Personal Data Processing Policy

1. General provisions

This Personal Data Processing Policy has been prepared in accordance with the requirements of Federal Law No. 152-FZ dated 27.07.2006 “On Personal Data” (hereinafter — the Personal Data Law) and defines the procedure for processing personal data and the measures to ensure the security of personal data undertaken by LLC “GURU” (hereinafter — the Operator).
1.1. The Operator’s primary goal and a key condition for carrying out its activities is the observance of human and civil rights and freedoms when processing personal data, including the protection of privacy, personal and family confidentiality rights.
1.2. This Policy of the Operator regarding the processing of personal data (hereinafter — the Policy) applies to all information that the Operator may obtain about visitors of the website https://guru-trans.ru/ .

2. Key terms used in this Policy

2.1. Automated processing of personal data — processing of personal data using computer equipment.
2.2. Blocking of personal data — temporary suspension of personal data processing (except when processing is required to уточнить/verify personal data).
2.3. Website — a set of graphic and information materials, as well as software and databases, ensuring their availability on the Internet at https://guru-trans.ru/ .
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, that personal data belongs to a specific User or other data subject.
2.6. Processing of personal data — any action (operation) or set of actions (operations) performed with personal data using automation tools or without such tools, including collection, recording, systematization, accumulation, storage, уточнение (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
2.7. Operator — a state authority, municipal authority, legal entity or individual who independently or jointly with others organizes and/or carries out personal data processing, and determines the purposes of processing, the composition of personal data to be processed, and actions (operations) performed with personal data.
2.8. Personal data — any information relating directly or indirectly to a defined or identifiable User of the website https://guru-trans.ru/ .
2.9. Personal data permitted by the personal data subject for distribution — personal data to which an unlimited number of persons is granted access by the personal data subject by giving consent to the processing of personal data permitted for distribution in accordance with the procedure provided by the Personal Data Law (hereinafter — personal data permitted for distribution).
2.10. User — any visitor of the website https://guru-trans.ru/ .
2.11. Provision of personal data — actions aimed at disclosing personal data to a certain person or a certain group of persons.
2.12. Distribution of personal data — any actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or making personal data available to an unlimited number of persons, including publication in mass media, размещение/placement in information and telecommunication networks, or granting access to personal data by any other means.
2.13. Cross-border transfer of personal data — transfer of personal data to the territory of a foreign state to a foreign state authority, a foreign individual, or a foreign legal entity.
2.14. Destruction of personal data — any actions resulting in the irreversible destruction of personal data without the possibility of further restoration of the content of personal data in the personal data information system and/or destruction of physical media containing personal data.

3. Basic rights and obligations of the Operator

3.1. The Operator has the right to:
— receive from the personal data subject accurate information and/or documents containing personal data;
— in case the personal data subject withdraws consent to personal data processing, as well as in case the subject submits a request to terminate personal data processing, the Operator has the right to continue processing personal data without consent if there are grounds specified in the Personal Data Law;
— independently determine the composition and list of measures necessary and sufficient to ensure compliance with obligations предусмотренных/established by the Personal Data Law and regulatory legal acts adopted pursuant to it, unless otherwise provided by the Personal Data Law 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 personal data processing in accordance with the procedure established by the current legislation of the Russian Federation;
— respond to inquiries and requests of personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
— provide the authorized body for the protection of personal data subjects’ rights, upon its request, with necessary information within 10 days from the date of receipt of such request;
— publish or otherwise ensure 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, alteration, blocking, copying, provision, distribution, and other unlawful actions with respect to personal data;
— terminate transfer (distribution, provision, access) of personal data, terminate processing and destroy personal data in the manner and cases предусмотренных/provided by the Personal Data Law;
— fulfill other obligations provided 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, except in cases provided by federal laws. Information is provided by the Operator in an accessible form and must not contain personal data relating to other data subjects, except where there are legal grounds to disclose such data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
— require the Operator to уточнить/rectify their personal data, block or destroy it if the personal data is incomplete, outdated, inaccurate, unlawfully obtained or not necessary for the stated purpose of processing, and to take measures provided by law to protect their rights;
— set the condition of prior consent for processing personal data for the purpose of promoting goods, works and services on the market;
— withdraw consent to personal data processing and submit a request to terminate personal data processing;
— appeal unlawful actions or inaction of the Operator when processing their personal data to the authorized body for the protection of personal data subjects’ rights 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 information about themselves;
— inform the Operator about clarification (updating, modification) of their personal data.
4.3. Persons who provided the Operator with inaccurate information about themselves or information about another personal data subject without the latter’s consent bear liability in accordance with the legislation of the Russian Federation.

5. Principles of personal data processing

5.1. Personal data is processed on a lawful and fair basis.
5.2. Personal data processing is limited to achieving specific, заранее determined and lawful purposes. Processing of personal data incompatible with the purposes of collecting personal data is not allowed.
5.3. It is not allowed to combine databases containing personal data processed for purposes incompatible with each other.
5.4. Only personal data that meets the purposes of processing is subject to processing.
5.5. The content and volume of processed personal data correspond to the stated purposes of processing. Excessive personal data processing in relation to the stated purposes is not allowed.
5.6. When processing personal data, accuracy, sufficiency, and where necessary, relevance of personal data in relation to the purposes of processing are ensured. The Operator takes necessary measures and/or ensures their adoption to delete or clarify incomplete or inaccurate data.
5.7. Personal data is stored in a form allowing identification of the personal data subject no longer than required by the purposes of processing, unless the retention period is established by federal law or by an agreement to which the personal data subject is a party, beneficiary or guarantor. Processed personal data is destroyed or depersonalized upon achieving the purposes of processing or upon loss of necessity to achieve these purposes, unless otherwise provided by federal law.

6. Purposes of personal data processing

Processing purposes:
— providing the User with access to services, information and/or materials contained on the website;
— improving the quality of the website, its content and functionality, and analytics of user activity.
Personal data processed:
— surname, first name, patronymic;
— company name and TIN (when submitted by a legal entity);
— contact phone number;
— email address;
— text of the request or other information contained in the data subject’s message;
— IP address;
— device and browser information;
— cookies and similar technologies;
— date and time of website visit;
— referral source to the website.
Legal grounds:
— the Operator’s charter (founding) documents;
— agreements concluded between the Operator and the personal data subject;
— consent of the personal data subject (including expressed through browser settings/interaction with a cookie banner, if applicable).
Types of personal data processing:
— collection, recording, systematization, accumulation, storage, destruction and depersonalization of personal data.

7. Conditions for personal data processing

7.1. Personal data is processed with the consent of the personal data subject to the processing of their personal data.
7.2. Personal data processing is necessary to achieve purposes provided by an international treaty of the Russian Federation or by law, and for the Operator to perform functions, powers and obligations imposed by the legislation of the Russian Federation.
7.3. Personal data processing is necessary for the administration of justice, execution of a court act, act of another authority or official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. Personal data processing is necessary for the performance of an agreement to which the personal data subject is a party, beneficiary or guarantor, as well as for concluding an agreement at the initiative of the personal data subject or an agreement under which the personal data subject will be a beneficiary or guarantor.
7.5. Personal data processing is necessary for the exercise of the Operator’s or third parties’ rights and legitimate interests or for achieving socially significant purposes, provided that this does not violate the rights and freedoms of the personal data subject.
7.6. Processing is carried out for personal data access to which is granted by the personal data subject to an unlimited number of persons or at the subject’s request (hereinafter — publicly available personal data).
7.7. Processing is carried out for personal data subject to publication or mandatory disclosure in accordance with federal law.

8. 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 fully comply with the requirements of current legislation in the field of personal data protection.
8.1. The Operator ensures the safety of personal data and takes all possible measures to prevent access to personal data by unauthorized persons.
8.2. The User’s personal data is not transferred to third parties, except in cases:
— when transfer is required to comply with the current legislation of the Russian Federation;
— when processing is performed by third parties on behalf of the Operator to achieve processing purposes (e.g., use of CRM, web analytics services and other contractors) on the basis of agreements containing confidentiality and personal data security provisions;
— when the personal data subject has given consent to such transfer.
8.3. If inaccuracies in personal data are identified, the User may update them independently by sending a notice to the Operator via email at info@guru-trans.ru with the subject “Personal Data Update”.
8.4. The processing period of personal data is determined by achieving the purposes for which personal data was collected, unless a different period is provided by an agreement or by applicable law.
The User may withdraw consent to personal data processing at any time by sending a notice to the Operator via email at info@guru-trans.ru with the subject “Withdrawal of Consent to Personal Data Processing”.
8.5. All information collected by third-party services, including payment systems, communication providers and other service providers, is stored and processed by such parties (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject shall familiarize themselves with the указанными documents. The Operator is not responsible for the actions of third parties, including the service providers referenced in this clause.
8.6. Prohibitions established by the personal data subject on transfer (except granting access), as well as on processing or processing conditions (except obtaining access) of personal data permitted for distribution, do not apply in cases of personal data processing in state, public and other public interests defined by the legislation of the Russian Federation.
8.7. The Operator ensures confidentiality of personal data during processing.
8.8. The Operator stores personal data in a form allowing identification of the personal data subject no longer than required by the purposes of processing, unless the retention period is established by federal law or by an agreement to which the personal data subject is a party, beneficiary or guarantor.
8.9. Grounds for termination of personal data processing may include achievement of processing purposes, expiration of consent, withdrawal of consent by the personal data subject or a request to terminate processing, as well as detection of unlawful personal data processing.

9. Use of cookies

9.1. The Website uses cookies for proper operation of services, analytics, and content personalization.
9.2. The User may change browser settings to disable cookies; this may affect the functionality of the Website.

10. List of actions performed by the Operator with received personal data

10.1. The Operator performs collection, recording, systematization, accumulation, storage, уточнение (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion and destruction of personal data.
10.2. The Operator carries out automated processing of personal data with receipt and/or transfer of received information via information and telecommunication networks or without such networks.

11. Cross-border transfer of personal data

11.1. Before commencing activities involving cross-border transfer of personal data, the Operator must notify the authorized body for the protection of personal data subjects’ rights of its intention to carry out such cross-border transfer (such notification is submitted separately from the notification of intent to process personal data).
11.2. Before submitting the above notification, the Operator must obtain from foreign state authorities, foreign individuals and foreign legal entities to whom cross-border transfer is planned, the relevant information.

12. 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 distribute personal data without the consent of the personal data subject, unless otherwise provided by federal law.

13. Final provisions

13.1. The User may obtain any explanations on issues related to the processing of their personal data by contacting the Operator via email at info@guru-trans.ru .
13.2. Any changes to the Operator’s personal data processing policy will be reflected in this document. The Policy remains in force indefinitely until replaced by a new version.
13.3. The current version of the Policy is publicly available on the Internet at https://guru-trans.ru/privacy .