestige-cargo.ru](mailto:sales@prestige-cargo.ru)** marked “Withdrawal of consent to the processing of personal data.”
8.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by those entities (Operators) in accordance with their User Agreements and Privacy Policies. The personal data subject must review these documents independently. The Operator is not responsible for the actions of third parties, including those listed in this clause.
8.6. The restrictions imposed by the personal data subject on the transfer (except granting access) and processing conditions of personal data permitted for distribution do not apply in cases where personal data is processed in state, public, or other socially significant interests as defined by the legislation of the Russian Federation.
8.7. The Operator ensures the confidentiality of personal data during its processing.
8.8. The Operator stores personal data in a form that allows identification of the personal data subject for no longer than required by the purposes of processing, unless a longer storage period is established by federal law or by a contract in which the personal data subject is a party, beneficiary, or guarantor.
8.9. The grounds for termination of personal data processing may include the achievement of the processing purposes, expiration of the consent validity period, withdrawal of consent by the personal data subject, a request to cease processing, or identification of unlawful processing of personal data.
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### 9. List of Actions Performed by the Operator with Collected Personal Data
9.1. The Operator performs collection, recording, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
9.2. The Operator performs automated processing of personal data with or without the use of information and telecommunication networks.
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### 10. Cross-Border Transfer of Personal Data
10.1. Before initiating any cross-border transfer of personal data, the Operator must notify the authorized body for the protection of personal data subjects’ rights of its intention to carry out such transfer (this notification is submitted separately from the notification of intent to process personal data).
10.2. Prior to submitting the above notification, the Operator must obtain the necessary information from the authorities of the foreign state, foreign individuals, or legal entities to which the cross-border transfer of personal data is planned.
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### 11. Confidentiality of Personal Data
The Operator and other persons who have gained access to personal data are obliged not to disclose or distribute such data to third parties without the consent of the personal data subject, unless otherwise provided by federal law.
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### 12. Final Provisions
12.1. The User may obtain any clarification on matters related to the processing of their personal data by contacting the Operator via email at **[sales@prestige-cargo.ru](mailto:sales@prestige-cargo.ru)**.
12.2. Any changes to this Policy regarding the processing of personal data by the Operator will be reflected in this document. The Policy remains in effect indefinitely until replaced by a new version.
12.3. The current version of the Policy is publicly available online at https://prestige-cargo.ru/privacy .