Privacy Policy

1. General Provisions

This personal data processing policy is drafted in accordance with the requirements of Federal Law No. 152-FZ of July 27, 2006, "On Personal Data" (hereinafter referred to as the "Personal Data Law") and defines the procedure for processing personal data and measures to ensure the security of personal data taken by LLC ATC Consulting&Logistics (hereinafter referred to as the "Operator").

1.1. The Operator sets compliance with the rights and freedoms of individuals as a key goal and condition for carrying out its activities when processing their personal data, including the protection of the rights to privacy, personal, and family secrets.
1.2. This Operator's policy on 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://atc-logistic.net.

2. Key Definitions Used in the Policy

2.1. Automated personal data processing: Processing personal data using computer technology.
2.2. Blocking personal data: Temporary suspension of personal data processing (except in cases where processing is necessary to clarify personal data).
2.3. Website: A set of graphical and informational materials, as well as computer programs and databases, ensuring their availability on the Internet at the network address https://atc-logistic.net.
2.4. Information system of personal data: A combination of personal data contained in databases and ensuring the processing of personal data using information technology and technical means.
2.5. Depersonalization of personal data: Actions that make it impossible to determine, without using additional information, the belonging of personal data to a specific User or other personal data subject.
2.6. Personal data processing: Any action (operation) or a combination of actions (operations) performed with personal data using or without using automated tools, including data collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transmission (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
2.7. Operator: A state body, a municipal body, a legal or natural person, either independently or jointly with others, organizing and (or) processing personal data, as well as determining the purposes of personal data processing, the composition of personal data to be processed, actions (operations) performed with personal data.
2.8. Personal data: Any information directly or indirectly related to a specific or determinable User of the website https://atc-logistic.net.
2.9. Personal data allowed for distribution by the personal data subject: Personal data to which an unlimited number of persons have access, provided that the personal data subject has given consent to the processing of personal data allowed for distribution, as provided by the Personal Data Law (hereinafter referred to as "personal data allowed for distribution").
2.10. User: Any visitor to the website https://atc-logistic.net.
2.11. Provision of personal data: Actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Personal data distribution: Any actions aimed at disclosing personal data to an indefinite number of persons (transferring personal data) or at acquainting personal data with an unlimited number of persons, including the disclosure of personal data in the media, posting on information and telecommunications networks, or providing access to personal data in any other way.
2.13. Cross-border transfer of personal data: The transfer of personal data to the territory of a foreign state to the authorities of a foreign state, foreign individuals, or foreign legal entities.
2.14. Destruction of personal data: Any actions that result in the destruction of personal data irreversibly with the impossibility of further restoring the content of personal data in the personal data information system and/or the destruction of material carriers of personal data.

3. Operator's Main Rights and Obligations

3.1. The Operator has the right to:
receive from the personal data subject reliable information and/or documents containing personal data;
in case of withdrawal by the personal data subject of consent to the processing of personal data, as well as upon receipt of a request from the personal data subject to terminate the processing of personal data, 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 the fulfillment of the obligations provided for by the Personal Data Law and the regulations adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.
3.2. The Operator is obliged to:
provide the personal data subject, upon their request, with information related to the processing of their personal data;
organize the processing of personal data in accordance with the current legislation of the Russian Federation;
respond to requests and inquiries of personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
provide the necessary information to the authorized body for the protection of the rights of personal data subjects upon request of such body within 10 days from the date of receipt of such request;
publish or otherwise provide 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 to them, destruction, alteration, blocking, copying, provision, distribution of personal data, as well as from other unlawful actions with personal data;
terminate the transfer (distribution, provision, access), processing, and destroy personal data in the manner and 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:
obtain information about the processing of their personal data, except as provided by federal laws. Information is provided to the personal data subject by the Operator in an accessible form, and it should not contain personal data related to other personal data subjects, except in cases when there are legal grounds for disclosing such personal data. The list of information and the procedure for its receipt are established by the Personal Data Law;
demand from the operator the clarification of their personal data, their blocking, or destruction if the personal data are incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated processing purposes, as well as take measures provided by law to protect their rights;
impose a requirement for prior consent when processing personal data for marketing purposes;
withdraw consent to the processing of personal data, as well as submit a request to cease the processing of personal data;
appeal to the authorized body for the protection of the rights of personal data subjects or in court in case of unlawful actions or inaction by the Operator in the processing of their personal data;
exercise other rights provided by the legislation of the Russian Federation.
4.2. Personal data subjects are obliged to:
provide the Operator with accurate information about themselves;
inform the Operator about the clarification (update, change) of their personal data.
4.3. Individuals who provided inaccurate information about themselves to the Operator or information about another personal data subject without their consent bear responsibility in accordance with the legislation.

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, predefined, and lawful purposes. Personal data processing that is incompatible with the purposes of personal data collection is not allowed.
5.3. Combining databases containing personal data, the processing of which is carried out for incompatible purposes, is not allowed.
5.4. Only personal data that meets the purposes of their processing shall be subject to processing.
5.5. The content and volume of the processed personal data correspond to the stated purposes of their processing. Redundancy of processed personal data in relation to the stated purposes of their processing is not allowed.
5.6. When processing personal data, their accuracy, sufficiency, and, if necessary, relevance to the purposes of processing are ensured. The Operator takes necessary measures and/or ensures their adoption to delete or clarify incomplete or inaccurate data.
5.7. Storage of personal data is carried out in a form that allows identifying the personal data subject for no longer than required by the purposes of personal data processing, unless otherwise provided by federal law, a contract, the beneficiary or guarantor of which is the personal data subject. Processed personal data are destroyed or depersonalized upon achieving the purposes of processing or in case the necessity to achieve these purposes is lost, unless otherwise provided by federal law.

6. Purposes of Personal Data Processing

Processing Purpose: Informing the User by sending electronic emails

Personal Data:

• Surname, First Name, Patronymic
• Email address
• Phone numbers

Legal Grounds:

• The Operator's constituent (founding) documents
• Contracts concluded between the Operator and the personal data subject

Types of Personal Data Processing:

Collection, recording, systematization, accumulation, storage, destruction, and depersonalization of personal data

7. Conditions for Personal Data Processing

7.1. Processing of personal data is carried out with the consent of the personal data subject for the processing of their personal data.
7.2. Processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, to fulfill the functions, powers, and duties imposed by the legislation of the Russian Federation on the Operator.
7.3. Processing of personal data is necessary for the administration of justice, the execution of a judicial act, an act of another authority, or an 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 of which the personal data subject is a party, beneficiary, or surety, as well as for the conclusion of a contract initiated by the personal data subject or a contract under which the personal data subject will be a beneficiary or surety.
7.5. Processing of personal data is necessary to protect the rights and legitimate interests of the Operator or third parties or to achieve socially significant goals, provided that the rights and freedoms of the personal data subject are not violated.
7.6. Processing of personal data is carried out for personal data that is made publicly available by the personal data subject or at their request (hereinafter referred to as publicly available personal data).
7.7. Processing of personal data is carried out for personal data that must be published or disclosed in accordance with law.

8. Procedure for Collecting, Storing, Transmitting, and Other Types of Personal Data Processing

The security of personal data processed by the Operator is ensured through the implementation of 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 security of personal data and takes all possible measures to prevent unauthorized access to personal data.
8.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to the execution of current legislation or if the personal data subject has given consent to the Operator for the transfer of data to a third party for the performance of obligations under a civil law contract.
8.3. In case of inaccuracies in personal data, the User can update them independently by sending a notification to the Operator at the email address info@atc-logistic.net with the subject "Update of personal data."
8.4. The processing period of personal data is determined by the achievement of the purposes for which personal data were collected unless otherwise provided by the contract or current legislation.
The User can 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 info@atc-logistic.net 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 entities (Operators) in accordance with their User Agreements and Privacy Policies. The personal data subject is subject to the terms and conditions specified in 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 providing access) and on the processing or conditions for processing (except for obtaining access) of personal data allowed for dissemination, established by the personal data subject, do not apply in cases of personal data processing for state, public, and other public interests defined by Russian legislation.
8.7. The Operator ensures the confidentiality of personal data during their processing.
8.8. The Operator stores personal data in a form that allows identifying the personal data subject for no longer than the purposes for which personal data were processed, unless the federal law, a contract, or the personal data subject acting as a party, beneficiary, or surety under the contract, establishes a longer data retention period.
8.9. The termination of personal data processing may be based on the achievement of the purposes of personal data processing, the expiration of the consent to personal data processing, the withdrawal of consent by the personal data subject, or the request to terminate personal data processing, as well as the identification of unlawful personal data processing. The full text jf Data Retention Policy is available here.

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

9.1. The Operator carries out the collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transmission (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
9.2. The Operator conducts automated processing of personal data with the receipt and/or transmission of the obtained information through information and telecommunication networks or without them.

10. Cross-Border Transfer of Personal Data:

10.1. Before commencing 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 notification is sent separately from the notification of the intention to process personal data).
10.2. Before submitting the above-mentioned notification, the Operator must obtain relevant information from the authorities of the foreign state, foreign individuals, 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 personal data subject, unless otherwise provided by federal law.

12. Final Provisions:

12.1. The User can obtain any clarifications on issues related to the processing of their personal data by contacting the Operator via email at info@atc-logistic.net.
12.2. Any changes to the policy for the processing of personal data by the Operator will be reflected in this document. The policy is valid indefinitely until replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet at https://atc-logistic.net/privacy_policy/.