1. General provisions

This personal data processing policy is drawn up in accordance with the requirements of Federal Law No. 152-FZ dated July 27, 2006, "On Personal Data" (hereinafter referred to as the Personal Data Law), and defines the procedure for processing personal data and the measures taken by LLC "ITC Logistics East" (hereinafter referred to as the Operator) to ensure the security of personal data.
1.1. The Operator's primary goal and condition for carrying out its activities is to respect the rights and freedoms of individuals and to protect their privacy, personal, and family information.
1.2. This Operator's policy regarding the processing of personal data (hereinafter referred to as the "Policy") applies to all information that the Operator may obtain about visitors to the website https://itc-i.com.

2. Basic concepts 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 termination of processing of personal data (except in cases where processing is necessary to clarify personal data).
2.3. A website is a collection of graphic and informational materials, as well as computer programs and databases that make them available on the Internet at a network address https://itc-i.com.
2.4. Personal data information system is a set of personal data contained in databases and information technologies and technical means that ensure their processing.
2.5. Personal data anonymization is an action that makes it impossible to determine, without using additional information, whether personal data belongs to a specific User or another subject of personal data.
2.6. Personal data processing is 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 (update, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
2.7. Operator — a state body, a municipal body, a legal entity, or an individual who organizes and/or carries out the processing of personal data independently or jointly with other persons, as well as determines the purposes of processing personal data, the composition of personal data to be processed, and the actions (operations) performed with personal data.
2.8. Personal data is any information that relates directly or indirectly to a specific or identifiable User of the website https://itc-i.com.
2.9. Personal data authorized by the subject of personal data for distribution is personal data to which an unlimited number of persons have been granted access by the subject of personal data by giving their consent to the processing of personal data authorized by the subject of personal data for distribution in accordance with the Law on Personal Data (hereinafter referred to as personal data authorized for distribution).
2.10. User is any visitor to the website https://itc-i.com.
2.11. Providing personal data is an action aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Dissemination of personal data is any action aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or at making personal data available to an unlimited circle of persons, including the publication of personal data in the media, posting in information and telecommunication networks, or providing access to personal data in any other way.
2.13. Cross-border transfer of personal data is the transfer of personal data to a foreign government agency, a foreign individual, or a foreign legal entity in a foreign country.
2.14. Destruction of personal data — any actions that result in the permanent destruction of personal data, making it impossible to recover the content of personal data in the personal data information system, and/or the destruction of physical media containing personal data.

3. Basic rights and obligations of the Operator

3.1. The Operator has the right to:
— receive reliable information and/or documents containing personal data from the subject of personal data;
— in the event that the subject of personal data revokes their consent to the processing of personal data, or submits a request to terminate the processing of personal data, the Operator may continue to process personal data without the subject of personal data's consent 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 the obligations provided for by the Personal Data Law and the regulations adopted in accordance with it, unless otherwise provided for by the Personal Data Law or other federal laws.
3.2. The operator is obliged to:
— provide the personal data subject with information regarding the processing of their personal data upon request;
— organize the processing of personal data in accordance with the current legislation of the Russian Federation;
— respond to the requests and inquiries of personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
— to report the necessary information to the authorized body for the protection of the rights of personal data subjects upon request of this body within 10 days from the date of receipt of such a request;
— to publish or otherwise provide unlimited access to this Policy regarding the processing of personal data;
— to take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, and distribution of personal data, as well as from other illegal actions regarding personal data;
— to stop the transfer (distribution, provision, access) of personal data, stop the processing, and destroy personal data in accordance with the procedures and cases provided for by the Personal Data Law;
— to fulfill other obligations provided for by the Personal Data Law.

4. Basic rights and obligations of personal data subjects

4.1. Personal data subjects have the right to:
— to receive information regarding the processing of his personal data, except in cases provided for by federal laws. The information is provided to the subject of personal data by the Operator in an accessible form, and it should not contain personal data related to other subjects of personal data, 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;
— to request the operator to clarify its personal data, block it, or destroy it if the personal data is incomplete, outdated, inaccurate, illegally obtained, or not necessary for the stated purpose of processing, and to take legal measures to protect its rights;
— to set a condition of prior consent when processing personal data for the purpose of promoting goods, works, and services on the market;
— to withdraw consent to the processing of personal data, as well as to send a request to terminate the processing of personal data;
— to appeal to the authorized body for the protection of the rights of personal data subjects or to the court for the Operator's unlawful actions or inaction in processing their personal data;
— to exercise other rights provided for by Russian law.
4.2. Personal data subjects are obliged to:
— provide the Operator with reliable information about yourself;
— inform the Operator about the clarification (update, change) of your personal data.
4.3. Persons who provide the Operator with false information about themselves or information about another personal data subject without the latter's consent are liable under Russian law.

5. Principles of personal data processing

5.1. Personal data processing is carried out on a legal and fair basis.
5.2. Personal data processing is limited to achieving specific, predetermined, and legal goals. Personal data processing that is incompatible with the purposes of collecting personal data is not allowed.
5.3. The merging of databases containing personal data that is processed for incompatible purposes is not allowed.
5.4. Only personal data that meets the purposes of processing is subject to processing.
5.5. The content and scope of the processed personal data correspond to the stated purposes of processing. Excessive personal data processing is not allowed in relation to the stated purposes of processing.
5.6. When processing personal data, the accuracy of personal data, its sufficiency, and, if necessary, its relevance to the purposes of processing personal data are ensured. The Operator takes the necessary measures and/or ensures that they are taken to delete or clarify incomplete or inaccurate data.
5.7. Personal data is stored in a form that allows the personal data subject to be identified, for no longer than is necessary for the purposes of processing personal data, unless a federal law or a contract in which the personal data subject is a party, beneficiary, or guarantor requires otherwise. Personal data is destroyed or anonymized once the purposes of processing have been achieved or if it is no longer necessary to achieve those purposes, unless otherwise specified by federal law.

6. Purposes of personal data processing

• last name, first name, patronymic
• email address
• phone numbers

• Federal Law "On Information, Information Technologies, and Information Protection" dated July 27, 2006, No. 149-FZ

• Transfer of personal data

7. Conditions of personal data processing

7.1. Personal data processing is carried out 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 goals provided for by an international treaty of the Russian Federation or by law, to exercise the functions, powers and duties assigned to the operator by the legislation of the Russian Federation.
7.3. Processing of personal data is necessary to exercise justice, to enforce a court order, an act of another body or official, subject to enforcement in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. The processing of personal data is necessary for the execution of a contract in which the subject of personal data is a party, a beneficiary, or a guarantor, as well as for the conclusion of a contract at the initiative of the subject of personal data or a contract in which the subject of personal data will be a beneficiary or a guarantor.
7.5. The processing of personal data is necessary for the exercise of the rights and legitimate interests of the operator or third parties, or for the achievement of socially significant goals, provided that the rights and freedoms of the subject of personal data are not violated.
7.6. Personal data is processed, access to which is granted to an unlimited number of persons by the subject of personal data or at their request (hereinafter referred to as public personal data).
7.7. Personal data is processed that is subject to publication or mandatory disclosure in accordance with federal law.

8. Procedure for collecting, storing, transferring, and other types of processing personal data

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 on the protection of personal data.
8.1. The Operator ensures the safety of personal data and takes all possible measures to prevent unauthorized access to personal data.
8.2. The User's personal data will never be transferred to third parties under any circumstances, except in cases related to the implementation of current legislation or if the subject of personal data has given their consent to the Operator to transfer data to a third party in order to fulfill obligations under a civil law contract.
8.3. In the event of inaccuracies in personal data, the User may update them independently by sending a notification to the Operator at the Operator's email address contact@itc-i.ru with the subject "Updating personal data."
8.4. The period of personal data processing is determined by the achievement of the purposes for which personal data was collected, unless otherwise specified in the contract or applicable law.
The User may withdraw their consent to the processing of personal data at any time by sending a notification to the Operator via email to the Operator's email address contact@itc-i.ru with the subject "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 these parties (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data and/or these documents. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this section.
8.6. The prohibitions on the transfer (except for granting access) and processing (except for obtaining access) of personal data that are permitted for dissemination, established by the personal data subject, do not apply in cases where personal data is processed in the public, social, and other interests defined by the legislation of the Russian Federation.
8.7. The Operator ensures the confidentiality of personal data during the processing.
8.8. The Operator stores personal data in a form that allows the personal data subject to be identified for no longer than necessary for the purposes of processing personal data, unless a federal law or a contract in which the personal data subject is a party, beneficiary, or guarantor requires otherwise.
8.9. The termination of personal data processing may be conditioned on the achievement of the purposes of personal data processing, the expiration of the personal data subject's consent, the withdrawal of personal data subject's consent, or the request to terminate personal data processing, as well as the identification of illegal personal data processing.

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

9.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), retrieves, uses, transfers (distributes, provides, accesses), anonymizes, blocks, deletes, and destroys personal data.
9.2. The Operator carries out automated processing of personal data with or without receiving and/or transmitting the received information via information and telecommunication networks.

10. Cross-border transfer of personal data

10.1. Before carrying out activities related to the cross-border transfer of personal data, the Operator must notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out the cross-border transfer of personal data (such a notification is sent separately from the notification of intention to process personal data).
10.2. Before submitting the above-mentioned notification, the Operator must obtain relevant information from the authorities of a foreign state, foreign individuals, and foreign legal entities to whom the cross-border transfer of personal data is planned.

11. Privacy of personal data

The operator and other persons who have access to personal data are obliged not to disclose or distribute personal data to third parties without the subject's consent, unless otherwise provided by federal law.

12. Final provisions

12.1. The User can obtain any clarifications on the processing of their personal data by contacting the Operator via email contact@itc-i.ru.
12.2. This document will reflect any changes to the Operator's personal data processing policy. The policy is valid indefinitely until it is replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet at https://itc-i.com/en/privacy.