Personal Data Processing Policy

1. General Provisions

1.1. This Personal Data Processing Policy (hereinafter — the “Policy”) sets out the procedure for the processing and protection of personal data by AURUS LOGISTIC LLC (hereinafter — the “Operator”).

Operator: AURUS LOGISTIC LLC

INN: 7709935198

KPP: 771401001

OGRN: 1137746758478

Address: 123007, Moscow, intra-city territory, Khoroshevsky municipal district, 5-ya Magistralnaya St., 20, floor/premises 1/I, room/office 1/A8G

Telephone: +7 (495) 181-67-75

Email: info@auruslogistic.ru

Website: https://[WEBSITE DOMAIN]

1.2. The Policy has been developed in accordance with the Constitution of the Russian Federation, Federal Law No. 152-FZ of 27 July 2006 “On Personal Data” and other regulatory legal acts of the Russian Federation in the field of personal data.

1.3. The Policy applies to all information the Operator may obtain about individuals through use of the Website, completion and submission of forms on the Website, contacting the Operator, sending a CV, or other interaction with the Operator.

1.4. Terms used in the Policy are used in the meanings established by the legislation of the Russian Federation on personal data.

2. Principles of Personal Data Processing

The Operator processes personal data on the basis of the following principles:

lawfulness and fairness;
limitation of processing to the achievement of specific, predetermined and lawful purposes;
inadmissibility of processing personal data incompatible with the purposes of their collection;
compliance of the scope and content of the data processed with the stated purposes;
inadmissibility of processing excessive personal data;
ensuring the accuracy and relevance of personal data;
retention of personal data for no longer than required by the purposes of processing or by the legislation of the Russian Federation;
ensuring the confidentiality and security of personal data.

3.Categories of Personal Data Subjects

The Operator may process the personal data of:

visitors and users of the Website;
representatives of potential and existing clients;
representatives of counterparties and partners;
individuals applying for consultation or a cost estimate for services;
candidates for the Operator’s vacancies;
other individuals who have independently provided their personal data to the Operator.

4. Purposes and Composition of Personal Data Processed

4.1. Handling Enquiries and Providing Consultations

Purpose:

processing the user’s request;
providing consultation;
communicating with the user;
preparing a proposal for the Operator’s logistics, transport, customs and other services;
taking actions at the user’s initiative prior to concluding an agreement.

May be processed:

name;
company name;
telephone number;
email address;
content of the enquiry;
information independently provided by the user.

4.2. Cost Calculation for Services

Purpose:

preparation of a preliminary calculation;
selection of a logistics scheme;
preparation of a commercial proposal;
communicating with the user;
subsequent conclusion and performance of an agreement at the user’s initiative.

May be processed:

name;
telephone number;
email address;
type of cargo;
weight and/or volume of cargo;
point of departure;
point of destination;
other information about the cargo and intended transportation provided by the user.

4.3. Working with Candidates

Purpose:

consideration of candidacy for available vacancies;
communicating with the candidate;
arranging an interview;
making a decision on possible employment.

May be processed:

surname, first name, patronymic;
telephone number;
email address;
information contained in the submitted CV;
information on education;
information on professional experience and qualifications;
other information voluntarily provided by the candidate in the CV.

Upon completion of consideration of the candidacy, the data is destroyed or anonymised unless further retention is required by the legislation of the Russian Federation.

Inclusion of information on a candidate in a talent pool for use in relation to future vacancies is carried out where there is an appropriate legal basis, including separate consent from the subject where such consent is required.

The Operator requests that the CV not include information unrelated to professional qualifications and employment, including special categories of personal data, unless the provision of such information is required by law.

4.4. Ensuring the Functioning and Security of the Website

When visiting the Website, the following technical information may be automatically processed:

IP address;
date and time of access;
information on the browser and operating system;
device type;
address of the requested page;
referral source;
cookie identifiers;
technical logs of the Website’s operation;
other technical information transmitted by the user’s browser or device.

The purposes of such processing are to ensure the functionality and security of the Website, prevent misuse, diagnose technical errors and protect the Operator’s information systems.

4.5. Web Analytics

If web analytics services are used on the Website, the Operator may process technical information about visits to the Website, including cookie data, information on the device and browser, pages visited, session duration, referral source and interaction with elements of the Website.

The use of optional analytical and other optional cookies is carried out in accordance with the Cookie Policy and applicable legal requirements.

5. Legal Grounds for Processing

The Operator processes personal data where there is a legal basis provided for by legislation, in particular:

consent of the personal data subject;
the necessity of processing for concluding an agreement at the initiative of the personal data subject or for performing an agreement to which the subject is a party, beneficiary or guarantor;
the necessity of fulfilling obligations imposed on the Operator by the legislation of the Russian Federation;
the necessity of exercising the rights and legitimate interests of the Operator or third parties, provided that the rights and freedoms of the personal data subject are not thereby violated;
other grounds provided for by the legislation of the Russian Federation.

6. Procedure and Methods of Processing

6.1. The Operator may carry out the following actions with personal data:

collection, recording, systematisation, accumulation, storage, clarification (updating, amendment), extraction, use, transfer (provision, access) in cases provided for by legislation, anonymisation, blocking, deletion and destruction.

6.2. Processing may be carried out both with and without the use of automation tools.

6.3. The Operator does not disseminate personal data to an indefinite range of persons without a separate legal basis.

6.4. The Operator does not make decisions that give rise to legal consequences for the personal data subject or otherwise significantly affect their rights and legitimate interests based solely on automated processing, unless otherwise expressly provided for by legislation.

7. Transfer of Personal Data to Third Parties

7.1. The Operator may entrust the processing of personal data to third parties or provide them with access to data to the extent necessary for:

hosting and technical maintenance of the Website;
the functioning of information systems;
the operation of email and communication tools;
ensuring information security;
processing enquiries;
performance of agreements;
fulfilment of obligations established by legislation.

7.2. Persons entrusted with the processing of personal data undertake to maintain confidentiality and comply with the requirements of the legislation of the Russian Federation in the field of personal data protection.

7.3. The transfer of personal data to government authorities is carried out in the cases and in the manner provided for by the legislation of the Russian Federation.

7.4. The Operator does not sell databases of personal data and does not provide personal data to third parties for their own independent marketing purposes without an appropriate legal basis.

8. Localisation and Storage of Personal Data

8.1. When collecting the personal data of citizens of the Russian Federation via the internet, the Operator ensures compliance with the requirements of the legislation of the Russian Federation on the localisation of personal data.

8.2. The recording, systematisation, accumulation, storage, clarification and extraction of the personal data of citizens of the Russian Federation, when collected via the Website, are carried out using databases located within the territory of the Russian Federation, in cases where such a requirement is provided for by legislation.

8.3. The retention period for personal data is determined by the purposes of processing, the terms of agreements and consents, the requirements of legislation and the need to protect the Operator’s legitimate interests.

8.4. Once the purposes of processing have been achieved or the legal grounds have ceased to apply, personal data is destroyed or anonymised, unless further retention is required in accordance with legislation.

9. Protection of Personal Data

The Operator takes the necessary legal, organisational and technical measures to protect personal data from:

unlawful or accidental access;
destruction;
alteration;
blocking;
copying;
provision;
dissemination;
other unlawful actions.

Access to personal data is granted only to those persons who require it for the performance of their official or contractual duties.

10. Rights of the Personal Data Subject

The personal data subject has the right to:

receive information about the processing of their personal data;
request the clarification, blocking or destruction of data if it is incomplete, outdated, inaccurate, unlawfully obtained or not necessary for the stated purpose;
withdraw consent to the processing of personal data;
request the cessation of processing in cases provided for by law;
appeal against the actions or inaction of the Operator to Roskomnadzor or in court;
exercise other rights provided for by the legislation of the Russian Federation.

11. Withdrawal of Consent and Requests from Subjects

11.1. The personal data subject has the right to withdraw previously given consent to the processing of personal data.

11.2. A withdrawal or other request may be sent:

by email: info@auruslogistic.ru

to the address: 123007, Moscow, intra-city territory, Khoroshevsky municipal district, 5-ya Magistralnaya St., 20, floor/premises 1/I, room/office 1/A8G.

11.3. It is recommended that the request include information allowing identification of the applicant and location of the relevant personal data, as well as the content of the request.

11.4. Withdrawal of consent does not affect the lawfulness of processing carried out prior to its receipt by the Operator.

11.5. After withdrawal of consent, the Operator ceases processing of personal data unless there are other grounds provided for by legislation for its continuation.

12. Cookies

12.1. The Website may use cookies and other similar technologies.

12.2. The procedure for their use, the categories of cookies, the purposes of processing and the methods of managing them are determined by the separate Cookie Policy published on the Website.

13. Final Provisions

13.1. This Policy is a publicly available document.

13.2. The Operator has the right to make changes to the Policy in connection with changes in legislation, the composition of information systems used, the functionality of the Website or personal data processing procedures.

13.3. The current version of the Policy is permanently available on the Website.

AURUS LOGISTIC LLC

INN 7709935198

OGRN 1137746758478

E-mail: info@auruslogistic.ru