PRIVACY POLICY from 13/02/2022

Terms and Definitions

Automated processing of personal data - processing of personal data using computer technology;
Blocking of personal data - temporary suspension of the processing of personal data;
Information system of personal data - a set of collected personal data, information technologies and technical means that ensure their processing;
Depersonalization of personal data - actions as a result of which it is impossible to determine, without the use of additional information, the ownership of personal data by a specific subject of personal data;
Processing of personal data - any action (operation) or a set of actions (operations) performed using automation tools or without using such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification, retrieval, use, transfer (distribution , provision, access), depersonalization, blocking, deletion, destruction of personal data;
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 processing personal data, the composition of personal data to be processed, the actions (operations) performed with personal data;
Personal data - any information relating to a directly or indirectly identified or identifiable natural person (subject of personal data);
Providing personal data - actions aimed at disclosing personal data to a certain person or a certain circle of persons;
Dissemination of personal data - actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or familiarizing with personal data of an unlimited number of persons, including the disclosure of personal data in the media, placement in information and telecommunication networks or providing access to personal data in any other way;
Destruction of personal data - actions as a result of which it is impossible to restore the content of personal data in the information system of personal data and (or) as a result of which material carriers of personal data are destroyed.

1. GENERAL PROVISIONS
This document defines the policy of Delivery Manager LLC (hereinafter referred to as the Operator) regarding the processing of personal data and discloses information about the measures taken to ensure the security of personal data by the Operator in order to protect the rights and freedoms of a person and citizen when processing his personal data, including protection of the rights to privacy, personal and family secrets.
This document "The Operator's Policy on the Processing of Personal Data" (hereinafter referred to as the "Policy") was developed in accordance with the Constitution of your country, Federal Law No. 160-FZ "On Ratification of the Council of Europe Convention for the Protection of Individuals with regard to Automatic Processing of Personal Data", the Labor Code of your country No 197-FZ, Federal Law No152-FZ "On Personal Data" (hereinafter - FZ-152), other federal laws and by-laws of your country that determine the cases and features of the processing of personal data and ensuring the security and confidentiality of such information.
The provisions of this Policy are binding on all employees of the Operator who process personal data.
The provisions of this Policy are the basis for organizing work on the processing of personal data by the Operator, including the development of internal regulatory documents governing the processing and protection of personal data by the Operator.
In the event that certain provisions of this Policy conflict with the current legislation on personal data, the provisions of the current legislation shall apply.
This Policy is a document to which unlimited access is provided. To ensure unlimited access, the Policy, in particular, is published on the official website of the Operator on the Internet at deliverymanager.biz

2. PRINCIPLES AND CONDITIONS FOR PROCESSING PERSONAL DATA
2.1. Principles of personal data processing
The operator processes personal data on the basis of the following principles:
− legitimacy and fairness;
- limiting the processing of personal data to the achievement of specific, predetermined and legitimate purposes;
− preventing the processing of personal data that is incompatible with the purposes of collecting personal data;
− preventing the merging of databases containing personal data, the processing of which is carried out for purposes that are incompatible with each other;
− processing only those personal data that meet the purposes of their processing;
− conformity of the content and volume of processed personal data for the stated purposes of processing;− preventing the processing of personal data that is excessive in relation to the stated purposes of their processing;
− ensuring the accuracy, sufficiency and relevance of personal data in relation to the purposes of processing personal data;
- destruction or depersonalization of personal data upon reaching the goals of their processing or in case of loss of the need to achieve these goals, if it is impossible for the Operator to eliminate the committed violations of personal data, unless otherwise provided by federal law.
2.2. Conditions for the processing of personal data
The operator processes personal data in the presence of at least one of the following conditions:
− the consent of the subject of personal data to the processing of his personal data has been obtained;
− the processing of personal data is necessary to achieve the goals stipulated by an international treaty of your country or the law, to exercise and fulfill the functions, powers and obligations assigned to the operator by the legislation of your country;
- 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 your country on enforcement proceedings;
- the processing of personal data is necessary for the performance of an agreement to which the subject of personal data is a party or beneficiary or guarantor, as well as to conclude an agreement on the initiative of the subject of personal data or an agreement under which the subject of personal data will be the beneficiary or guarantor;
- the processing of personal data is necessary for the exercise of the rights and legitimate interests of the operator or third parties, or for the achievement of socially significant goals, provided that the rights and freedoms of the subject of personal data are not violated;
− personal data are subject to publication or mandatory disclosure in accordance with federal law.
2.3. Confidentiality of personal data
The operator does not transfer or disclose personal data to third parties without the consent of the subject of personal data, unless otherwise provided by federal law.
2.4. Public sources of personal data
For the purpose of information support, the Operator may create publicly available sources of personal data of subjects, including directories and address books. Publicly available sources of personal data, with the written consent of the subject, may include his last name, first name, patronymic, date and place of birth, position, contact phone numbers, e-mail address and other personal data reported by the subject of personal data.
Information about the subject must be excluded from public sources of personal data at any time at the request of the subject, or by decision of a court or other authorized state bodies.
2.5. Special categories of personal data
Special categories of personal data relating to race, nationality, political views, religious or philosophical beliefs, intimate life are not processed by the Operator. Processing by the Operator of special categories of personal data relating to the state of health is allowed in cases established by Federal Law-152.
2.6. Biometric personal data
Information that characterizes the physiological and biological characteristics of a person, on the basis of which it is possible to establish his identity - biometric personal data - can be processed by the Operator only with the consent of the subject of personal data in writing.
2.7. Entrusting the processing of personal data to another person
The operator entrusts the processing of personal data to another person with the consent of the subject of personal data, unless otherwise provided by federal law, on the basis of an agreement concluded with this person.
2.8. Processing of personal data of citizens of the your country
In accordance with part 5 of article 18 of Federal Law-152, the Operator must ensure the collection, recording, systematization, accumulation, storage, clarification (updating, changing), retrieval of personal data of citizens of your country using databases located on the territory of your country, with the exception of the cases specified in paragraphs 2,3,4,8 of part 1 of Art. 6 FZ-152.
− The Operator applies this requirement to PD, which was collected on the territory of your country and which are related to PD subjects, the pickup/delivery addresses of the goods and documents sent/received by them are located on the territory of your country.
− The Operator does not apply this requirement to PD, which was collected on the territory of your country and which are related to PD subjects, the pickup/delivery addresses of the goods and documents sent/received by them are outside the territory of your country.
The requirement of Part 5 of Art. 18 FZ-152 is applied by the Operator to all personal data collected on the territory of your country.
2.9. Cross-border transfer of personal data
Prior to the start of a cross-border transfer, the Operator determines whether adequate protection of the rights of personal data subjects is provided by a foreign state to whose territory it is planned to transfer personal data.
In case of cross-border transfer of personal data on the territory of foreign states that do not provide adequate protection of the rights of personal data subjects, the Operator ensures the legality of such transfer:
− obtaining consent in writing from the subject of personal data for the cross-border transfer of his personal data;
− signing an agreement to which the subject of personal data is a party.
2.10. The procedure for contacting personal data subjects
Requests from Personal Data Subjects regarding the processing of their personal data by the Operator are accepted at the following addresses:
− 454080, Lesoparkovaya street 7-G, apt. 35
− E-mail: [email protected]
The term for consideration of applications does not exceed thirty days from the date of application.

3. RIGHTS AND OBLIGATIONS
As part of the processing of personal data, the following rights are defined for the Operator and the Subjects of personal data:
The subject of personal data has the right:
− receive information regarding the processing of his personal data, in
the procedure, form and terms established by the Personal Data Legislation;
- demand clarification of their personal data, their blocking or destruction if the personal data is incomplete, outdated, unreliable, illegally obtained, is not necessary for the stated purpose of processing or is used for purposes not previously declared when the Personal Data Subject provided consent to processing personal data;
− take legally prescribed measures to protect their rights;
− withdraw your consent to the processing of personal data;
− as well as other rights provided for by the Personal Data Legislation.
The operator has the right:
− process the personal data of the Personal Data Subject in accordance with the stated purpose;
− require the Personal Data Subject to provide reliable
personal data necessary for the execution of the contract, identification of the Personal Data Subject, as well as in other cases provided for by the Personal Data Legislation;
- restrict the Personal Data Subject's access to his personal data if the Personal Data Subject's access to his personal data violates the rights and legitimate interests of third parties, as well as in other cases provided for by the legislation of your country;
− carry out the processing of personal data subject to publication or mandatory disclosure in accordance with the legislation of your country.
− entrust the processing of personal data to another person with the consent of the Personal Data Subject;
− as well as other rights provided for by the Personal Data Legislation.

4. ENFORCEMENT OF THE OBLIGATIONS OF THE OPERATOR AND MEASURES TO PROTECT PERSONAL DATA
The security of personal data processed by the Operator is ensured by the implementation of legal, organizational and technical measures necessary to meet the requirements of federal legislation in the field of personal data protection.
To prevent unauthorized access to personal data, the Operator applies the following organizational and technical measures:
− appointment of a person responsible for organizing the processing of personal data;
− appointment of a person responsible for ensuring the security of personal data;
− restriction of the composition of persons admitted to the processing of personal data;
− familiarization of subjects with the requirements of federal legislation and
regulatory documents of the Operator for the processing and protection of personal data;
− organization of accounting, storage and circulation of media containing information with personal data;
− determination of threats to the security of personal data during their processing,
formation of threat models on their basis;
− development of a personal data protection system based on the threat model;
− checking the readiness and effectiveness of the use of information security tools;
− delimitation of user access to information resources and software and hardware for information processing;
− registration and accounting of actions of users of personal data information systems;
− use of anti-virus tools and means of restoring the personal data protection system;
− application, if necessary, of firewalls,
intrusion detection, security analysis and cryptographic
information protection;
− organization of access control to the territory of the Operator, protection of premises with technical means for processing personal data.

5. FINAL PROVISIONS
Other rights and obligations of the Operator in connection with the processing of personal data are determined by the legislation of your country in the field of personal data.
The Operator's employees guilty of violating under the rules governing the processing and protection of personal data, bear material, disciplinary, administrative, civil or criminal liability in the manner prescribed by federal laws.