Personal Data Processing Policy
1. General Provisions
This Personal Data Processing Policy has been drafted in accordance with the requirements of Federal Law No. 152-FZ dated July 27, 2006, "On Personal Data" (hereinafter referred to as the "Personal Data Law"). It defines the procedure for processing personal data and the measures taken to ensure the security of personal data by the Waybill platform, represented by the self-employed individual Andrey Vladimirovich Gavrilin (hereinafter referred to as the "Operator").
1.1. The Operator establishes the observance of human and civil rights and freedoms—including the right to privacy and the protection of personal and family secrets—during the processing of personal data as a primary objective and a fundamental condition for its operations.
1.2. This Personal Data Processing Policy (hereinafter referred to as the "Policy") applies to all information that the Operator may obtain regarding visitors to the website https://way-bill.ru.
2. Key Terms Used in the Policy
2.1. Automated processing of personal data — the processing of personal data using computing equipment.
2.2. Blocking of personal data — the temporary suspension of personal data processing (except in cases where processing is necessary to verify or update the personal data).
2.3. Website — a collection of graphic and informational materials, as well as computer programs and databases, made accessible on the Internet at the network address https://way-bill.ru (and https://waybill.tilda.cc).
2.4. Personal data information system — a collection of personal data contained in databases, along with the information technologies and technical means that facilitate their processing.
2.5. Anonymization of personal data — actions resulting in the inability to determine—without the use of additional information—which specific User or other personal data subject the personal data belongs to.
2.6. Processing of personal data — any action (operation) or set of actions (operations) performed on personal data, whether or not by automated means, including collection, recording, systematization, accumulation, storage, refinement (updating, modification), retrieval, use, transfer (dissemination, provision, access), depersonalization, blocking, deletion, or destruction of personal data.
2.7. Operator — a state body, municipal body, legal entity, or natural person that, independently or jointly with other persons, organizes and/or carries out the processing of personal data, and determines the purposes of personal data processing, the scope of personal data to be processed, and the actions (operations) performed on personal data.
2.8. Personal data — any information relating directly or indirectly to a specific or identifiable User of the website https://way-bill.ru.
2.9. Personal data authorized by the data subject for dissemination — personal data to which access by an unlimited number of persons has been granted by the data subject through the provision of consent for the processing of personal data authorized by the data subject for dissemination, in the manner prescribed by the Personal Data Law (hereinafter referred to as "personal data authorized for dissemination").
2.10. User — any visitor to the website https://way-bill.ru.
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 making personal data known to an unlimited circle of persons, including the publication of personal data in the mass media, posting it on information and telecommunication networks, or providing access to personal data in any other way.
2.13. Cross-border transfer of personal data — the 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 impossibility of restoring the content of personal data within a personal data information system and/or resulting in the destruction of the physical media containing personal data.
3. Key Rights and Obligations of the Operator
3.1. The Operator has the right to:
— receive accurate information and/or documents containing personal data from the personal data subject;
— continue processing personal data without the subject's consent—in the event that the personal data subject withdraws their consent—provided there are grounds for doing so as specified in the Personal Data Law;
— independently determine the scope and list of measures necessary and sufficient to ensure compliance with the obligations stipulated by the Personal Data Law and regulatory legal acts adopted pursuant thereto, 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 the manner established by the current 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 Personal Data Law;
— provide the authorized body for the protection of personal data subjects' rights with necessary information upon that body's request, within 10 working days of receiving such a request;
— publish or otherwise ensure unrestricted access to this Policy regarding the processing of personal data;
— adopt legal, organizational, and technical measures to protect personal data against unauthorized or accidental access, destruction, alteration, blocking, copying, disclosure, or dissemination, as well as against other unlawful actions involving personal data;
— cease the transfer (dissemination, disclosure, provision of access) of personal data, cease processing, and destroy personal data in the manner and cases prescribed by the Personal Data Law;
— fulfill other obligations stipulated by the Personal Data Law.
4. Key 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 for by federal laws. Such information is provided to the personal data subject by the Operator in an accessible format and must not contain personal data relating to 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 that the Operator update, block, or destroy their personal data if the data is incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the stated purpose of processing, and to take measures provided by law to protect their rights;
— stipulate a requirement for prior consent regarding the processing of personal data for the purpose of promoting goods, works, and services on the market;
— withdraw consent for the processing of personal data;
— appeal—either to the authorized body for the protection of personal data subjects' rights or through judicial proceedings—against unlawful actions or inaction by the Operator regarding the processing of their personal data;
— exercise other rights provided for by the legislation of the Russian Federation.
4.2. Personal data subjects are obliged to:
— provide the Operator with accurate information about themselves;
— notify the Operator of any updates (updates or changes) to 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 the legislation of the Russian Federation.
5. Principles of personal data processing
5.1. Personal data processing is carried out on a lawful and fair basis.
5.2. Personal data processing is limited to the achievement of specific, predetermined, and lawful purposes. Processing of personal data that is incompatible with the purposes of data collection is not permitted.
5.3. The merging of databases containing personal data processed for mutually incompatible purposes is prohibited.
5.4. Only personal data that are relevant to the purposes of their processing shall be processed.
5.5. The content and volume of the personal data being processed shall correspond to the stated purposes of processing. The personal data being processed shall not be excessive in relation to the stated purposes of their processing.
5.6. During the processing of personal data, the accuracy, sufficiency, and—where necessary—currency of the personal data in relation to the purposes of processing shall be ensured. The Operator shall take, or ensure the taking of, necessary measures to delete or rectify incomplete or inaccurate data.
5.7. Personal data shall be stored in a form that allows for identify the personal data subject, for no longer than is required for the purposes of personal data processing, unless a retention period is established by federal law or by a contract to which the personal data subject is a party, beneficiary, or guarantor. Personal data undergoing processing shall be destroyed or anonymized upon the achievement of the processing purposes or if the need to achieve such purposes ceases to exist, unless otherwise provided by federal law.
6. Purposes and legal grounds for personal data processing
6.1. Purpose of processing: informing the User by sending emails containing, among other things, documents, commercial proposals, and other promotional materials.
6.2. Personal data:
- surname, first name, patronymic;
- email address;
- phone numbers;
- organization name;
Legal grounds:
- Federal Law No. 149-FZ "On Information, Information Technologies and Information Protection" dated July 27, 2006, and other federal laws and regulatory legal acts adopted pursuant thereto, in fulfillment of and in accordance with which the Operator processes personal data;
- consent of personal data subjects to the processing of personal data;
- other grounds where consent to the processing of personal data is not required under the legislation of the Russian Federation.
- sending informational emails to the email address, containing, among other things, documents, commercial proposals, and other promotional materials.
6.4. Types of personal data processing:
6.5. The Operator processes the User's personal data only if the User fills them in and/or sends them independently via special forms located on the website https://way-bill.ru or sends them to the Operator via email. By filling out the relevant forms and/or sending their personal data to the Operator, the User expresses their consent to this Policy.
7. List of actions performed by the Operator with the received personal data
7.1. The Operator carries out the collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (dissemination, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
7.2. The Operator carries out automated processing of personal data, involving the receipt and/or transmission of the obtained information via information and telecommunication networks or without such transmission. 8. Conditions and Procedure for Personal Data Processing
8.1. Personal data processing is carried out with the consent of the personal data subject, except in cases established by the legislation of the Russian Federation where such processing may occur without such consent.
9. Cross-Border Transfer of Personal Data
9.1. Prior to commencing cross-border transfer activities, the Operator must notify the authorized body for the protection of personal data subjects' rights of its intention to conduct such transfers (this notification is submitted separately from the notification regarding the intention to process personal data).
9.2. Prior to submitting the aforementioned notification, the Operator must obtain relevant information from the foreign state authorities, foreign individuals, or foreign legal entities to whom the personal data is intended to be transferred.
10. Confidentiality of Personal Data
The Operator and other parties who have gained access to personal data are prohibited from disclosing or disseminating such data to third parties without the consent of the personal data subject, unless otherwise provided by federal law.
11. Final Provisions
11.1. Users may obtain clarifications regarding the processing of their personal data by contacting the Operator via email at service@way-bill.ru.
11.2. This document reflects any changes to the Operator's personal data processing policy. The Policy remains in effect indefinitely until replaced by a new version.
11.3. The current version of the Policy is publicly available on the Internet at https://way-bill.ru/en/privacy.
1. General Provisions
This Personal Data Processing Policy has been drafted in accordance with the requirements of Federal Law No. 152-FZ dated July 27, 2006, "On Personal Data" (hereinafter referred to as the "Personal Data Law"). It defines the procedure for processing personal data and the measures taken to ensure the security of personal data by the Waybill platform, represented by the self-employed individual Andrey Vladimirovich Gavrilin (hereinafter referred to as the "Operator").
1.1. The Operator establishes the observance of human and civil rights and freedoms—including the right to privacy and the protection of personal and family secrets—during the processing of personal data as a primary objective and a fundamental condition for its operations.
1.2. This Personal Data Processing Policy (hereinafter referred to as the "Policy") applies to all information that the Operator may obtain regarding visitors to the website https://way-bill.ru.
2. Key Terms Used in the Policy
2.1. Automated processing of personal data — the processing of personal data using computing equipment.
2.2. Blocking of personal data — the temporary suspension of personal data processing (except in cases where processing is necessary to verify or update the personal data).
2.3. Website — a collection of graphic and informational materials, as well as computer programs and databases, made accessible on the Internet at the network address https://way-bill.ru (and https://waybill.tilda.cc).
2.4. Personal data information system — a collection of personal data contained in databases, along with the information technologies and technical means that facilitate their processing.
2.5. Anonymization of personal data — actions resulting in the inability to determine—without the use of additional information—which specific User or other personal data subject the personal data belongs to.
2.6. Processing of personal data — any action (operation) or set of actions (operations) performed on personal data, whether or not by automated means, including collection, recording, systematization, accumulation, storage, refinement (updating, modification), retrieval, use, transfer (dissemination, provision, access), depersonalization, blocking, deletion, or destruction of personal data.
2.7. Operator — a state body, municipal body, legal entity, or natural person that, independently or jointly with other persons, organizes and/or carries out the processing of personal data, and determines the purposes of personal data processing, the scope of personal data to be processed, and the actions (operations) performed on personal data.
2.8. Personal data — any information relating directly or indirectly to a specific or identifiable User of the website https://way-bill.ru.
2.9. Personal data authorized by the data subject for dissemination — personal data to which access by an unlimited number of persons has been granted by the data subject through the provision of consent for the processing of personal data authorized by the data subject for dissemination, in the manner prescribed by the Personal Data Law (hereinafter referred to as "personal data authorized for dissemination").
2.10. User — any visitor to the website https://way-bill.ru.
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 making personal data known to an unlimited circle of persons, including the publication of personal data in the mass media, posting it on information and telecommunication networks, or providing access to personal data in any other way.
2.13. Cross-border transfer of personal data — the 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 impossibility of restoring the content of personal data within a personal data information system and/or resulting in the destruction of the physical media containing personal data.
3. Key Rights and Obligations of the Operator
3.1. The Operator has the right to:
— receive accurate information and/or documents containing personal data from the personal data subject;
— continue processing personal data without the subject's consent—in the event that the personal data subject withdraws their consent—provided there are grounds for doing so as specified in the Personal Data Law;
— independently determine the scope and list of measures necessary and sufficient to ensure compliance with the obligations stipulated by the Personal Data Law and regulatory legal acts adopted pursuant thereto, 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 the manner established by the current 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 Personal Data Law;
— provide the authorized body for the protection of personal data subjects' rights with necessary information upon that body's request, within 10 working days of receiving such a request;
— publish or otherwise ensure unrestricted access to this Policy regarding the processing of personal data;
— adopt legal, organizational, and technical measures to protect personal data against unauthorized or accidental access, destruction, alteration, blocking, copying, disclosure, or dissemination, as well as against other unlawful actions involving personal data;
— cease the transfer (dissemination, disclosure, provision of access) of personal data, cease processing, and destroy personal data in the manner and cases prescribed by the Personal Data Law;
— fulfill other obligations stipulated by the Personal Data Law.
4. Key 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 for by federal laws. Such information is provided to the personal data subject by the Operator in an accessible format and must not contain personal data relating to 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 that the Operator update, block, or destroy their personal data if the data is incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the stated purpose of processing, and to take measures provided by law to protect their rights;
— stipulate a requirement for prior consent regarding the processing of personal data for the purpose of promoting goods, works, and services on the market;
— withdraw consent for the processing of personal data;
— appeal—either to the authorized body for the protection of personal data subjects' rights or through judicial proceedings—against unlawful actions or inaction by the Operator regarding the processing of their personal data;
— exercise other rights provided for by the legislation of the Russian Federation.
4.2. Personal data subjects are obliged to:
— provide the Operator with accurate information about themselves;
— notify the Operator of any updates (updates or changes) to 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 the legislation of the Russian Federation.
5. Principles of personal data processing
5.1. Personal data processing is carried out on a lawful and fair basis.
5.2. Personal data processing is limited to the achievement of specific, predetermined, and lawful purposes. Processing of personal data that is incompatible with the purposes of data collection is not permitted.
5.3. The merging of databases containing personal data processed for mutually incompatible purposes is prohibited.
5.4. Only personal data that are relevant to the purposes of their processing shall be processed.
5.5. The content and volume of the personal data being processed shall correspond to the stated purposes of processing. The personal data being processed shall not be excessive in relation to the stated purposes of their processing.
5.6. During the processing of personal data, the accuracy, sufficiency, and—where necessary—currency of the personal data in relation to the purposes of processing shall be ensured. The Operator shall take, or ensure the taking of, necessary measures to delete or rectify incomplete or inaccurate data.
5.7. Personal data shall be stored in a form that allows for identify the personal data subject, for no longer than is required for the purposes of personal data processing, unless a retention period is established by federal law or by a contract to which the personal data subject is a party, beneficiary, or guarantor. Personal data undergoing processing shall be destroyed or anonymized upon the achievement of the processing purposes or if the need to achieve such purposes ceases to exist, unless otherwise provided by federal law.
6. Purposes and legal grounds for personal data processing
6.1. Purpose of processing: informing the User by sending emails containing, among other things, documents, commercial proposals, and other promotional materials.
6.2. Personal data:
- surname, first name, patronymic;
- email address;
- phone numbers;
- organization name;
Legal grounds:
- Federal Law No. 149-FZ "On Information, Information Technologies and Information Protection" dated July 27, 2006, and other federal laws and regulatory legal acts adopted pursuant thereto, in fulfillment of and in accordance with which the Operator processes personal data;
- consent of personal data subjects to the processing of personal data;
- other grounds where consent to the processing of personal data is not required under the legislation of the Russian Federation.
- sending informational emails to the email address, containing, among other things, documents, commercial proposals, and other promotional materials.
6.4. Types of personal data processing:
6.5. The Operator processes the User's personal data only if the User fills them in and/or sends them independently via special forms located on the website https://way-bill.ru or sends them to the Operator via email. By filling out the relevant forms and/or sending their personal data to the Operator, the User expresses their consent to this Policy.
7. List of actions performed by the Operator with the received personal data
7.1. The Operator carries out the collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (dissemination, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
7.2. The Operator carries out automated processing of personal data, involving the receipt and/or transmission of the obtained information via information and telecommunication networks or without such transmission. 8. Conditions and Procedure for Personal Data Processing
8.1. Personal data processing is carried out with the consent of the personal data subject, except in cases established by the legislation of the Russian Federation where such processing may occur without such consent.
9. Cross-Border Transfer of Personal Data
9.1. Prior to commencing cross-border transfer activities, the Operator must notify the authorized body for the protection of personal data subjects' rights of its intention to conduct such transfers (this notification is submitted separately from the notification regarding the intention to process personal data).
9.2. Prior to submitting the aforementioned notification, the Operator must obtain relevant information from the foreign state authorities, foreign individuals, or foreign legal entities to whom the personal data is intended to be transferred.
10. Confidentiality of Personal Data
The Operator and other parties who have gained access to personal data are prohibited from disclosing or disseminating such data to third parties without the consent of the personal data subject, unless otherwise provided by federal law.
11. Final Provisions
11.1. Users may obtain clarifications regarding the processing of their personal data by contacting the Operator via email at service@way-bill.ru.
11.2. This document reflects any changes to the Operator's personal data processing policy. The Policy remains in effect indefinitely until replaced by a new version.
11.3. The current version of the Policy is publicly available on the Internet at https://way-bill.ru/en/privacy.
