+7 495 150 04 64

Moscow, Chistoprudny Boulevard, 17, Building 1

sales@dgdbtransport. com

Personal Data Processing Policy

1. General Provisions

This Personal Data Processing Policy has been developed in accordance with the requirements of the Federal Law № 152-FZ of 27.07.2006 “On Personal Data” (hereinafter referred to as “the Personal Data Law”) and defines the process of processing personal data and measures to ensure the security of such data taken by De Girolami De Bortoli LLC (hereinafter “the Operator”).

1.1. The Operator’s most important goal and a condition for the execution of its activities is the observance of human and civil rights and freedoms while processing personal data, including protection of the right to privacy and personal and family secrets.

1.2. This Policy regarding the processing of personal data applies to all the information that the Operator may receive about website visitors at http://dgdbtransport.com.

2. Key Concepts Used in the Policy

  • Automated personal data processing refers to the processing of personal information using computer technology.
  • Blocking of personal data refers to the temporary suspension of the processing of such information (except in instances where processing is required to clarify the data).
  • Website refers to a collection of graphical and informational materials as well as computer programs and databases, which ensure their availability on the internet at the network address http://dgdbtransport.com.
  • The personal data information system refers to a set of information about individuals contained in databases, as well as information technologies and technical means used to process such data.
  • Depersonalizing personal data means taking actions that make it impossible to determine, without the use of additional information, whether the data belongs to a specific individual or another data subject.
  • Processing of personal data is any action or set of actions performed with or without automation tools on personal data, including the collection, recording, organization, accumulation, storage, updating, extraction, use, transmission (distribution, access), de-identification, blocking, erasure, and destruction of such data.
  • Operator is a state or municipal body, a legal entity, or an individual who, independently or in conjunction with others, organizes and/or processes personal data, determines the purposes for which personal data will be processed, and specifies the types of personal data that will be collected.
  • Personal data is any information directly or indirectly related to a specific identifiable user of the Website at http://dgdbtransport.com.
  • Personal data authorized for disclosure is personal data that an unlimited number of people have access to by the data subject's consent to the processing of such data in accordance with the procedures outlined in the Personal Data Protection Act.
  • User - any person who visits the website http://dgdbtransport.com.
  • Disclosure of personal data - actions taken to make personal data available to a specific individual or group of individuals.
  • Dissemination of Personal Data - Any actions aimed at making personal data available to an unspecified group of individuals (transfer of personal data) or making personal data known to an unlimited number of people, including publishing personal data in media, posting on information and telecommunication networks, or providing access to personal data in any other manner.
  • Transboundary Transfer of Personal Data is the transfer of personal data outside the territory of the country to the authority of a foreign country, a foreign natural person, or a foreign legal entity.
  • Destruction of Personal Data refers to any actions that result in the permanent destruction of personal data, making it impossible to recover the content of the personal data in a personal data information system, and/or destroying the physical media containing personal data.

3. Fundamental Rights and Obligations of the Operator

3.1. The operator has the right to:

  • receive reliable information and/or documents containing personal data from the data subject;
  • in the event that the data subject revokes consent to the processing of their personal data, continue processing personal data without consent from the data subject, providing there are grounds specified in the Personal Data Law;
  • independently determine the scope and list of measures necessary and sufficient to fulfill obligations stipulated by the Personal Data Act and regulatory legal acts adopted pursuant thereto, unless otherwise specified by the Personal Data Law or other federal legislation.

3.2. The Operator shall:

  • provide the data subject with information regarding the processing of their data upon request;
  • organize the processing of personal data in accordance with the procedures established by the relevant legislation of the Russian Federation;
  • respond to inquiries and requests from individuals and their authorized representatives in accordance with the requirements of the Personal Data Protection Act;
  • provide the necessary information to the relevant authorities for the protection of individuals' rights upon request from these authorities within 10 business days of receipt of the request;
  • publish or otherwise make available this Personal Data Processing Policy;
  • take legal, organizational, and technical measures to safeguard personal data against unlawful or accidental access, destruction, alteration, blocking, copying, providing, dissemination, and other unlawful activities involving personal data;
  • stop transmitting (distributing, providing, accessing) personal data, stop processing and delete personal data in accordance with the procedures and cases provided for in the Law on Personal Data;
  • perform other duties provided for in the Law on Personal Data.

4. Fundamental rights and obligations of individuals whose data is processed

4.1. Individuals whose data is processed have the right to:

  • receive information about the processing of their data, except in cases specified by federal laws;
  • require the Operator to clarify their personal data, delete or destroy it if the personal information is incomplete, outdated, inaccurate, obtained illegally, or not necessary for the specified purpose of processing, and also take legally prescribed measures to protect their rights;
  • put forward a condition for prior consent when processing personal information in order to promote goods, works, and services on the market;
  • revoke consent for the processing of personal information, as well as send a request to stop the processing of personal information;
  • appeal to the relevant authority for the protection of the rights of individuals whose personal information is being processed or to court against unlawful actions or omissions by the Operator during the processing of their personal information;
  • exercise other rights provided by the legislation of the Russian Federation.

4.2. Individuals whose personal information is processed are obligated to:

  • provide reliable information to the Operator about themselves.

4.3. Individuals who provide the Operator with inaccurate information about themselves or other personal data subjects without the latter's consent shall be held liable in accordance with the laws of the Russian Federation.

5. Principles of Personal Data Processing

  • Personal data shall be processed in a legal and fair manner.
  • Processing of personal data shall be limited to achieving specific, pre-determined, and legitimate purposes.
  • Combining databases containing personal data whose processing is carried out for incompatible purposes is not allowed.
  • Only personal data that are relevant to the purposes of processing may be processed.
  • The content and amount of personal data processed are consistent with the stated purposes for processing.
  • When processing personal data, accuracy, completeness, and, where necessary, relevance to the purpose of personal data processing, are ensured.
  • Personal data is stored for no longer than is necessary for the purposes of processing the data, unless a longer period of storage is specified by federal law or an agreement.

6. Purpose of Processing

Purpose: to conclude, execute, and terminate civil law contracts.

Personal data: phone numbers.

Legal Basis: Contracts between the operator and individual.

Type of Data Processing: Collection, recording, organization, accumulation, storage, deletion, anonymization of data.

7. Conditions for Personal Data Processing

  • With the consent of the data subject.
  • To achieve goals specified in an international agreement or in accordance with a law.
  • For the administration of justice or the execution of a judicial decision.
  • For the execution of an agreement in which the individual is a party, beneficiary, or guarantor.
  • To exercise the rights and legitimate interests of the controller or third parties, or to achieve socially significant objectives.
  • Processing of personal data that is publicly available.
  • Processing of data that is subject to publication or mandatory disclosure in accordance with applicable law.

8. Procedure for collecting, storing, transferring, and other types of processing of personal data

  • The Operator ensures the security and confidentiality of personal data.
  • The Operator will not disclose personal data to third parties without consent, except as required by law.
  • The User has the right to update their data by contacting the Operator via email: sales@dgdbtransport.com.
  • The period for processing personal data is determined by the purpose for which it was collected or by law.
  • The user can withdraw their consent to the processing of their personal data by sending an email to: sales@dgdbtransport.com.
  • Information collected by third-party services is stored and processed by those entities in accordance with their own policies.
  • Prohibitions on transfer and processing do not apply in cases of state, public, or other public interest as defined by law.
  • The operator ensures the confidentiality of personal data during processing.
  • Personal data is stored for no longer than required for the purpose of processing.

9. Actions performed by the operator with personal data

Collection, recording, organization, accumulation, storage, updating (modification), extraction, utilization, transfer (dissemination, provision of access), anonymization, blocking, elimination, and deletion of personal data. Automated processing of personal information.

10. Transfers of personal data across borders

The operator is required to notify the relevant authority and obtain relevant information from foreign entities prior to commencing cross-border transfer of personal data.

11. Confidentiality of Personal Data

The operator and any other individuals or entities who have access to personal data must not disclose or share such data with third parties without the personal data owner's consent, unless otherwise permitted by applicable law.

12. Final Provisions

12.1. The User may request any clarifications by contacting the Operator via email at sales@dgdbtransport.com.

12.2. Any amendments to this Policy will be reflected in this document. The Policy remains in effect until replaced by a newer version.

12.3. The current version of this Policy is publicly available on the internet at: http://dgdbtransport.com/privacy.