Policy on the Processing of Personal Data

1. General Provisions

This personal data processing policy is drafted 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 defines the procedure for processing personal data and measures to ensure the security of personal data taken by Prestige Cargo Trans LLC (hereinafter referred to as the Operator).

• 1.1. The Operator’s primary objective and condition for its activities is to ensure the protection of human and citizen rights and freedoms during the processing of their personal data, including the protection of privacy, personal, and family secrets.
• 1.2. This Operator’s policy on personal data processing (hereinafter referred to as the Policy) applies to all information that the Operator may obtain about visitors to the website https://thismywebsite.com.

2. Key Terms Used in the Policy

• 2.1. Automated processing of personal data — processing of personal data using computing technology.
• 2.2. Blocking personal data — temporary suspension of personal data processing (except when processing is necessary 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 network address https://prestige-cargo.ru/.
• 2.4. Personal data information system — a collection of personal data contained in databases and providing their processing using information technologies and technical means.
• 2.5. Anonymization of personal data — actions resulting in the impossibility of identifying the personal data belonging to a specific User without additional information.
• 2.6. Processing personal data — any action (operation) or a set of actions (operations) performed using automation tools or without such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, destruction of personal data.
• 2.7. Operator — a government body, municipal body, legal or physical person organizing and/or processing personal data, determining the purposes of processing personal data, the composition of personal data to be processed, and actions (operations) performed with personal data.
• 2.8. Personal data — any information relating directly or indirectly to a determined or determinable User of the website https://prestige-cargo.ru/.
• 2.9. Publicly available personal data — personal data that has been made available to an unlimited number of persons by the subject of personal data through consent in the manner provided by the Personal Data Law.
• 2.10. User — any visitor to the website 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 people.
• 2.12. Distribution of personal data — actions aimed at disclosing personal data to an unlimited group of persons, including publication in media, posting on information and telecommunication networks, or providing access to personal data in any other way.
• 2.13. Cross-border transfer of personal data — the transfer of personal data to a foreign country’s territory, foreign government authority, foreign individual, or foreign legal entity.
• 2.14. Destruction of personal data — actions resulting in the permanent destruction of personal data with no possibility of further restoration of the content.

3. Main Rights and Duties of the Operator

• 3.1. The Operator has the right:
• — to request accurate information and/or documents containing personal data from the subject of personal data;
• — to continue processing personal data without consent in cases provided for by the Personal Data Law;
• — to independently determine the composition and list of measures necessary to ensure the fulfillment of obligations stipulated by the Personal Data Law and related acts.
• 3.2. The Operator is obliged to:
• — provide the subject of personal data with information about their processing upon request;
• — organize the processing of personal data according to applicable laws;
• — respond to requests from personal data subjects in line with the requirements of the Personal Data Law;
• — publish or otherwise provide unrestricted access to this Policy;
• — take measures to protect personal data against unauthorized access, destruction, alteration, or dissemination;
• — stop processing and destroy personal data when necessary.

4. Main Rights and Obligations of Personal Data Subjects

• 4.1. Personal data subjects have the right:
• — to obtain information regarding the processing of their personal data, except in cases provided by federal laws. Information is provided to the personal data subject by the Operator in an accessible form, and it should not contain personal data related to other personal data subjects, except when there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
• — to request the Operator to clarify, block, or destroy their personal data if the personal data is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the declared purpose of processing, as well as to take measures provided by law to protect their rights;
• — to set a condition for prior consent when processing personal data for the purpose of marketing goods, works, and services;
• — to withdraw consent to the processing of personal data and to submit a request for the termination of personal data processing;
• — to appeal to the authorized body for the protection of personal data subjects’ rights or to a court regarding unlawful actions or inaction by the Operator in processing their personal data;
• — to exercise other rights provided by Russian legislation.
• 4.2. Personal data subjects are obliged to:
• — provide accurate information about themselves to the Operator;
• — notify the Operator of any clarification (update or modification) of their personal data.
• 4.3. Persons who have provided inaccurate information about themselves to the Operator or information about another personal data subject without their consent are liable in accordance with Russian legislation.

5. Principles of Personal Data Processing

• 5.1. The processing of personal data is carried out on a lawful and fair basis.
• 5.2. The processing of personal data is limited to achieving specific, pre-determined, and legitimate purposes. Processing of personal data incompatible with the purposes of collecting personal data is not allowed.
• 5.3. Combining databases containing personal data, which are processed for purposes incompatible with one another, is not allowed.
• 5.4. Only personal data that meets the purposes of its processing is subject to processing.
• 5.5. The content and scope of processed personal data correspond to the stated purposes of processing. Excessive personal data processing in relation to the stated purposes is not allowed.
• 5.6. Accuracy, sufficiency, and, where necessary, relevance of personal data are ensured during its processing in relation to the purposes of processing. The Operator takes necessary measures and/or ensures that incomplete or inaccurate data is removed or clarified.
• 5.7. Personal data is stored in a form that allows the identification of the personal data subject for no longer than the purposes of personal data processing require unless the storage period for personal data is established by federal law, a contract, or an agreement where the personal data subject is a party, beneficiary, or guarantor. Processed personal data is destroyed or anonymized upon achieving the purposes of processing or if the necessity to achieve these purposes is lost, 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	Email address Phone numbers Name Transportation route and type of transport
Legal Basis	Federal Law “On Information, Information Technologies, and Information Protection” No. 149-FZ dated 27.07.2006
Types of Personal Data Processing	Collection, recording, systematization, accumulation, storage, destruction, and anonymization of personal data Sending informational emails to the email address

7. Conditions for Processing 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. Processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or law, for the exercise of the functions, powers, and responsibilities assigned to the operator by the legislation of the Russian Federation.
• 7.3. Processing of personal data is necessary for the administration of justice, the execution of a judicial act, or an act of another body or official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
• 7.4. Processing of personal data is necessary for the execution of a contract to which the personal data subject is a party, beneficiary, or guarantor, as well as for the conclusion of a contract on the initiative of the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor.
• 7.5. Processing of personal data is necessary for the exercise of the rights and legitimate interests of the operator or third parties or for achieving socially significant goals, provided that this does not violate the rights and freedoms of the personal data subject.
• 7.6. Processing of personal data made publicly accessible by the personal data subject or at their request (hereinafter referred to as publicly accessible personal data) is carried out.
• 7.7. Processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.

8. Procedure for Collecting, Storing, Transmitting, 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 current legislation on personal data protection.

• 8.1. The Operator ensures the security of personal data and takes all possible measures to prevent unauthorized access to personal data.
• 8.2. User personal data will never, under any circumstances, be transferred to third parties, except in cases related to compliance with current legislation or when the personal data subject has given consent for the Operator to transfer data to a third party to fulfill obligations under a civil contract.
• 8.3. In case of inaccuracies in personal data, the User can update them independently by sending a notification to the Operator’s email address sales@prestige-cargo.ru with the subject line “Personal Data Update.”
• 8.4. The period for processing personal data is determined by achieving the purposes for which the personal data was collected unless otherwise specified by a contract or current legislation. The User can revoke their consent to personal data processing at any time by sending a notification to the Operator via email at sales@prestige-cargo.ru with the subject line “Withdrawal of Consent for Personal Data Processing.”
• 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 familiarize themselves with these documents. The Operator is not responsible for the actions of third parties, including service providers mentioned in this clause.
• 8.6. Restrictions established by the personal data subject on the transfer (other than granting access), as well as on the processing or conditions of processing (other than access) of personal data authorized for dissemination, do not apply in cases of personal data processing in the interests of the state, society, or other public interests as determined by Russian legislation.
• 8.7. The Operator ensures the confidentiality of personal data during processing.
• 8.8. The Operator stores personal data in a form that allows identification of the personal data subject no longer than required by the purposes of personal data processing unless a retention period for personal data is established by federal law, a contract, or an agreement under which the personal data subject is a party, beneficiary, or guarantor.
• 8.9. Conditions for terminating personal data processing may include achieving the purposes of personal data processing, the expiration of the personal data subject’s consent, withdrawal of consent by the personal data subject, or a request to terminate the processing of personal data, as well as identifying unlawful processing of personal data.

9. List of Actions Performed by the Operator with Received Personal Data

• 9.1. The Operator performs the collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
• 9.2. The Operator carries out automated processing of personal data with the receipt and/or transfer of the obtained information via telecommunication networks or without such use.

10. Cross-Border Transfer of Personal Data

• 10.1. Before commencing activities related to the cross-border transfer of personal data, the Operator must notify the authorized body for the protection of personal data subjects’ rights about its intention to carry out the cross-border transfer of personal data. This notification is submitted separately from the notification of the intent to process personal data.
• 10.2. Before submitting the above-mentioned notification, the Operator is required to obtain relevant information from the foreign government authorities, foreign individuals, or foreign legal entities to which the cross-border transfer of personal data is planned.

11. Конфиденциальность персональных данных

• Оператор и иные лица, получившие доступ к персональным данным, обязаны не раскрывать третьим лицам и не распространять персональные данные без согласия субъекта персональных данных, если иное не предусмотрено федеральным законом.

12. Final Provisions

• 12.1. The User can request any clarifications regarding the processing of their personal data by contacting the Operator via email at sales@prestige-cargo.ru.
• 12.2. Any changes to the Operator’s personal data processing policy will be reflected in this document. The policy is valid indefinitely until replaced by a new version.
• 12.3. The current version of the Policy is publicly available on the Internet at https://prestige-cargo.ru/privacy.