Personal Data Processing Policy
1. General Provisions
This Personal Data Processing Policy is drafted in accordance with the requirements of Federal Law No. 152-FZ of July 27, 2006, "On Personal Data" (hereinafter referred to as the Personal Data Law) and establishes the procedure for processing personal data and the measures taken to ensure the security of personal data by LLC "Sea Cont Shipping" (hereinafter referred to as the Operator).
1.1. The Operator considers compliance with the rights and freedoms of individuals, including the protection of the right to privacy, personal, and family secrets, as a primary goal and condition of its activities when processing personal data.
1.2. This Operator’s Policy on the Processing of Personal Data (hereinafter referred to as the Policy) applies to all information that the Operator may obtain about visitors to the website https://sea-cont.com.
2. Key Definitions Used in the Policy
2.1. **Automated Processing of Personal Data** – processing of personal data using computer technology.
2.2. **Blocking of Personal Data** – temporary suspension of personal data processing (except in cases where processing is necessary to clarify personal data).
2.3. **Website** – a collection of graphic and informational materials, as well as computer programs and databases, ensuring their availability on the Internet at the network address https://sea-cont.com.
2.4. **Personal Data Information System** – a set of personal data contained in databases and the information technologies and technical means that ensure their processing.
2.5. **Anonymization of Personal Data** – actions that make it impossible to attribute personal data to a specific User or other personal data subject without the use of additional information.
2.6. **Processing of Personal Data** – any action (operation) or set of actions (operations) performed with personal data, whether or not using automated means, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (dissemination, provision, access), anonymization, blocking, deletion, and destruction of personal data.
2.7. **Operator** – a state authority, municipal body, legal entity, or individual, independently or jointly with others, 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, and the actions (operations) performed with personal data.
2.8. **Personal Data** – any information relating directly or indirectly to an identified or identifiable User of the website https://sea-cont.com.
2.9. **Personal Data Authorized for Dissemination by the Data Subject** – personal data to which unlimited access is granted by the personal data subject through their consent to the processing of personal data authorized for dissemination, in accordance with the procedure provided by the Personal Data Law (hereinafter referred to as personal data authorized for dissemination).
2.10. **User** – any visitor to the website https://sea-cont.com.
2.11. **Provision of Personal Data** – actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. **Dissemination 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 of personal data in the 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 state authority, foreign individual, or foreign legal entity.
2.14. **Destruction of Personal Data** – any actions resulting in the irreversible destruction of personal data, making it impossible to further restore the content of personal data in the personal data information system and/or the destruction of physical media containing personal data.
3. Main Rights and Obligations of the Operator
3.1. The Operator has the right to:
- Obtain accurate information and/or documents containing personal data from the personal data subject;
- Continue processing personal data without the consent of the personal data subject in case of withdrawal of consent or receipt of a request to cease processing, if there are grounds specified in the Personal Data Law;
- Independently determine the composition and list of measures necessary and sufficient to fulfill obligations stipulated by the Personal Data Law and regulations adopted in accordance with 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 their request, with information regarding the processing of their personal data;
- Organize the processing of personal data in accordance with the procedure established by current Russian legislation;
- Respond to requests and inquiries from 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 with the requested information within 10 days from the date of receiving such a request;
- Publish or otherwise ensure unrestricted access to this Policy on 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, dissemination, or other unlawful actions concerning personal data;
- Cease the transfer (dissemination, provision, access), processing, and destruction of personal data in the manner and cases provided by the Personal Data Law;
- Fulfill other obligations stipulated by the Personal Data Law.
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 in cases provided by federal laws. The information shall be provided by the Operator in an accessible form and must not contain personal data relating to other personal data subjects, except where there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
- Demand that the Operator clarify, block, or destroy their personal data if the data is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, as well as take legal measures to protect their rights;
- Require prior consent for the processing of personal data for the purpose of promoting goods, works, or services on the market;
- Withdraw consent to the processing of personal data and demand the cessation of personal data processing;
- Appeal to the authorized body for the protection of personal data subjects or in court against unlawful actions or inaction of the Operator in the processing of their personal data;
- Exercise other rights provided by Russian legislation.
4.2. Personal data subjects are obliged to:
- Provide the Operator with accurate information about themselves;
- Inform the Operator about the clarification (updating, modification) of their personal data.
4.3. Persons who provide the Operator with inaccurate information about themselves or information about another personal data subject without the latter’s consent shall be held liable in accordance with Russian legislation.
5. Principles of Personal Data Processing
5.1. The processing of personal data is carried out on a lawful and fair basis.
5.2. The processing of personal data is limited to achieving specific, predetermined, and lawful purposes. Processing of personal data that is incompatible with the purposes of collecting personal data is not permitted.
5.3. The merging of databases containing personal data processed for incompatible purposes is not permitted.
5.4. Only personal data that meets the purposes of its processing shall be processed.
5.5. The content and volume of processed personal data correspond to the stated purposes of processing. Excessive processing of personal data in relation to the stated purposes is not permitted.
5.6. The processing of personal data ensures the accuracy, sufficiency, and, where necessary, relevance of personal data in relation to the purposes of processing. The Operator takes necessary measures or ensures their implementation to delete or clarify incomplete or inaccurate data.
5.7. The storage of personal data is carried out in a form that allows identification of the personal data subject for no longer than required by the purposes of processing, unless the storage period is established by federal law or a contract to which the personal data subject is a party, beneficiary, or guarantor. Processed personal data is destroyed or anonymized upon achieving the purposes of processing or when there is no further need to achieve these purposes, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing
6.1. **Purpose of Processing** – informing the User through sending emails, SMS messages, messages in messengers, and/or phone calls.
6.2. **Personal Data**: surname, first name, patronymic, email address, phone numbers.
6.3. **Legal Grounds**: informing Users about the conditions for obtaining the Operator’s services; contracts concluded between the Operator and the personal data subject.
6.4. **Types of Personal Data Processing**: collection, recording, systematization, accumulation, storage, destruction, and anonymization of personal data.
7. Conditions for Personal Data Processing
7.1. The processing of personal data is carried out with the consent of the personal data subject to 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, or to fulfill the functions, powers, and duties imposed on the Operator by Russian legislation.
7.3. The processing of personal data is necessary for the administration of justice, execution of a judicial act, or an act of another authority or official subject to execution in accordance with Russian legislation on enforcement proceedings.
7.4. The processing of personal data is necessary for the execution of a contract to which the personal data subject is a party, beneficiary, or guarantor, as well as for concluding a contract at the initiative of the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor.
7.5. The processing of personal data is necessary to protect the rights and legitimate interests of the Operator or third parties or to achieve socially significant goals, provided that the rights and freedoms of the personal data subject are not violated.
7.6. The processing of personal data to which unlimited access is granted by the personal data subject or at their request (hereinafter referred to as publicly available personal data) is carried out.
7.7. The processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.
8. Procedure for Collection, Storage, Transfer, and Other Types of Personal Data Processing
The security of personal data processed by the Operator is ensured through the implementation of 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 security of personal data and takes all possible measures to prevent access to personal data by unauthorized persons.
8.2. The User’s personal data will never, under any circumstances, be transferred to third parties, except in cases related to compliance with current legislation or if the personal data subject has given consent to the Operator to transfer data to a third party to fulfill obligations under a civil law contract.
8.3. In case of inaccuracies in personal data, the User may update them independently by sending a notification to the Operator’s email address info@sea-cont.com with the subject “Personal Data Update.”
8.4. The duration of personal data processing is determined by achieving the purposes for which the personal data was collected, unless a different period is stipulated by a contract or current legislation. The User may withdraw their consent to the processing of personal data at any time by sending a notification to the Operator via email to the Operator’s email address info@sea-cont.com with the subject “Withdrawal of Consent to Personal Data Processing.”
8.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by these entities (Operators) in accordance with their User Agreements and Privacy Policies. The personal data subject is responsible for familiarizing themselves with these documents. The Operator is not liable for the actions of third parties, including the service providers mentioned in this clause.
8.6. Restrictions established by the personal data subject on the transfer (except for providing access) or processing (except for obtaining access) of personal data authorized for dissemination do not apply in cases of processing personal data in state, public, or other public interests as defined by Russian legislation.
8.7. The Operator ensures the confidentiality of personal data during processing.
8.8. The Operator stores personal data in a form that allows identification of the personal data subject for no longer than required by the purposes of processing, unless the storage period is established by federal law or a contract to which the personal data subject is a party, beneficiary, or guarantor.
8.9. The processing of personal data may be terminated upon achieving the purposes of processing, expiration of the personal data subject’s consent, withdrawal of consent by the personal data subject, a request to cease processing, or identification of unlawful processing of personal data.
9. List of Actions Performed by the Operator with Received Personal Data
9.1. The Operator performs collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (dissemination, provision, access), anonymization, blocking, deletion, and destruction of personal data.
9.2. The Operator performs automated processing of personal data with the receipt and/or transmission of the obtained information via information and telecommunication networks or otherwise.
10. Cross-Border Transfer of Personal Data
10.1. Before initiating cross-border transfer of personal data, the Operator must notify the authorized body for the protection of personal data subjects of its intention to carry out such a transfer (this notification is sent separately from the notification of intent to process personal data).
10.2. Before submitting the above notification, the Operator must obtain relevant information from the authorities of the foreign state, foreign individuals, or foreign legal entities to which the cross-border transfer of personal data is planned.
11. Confidentiality of Personal Data
The Operator and other persons who have gained access to personal data are obliged not to disclose or disseminate personal data to third parties without the consent of the personal data subject, unless otherwise provided by federal law.
12. Final Provisions
12.1. The User may obtain clarifications on any questions regarding the processing of their personal data by contacting the Operator via email at info@sea-cont.com.
12.2. This document will reflect any changes to the Operator’s personal data processing policy. The Policy is valid indefinitely until replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet at https://sea-cont.com/data_rus.
1. General Provisions
This Personal Data Processing Policy is drafted in accordance with the requirements of Federal Law No. 152-FZ of July 27, 2006, "On Personal Data" (hereinafter referred to as the Personal Data Law) and establishes the procedure for processing personal data and the measures taken to ensure the security of personal data by LLC "Sea Cont Shipping" (hereinafter referred to as the Operator).
1.1. The Operator considers compliance with the rights and freedoms of individuals, including the protection of the right to privacy, personal, and family secrets, as a primary goal and condition of its activities when processing personal data.
1.2. This Operator’s Policy on the Processing of Personal Data (hereinafter referred to as the Policy) applies to all information that the Operator may obtain about visitors to the website https://sea-cont.com.
2. Key Definitions Used in the Policy
2.1. **Automated Processing of Personal Data** – processing of personal data using computer technology.
2.2. **Blocking of Personal Data** – temporary suspension of personal data processing (except in cases where processing is necessary to clarify personal data).
2.3. **Website** – a collection of graphic and informational materials, as well as computer programs and databases, ensuring their availability on the Internet at the network address https://sea-cont.com.
2.4. **Personal Data Information System** – a set of personal data contained in databases and the information technologies and technical means that ensure their processing.
2.5. **Anonymization of Personal Data** – actions that make it impossible to attribute personal data to a specific User or other personal data subject without the use of additional information.
2.6. **Processing of Personal Data** – any action (operation) or set of actions (operations) performed with personal data, whether or not using automated means, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (dissemination, provision, access), anonymization, blocking, deletion, and destruction of personal data.
2.7. **Operator** – a state authority, municipal body, legal entity, or individual, independently or jointly with others, 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, and the actions (operations) performed with personal data.
2.8. **Personal Data** – any information relating directly or indirectly to an identified or identifiable User of the website https://sea-cont.com.
2.9. **Personal Data Authorized for Dissemination by the Data Subject** – personal data to which unlimited access is granted by the personal data subject through their consent to the processing of personal data authorized for dissemination, in accordance with the procedure provided by the Personal Data Law (hereinafter referred to as personal data authorized for dissemination).
2.10. **User** – any visitor to the website https://sea-cont.com.
2.11. **Provision of Personal Data** – actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. **Dissemination 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 of personal data in the 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 state authority, foreign individual, or foreign legal entity.
2.14. **Destruction of Personal Data** – any actions resulting in the irreversible destruction of personal data, making it impossible to further restore the content of personal data in the personal data information system and/or the destruction of physical media containing personal data.
3. Main Rights and Obligations of the Operator
3.1. The Operator has the right to:
- Obtain accurate information and/or documents containing personal data from the personal data subject;
- Continue processing personal data without the consent of the personal data subject in case of withdrawal of consent or receipt of a request to cease processing, if there are grounds specified in the Personal Data Law;
- Independently determine the composition and list of measures necessary and sufficient to fulfill obligations stipulated by the Personal Data Law and regulations adopted in accordance with 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 their request, with information regarding the processing of their personal data;
- Organize the processing of personal data in accordance with the procedure established by current Russian legislation;
- Respond to requests and inquiries from 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 with the requested information within 10 days from the date of receiving such a request;
- Publish or otherwise ensure unrestricted access to this Policy on 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, dissemination, or other unlawful actions concerning personal data;
- Cease the transfer (dissemination, provision, access), processing, and destruction of personal data in the manner and cases provided by the Personal Data Law;
- Fulfill other obligations stipulated by the Personal Data Law.
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 in cases provided by federal laws. The information shall be provided by the Operator in an accessible form and must not contain personal data relating to other personal data subjects, except where there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
- Demand that the Operator clarify, block, or destroy their personal data if the data is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, as well as take legal measures to protect their rights;
- Require prior consent for the processing of personal data for the purpose of promoting goods, works, or services on the market;
- Withdraw consent to the processing of personal data and demand the cessation of personal data processing;
- Appeal to the authorized body for the protection of personal data subjects or in court against unlawful actions or inaction of the Operator in the processing of their personal data;
- Exercise other rights provided by Russian legislation.
4.2. Personal data subjects are obliged to:
- Provide the Operator with accurate information about themselves;
- Inform the Operator about the clarification (updating, modification) of their personal data.
4.3. Persons who provide the Operator with inaccurate information about themselves or information about another personal data subject without the latter’s consent shall be held liable in accordance with Russian legislation.
5. Principles of Personal Data Processing
5.1. The processing of personal data is carried out on a lawful and fair basis.
5.2. The processing of personal data is limited to achieving specific, predetermined, and lawful purposes. Processing of personal data that is incompatible with the purposes of collecting personal data is not permitted.
5.3. The merging of databases containing personal data processed for incompatible purposes is not permitted.
5.4. Only personal data that meets the purposes of its processing shall be processed.
5.5. The content and volume of processed personal data correspond to the stated purposes of processing. Excessive processing of personal data in relation to the stated purposes is not permitted.
5.6. The processing of personal data ensures the accuracy, sufficiency, and, where necessary, relevance of personal data in relation to the purposes of processing. The Operator takes necessary measures or ensures their implementation to delete or clarify incomplete or inaccurate data.
5.7. The storage of personal data is carried out in a form that allows identification of the personal data subject for no longer than required by the purposes of processing, unless the storage period is established by federal law or a contract to which the personal data subject is a party, beneficiary, or guarantor. Processed personal data is destroyed or anonymized upon achieving the purposes of processing or when there is no further need to achieve these purposes, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing
6.1. **Purpose of Processing** – informing the User through sending emails, SMS messages, messages in messengers, and/or phone calls.
6.2. **Personal Data**: surname, first name, patronymic, email address, phone numbers.
6.3. **Legal Grounds**: informing Users about the conditions for obtaining the Operator’s services; contracts concluded between the Operator and the personal data subject.
6.4. **Types of Personal Data Processing**: collection, recording, systematization, accumulation, storage, destruction, and anonymization of personal data.
7. Conditions for Personal Data Processing
7.1. The processing of personal data is carried out with the consent of the personal data subject to 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, or to fulfill the functions, powers, and duties imposed on the Operator by Russian legislation.
7.3. The processing of personal data is necessary for the administration of justice, execution of a judicial act, or an act of another authority or official subject to execution in accordance with Russian legislation on enforcement proceedings.
7.4. The processing of personal data is necessary for the execution of a contract to which the personal data subject is a party, beneficiary, or guarantor, as well as for concluding a contract at the initiative of the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor.
7.5. The processing of personal data is necessary to protect the rights and legitimate interests of the Operator or third parties or to achieve socially significant goals, provided that the rights and freedoms of the personal data subject are not violated.
7.6. The processing of personal data to which unlimited access is granted by the personal data subject or at their request (hereinafter referred to as publicly available personal data) is carried out.
7.7. The processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.
8. Procedure for Collection, Storage, Transfer, and Other Types of Personal Data Processing
The security of personal data processed by the Operator is ensured through the implementation of 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 security of personal data and takes all possible measures to prevent access to personal data by unauthorized persons.
8.2. The User’s personal data will never, under any circumstances, be transferred to third parties, except in cases related to compliance with current legislation or if the personal data subject has given consent to the Operator to transfer data to a third party to fulfill obligations under a civil law contract.
8.3. In case of inaccuracies in personal data, the User may update them independently by sending a notification to the Operator’s email address info@sea-cont.com with the subject “Personal Data Update.”
8.4. The duration of personal data processing is determined by achieving the purposes for which the personal data was collected, unless a different period is stipulated by a contract or current legislation. The User may withdraw their consent to the processing of personal data at any time by sending a notification to the Operator via email to the Operator’s email address info@sea-cont.com with the subject “Withdrawal of Consent to Personal Data Processing.”
8.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by these entities (Operators) in accordance with their User Agreements and Privacy Policies. The personal data subject is responsible for familiarizing themselves with these documents. The Operator is not liable for the actions of third parties, including the service providers mentioned in this clause.
8.6. Restrictions established by the personal data subject on the transfer (except for providing access) or processing (except for obtaining access) of personal data authorized for dissemination do not apply in cases of processing personal data in state, public, or other public interests as defined by Russian legislation.
8.7. The Operator ensures the confidentiality of personal data during processing.
8.8. The Operator stores personal data in a form that allows identification of the personal data subject for no longer than required by the purposes of processing, unless the storage period is established by federal law or a contract to which the personal data subject is a party, beneficiary, or guarantor.
8.9. The processing of personal data may be terminated upon achieving the purposes of processing, expiration of the personal data subject’s consent, withdrawal of consent by the personal data subject, a request to cease processing, or identification of unlawful processing of personal data.
9. List of Actions Performed by the Operator with Received Personal Data
9.1. The Operator performs collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (dissemination, provision, access), anonymization, blocking, deletion, and destruction of personal data.
9.2. The Operator performs automated processing of personal data with the receipt and/or transmission of the obtained information via information and telecommunication networks or otherwise.
10. Cross-Border Transfer of Personal Data
10.1. Before initiating cross-border transfer of personal data, the Operator must notify the authorized body for the protection of personal data subjects of its intention to carry out such a transfer (this notification is sent separately from the notification of intent to process personal data).
10.2. Before submitting the above notification, the Operator must obtain relevant information from the authorities of the foreign state, foreign individuals, or foreign legal entities to which the cross-border transfer of personal data is planned.
11. Confidentiality of Personal Data
The Operator and other persons who have gained access to personal data are obliged not to disclose or disseminate personal data to third parties without the consent of the personal data subject, unless otherwise provided by federal law.
12. Final Provisions
12.1. The User may obtain clarifications on any questions regarding the processing of their personal data by contacting the Operator via email at info@sea-cont.com.
12.2. This document will reflect any changes to the Operator’s personal data processing policy. The Policy is valid indefinitely until replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet at https://sea-cont.com/data_rus.