Privacy Policy of Transportnaya Kompaniya Avtologistika LLC regarding the processing of personal data

1. GENERAL PROVISIONS

1.1. This Policy of Transportnaya Kompaniya Avtologistika LLC (hereinafter referred to as the "Policy") is developed in accordance with the requirements of Part 1, Article 18.1 of the Federal Law No. 152-FZ dated July 27, 2006 "On Personal Data" to protect human rights and freedoms when processing their personal data, including the right to privacy, personal and family secrets.
1.2. The Policy applies to all personal data processed by Transportnaya Kompaniya Avtologistika LLC (hereinafter referred to as the "Operator").
1.3. The Policy covers relations in the field of personal data processing that arose with the Operator both before and after the approval of this Policy.
1.4. In accordance with the requirements of Part 2, Article 18.1 of the Law on Personal Data, this Policy is published in free access on the Operator's website at busfer.ru/policy.
1.5. Basic terms used in the Policy:

• Personal data - any information relating to a directly or indirectly identified or identifiable individual;
• Operator - Transportnaya Kompaniya Avtologistika LLC, which independently or jointly with others organizes and/or carries out the processing of personal data;
• Processing of personal data - any action or set of actions performed with personal data;
• Automated processing - processing using computer technology;
• Distribution of personal data - actions aimed at disclosing personal data to an indefinite circle of persons;
• Provision of personal data - actions aimed at disclosing personal data to a specific person or circle of persons;
• Blocking of personal data - temporary cessation of processing;
• Destruction of personal data - actions making it impossible to restore personal data;
• Depersonalization - actions making it impossible to determine ownership of personal data without additional information;
• Personal data information system - a set of personal data contained in databases and information technologies ensuring their processing.

1.6. The Operator has the right to:

• Determine the composition of measures necessary to fulfill obligations under the Law on Personal Data;
• Entrust processing to another person with the subject's consent;
• Continue processing without consent if there are grounds provided by law.

1.7. The Operator must:

• Organize processing in accordance with legal requirements;
• Respond to appeals and requests from personal data subjects;
• Provide necessary information to Roskomnadzor upon request.

1.8. The personal data subject has the right to:

• Receive information about the processing of their personal data;
• Demand clarification, blocking, or destruction of incomplete, outdated, or inaccurate data;
• Give preliminary consent for marketing purposes;
• Appeal the Operator's actions to Roskomnadzor or in court.

1.9. Control over compliance with this Policy is carried out by the authorized person responsible for organizing personal data processing.
1.10. Processing of personal data is carried out based on the principles of:

• Lawfulness and fairness;
• Purpose limitation;
• Data minimization;
• Accuracy;
• Storage limitation;
• Integrity and confidentiality.

2. PURPOSES OF PERSONAL DATA PROCESSING
2.1. Processing is limited to achieving specific, predetermined lawful purposes.
2.2. Only personal data relevant to the processing purposes is processed.
2.3. The Operator processes personal data for the following purposes:

• Conducting activities in accordance with the charter, including concluding and executing contracts for transportation services;
• Ensuring compliance with labor legislation;
• Maintaining personnel and accounting records;
• Ensuring compliance with tax and pension legislation.

3. LEGAL BASIS FOR PERSONAL DATA PROCESSING
3.1. The legal basis includes:

• Constitution of the Russian Federation;
• Civil Code;
• Labor Code;
• Tax Code;
• Federal laws governing the Operator's activities.

3.2. Additional legal bases:

• Charter of Transportnaya Kompaniya Avtologistika LLC;
• Contracts with personal data subjects;
• Consent of personal data subjects.

4. SCOPE AND CATEGORIES OF PROCESSED PERSONAL DATA
4.1. The content and volume of processed personal data must correspond to the stated purposes.
4.2. The Operator processes personal data of the following categories:

• Job candidates;
• Employees and former employees;
• Family members of employees;
• Clients and contractors;
• Website visitors.

4.3. The Operator does not process special categories of personal data except as provided by law.

5. PROCEDURE AND CONDITIONS FOR PERSONAL DATA PROCESSING
5.1. Processing is carried out in accordance with Russian legislation.
5.2. Processing is carried out with the subject's consent or without it in cases provided by law.
5.3. The Operator takes necessary legal, organizational, and technical measures to protect personal data.
5.4. Access to personal data is limited to employees whose job responsibilities include such processing.
5.5. Personal data may be transferred to affiliated entities and actual carriers for service provision.
5.6. Storage of personal data does not exceed the period required for processing purposes.
5.7. Processing ceases when:

• Unlawful processing is detected;
• Processing purposes are achieved;
• Consent expires or is withdrawn;
• The Operator ceases operations.

6. UPDATING, CORRECTION, DELETION, AND DESTRUCTION OF PERSONAL DATA
6.1. The Operator provides information about processing to the subject within 10 working days of request.
6.2. In case of inaccurate data, the Operator blocks it during verification and corrects it within 7 working days if inaccuracy is confirmed.
6.3. In case of unlawful processing, the Operator blocks the relevant data.
6.4. The Operator notifies Roskomnadzor of data breaches within 24 hours.
6.5. Personal data is destroyed when:

• Processing purposes are achieved;
• Maximum storage periods are reached;
• The subject provides confirmation of unlawful collection;
• Consent is withdrawn.

7. OPERATOR'S CONTACT INFORMATION
Full name: TRANSPORTNAYA KOMPANIYA AVTOLOGISTIKA LLC
Short name: TC AVTOLOGISTIKA LLC
INN 1655299714
KPP 165501001
OGRN 1141690060511
Legal address: 115088, Moscow, internal territory of the municipal district Pechatniki, 2nd Yuzhnoportovy passage, 16, building 8.
Postal address: 115142, Moscow, P.O. Box 6
Email: info@busfer.com

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