1. General Provisions
1.1. This Privacy Policy (“Policy”) is designed to protect the rights and freedoms of individuals whose personal data is processed by Limited Liability Company “MCT Shipping Service” (hereinafter referred to as the “Operator”).
1.2. This Policy has been developed in accordance with Federal Law No. 152-FZ dated July 27, 2006, “On Personal Data” (hereinafter referred to as the “Personal Data Law”).
1.3. This Policy contains information subject to disclosure in accordance with the Personal Data Law and is a publicly available document.
2. Information About the Operator
2.1. The Operator is Limited Liability Company “MCT Shipping Service” (OGRN 1157847167708, INN 7805314620, located at: Russia, 198035, Saint Petersburg, Dvinskaya Street, 10, Building 3, Letter A, Office 15).
3. Information on Personal Data Processing
3.1. The Operator processes personal data on a lawful and fair basis to fulfill functions, powers, and obligations imposed by legislation, to exercise the rights and legitimate interests of the Operator, the Operator’s employees, and third parties.
3.2. The Operator obtains personal data directly from the subjects of personal data.
3.3. The Operator processes personal data using both automated and non-automated methods, with and without the use of computing equipment.
3.4. Personal data processing actions include collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction.
4. Processing of Clients’ Personal Data
4.1. The Operator processes personal data of third parties (clients) within the framework of legal relations with the Operator, regulated by Part Two of the Civil Code of the Russian Federation No. 4-FZ dated January 26, 1996 (hereinafter referred to as “clients”).
4.2. The Operator processes clients’ personal data to comply with the requirements of the legislation of the Russian Federation, as well as for the following purposes:
- Receiving inquiries and applications from the personal data subject;
- Informing about existing and new services provided by the Operator;
- Concluding and executing the terms of contracts.
4.3. The Operator processes personal data of third parties (clients) with their consent, provided by third parties (clients) and/or their legal representatives through conclusive actions on this website, including but not limited to: placing orders, registering in the personal account, subscribing to newsletters, using the feedback form, preparing forwarding applications in accordance with this Policy.
4.4. The Operator processes personal data of third parties (clients) for no longer than required by the purposes of personal data processing, unless otherwise provided by the requirements of the legislation of the Russian Federation.
4.5. The Operator may process the following personal data of third parties (clients): surname, first name, patronymic, date of birth, place of birth, passport data, place of registration and place of residence, place of work, landline or mobile phone numbers, email addresses.
5. Information on Personal Data Security Measures
5.1. When processing personal data, the Operator takes necessary legal, organizational, and technical measures or ensures their implementation to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, distribution, as well as from other unlawful actions in relation to personal data.
5.2. Measures to ensure the security of personal data during their processing, applied by the Operator, are planned and implemented to ensure compliance with the requirements set forth in Article 19 of the Personal Data Law.
5.3. In accordance with Article 18.1 of the Personal Data Law, the Operator independently determines the composition and list of measures necessary and sufficient to ensure compliance with legislative requirements. In particular, the Operator has taken the following measures:
- Appointed a person responsible for organizing the processing of personal data of third parties;
- Applied legal, organizational, and technical measures to ensure the security of personal data in accordance with Article 19 of the Personal Data Law;
- Implemented internal control of compliance of personal data processing with the Personal Data Law and regulatory legal acts adopted in accordance with it, requirements for the protection of personal data, the Operator’s policy regarding personal data processing, and the Operator’s local acts;
- Conducted an assessment of potential harm that may be caused to subjects of personal data in case of violation of the Personal Data Law, and the correlation of such harm with measures taken by the operator to ensure the fulfillment of obligations provided for by the Personal Data Law;
- Ensured that the Operator’s employees directly involved in the processing of personal data are familiar with the provisions of the legislation of the Russian Federation on personal data, including requirements for the protection of personal data, documents defining the Operator’s policy regarding personal data processing, and local acts on personal data processing;
- In addition to the requirements of the Personal Data Law, the Operator implements a set of measures aimed at protecting information about clients, employees, and counterparties.
6. Rights of Personal Data Subjects
6.1. A personal data subject has the right:
- To receive personal data relating to this subject and information concerning their processing;
- To clarify, block, or destroy their personal data if it is incomplete, outdated, inaccurate, illegally obtained, or not necessary for the stated purpose of processing;
- To withdraw their consent to personal data processing;
- To protect their rights and legitimate interests, including compensation for losses and moral damage in court;
- To appeal against actions or inaction of the Operator to the authorized body for the protection of the rights of personal data subjects or in court.
6.2. To exercise their rights and legitimate interests, personal data subjects have the right to contact the Operator or submit a request personally or through a representative. The request must contain the information specified in paragraph 3 of Article 14 of the Personal Data Law.
7. Final Provisions
7.1. This Policy is an internal document of LLC “MCT Shipping Service,” publicly available and subject to publication on the official website of LLC “MCT Shipping Service.”
7.2. This Policy is subject to change and amendment in case of new legislative acts and special regulatory documents on the processing and protection of personal data. When changes are made, the date of the last update is indicated in the current version. The new version of the Policy comes into force from the moment of its publication, unless otherwise provided by the new version of the Policy. The current version is always available at: http://www.mctss.spb.ru/.
7.3. Control over the implementation of the requirements of this Policy is carried out by the person responsible for organizing the processing of personal data of third parties.
7.4. The liability of officials of LLC “MCT Shipping Service” who have access to personal data for non-compliance with the requirements of the norms regulating the processing and protection of personal data is determined in accordance with the legislation of the Russian Federation.