PERSONAL DATA PROCESSING POLICY
для сайта www.ace-moving.ru
General provisions
This Personal Data Processing Policy (hereinafter referred to as the Policy) defines the procedure for processing personal data and measures to ensure the security of personal data taken by the Limited Liability Company "As International Muving" (hereinafter referred to as the Operator).
The policy is developed in accordance with the requirements of:
Constitution of the Russian Federation;
Federal Law dated 27.07.2006 No. 152-FZ "On Personal Data";
Federal Law of 27.07.2006 No. 149-FZ "On Information, Information Technologies and Information Protection";
other regulatory legal acts of the Russian Federation in the field of processing and protection of personal data.
This Policy applies to all information that the Operator may receive about visitors to the www.ace-moving.ru website (hereinafter referred to as the Website).
Using the Site means familiarizing the User with this Policy.
The provision of personal data by the User through the forms of the Site is carried out voluntarily and is confirmed by marking (checkbox) the consent to the processing of personal data.
The policy applies to all personal data received by the Operator both using automation tools and without their use.
The Operator shall process personal data in accordance with the following principles:
legality;
equity;
limiting processing to specific goals;
minimizing the amount of data processed;
reliability of personal data;
ensuring their safety;
preventing data processing incompatible with the stated purposes.
Information about the operator of personal data
Personal data operator:
As International Muving Limited Liability Company
Registered office:
115372
40 Lipetskaya str., office 400, Moscow
Site address:
https://www.ace-moving.ru
Personal data processing e-mail address: info@ace-moving.ru
Tax ID: 7717659512
OGRN: 1097746579798
Responsible person for organization of personal data processing (if any):
Basic terms and definitions
The following terms are used in this Policy.
Personal Data means any information relating directly or indirectly to a particular or identifiable individual.
Personal data processing - any action or combination of actions with personal data performed using automation tools or without using such tools.
Processing includes:
collection;
recording;
systematization;
accumulation;
storage;
clarification (update, change);
extraction;
use;
transmission;
provision;
access;
depersonalization;
blocking;
removal;
destruction.
The operator is As International Muving LLC, which independently organizes the processing of personal data and determines the purpose of such processing.
User means any individual visiting the Site.
Automated processing of personal data - processing using computer technology.
Personal data blocking - temporary termination of personal data processing.
Destruction of personal data - actions as a result of which it becomes impossible to restore the content of personal data.
Depersonalization of personal data - actions in which it is impossible to determine the ownership of personal data to a specific subject without using additional information.
Legal grounds for personal data processing
4.1. The operator processes personal data in accordance with the requirements of the legislation of the Russian Federation.
4.2. The legal grounds for processing personal data are:
Constitution of the Russian Federation;
Civil Code of the Russian Federation;
Federal Law No. 27.07.2006 of 152-FZ "On Personal Data";
Federal Law of 27.07.2006 No. 149-FZ "On Information, Information Technologies and Information Protection";
other regulatory legal acts of the Russian Federation;
consent of the personal data subject to the processing of his/her personal data;
contracts concluded between the Operator and the personal data subject, as well as actions initiated by the personal data subject prior to the conclusion of the contract;
legitimate interests of the Operator in cases stipulated by the legislation of the Russian Federation.
4.3. Processing of personal data is carried out only if there are legal grounds and only to the extent necessary to achieve the stated goals.
4.4. The operator does not process special categories of personal data (information about the state of health, race and nationality, political views, religious beliefs, intimate life), unless such processing is directly provided for by the legislation of the Russian Federation.
4.5. The operator does not process biometric personal data, unless otherwise provided by the legislation of the Russian Federation or a separate written consent of the personal data subject.
Categories of personal data subjects
5.1. This Policy applies to the processing of personal data of the following categories of subjects:
site users;
individuals who sent appeals through feedback forms;
Operator's clients;
representatives of legal entities;
persons seeking advice;
persons who sent requests by e-mail or by phone.
5.2. The operator does not purposefully collect personal data of minors.
5.3. If the personal data of a minor were provided without the consent of his legal representative, the Operator has the right to delete such data after receiving the relevant appeal or if the specified fact is revealed.
Categories and list of processed personal data
6.1 Depending on the purposes of processing, the Operator may process the following personal data:
6.1.1 Data provided by the User independently:
surname;
name;
middle name;
phone number;
email address;
loading address;
delivery address;
country, city and other information about the transportation route;
content of the appeal;
information on the transported property (if it is necessary to calculate the cost of services);
other information voluntarily provided by the User.
6.1.2. Data obtained automatically
When visiting the Site, the following information can be automatically processed:
IP address;
Browser information
information about the operating system;
device type;
screen resolution;
browser language;
date and time of visit;
Site navigation source
addresses of visited pages;
duration of visit;
User's actions on the Site;
Cookie data
technical identifiers of the device.
6.1.3. Operator does not process
special categories of personal data;
biometric personal data;
personal data not related to the stated purposes of processing.
Purposes of personal data processing
The operator processes personal data solely to achieve legitimate goals.
These goals include:
7.1 Processing of Users "requests
including:
registration of requests;
preparation of responses;
provision of advice;
organization of feedback.
7.2. Calculation of the cost of services
including:
obtaining transportation information;
preparation of a preliminary quotation;
calculation of the cost of services;
agreement on the terms of services.
7.3. Conclusion and execution of contracts
including:
execution of contracts;
fulfillment of obligations;
customer support;
execution of documents;
interaction on contract execution issues.
7.4. Improving the quality of the site
including:
analysis of attendance;
improved usability of the site;
elimination of technical errors;
site security;
conducting statistical studies.
7.5. Compliance with the requirements of the legislation of the Russian Federation
in cases where the processing of personal data is necessary to fulfill the duties imposed by the legislation of the Russian Federation.
7.6. Protection of the Operator's legitimate interests
including:
fraud prevention;
ensuring information security;
review of claims;
protection of the Operator's rights in court and out of court.
7.7. Information interaction with the User
If there is a separate consent of the User, the Operator may send:
responses to appeals;
notifications about the progress of the application;
information on changes in the services provided;
information messages related to the execution of the contract.
Important: advertising and marketing mailings should be carried out only with the separate consent of the User, if such consent is required by law.
Procedure and conditions of personal data processing
8.1. General provisions
Personal data are processed by the Operator in accordance with the requirements of the legislation of the Russian Federation on the principles of:
legality and justice;
limiting processing to specific, predetermined and legitimate purposes;
preventing processing of personal data incompatible with the purposes of their collection;
compliance of the volume and content of processed personal data with the stated purposes of processing;
ensuring the accuracy, sufficiency and relevance of personal data;
storage of personal data for no longer than required by the purposes of processing, unless otherwise established by the legislation of the Russian Federation.
8.2. Methods of personal data processing
The operator processes personal data:
using automation tools;
without the use of automation tools;
in a mixed way.
8.3. Operations with personal data
In the process of processing personal data, the Operator has the right to perform the following actions:
collection;
recording;
systematization;
accumulation;
storage;
clarification (update, change);
extraction;
use;
transfer (provision, access) in cases provided for by the legislation of the Russian Federation;
depersonalization;
blocking;
removal;
destruction.
8.4. Term of personal data processing
Personal data are processed until the goals of their processing are achieved or until the personal data subject withdraws his consent, unless otherwise provided by the legislation of the Russian Federation.
Documents containing personal data may be stored within the terms established by the legislation of the Russian Federation, including the legislation on archiving, accounting and tax legislation.
8.5. Termination of personal data processing
Processing of personal data is terminated:
once the processing objectives have been achieved;
upon withdrawal of consent by the personal data subject, if there are no other legal grounds for processing;
in case of detection of illegal processing of personal data;
in case of liquidation of the Operator;
in other cases stipulated by the legislation of the Russian Federation.
8.6. Destruction of personal data
After achieving the processing goals or upon occurrence of other grounds for termination of processing, personal data are subject to destruction or depersonalization, if their further storage is not required in accordance with the legislation of the Russian Federation.
Using Cookies and Analytics Services
9.1.
The site uses cookies and similar technologies to ensure the correct operation of the site, improve its usability, analyze traffic and improve the services provided.
9.2.
Cookies may contain the following information:
User ID
Browser information
Device information
work session information;
User preferences
technical parameters of connection.
9.3.
The operator can use the following cookie categories:
mandatory;
functional;
analytical;
technical.
9.4.
The user has the right to independently change the settings of his browser in such a way as to:
completely prohibit the use of cookies;
receive notifications about their use;
delete previously saved Cookies.
It should be borne in mind that disabling Cookie may lead to incorrect operation of certain functions of the Site.
9.5.
Web analytics systems such as Yandex Metric and other similar services can be used to analyze site traffic if they are connected to the site.
When using such services, data processing is carried out in accordance with the legislation of the Russian Federation and the policies of the relevant services.
Transfer of personal data to third parties
10.1.
The operator ensures the confidentiality of personal data and does not disclose them to third parties without legal grounds.
10.2.
Transfer of personal data is allowed:
with the consent of the personal data subject;
at the request of state bodies in cases provided for by the legislation of the Russian Federation;
to perform the contract to which the personal data subject is a party;
in other cases stipulated by the legislation of the Russian Federation.
10.3.
The operator has the right to entrust the processing of personal data to a third party on the basis of an agreement.
Such person shall:
comply with the requirements of the legislation of the Russian Federation;
ensure confidentiality of personal data;
take necessary measures to protect personal data;
use personal data solely for the purpose of performing the contract with the Operator.
10.4.
If the site uses third-party services (for example, CRM systems, telephony services, mail services, online chat systems), the processing of personal data by such services is carried out in accordance with the concluded contracts and applicable law.
10.5.
The operator does not sell, exchange or otherwise provide personal data to third parties.
Measures to ensure the security of personal data
11.1.
The Operator shall take the necessary organizational and technical measures to protect personal data from:
illegal access;
destruction;
changes;
blocking;
copying;
distribution;
other illegal actions.
11.2.
To protect personal data, the Operator has the right to use:
access rights delimitation;
use of anti-virus software;
use of information protection tools;
data backup;
control of access to information systems;
use of protected information transmission channels;
Logging of security events
regular software updates.
11.3.
Only employees of the Operator or persons engaged under the contract who need such information to fulfill their duties are allowed to process personal data.
These persons are obliged to comply with the requirements of the legislation of the Russian Federation on personal data and information confidentiality.
11.4.
The Operator shall exercise internal control over compliance of personal data processing with the requirements of the legislation of the Russian Federation and local regulations.
11.5.
If illegal access to personal data is revealed, the Operator shall take measures to eliminate the consequences of such access and, if necessary, notify the authorized bodies and personal data subjects in the manner prescribed by the legislation of the Russian Federation.
Rights of personal data subjects
12.1. The personal data subject has the right to:
receive information regarding the processing of his personal data in cases and in the manner prescribed by the legislation of the Russian Federation;
demand clarification of their personal data if they are incomplete, outdated, inaccurate or processed in violation of the law;
require the blocking or destruction of personal data if they are no longer necessary for the stated purposes of processing or are processed illegally;
withdraw the previous consent to the processing of personal data;
object to the processing of personal data in cases provided for by the legislation of the Russian Federation;
appeal against the actions (inaction) of the Operator to the authorized body for the protection of the rights of personal data subjects or in court;
exercise other rights provided for by the legislation of the Russian Federation.
12.2. Obtaining information
The personal data subject has the right to request information from the Operator regarding the processing of his personal data, including:
confirmation of personal data processing;
legal grounds and purposes of processing;
processing methods;
information on applied protection measures;
list of processed personal data;
sources of obtaining personal data (unless otherwise established by law);
terms of processing and storage of personal data;
information on persons to whom personal data may be transferred;
other information provided for by the legislation of the Russian Federation.
12.3. Procedure for consideration of appeals
Appeals of personal data subjects shall be considered by the Operator within the terms and in accordance with the procedure established by the legislation of the Russian Federation.
If necessary, the Operator has the right to request information confirming the identity of the applicant or his powers as a representative.
Procedure for revoking consent to personal data processing
13.1.
The personal data subject has the right at any time to revoke the previously given consent to the processing of personal data.
13.2.
Withdrawal of consent may be directed to:
in writing at the Operator's address;
in electronic form to the email address specified in this Policy;
in another way that allows to reliably establish the fact of the referral.
13.3.
After receiving an application for withdrawal of consent, the Operator stops processing personal data and ensures their destruction or depersonalization, if there are no other legal grounds for continuing processing.
13.4.
Withdrawal of consent does not affect the legality of the processing of personal data carried out before receiving such a withdrawal.
Cross-border transfer of personal data
14.1.
The Operator shall transfer personal data across borders only in cases and in the manner prescribed by the legislation of the Russian Federation.
14.2.
Prior to the start of cross-border transfer of personal data, the Operator shall take measures to comply with the requirements of the legislation of the Russian Federation, including an assessment of ensuring proper protection of the rights of personal data subjects in the state to whose territory the transfer is intended.
14.3.
If cross-border transfer of personal data is not performed in the course of the Operator's activities, such transfer is not performed.
Privacy of personal data
15.1.
The Operator and other persons who have gained access to personal data shall not disclose or distribute personal data without the consent of the personal data subject, unless otherwise provided by the legislation of the Russian Federation.
15.2.
Persons admitted to the processing of personal data are obliged to observe the confidentiality regime in relation to information that became known to them in the performance of their official duties.
Policy Change
16.1.
The Operator may amend this Policy at any time.
16.2.
The new version of the Policy comes into force from the moment of its publication on the Site, unless otherwise provided by the new version.
16.3.
Users are advised to familiarize themselves with the current version of the Policy every time they visit the Site.
Operator Contact Information
Operator:
As International Muving Limited Liability Company
Registered office:
115372
40 Lipetskaya str., office 400, Moscow
Site:
https://www.ace-moving.ru
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