1. General Provisions
This personal data processing policy is formulated in accordance with the requirements of Federal Law of July 27, 2006, No. 152-FZ “On Personal Data” and defines the procedure for processing personal data and measures to ensure the security of personal data undertaken by SEA GATE LOGISTICS BG EOOD (hereinafter referred to as the Operator).
1.1. The Operator’s primary goal and condition for its activities is to respect the rights and freedoms of individuals concerning the processing of their personal data, including the protection of rights to privacy, personal and family secrets.
1.2. This Operator’s Policy regarding personal data processing (hereinafter referred to as the Policy) applies to all information the Operator can obtain about visitors to the website https://seagatelogistics.org.
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 – a temporary cessation of personal data processing (except when processing is necessary to clarify personal data).
2.3. Website – a set of graphic and information materials, as well as computer programs and databases, ensuring their availability on the internet at the network address https://seagatelogistics.org.
2.4. Personal data information system – a set of personal data contained in databases and information technologies and technical means ensuring their processing.
2.5. Anonymization of personal data – actions resulting in no way to determine the ownership of personal data by a specific user or other personal data subject without using additional information.
2.6. Processing of personal data – any action (operation) or set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (update, change), 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 other persons, organizing and (or) carrying out the processing of 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 relating directly or indirectly to a specific or identifiable website user https://seagatelogistics.org.
2.9. User’s personal data allowed for distribution – personal data, access to an unlimited number of persons to which is provided by the subject of personal data by giving consent to the processing of personal data allowed for distribution under the Law on personal data.
2.10. User – any visitor to the website https://seagatelogistics.org.
2.11. Provision of personal data – actions aimed at disclosing personal data to a specific person or a specific circle of persons.
2.12. Dissemination of personal data – any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or at familiarization with the personal data of an unlimited circle of persons, including the disclosure of personal data in the mass media, placement in information and telecommunication networks, or providing access to personal data in any other way.
2.13. Cross-border transfer of personal data – transfer of personal data to the territory of a foreign state to a foreign authority, foreign individual, or foreign legal entity.
2.14. Destruction of personal data – any actions resulting in personal data being irretrievably destroyed with the impossibility of further restoring the content of personal data in the personal data information system and/or resulting in the destruction of physical carriers of personal data.
3. Operator’s Main Rights and Obligations
3.1. The Operator has the right to:
- Receive reliable information and/or documents containing personal data from the subject of personal data.
- Continue processing personal data without the consent of the personal data subject if the subject withdraws consent and/or requests the cessation of their personal data processing, provided there are grounds specified by the Law on Personal Data.
- Independently determine the composition and list of measures necessary and sufficient to ensure compliance with the obligations under the Law on Personal Data and the regulatory acts adopted in accordance with it unless otherwise provided by the Law on Personal Data or other federal laws.
3.2. The Operator is obliged to:
- Provide the personal data subject, upon request, with information regarding the processing of their personal data.
- Organize the processing of personal data according to the existing legislation of the Russian Federation.
- Respond to inquiries and requests from personal data subjects and their legal representatives in accordance with the requirements of the Law on Personal Data.
- Inform the authorized body for the protection of the rights of personal data subjects at the request of this body the necessary information within 10 days from the date of receipt of such a 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 unauthorized or accidental access, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other illegal actions concerning personal data.
- Discontinue transmission (distribution, provision, access) of personal data, cease processing, and destroy personal data in the manner and cases provided by the Law on Personal Data.
- Fulfill other obligations provided by the Law on Personal Data.
4. Main Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects have the right to:
- Obtain information regarding 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 should not contain personal data concerning other personal data subjects unless there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Law on Personal Data.
- Demand the Operator clarify their personal data, block or destroy them if the personal data are incomplete, outdated, inaccurate, illegally obtained, or are not necessary for the stated processing purpose, as well as to take legally provided measures to protect their rights.
- Set conditions of prior consent when processing personal data in promoting goods, works, services on the market.
- Withdraw their consent to the processing of personal data, as well as to demand the cessation of their personal data processing.
- Appeal against the Operator’s unlawful actions or inaction in processing their personal data to the authorized body for the protection of the rights of personal data subjects or in court.
- Exercise other rights provided by the legislation of the Russian Federation.
4.2. Personal data subjects are obliged to:
- Provide the Operator with accurate data about themselves.
- Inform the Operator about the clarification (updating, change) of their personal data.
4.3. Individuals who have provided the Operator with unreliable information about themselves or information about another personal data subject without the consent of the latter are liable under the legislation of the Russian Federation.
5. Principles of Personal Data Processing
5.1. The processing of personal data is carried out on a lawful and fair basis.
3. Operator’s Main Rights and Obligations
3.1. The Operator has the right to:
- Receive reliable information and/or documents containing personal data from the subject of personal data.
- Continue processing personal data without the consent of the personal data subject if the subject withdraws consent and/or requests the cessation of their personal data processing, provided there are grounds specified by the Law on Personal Data.
- Independently determine the composition and list of measures necessary and sufficient to ensure compliance with the obligations under the Law on Personal Data and the regulatory acts adopted in accordance with it unless otherwise provided by the Law on Personal Data or other federal laws.
3.2. The Operator is obliged to:
- Provide the personal data subject, upon request, with information regarding the processing of their personal data.
- Organize the processing of personal data according to the existing legislation of the Russian Federation.
- Respond to inquiries and requests from personal data subjects and their legal representatives in accordance with the requirements of the Law on Personal Data.
- Inform the authorized body for the protection of the rights of personal data subjects at the request of this body the necessary information within 10 days from the date of receipt of such a 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 unauthorized or accidental access, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other illegal actions concerning personal data.
- Discontinue transmission (distribution, provision, access) of personal data, cease processing, and destroy personal data in the manner and cases provided by the Law on Personal Data.
- Fulfill other obligations provided by the Law on Personal Data.
4. Main Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects have the right to:
- Obtain information regarding 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 should not contain personal data concerning other personal data subjects unless there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Law on Personal Data.
- Demand the Operator clarify their personal data, block or destroy them if the personal data are incomplete, outdated, inaccurate, illegally obtained, or are not necessary for the stated processing purpose, as well as to take legally provided measures to protect their rights.
- Set conditions of prior consent when processing personal data in promoting goods, works, services on the market.
- Withdraw their consent to the processing of personal data, as well as to demand the cessation of their personal data processing.
- Appeal against the Operator’s unlawful actions or inaction in processing their personal data to the authorized body for the protection of the rights of personal data subjects or in court.
- Exercise other rights provided by the legislation of the Russian Federation.
4.2. Personal data subjects are obliged to:
- Provide the Operator with accurate data about themselves.
- Inform the Operator about the clarification (updating, change) of their personal data.
4.3. Individuals who have provided the Operator with unreliable information about themselves or information about another personal data subject without the consent of the latter are liable under the legislation of the Russian Federation.
5. Principles of Personal Data Processing
5.1. The processing of personal data is carried out on a lawful and fair basis.
5.2. Processing of personal data is limited to achieving specific, predefined, and legitimate purposes. Processing of personal data incompatible with the purposes of collecting personal data is not allowed.
5.3. The merging of databases containing personal data processed for purposes incompatible with each other is not allowed.
5.4. Only personal data that is necessary for the purposes for which it is processed is subject to processing.
5.5. The content and volume of processed personal data shall correspond to the stated processing purposes. The processing of excessive personal data relative to the stated purposes of their processing is not allowed.
5.6. When processing personal data, its accuracy, sufficiency, and, if necessary, relevance concerning the purposes of personal data processing should be ensured. The operator takes necessary measures or ensures their adoption for the removal or clarification of incomplete or inaccurate data.
5.7. Storage of personal data is carried out in a form that allows determining the subject of personal data no longer than the purposes of personal data processing require, unless the period of personal data storage is established by federal law, a contract to which the beneficiary or guarantor is the subject of personal data. Processed personal data is destroyed or anonymized upon reaching the processing goals or if there is no longer a need to achieve these goals unless otherwise provided by federal law.
- Objectives of Personal Data Processing
The purpose of processing personal data is to inform the User by sending emails.
Personal data:
- Email address
Types of personal data processing:
- Sending informational emails to the email address
- Conditions for Processing Personal Data
7.1. The processing of personal data is carried out with the consent of the personal data subject for the processing of their personal data.
7.2. The processing of personal data is necessary to achieve the purposes provided by an international treaty of the Russian Federation or law, to perform functions, powers, and duties imposed by the legislation of the Russian Federation on the operator.
7.3. The processing of personal data is necessary for the administration of justice, the execution of a judicial act, an act of another body or official, subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. The processing of personal data is necessary for the execution of a contract, the party, beneficiary, or guarantor under which is the subject of personal data, as well as for concluding a contract on the initiative of the personal data subject or a contract under which the personal data subject will be the beneficiary or guarantor.
7.5. The processing of personal data is necessary for exercising the rights and legitimate interests of the operator or third parties or for achieving socially significant purposes, provided that this does not violate the rights and freedoms of the personal data subject.
7.6. Processing of personal data that is accessible to an unlimited number of persons provided by the personal data subject or at their request is carried out (hereinafter – public personal data).
7.7. Processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.
- The Procedure for Collection, Storage, Transfer, and Other Types of Personal Data Processing
The security of personal data processed by the Operator is ensured by implementing legal, organizational, and technical measures necessary to comply fully with the requirements of the current personal data protection legislation.
8.1. The Operator ensures the safety of personal data and takes all possible measures excluding access to personal data by unauthorized persons.
8.2. The User’s personal data will never, under any conditions, be transferred to third parties, except for cases related to the implementation of current legislation or if the personal data subject has consented to the transfer of data to a third party to fulfill 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’s email address privacy@seagatelogistics.org marked “Updating personal data.”
8.4. The term for personal data processing is determined by the achievement of the purposes for which the personal data were collected unless another term is provided by the contract or applicable 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 at privacy@seagatelogistics.org marked “Withdrawal of consent to the processing of personal data.”
8.5. All information collected by third-party services, including payment systems, communication facilities, and other service providers, is stored and processed by the said persons (operators) following their User agreements and Privacy Policies. The personal data subject agrees with these documents. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this clause.
5.2. Processing of personal data is limited to achieving specific, predefined, and legitimate purposes. Processing of personal data incompatible with the purposes of collecting personal data is not allowed.
5.3. The merging of databases containing personal data processed for purposes incompatible with each other is not allowed.
5.4. Only personal data that is necessary for the purposes for which it is processed is subject to processing.
5.5. The content and volume of processed personal data shall correspond to the stated processing purposes. The processing of excessive personal data relative to the stated purposes of their processing is not allowed.
5.6. When processing personal data, its accuracy, sufficiency, and, if necessary, relevance concerning the purposes of personal data processing should be ensured. The operator takes necessary measures or ensures their adoption for the removal or clarification of incomplete or inaccurate data.
5.7. Storage of personal data is carried out in a form that allows determining the subject of personal data no longer than the purposes of personal data processing require, unless the period of personal data storage is established by federal law, a contract to which the beneficiary or guarantor is the subject of personal data. Processed personal data is destroyed or anonymized upon reaching the processing goals or if there is no longer a need to achieve these goals unless otherwise provided by federal law.
- Objectives of Personal Data Processing
The purpose of processing personal data is to inform the User by sending emails.
Personal data:
- Email address
Legal basis:
- Federal Law “On Information, Information Technologies, and Protection of Information” dated July 27, 2006, No. 149-FZ
Types of personal data processing:
- Sending informational emails to the email address
- Conditions for Processing Personal Data
7.1. The processing of personal data is carried out with the consent of the personal data subject for the processing of their personal data.
7.2. The processing of personal data is necessary to achieve the purposes provided by an international treaty of the Russian Federation or law, to perform functions, powers, and duties imposed by the legislation of the Russian Federation on the operator.
7.3. The processing of personal data is necessary for the administration of justice, the execution of a judicial act, an act of another body or official, subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. The processing of personal data is necessary for the execution of a contract, the party, beneficiary, or guarantor under which is the subject of personal data, as well as for concluding a contract on the initiative of the personal data subject or a contract under which the personal data subject will be the beneficiary or guarantor.
7.5. The processing of personal data is necessary for exercising the rights and legitimate interests of the operator or third parties or for achieving socially significant purposes, provided that this does not violate the rights and freedoms of the personal data subject.
7.6. Processing of personal data that is accessible to an unlimited number of persons provided by the personal data subject or at their request is carried out (hereinafter – public personal data).
7.7. Processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.
- The Procedure for Collection, Storage, Transfer, and Other Types of Personal Data Processing
The security of personal data processed by the Operator is ensured by implementing legal, organizational, and technical measures necessary to comply fully with the requirements of the current personal data protection legislation.
8.1. The Operator ensures the safety of personal data and takes all possible measures excluding access to personal data by unauthorized persons.
8.2. The User’s personal data will never, under any conditions, be transferred to third parties, except for cases related to the implementation of current legislation or if the personal data subject has consented to the transfer of data to a third party to fulfill 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’s email address privacy@seagatelogistics.org marked “Updating personal data.”
8.4. The term for personal data processing is determined by the achievement of the purposes for which the personal data were collected unless another term is provided by the contract or applicable 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 at privacy@seagatelogistics.org marked “Withdrawal of consent to the processing of personal data.”
8.5. All information collected by third-party services, including payment systems, communication facilities, and other service providers, is stored and processed by the said persons (operators) following their User agreements and Privacy Policies. The personal data subject agrees with these documents. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this clause.
5.2. Processing of personal data is limited to achieving specific, predefined, and legitimate purposes. Processing of personal data incompatible with the purposes of collecting personal data is not allowed.
5.3. The merging of databases containing personal data processed for purposes incompatible with each other is not allowed.
5.4. Only personal data that is necessary for the purposes for which it is processed is subject to processing.
5.5. The content and volume of processed personal data shall correspond to the stated processing purposes. The processing of excessive personal data relative to the stated purposes of their processing is not allowed.
5.6. When processing personal data, its accuracy, sufficiency, and, if necessary, relevance concerning the purposes of personal data processing should be ensured. The operator takes necessary measures or ensures their adoption for the removal or clarification of incomplete or inaccurate data.
5.7. Storage of personal data is carried out in a form that allows determining the subject of personal data no longer than the purposes of personal data processing require, unless the period of personal data storage is established by federal law, a contract to which the beneficiary or guarantor is the subject of personal data. Processed personal data is destroyed or anonymized upon reaching the processing goals or if there is no longer a need to achieve these goals unless otherwise provided by federal law.
- Objectives of Personal Data Processing
The purpose of processing personal data is to inform the User by sending emails.
Personal data:
- Email address
Legal basis:
- Federal Law “On Information, Information Technologies, and Protection of Information” dated July 27, 2006, No. 149-FZ
Types of personal data processing:
- Sending informational emails to the email address
- Conditions for Processing Personal Data
7.1. The processing of personal data is carried out with the consent of the personal data subject for the processing of their personal data.
7.2. The processing of personal data is necessary to achieve the purposes provided by an international treaty of the Russian Federation or law, to perform functions, powers, and duties imposed by the legislation of the Russian Federation on the operator.
7.3. The processing of personal data is necessary for the administration of justice, the execution of a judicial act, an act of another body or official, subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. The processing of personal data is necessary for the execution of a contract, the party, beneficiary, or guarantor under which is the subject of personal data, as well as for concluding a contract on the initiative of the personal data subject or a contract under which the personal data subject will be the beneficiary or guarantor.
7.5. The processing of personal data is necessary for exercising the rights and legitimate interests of the operator or third parties or for achieving socially significant purposes, provided that this does not violate the rights and freedoms of the personal data subject.
7.6. Processing of personal data that is accessible to an unlimited number of persons provided by the personal data subject or at their request is carried out (hereinafter – public personal data).
7.7. Processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.
- The Procedure for Collection, Storage, Transfer, and Other Types of Personal Data Processing
The security of personal data processed by the Operator is ensured by implementing legal, organizational, and technical measures necessary to comply fully with the requirements of the current personal data protection legislation.
8.1. The Operator ensures the safety of personal data and takes all possible measures excluding access to personal data by unauthorized persons.
8.2. The User’s personal data will never, under any conditions, be transferred to third parties, except for cases related to the implementation of current legislation or if the personal data subject has consented to the transfer of data to a third party to fulfill 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’s email address privacy@seagatelogistics.org marked “Updating personal data.”
8.4. The term for personal data processing is determined by the achievement of the purposes for which the personal data were collected unless another term is provided by the contract or applicable 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 at privacy@seagatelogistics.org marked “Withdrawal of consent to the processing of personal data.”
8.5. All information collected by third-party services, including payment systems, communication facilities, and other service providers, is stored and processed by the said persons (operators) following their User agreements and Privacy Policies. The personal data subject agrees with these documents. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this clause.
8.6. The restrictions set by the personal data subject on the transfer (except for providing access), as well as on processing or conditions of processing (except for gaining access) of personal data allowed for dissemination, do not apply in cases where processing of personal data is carried out in state, public, or other public interests determined by the legislation of the Russian Federation.
8.7. The Operator ensures the confidentiality of personal data during its processing.
8.8. The Operator stores personal data in a form that allows determining the personal data subject, no longer than the purposes of personal data processing require, if the storage period of personal data is not established by federal law, a contract to which the beneficiary or guarantor is the subject of personal data.
8.9. The condition for terminating personal data processing may be achieving the objectives of personal data processing, the expiration of the personal data subject’s consent, withdrawal of consent by the personal data subject, or a request to stop processing personal data, as well as the identification of unlawful processing of personal data.
- List of Actions Performed by the Operator with the Obtained Personal Data
9.1. The Operator carries out the collection, recording, systematization, accumulation, storage, clarification (updating, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
9.2. The Operator performs automated processing of personal data with receiving and/or transmitting the received information through information and telecommunication networks or without it.
- Cross-border Transfer of Personal Data
10.1. Before starting to perform cross-border transfer of personal data, the Operator is obliged to ensure that the foreign state to which the personal data is to be transferred provides reliable protection of the rights of personal data subjects.
10.2. Cross-border transfer of personal data on the territory of foreign states that do not meet the above requirements can only be carried out if the personal data subject consents in writing to the cross-border transfer of their personal data and/or the execution of a contract to which the personal data subject is a party.
- Confidentiality of Personal Data
The Operator and other persons who have gained access to personal data are obliged not to disclose to third parties and not to disseminate personal data without the consent of the personal data subject unless otherwise provided by federal law.
- Final Provisions
12.1. The User can get any clarifications on issues of interest concerning the processing of their personal data by contacting the Operator via email at privacy@seagatelogistics.org.
12.2. Any changes to the Operator’s policy regarding personal data processing will be reflected in this document. The policy is effective indefinitely until replaced by a new version.
12.3. The current version of the Policy is freely accessible on the Internet at https://seagatelogistics.org/privacy/.
