1. General Provisions This Personal Data Processing Policy has been prepared in accordance with the requirements of Federal Law No. 152-FZ “On Personal Data” dated July 27, 2006, hereinafter referred to as the “Personal Data Law,” and defines the procedure for processing personal data and the measures taken to ensure the security of personal data by ООО «Платформа №8», represented by Yuri Nikolaevich Pilipyuk, acting on the basis of the Charter, hereinafter referred to as the “Operator.” 1.1. The Operator considers the protection of human and civil rights and freedoms during the processing of personal data to be one of its most important goals and a necessary condition for carrying out its activities, including the protection of the rights to privacy, personal privacy, and family confidentiality. 1.2. This Policy of the Operator regarding the processing of personal data, hereinafter referred to as the “Policy,” applies to all information that the Operator may receive about visitors to the website https://uplogistics.ru/. 2. Key Terms Used in the Policy 2.1. Automated processing of personal data means the processing of personal data using computer technology. 2.2. Blocking of personal data means the temporary suspension of personal data processing, except in cases where processing is necessary to clarify personal data. 2.3. Website means a collection of graphic and informational materials, as well as computer programs and databases, that ensure their availability on the Internet at the network address https://uplogistics.ru/. 2.4. Personal data information system means a set of personal data contained in databases, together with information technologies and technical tools that enable the processing of such data. 2.5. Depersonalization of personal data means actions that make it impossible to determine, without the use of additional information, whether personal data belongs to a specific User or another personal data subject. 2.6. Processing of personal data means any action or set of actions performed with personal data, with or without the use of automated means, including collection, recording, systematization, accumulation, storage, clarification, including updating and modification, extraction, use, transfer, including distribution, provision and access, depersonalization, blocking, deletion, and destruction of personal data. 2.7. Operator means a government authority, municipal authority, legal entity, or individual who independently or jointly with other persons organizes and/or carries out the processing of personal data, and also determines the purposes of personal data processing, the composition of personal data to be processed, and the actions or operations performed with personal data. 2.8. Personal data means any information relating directly or indirectly to an identified or identifiable User of the website https://uplogistics.ru/. 2.9. User means any visitor to the website https://uplogistics.ru/. 2.10. Provision of personal data means actions aimed at disclosing personal data to a specific person or a specific group of persons. 2.11. Destruction of personal data means any actions resulting in the irreversible destruction of personal data, making it impossible to restore the content of personal data in the personal data information system, and/or the destruction of physical media containing personal data. 3. Main 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 personal data subject; — if the personal data subject withdraws consent to the processing of personal data, or submits a request to stop 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 Personal Data Law; — independently determine the composition and list of measures necessary and sufficient to ensure compliance with the obligations provided for by the Personal Data Law and the regulatory legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws. 3.2. The Operator is obligated to: — provide the personal data subject, upon 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 inquiries and requests from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law; — provide the authorized body for the protection of the rights of personal data subjects, upon request, with the necessary information within 10 days from the date of receipt of such request; — publish or otherwise provide unrestricted access to this Personal Data Processing Policy; — take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, distribution, and other unlawful actions involving personal data; — stop the transfer, including distribution, provision and access, of personal data, stop processing personal data, and destroy personal data in the manner and in the cases provided for by the Personal Data Law; — fulfill other obligations provided for by the Personal Data Law. 4. Main Rights and Obligations of Personal Data Subjects 4.1. Personal data subjects have the right to: — receive information concerning the processing of their personal data, except in cases provided for by federal laws. Such information shall be provided by the Operator to the personal data subject in an accessible form and shall 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 Personal Data Law; — require the Operator to clarify their personal data, block it, or destroy it if the personal data is incomplete, outdated, inaccurate, unlawfully obtained, or no longer necessary for the stated purpose of processing, as well as to take measures provided by law to protect their rights; — impose the condition of prior consent when personal data is processed for the purpose of promoting goods, works, and services on the market; — withdraw consent to the processing of personal data and submit a request to stop the processing of personal data; — appeal unlawful actions or inaction of the Operator in the processing of personal data 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. 4.2. Personal data subjects are obligated to: — provide the Operator with accurate information about themselves; — notify the Operator of any clarification, update, or change to their personal data. 4.3. Persons who provide the Operator with inaccurate information about themselves, or information about another personal data subject without that subject’s consent, shall bear liability in accordance with the legislation of the Russian Federation. 5. Principles of Personal Data Processing 5.1. Personal data shall be processed on a lawful and fair basis. 5.2. Personal data processing shall be limited to achieving specific, predetermined, and lawful purposes. Processing personal data in a manner incompatible with the purposes for which the personal data was collected is not permitted. 5.3. Databases containing personal data processed for incompatible purposes shall not be combined. 5.4. Only personal data that meets the purposes of its processing shall be processed. 5.5. The content and volume of personal data being processed shall correspond to the stated purposes of processing. Excessive processing of personal data in relation to the stated purposes of its processing is not permitted. 5.6. During the processing of personal data, the accuracy of personal data, its sufficiency, and, where necessary, its relevance in relation to the purposes of personal data processing shall be ensured. The Operator shall take necessary measures and/or ensure that such measures are taken to delete or clarify incomplete or inaccurate data. 5.7. Personal data shall be stored in a form that allows identification of the personal data subject for no longer than required by the purposes of personal data processing, unless the storage period for personal data is established by federal law or by an agreement to which the personal data subject is a party, beneficiary, or guarantor. Processed personal data shall be destroyed or depersonalized once the purposes of processing have been achieved or if the need to achieve such purposes no longer exists, unless otherwise provided by federal law. 6. Purposes of Personal Data Processing The purpose of processing is to identify the User when fulfilling the Public Offer for the distance sale of goods and contracts with the Company; to send a cash receipt in electronic form to the User’s email address and/or phone number; to provide the User with personalized Services; to communicate with the User, including sending notifications, requests, and information related to the use of the Services, the provision of services for ordering and delivering the Company’s goods, as well as processing User inquiries and requests; to improve the quality of the Services, the convenience of their use, and the development of new Services and offerings; to advertise the Company’s goods and services; to conduct statistical and other research based on the data provided; and for other purposes that do not contradict the current legislation of the Russian Federation. Personal data:
last name, first name, patronymic;
phone numbers;
city, street, building, building block, entrance, intercom, floor, apartment/office.
Legal grounds: Federal Law No. 149-FZ “On Information, Information Technologies and Information Protection” dated July 27, 2006; Federal Law No. 152-FZ “On Personal Data” dated July 27, 2006; Resolution No. 1119 dated November 1, 2012 “On Approval of Requirements for the Protection of Personal Data When Processing Such Data in Personal Data Information Systems”; Order of the Federal Service for Technical and Export Control of Russia No. 21 dated February 18, 2013 “On Approval of the Composition and Content of Organizational and Technical Measures to Ensure the Security of Personal Data When Processing Such Data in Personal Data Information Systems”; other regulatory legal acts of the Russian Federation and regulatory documents of authorized government bodies; local regulatory acts of the Operator; and consent of the personal data subject to the processing of personal data. The Website collects only the personal data necessary to provide services or fulfill agreements and contracts with the User, except in cases where the legislation of the Russian Federation requires the mandatory storage of personal data for a period established by law. Types of personal data processing: Collection, recording, systematization, accumulation, storage, and destruction of personal data. 7. Conditions for Personal Data Processing 7.1. Personal data shall be processed with the consent of the personal data subject to the processing of their personal data. 7.2. Personal data processing is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, and to exercise the functions, powers, and duties imposed on the Operator by the legislation of the Russian Federation. 7.3. Personal data processing is necessary for the performance of an agreement to which the personal data subject is a party, beneficiary, or guarantor, as well as for entering into an agreement at the initiative of the personal data subject or an agreement under which the personal data subject will be a beneficiary or guarantor. 8. 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. 8.1. The Operator ensures the safety of personal data and takes all possible measures to prevent unauthorized persons from accessing personal data. 8.2. The User’s personal data shall never, under any circumstances, be transferred to third parties, except in cases related to compliance with current legislation or where the personal data subject has given the Operator consent to transfer data to a third party for the performance of obligations under a civil law agreement. 8.3. If inaccuracies in personal data are identified, the User may update such data independently by sending a notification to the Operator’s email address at minutto@mail.ru with the subject line “Personal Data Update.” 8.4. The period of personal data processing is 5 years from the date for which the personal data was collected, unless another period is provided by an agreement or current legislation. The User may withdraw their consent to the processing of personal data at any time by sending the Operator a notification by email to minutto@mail.ru with the subject line “Withdrawal of Consent to 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 such persons, acting as Operators, in accordance with their User Agreement and Privacy Policy. The personal data subject and/or User is responsible for reviewing such documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause. 8.6. Restrictions established by the personal data subject on the transfer, except for granting access, as well as on the processing or conditions of processing, except for obtaining access, of personal data permitted for distribution shall not apply in cases where personal data is processed in state, public, or other public interests as defined by the legislation of the Russian Federation. 8.7. When processing personal data, the Operator ensures the confidentiality of personal data. 8.8. The Operator stores personal data in a form that makes it possible to identify the personal data subject for no longer than required by the purposes of personal data processing, unless the storage period for personal data is established by federal law or by an agreement to which the personal data subject is a party, beneficiary, or guarantor. 8.9. Grounds for termination of personal data processing may include the achievement of the purposes of personal data processing, expiration of the personal data subject’s consent, withdrawal of consent by the personal data subject or a request to stop personal data processing, as well as the detection of unlawful personal data processing. 9. List of Actions Performed by the Operator with the Personal Data Received 9.1. The Operator carries out the collection, recording, systematization, accumulation, storage, clarification, including updating and modification, extraction, use, transfer, including distribution, provision and access, depersonalization, blocking, deletion, and destruction of personal data. 9.2. The Operator carries out automated processing of personal data with or without receiving and/or transferring the information obtained through information and telecommunications networks. 10. Confidentiality of Personal Data The Operator and other persons who have gained access to personal data are obligated not to disclose personal data to third parties and not to distribute personal data without the consent of the personal data subject, unless otherwise provided by federal law. 11. Final Provisions 11.1. The User may obtain any clarification on questions concerning the processing of their personal data by contacting the Operator by email at minutto@mail.ru. 11.2. Any changes to the Operator’s Personal Data Processing Policy will be reflected in this document. The Policy remains valid indefinitely until replaced by a new version. 11.3. The current version of the Policy is freely available on the Internet at https://uplogistics.ru/en/policy.