Policy regarding the processing of personal data

*By accepting this policy, you also give consent to the processing of personal data.
*Additional information: cookie processing rules.

1. General Provisions

This policy regarding the processing of personal data has been drawn up in accordance with the requirements of Federal Law No. 152-FZ of July 27, 2006 “On Personal Data” (hereinafter – the Law on Personal Data) and the Recommendations of the Federal Service for Supervision of Communications and Mass Media dated July 27, 2017.

The Policy is intended to inform personal data subjects about the procedure for processing personal data and measures to ensure the security of personal data by the website owner (hereinafter referred to as the Operator).

Contact details of the operator. Address – 297420, Crimea Rep, Evpatoria city, 9 Maya st., house No. 114, apartment 24. TIN: 9110021948. RTU LLC

Key Concepts used in the Policy:

Automated personal data processing – processing of personal data using computer technology.
Blocking of personal data – temporary cessation of personal data processing (unless processing is necessary for the clarification of personal data).
Website – a collection of graphical and informational materials, as well as computer programs and databases, ensuring their availability on the Internet at the network address https://rtucargo.com/ (hereinafter referred to as the site, website). Site Mail (Operator’s mail – inforf@rtucargo.com)
Personal data information system — a set of personal data contained in databases, and the information technologies and technical means ensuring their processing.
Depersonalization of personal data — actions as a result of which it is impossible to determine the ownership of personal data to a specific User or other personal data subject without the use of additional information.
Processing of personal data – any action (operation) or set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, distribution, destruction of personal data.
Operator – a state body, municipal body, legal entity or individual, independently or jointly with other persons organizing and/or carrying out the processing of personal data, as well as determining the purposes of personal data processing, the composition of personal data to be processed, actions (operations) performed with personal data. In the context of this policy, the Operator is the owner of this website.
Personal data – any information relating directly or indirectly to an identified or identifiable User of the website.
Personal data authorized by the personal data subject for dissemination – personal data to which an unlimited circle of persons has been given access by the personal data subject through giving consent to the processing of personal data authorized by the personal data subject for dissemination in the manner prescribed by the Law on Personal Data (hereinafter – personal data authorized for dissemination).
User – any visitor to the website.
Provision of personal data – actions aimed at disclosing personal data to a specific person or a specific circle of persons.
Dissemination of personal data – any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or familiarizing an unlimited circle of persons with personal data, including the publication of personal data in the media, placement in information and telecommunication networks, or providing access to personal data in any other way.
Cross-border transfer of personal data – transfer of personal data to the territory of a foreign state to an authority of a foreign state, a foreign individual, or a foreign legal entity.
Destruction of personal data – any actions as a result of which personal data are irreversibly destroyed with the impossibility of further restoring the content of personal data in the personal data information system and/or the physical carriers of personal data are destroyed.

Main Rights and Obligations of the Operator

The Operator sets as its most important goal and condition for the implementation of its activities the observance of human and civil rights and freedoms when processing their personal data, including the protection of the rights to privacy, personal and family secrets.

This policy of the Operator regarding the processing of personal data (hereinafter – the Policy) applies to all information that the Operator may receive about visitors to the website.

The Operator has the right to:

receive accurate information containing personal data from the personal data subject;
in case the personal data subject withdraws consent to the processing of personal data, the Operator has the right to continue processing personal data without the consent of the personal data subject if there are grounds specified in the Law on Personal Data;
independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations provided for by the Law on Personal Data and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Law on Personal Data or other federal laws;

The Operator is obliged to:

provide the personal data subject, upon their request, with information concerning the processing of their personal data;
organize the processing of personal data in the manner established by the current legislation of the Russian Federation;
respond to requests and inquiries from personal data subjects and their legal representatives in accordance with the requirements of the Law on Personal Data;
notify the authorized body for the protection of the rights of personal data subjects, upon request of this body, of the necessary information within 30 days from the date of receipt of such request;
publish or otherwise ensure unrestricted access to this Policy regarding the processing of personal data;
take legal, organizational, and technical measures to protect personal data from unlawful or accidental access to them, destruction, modification, blocking, copying, provision, dissemination of personal data, as well as from other unlawful actions in relation to personal data;
stop the transfer (dissemination, provision, access) of personal data, stop processing and destroy personal data in the manner and cases provided for by the Law on Personal Data;
fulfill other obligations provided for by the Law on Personal Data.

Main Rights and Obligations of Personal Data Subjects
Personal data subjects have the right to:

receive information concerning the processing of their personal data, except in cases provided for by federal laws. The information is provided to the personal data subject by the Operator in an accessible form, and must not contain personal data relating to other personal data subjects, except in cases where there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Law on Personal Data;
demand that the operator clarify their personal data, block or destroy them if the personal data is incomplete, outdated, inaccurate, illegally obtained, or not necessary for the stated purpose of processing, and also take measures provided for by law to protect their rights;
put forward the condition of prior consent when processing personal data for the purpose of promoting goods, works, and services on the market;
withdraw consent to the processing of personal data;
appeal to the authorized body for the protection of the rights of personal data subjects or in court against unlawful actions or inaction of the Operator when processing their personal data;
exercise other rights provided for by the legislation of the Russian Federation.

Personal data subjects are obliged to:

provide the Operator with reliable data about themselves;

Persons who have provided the Operator with unreliable information about themselves, or information about another personal data subject without the latter’s consent, are liable in accordance with the legislation of the Russian Federation.
The Operator may process (if the corresponding form is available on the site) the following personal data of the User:

Last name, first name, patronymic;
Email address;
Phone numbers;
Nickname (if any);
User avatar (image);
User address;
Information about the user (about themselves);
Questions from the user;
The site also collects and processes anonymized data about visitors (including “cookie” files) using internet statistics services (Yandex Metrica and Google Analytics and others).
The above data are hereinafter combined under the general concept of Personal Data in the Policy text.
The Operator does not process special categories of personal data concerning racial, national origin, political views, religious or philosophical beliefs, intimate life. If the user’s question to the lawyer concerns the specified data, the user must refrain from publishing such a question or information about themselves.
Processing of personal data authorized for dissemination, from among the special categories of personal data specified in Part 1 of Article 10 of the Law on Personal Data, is allowed if the prohibitions and conditions provided for in Article 10.1 of the Law on Personal Data are observed.

User Consent to the processing of personal data authorized for dissemination is formalized separately from other consents to the processing of their personal data by means of a tick mark when submitting any form.

In doing so, the conditions provided for, in particular, in Article 10.1 of the Law on Personal Data are observed. Requirements for the content of such consent are established by the authorized body for the protection of the rights of personal data subjects.

Consent to the processing of personal data authorized for dissemination is provided by the User directly to the Operator.

The Operator is obliged, no later than three working days from the moment of receiving the specified User consent, to publish information about the conditions of processing, the existence of prohibitions and conditions for processing by an unlimited circle of persons of personal data authorized for dissemination. The transfer (dissemination, provision, access) of personal data authorized by the personal data subject for dissemination must be terminated at any time upon the demand of the personal data subject.

This demand must include the full name (if any), contact information (phone number, email address, or postal address) of the personal data subject, as well as a list of personal data whose processing is subject to termination. The personal data specified in this demand can only be processed by the Operator to whom it was sent.

Consent to the processing of personal data authorized for dissemination ceases to be effective from the moment the Operator receives the demand specified in this Policy regarding the processing of personal data.

Principles of Personal Data Processing

Personal data processing is carried out on a legal and fair basis.
Personal data processing is limited to achieving specific, predetermined, and legitimate goals. Processing of personal data incompatible with the purposes of personal data collection is not allowed.
Combining databases containing personal data whose processing is carried out for mutually incompatible purposes is not allowed.
Only personal data that meets the purposes of its processing is subject to processing.
The content and volume of the processed personal data correspond to the stated processing goals. The redundancy of the processed personal data in relation to the stated goals of their processing is not allowed.
When processing personal data, the accuracy of personal data, its sufficiency, and, if necessary, its relevance to the purposes of personal data processing are ensured. The Operator takes the necessary measures and/or ensures their adoption to delete or clarify incomplete or inaccurate data.
Storage of personal data is carried out in a form that allows identifying the personal data subject, no longer than required by the purposes of personal data processing, unless the storage period of personal data is established by federal law, a contract, a party to which, a beneficiary or guarantor of which is the personal data subject. The processed personal data is destroyed or depersonalized upon achieving the goals of processing or in case of loss of the need to achieve these goals, unless otherwise provided by federal law.

Purposes of Personal Data Processing

The purpose of processing User personal data is:
informing the User by sending electronic letters;
conclusion, execution, and termination of civil law contracts;
providing the User with access to the services, information, and/or materials contained on the website.
The Operator also has the right to send the User notifications about new products and services, special offers, and various events. The User can always refuse to receive informational messages by sending a letter to the operator’s email address with the note “Refusal of notifications about new products and services and special offers.”
Anonymized data of Users collected using internet statistics services serve to collect information about User actions on the site, improve the quality of the site and its content.

Legal Grounds for Personal Data Processing

The legal grounds for processing personal data by the Operator are:

list the regulatory legal acts governing relations related to your activity, for example, if your activity is related to information technologies, in particular the creation of websites, then Federal Law “On Information, Information Technologies and Information Protection” of 27.07.2006 N 149-FZ can be specified here;
Operator’s documents;
agreements concluded between the operator and the personal data subject, if any are concluded;
federal laws, other regulatory legal acts in the field of personal data protection; – User consents to the processing of their personal data, to the processing of personal data authorized for dissemination.

The Operator processes User personal data only if they are filled in and/or sent by the User independently through special forms located on the site or sent to the Operator via email. By filling out the relevant forms and/or sending their personal data to the Operator, the User expresses their consent to this Policy.
The Operator processes anonymized data about the User if this is allowed in the User’s browser settings (saving of “cookie” files and the use of JavaScript technology is enabled).

The personal data subject independently decides on the provision of their personal data and gives consent freely, by their own will, and in their own interest.

Conditions for Personal Data Processing

Personal data processing is carried out with the consent of the personal data subject to the processing of their personal data.
Personal data processing is necessary to achieve the goals provided for by an international treaty of the Russian Federation or by law, to carry out the functions, powers, and duties assigned by the legislation of the Russian Federation to the operator.
Personal data processing is necessary for the administration of justice, the execution of a judicial act, an act of another body or official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
Personal data processing is necessary for the performance of a contract to which the personal data subject is a party, beneficiary, or guarantor, as well as for concluding 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.
Personal data processing 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 the rights and freedoms of the personal data subject are not violated.
Personal data is processed to which an unlimited circle of persons has been granted access by the personal data subject or at their request (hereinafter – publicly available personal data).
Personal data subject to publication or mandatory disclosure in accordance with federal law is processed.

Procedure for collection, storage, transfer, and other types of personal data processing The security of personal data processed by the Operator is ensured by implementing legal, organizational, and technical measures necessary to fully comply with the requirements of current legislation in the field of personal data protection.
The Operator ensures the safety of personal data and takes all possible measures excluding access to personal data by unauthorized persons.

The User’s personal data will never, under any circumstances, be transferred to third parties, except in cases related to the execution of current legislation or in case the personal data subject has given consent to the Operator to transfer the data to a third party to fulfill obligations under a civil law contract.

In case of inaccuracies in the personal data, the User can update them independently by sending a notification to the Operator’s email address with the note “Personal Data Update.”

The term of personal data processing is determined by the achievement of the purposes for which the personal data was collected, unless a different term is provided by the contract or current legislation. The User can withdraw their consent to personal data processing at any time by sending a notification to the Operator via email to the Operator’s email address with the note “Withdrawal of consent to personal data processing.”

All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by these persons (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject and/or User must independently and timely familiarize themselves with these documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this paragraph.

Prohibitions established by the personal data subject on the transfer (other than providing access), as well as on the processing or conditions of processing (other than obtaining access) of personal data authorized for dissemination, are not valid in cases of processing personal data in state, public, and other public interests defined by the legislation of the Russian Federation.

The Operator ensures the confidentiality of personal data when processing personal data.

The Operator stores personal data in a form that allows identifying the personal data subject, no longer than required by the purposes of personal data processing, unless the storage period of personal data is established by federal law, a contract, a party to which, a beneficiary or guarantor of which is the personal data subject.

The condition for terminating personal data processing may be the achievement of the purposes of personal data processing, the expiration of the consent of the personal data subject, or the withdrawal of consent by the personal data subject, as well as the detection of unlawful personal data processing.

List of actions performed by the Operator with the received personal data

The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), extracts, uses, transfers (disseminates, provides, accesses), depersonalizes, blocks, deletes, and destroys personal data.

The Operator carries out automated processing of personal data with or without the receipt and/or transfer of the received information via information and telecommunication networks.

Cross-border transfer of personal data is not performed.

Confidentiality of Personal Data The Operator and other persons who have gained access to personal data are obliged not to disclose personal data to third parties or disseminate it without the consent of the personal data subject, unless otherwise provided by federal law.

Final Provisions

The User can receive any necessary clarifications regarding the processing of their personal data by contacting the Operator via the Operator’s email.

Any changes to the Operator’s personal data processing policy will be reflected in this document. The Policy is valid indefinitely until it is replaced by a new version.

The current version of the Policy is freely available on the Internet at the address specified in your browser’s URL.