Personal data processing policy
1. General Provisions
1.1. This Personal Data Processing Policy (the "Policy") has been drafted in accordance with the requirements of Federal Law No. 152-FZ of July 27, 2006, "On Personal Data" (the "Personal Data Law") and governs the procedure for processing personal data and the security measures implemented by Exima Trans (the "Operator").
1.2. The Operator's primary mission and a fundamental condition for its operations are the observance of human and civil rights and freedoms when processing their personal data, including the protection of the rights to privacy, personal and family secrets.
1.3. This Policy of the Operator regarding the processing of personal data applies to all information that the Operator may obtain about visitors to the website http://eximatrans.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 cessation of personal data processing (except where processing is necessary to clarify personal data).
2.3. Website - a collection of graphical and informational materials, as well as computer programs and databases, making them available on the internet at the network address http://eximatrans.com.
2.4. Personal Data Information System - a set of personal data contained in databases and the information technologies and technical means ensuring their processing.
2.5. Depersonalization of Personal Data - actions resulting in the inability to determine, without additional information, the ownership of personal data to a specific User or other subject of personal data.
2.6. Processing of Personal Data - any action (operation) or set of actions (operations) performed with or without automation tools on personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
2.7. Operator - a state body, municipal body, legal entity, or individual, independently or jointly with others, organizing and/or carrying out the processing of personal data, and determining the purposes of processing personal data, the composition of personal data to be processed, and the actions (operations) performed with them. In this context, the Operator is Exima Trans.
2.8. Personal Data - any information relating directly or indirectly to a specific or identifiable User of the website http://eximatrans.com.
2.9. User - any visitor to the website http://eximatrans.com.
2.10. Provision of Personal Data - actions aimed at disclosing personal data to a specific person or a specific circle of persons.
2.11. Dissemination of Personal Data - actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or familiarizing an unlimited circle of persons with personal data, including publishing personal data in the media, posting in information and telecommunication networks, or providing access to personal data in any other way.
2.12. Cross-Border Transfer of Personal Data - the transfer of personal data to the territory of a foreign state to an authority of a foreign state, a foreign individual, or a foreign legal entity.
2.13. Destruction of Personal Data - actions resulting in the irreversible destruction of personal data with the impossibility of further restoring the content of the personal data in the personal data information system and/or the destruction of the physical media of personal data.
3. Basic Rights and Obligations of the Operator
3.1. The Operator has the right to:
— Receive accurate information and/or documents containing personal data from the subject of personal data;
— Continue processing personal data without the subject's consent if grounds specified in the Personal Data Law exist;
— Independently determine the composition and list of measures necessary and sufficient to ensure compliance with the obligations stipulated by the Personal Data Law.
3.2. The Operator is obliged to:
— Provide the subject of personal data, upon request, with information regarding the processing of their personal data;
— Organize the processing of personal data in accordance with current Russian legislation;
— Respond to inquiries and requests from personal data subjects and their legal representatives;
— Publish or otherwise provide unrestricted access to this Policy;
— Take legal, organizational, and technical measures to protect personal data;
— Cease the processing and destroy personal data in cases stipulated by the Personal Data Law;
— Perform other duties stipulated by the Personal Data Law.
4. Basic Rights and Obligations of Personal Data Subjects
4.1. Personal Data Subjects have the right to:
— Receive information regarding the processing of their personal data;
— Demand the clarification, blocking, or destruction of their personal data if it is incomplete, outdated, inaccurate, illegally obtained, or not necessary for the stated processing purpose;
— Withdraw consent to the processing of personal data;
— Appeal against the Operator's unlawful actions or inaction regarding the processing of their personal data;
— Exercise other rights provided by Russian law.
4.2. Personal Data Subjects are obliged to:
— Provide the Operator with accurate information about themselves;
— Notify the Operator of any updates or changes to their 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 bear responsibility under Russian law.
5. Principles of Personal Data Processing
5.1. The processing of personal data is conducted on a lawful and fair basis.
5.2. The processing of personal data is limited to achieving specific, predetermined, and legitimate purposes.
5.3. The merging of databases containing personal data processed for incompatible purposes is prohibited.
5.4. Only personal data that meets the processing purposes may be processed.
5.5. The content and volume of processed personal data correspond to the stated processing purposes.
5.6. The accuracy, sufficiency, and relevance of personal data in relation to the processing purposes are ensured.
5.7. Personal data is stored in a form that allows identification of the data subject for no longer than required by the processing purposes.
6. Purposes of Personal Data Processing
Processing Purpose: Informing the User via email newsletters.
Personal Data Processed: Last name, first name, patronymic; email address; phone numbers.
Legal Basis: Federal Law No. 149-FZ of July 27, 2006 "On Information, Information Technologies and Information Protection."
Processing Activities: Sending informational emails to the email address.
7. Conditions for Personal Data Processing
7.1. Processing is carried out with the consent of the personal data subject.
7.2. Processing is necessary to achieve purposes stipulated by an international treaty or Russian law.
7.3. Processing is necessary for the administration of justice.
7.4. Processing is necessary for the performance of a contract.
7.5. Processing is necessary to protect the legitimate interests of the Operator or third parties.
8. Procedure for Collection, Storage, Transfer, and Other Processing of Personal Data
8.1. The Operator ensures the security of personal data by implementing necessary legal, organizational, and technical measures.
8.2. The Operator ensures the confidentiality of personal data and prevents unauthorized access.
8.3. The User's personal data will not be transferred to third parties except as required by law or with the User's consent.
8.4. The User can update their personal data by sending a notification to the Operator's email info@exima-msk.com with the subject "Update of Personal Data."
8.5. The processing period ends upon achieving the processing purposes. The User may withdraw consent by emailing info@exima-msk.com with the subject "Withdrawal of Consent to Personal Data Processing."
8.6. The Operator ensures the confidentiality of personal data during processing.
8.7. The Operator stores personal data in a form allowing identification for no longer than necessary.
9. List of Actions Performed by the Operator with Personal Data
9.1. The Operator performs collection, recording, systematization, accumulation, storage, clarification, extraction, use, transfer, depersonalization, blocking, deletion, and destruction of personal data.
9.2. The Operator performs automated processing of personal data with or without the transfer of obtained information via telecommunication networks.
10. Cross-Border Transfer of Personal Data
10.1. Before commencing cross-border transfer, the Operator must notify the authorized body for the protection of personal data subjects' rights.
10.2. The Operator must obtain relevant information from the foreign entities receiving the personal data prior to such transfer.
11. Confidentiality of Personal Data
The Operator and other persons who have gained access to personal data are obliged not to disclose or distribute personal data to third parties 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 matters concerning the processing of their personal data by contacting the Operator via email at info@exima-msk.com.
12.2. This document will reflect any changes to the Operator's Personal Data Processing Policy. The Policy is valid indefinitely until replaced by a new version.
12.3. The current version of the Policy is freely available online at http://eximatrans.com/privacy.