Data processing policy

1. General Provisions

This Personal Data Processing Policy is drafted in accordance with Federal Law No. 152‑FZ of July 27, 2006 “On Personal Data” (hereinafter – the Personal Data Law) and defines the procedure for processing personal data and measures to ensure the security of personal data implemented by LLC “SV‑Logistik” (hereinafter – the Operator).

1.1. The Operator considers observance of human and civil rights and freedoms in the processing of personal data, including protection of the right to privacy, personal and family confidentiality, to be its highest priority and essential condition for carrying out its activities.

1.2. This Policy of the Operator regarding the processing of personal data (hereinafter – the Policy) applies to all information that the Operator may obtain about visitors of the website https://turkeyrussia.com/.

2. Basic Terms Used in the Policy

2.1. Automated processing of personal data – processing of personal data by means of computer technology.

2.2. Blocking of personal data – temporary suspension of processing of personal data (except where processing is necessary for clarification of personal data).

2.3. Website – a set of graphic and information materials, as well as software and databases ensuring their availability on the Internet at the network address https://turkeyrussia.com/.

2.4. Personal data information system – a set of personal data contained in databases, and the information technologies and technical means that ensure their processing.

2.5. Anonymization of personal data – actions that result in it being impossible, without the use of additional information, to determine whether personal data belongs to a specific User or another subject of personal data.

2.6. Processing of personal data – any action (operation) or set of actions (operations) performed, with or without the use of automation tools, on personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), anonymization, blocking, deletion and destruction of personal data.

2.7. Operator – a state body, municipal body, legal or natural person which, independently or jointly with other persons, organizes and/or carries out processing of personal data, as well as determines the purposes of personal data processing, 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 specific or identifiable User of the website https://turkeyrussia.com/.

2.9. Personal data permitted for dissemination by the subject of personal data – personal data to which access of an unlimited number of persons is granted by the subject of personal data by giving consent to the processing of personal data permitted for dissemination in accordance with the procedure established by the Personal Data Law (hereinafter – personal data permitted for dissemination).

2.10. User – any visitor of the website https://turkeyrussia.com/.

2.11. Provision of personal data – actions aimed at disclosing personal data to a specific person or a specific circle of persons.

2.12. Dissemination of personal data – any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or at familiarizing an indefinite number of persons with personal data, including publishing personal data in mass media, posting them in information and telecommunication networks, or providing access to personal data in any other way.

2.13. Cross‑border transfer of personal data – transfer of personal data to the territory of a foreign state to a foreign state authority, a foreign natural person, or a foreign legal entity.

2.14. Destruction of personal data – any actions resulting in personal data being destroyed irreversibly with no possibility of restoring the content of personal data in the personal data information system and/or resulting in destruction of material media containing personal data.

3. Basic Rights and Obligations of the Operator

3.1. The Operator has the right to:
– receive from the subject of personal data reliable information and/or documents containing personal data;
– upon withdrawal by the subject of personal data of consent to the processing of personal data, as well as upon receipt of a request demanding termination of processing of personal data, continue processing of personal data without consent of the subject of personal data where there are grounds specified in the Personal Data Law;
– independently determine the composition and list of measures necessary and sufficient to ensure fulfillment of the obligations stipulated by the Personal Data Law and regulations adopted pursuant to it, unless otherwise provided by the Personal Data Law or other federal laws.

3.2. The Operator is obliged to:
– provide the subject of personal data, upon his/her request, with information relating to the processing of his/her personal data;
– organize the processing of personal data in accordance with the current legislation of the Russian Federation;
– respond to requests and inquiries of subjects of personal data 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 subjects of personal data, upon its request, with the necessary information within 10 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, destruction, modification, blocking, copying, provision, dissemination, as well as from other unlawful actions in relation to personal data;
– cease transfer (dissemination, provision, access) of personal data, terminate processing and destroy personal data in the manner and cases provided for by the Personal Data Law;
– perform other obligations stipulated by the Personal Data Law.

4. Basic Rights and Obligations of Subjects of Personal Data

4.1. Subjects of personal data have the right to:
– receive information relating to the processing of their personal data, except in cases provided for by federal laws. Such information shall be provided by the Operator to the subject of personal data in an accessible form and must not contain personal data relating to other subjects of personal data, except where there are lawful grounds for disclosure of such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
– demand that the Operator clarify their personal data, block or destroy them if personal data are incomplete, outdated, inaccurate, unlawfully obtained, or are not necessary for the stated purpose of processing, as well as take measures provided by law to protect their rights;
– stipulate a condition for prior consent when personal data are processed for the purposes of promoting goods, works and services on the market;
– withdraw consent to the processing of personal data and send a demand to terminate processing of personal data;
– appeal to the authorized body for the protection of the rights of subjects of personal data or to a court against unlawful actions or inaction of the Operator in the processing of personal data;
– exercise other rights provided by the legislation of the Russian Federation.

4.2. Subjects of personal data are obliged to:
– provide the Operator with reliable information about themselves;
– notify the Operator about clarification (updating, modification) of their personal data.

4.3. Persons who have provided the Operator with false information about themselves or information about another subject of personal data without the consent of that subject bear liability in accordance with the legislation of the Russian Federation.

5. Principles of Personal Data Processing

5.1. Processing of personal data is carried out on a lawful and fair basis.

5.2. Processing of personal data is limited to achieving specific, predetermined and lawful purposes. Processing of personal data that is incompatible with the purposes of collecting personal data is not allowed.

5.3. It is not allowed to combine databases containing personal data if such processing is carried out for purposes that are incompatible with each other.

5.4. Only personal data that meet the purposes of their processing are subject to processing.

5.5. The content and volume of personal data being processed must correspond to the stated purposes of processing. Excessive personal data in relation to the stated purposes of their processing is not allowed.

5.6. In processing personal data, accuracy of personal data, their sufficiency and, where necessary, relevance with respect to the purposes of personal data processing shall be ensured. The Operator takes necessary measures and/or ensures that such measures are taken to remove or clarify incomplete or inaccurate data.

5.7. Personal data shall be stored in a form that allows identifying the subject of personal data no longer than required by the purposes of personal data processing, unless the period of storage of personal data is established by federal law, by a contract to which the subject of personal data is a party, beneficiary or guarantor. Processed personal data shall be destroyed or anonymized upon achievement of the purposes of processing or in case of loss of necessity to achieve these purposes, unless otherwise provided by federal law.

6. Purposes of Personal Data Processing

Purpose of processing:
informing the User by sending e‑mails.

Personal data:
telephone numbers.

Legal grounds:
the Operator’s constituent (founding) documents.

Types of personal data processing:
collection, recording, systematization, accumulation, storage, destruction and anonymization of personal data.

7. Conditions for Personal Data Processing

7.1. Personal data are processed with the consent of the subject of personal data to the processing of his/her 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 perform the functions, powers and duties imposed on the Operator by the legislation of the Russian Federation.

7.3. Processing of personal data is necessary for the administration of justice, execution of a court 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 performance of a contract to which the subject of personal data is a party, beneficiary or guarantor, and also for the conclusion of a contract on the initiative of the subject of personal data or a contract under which the subject of personal data 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 the achievement of socially significant purposes, provided that the rights and freedoms of the subject of personal data are not violated.

7.6. Personal data for which access of an unlimited number of persons is provided by the subject of personal data or upon his/her request (publicly available personal data) are processed.

7.7. Personal data subject to publication or mandatory disclosure in accordance with federal law are processed.

8. Procedure for Collection, Storage, Transfer and Other Processing of Personal Data

The security of personal data processed by the Operator is ensured by implementation of legal, organizational and technical measures necessary to fully comply with the requirements of the applicable 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 access to personal data.

8.2. Personal data of the User shall never, under any circumstances, be transferred to third parties, except for cases related to compliance with the current legislation or if the subject of personal data has given the Operator consent to transfer the data to a third party for the purpose of fulfilling obligations under a civil‑law contract.

8.3. If inaccuracies in personal data are discovered, the User may update them independently by sending the Operator a notification to the Operator’s e‑mail address svlojistik@mail.ru with the note “Updating personal data”.

8.4. The period of personal data processing is determined by the achievement of the purposes for which personal data were collected, unless another period is provided for by a contract or by the applicable legislation.
The User may withdraw his/her consent to the processing of personal data at any time by sending the Operator a notification by e‑mail to the Operator’s e‑mail address svlojistik@mail.ru with the note “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 parties (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data shall familiarize himself/herself with the said documents. The Operator is not responsible for the actions of third parties, including service providers specified in this clause.

8.6. Restrictions established by the subject of personal data on transfer (other than granting access), as well as on processing or conditions of processing (other than obtaining access) of personal data permitted for dissemination, do not apply in cases of processing personal data in state, public and other public interests defined by the legislation of the Russian Federation.

8.7. In processing personal data, the Operator ensures the confidentiality of personal data.

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

8.9. Grounds for termination of personal data processing may include achievement of the purposes of personal data processing, expiry of the consent of the subject of personal data, withdrawal of consent by the subject of personal data or a demand to terminate processing of personal data, as well as identification of unlawful processing of personal data.

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

9.1. The Operator carries out collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), anonymization, blocking, deletion and destruction of personal data.

9.2. The Operator performs automated processing of personal data with the receipt and/or transfer of the obtained information via information and telecommunication networks or without such networks.

10. Cross‑Border Transfer of Personal Data

10.1. Before starting cross‑border transfer of personal data, the Operator must notify the authorized body for the protection of the rights of subjects of personal data of its intention to perform cross‑border transfer of personal data (such notification is sent separately from the notification of the intention to process personal data).

10.2. Prior to submitting the above notification, the Operator must obtain the relevant information from the authorities of the foreign state, foreign natural persons and foreign legal entities to whom the cross‑border transfer of personal data is planned.

11. 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 and not to disseminate personal data without the consent of the subject of personal data, unless otherwise provided by federal law.

12. Final Provisions

12.1. The User may obtain any clarifications on matters relating to the processing of his/her personal data by contacting the Operator via e‑mail at svlojistik@mail.ru.

12.2. Any changes to the Operator’s personal data processing policy will be reflected in this document. The Policy is valid for an indefinite period until it is replaced with a new version.

12.3. The current version of the Policy is freely available on the Internet at:
https://turkeyrussia.com/en/privacy-policy/