1. General Provisions
This Personal Data Processing Policy is formulated in accordance the measures to ensure the security of personal data undertaken by First Mile for Trading and Logistics FZC SPC (hereinafter referred to as the "Operator").
1.1. The Operator's paramount goal and condition for carrying out its activities is the observance of human and citizen's rights and freedoms when processing their personal data, including the protection of the rights to privacy, personal and family secrets.
1.2. This Operator's policy regarding 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://firstmile-spc.com/
2. Basic Concepts Used in the Policy
2.1. Automated processing of personal data – processing of personal data by means of computer technology.
2.2. Blocking of personal data – temporary cessation of personal data processing (except for cases where processing is necessary to clarify personal data).
2.3. Website – a combination of graphical and informational materials, as well as computer programs and databases ensuring their availability on the Internet at the network address https://firstmile-spc.com/
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. Depersonalization of personal data – actions as a result of which it is impossible to determine, without the use of additional information, the belonging of personal data to a specific User or other subject of personal data.
2.6. Processing of personal data – any action (operation) or a set of actions (operations) performed with or without the use of automation means with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), 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, and the actions (operations) performed with personal data.
2.8. Personal data – any information relating directly or indirectly to a specific or identifiable User of the website https://firstmile-spc.com/
2.9. Personal data permitted by the data subject for dissemination – personal data to which access by an unlimited number of persons is provided by the data subject by giving consent to the processing of personal data permitted by the data subject for dissemination in the manner prescribed by the Personal Data Law (hereinafter referred to as "personal data permitted for dissemination").
2.10. User – any visitor to the website https://firstmile-spc.com/
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 familiarizing an unlimited number of persons with personal data, including the publication of personal data in the mass media, posting 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 an authority of a foreign state, a foreign individual, or a foreign legal entity.
2.14. Destruction of personal data – any actions as a result of which personal data are irretrievably destroyed with no possibility of further restoring the content of personal data in the personal data information system and/or material carriers of personal data are destroyed.
3. Basic Rights and Obligations of the Operator
3.1. The Operator has the right to:
— Receive from the data subject reliable information and/or documents containing personal data;
— If the data subject withdraws consent to the processing of personal data, as well as submits a request to cease the processing of personal data, the Operator has the right to continue processing personal data without the data subject's consent if there are grounds specified in the Personal Data Law;
— Independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations under the Personal Data Law and regulatory legal acts 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 data subject, upon request, with information concerning the processing of their personal data;
— Organize the processing of personal data in the manner established by the current legislation;
— Respond to appeals and requests from data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
— Communicate to the authorized body for the protection of the rights of data subjects, upon this body's request, the necessary information within 10 days from the date of receipt of such request;
— Publish or otherwise provide 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, modification, blocking, copying, provision, dissemination of personal data, as well as from other unlawful actions in relation to personal data;
— Cease the transfer (distribution, provision, access) of personal data, cease processing, and destroy personal data in the manner and cases provided for by the Personal Data Law;
— Perform other duties provided for by the Personal Data Law.
4. Basic Rights and Obligations of Data Subjects
4.1. Data subjects have the right to:
— Receive information regarding the processing of their personal data, except in cases provided for by federal laws. The information is provided to the data subject by the Operator in an accessible form, and it shall not contain personal data relating to other data subjects, except in cases where there are lawful grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
— Require the Operator to 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 purpose of processing, and to take statutory measures to protect their rights;
— Impose the condition of prior consent when processing personal data for the purpose of promoting goods, works, and services on the market;
— Withdraw consent to the processing of personal data, as well as submit a request to cease the processing of personal data;
— Appeal to the authorized body for the protection of the rights of data subjects or in court against unlawful actions or inaction of the Operator in the processing of their personal data;
— Exercise other rights provided for by the legislation.
4.2. Data subjects are obliged to:
— Provide the Operator with accurate data about themselves;
— Inform the Operator about the clarification (update, change) of their personal data.
4.3. Persons who have provided the Operator with false information about themselves or information about another data subject without the latter's consent shall be liable in accordance with the 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 the achievement of specific, predetermined, and lawful purposes. Processing of personal data that is incompatible with the purposes of personal data collection is not permitted.
5.3. It is not allowed to combine databases containing personal data that are processed for purposes that are incompatible with each other.
5.4. Only personal data that meet the purposes of their processing are subject to processing.
5.5. The content and volume of the processed personal data correspond to the stated purposes of processing. The processed personal data shall not be excessive in relation to the stated purposes of their processing.
5.6. When processing personal data, the accuracy of personal data, their sufficiency, and, where necessary, relevance in relation to the purposes of personal data processing are ensured. The Operator takes necessary measures and/or ensures their adoption 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 data subject for no longer than required by the purposes of personal data processing, unless the storage period for personal data is established by federal law, an agreement to which the data subject is a party, beneficiary, or guarantor. Processed personal data are destroyed or depersonalized upon achievement of the processing purposes or in case of loss of necessity to achieve these purposes, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing
7. Conditions for Personal Data Processing
7.1. The processing of personal data is carried out with the consent of the data subject to the processing of their personal data.
7.2. The processing of personal data is necessary to achieve the goals specified in an international treaty or law, and to perform the functions, powers, and duties assigned to the Operator by law.
7.3. The processing of personal data is necessary for the administration of justice, the execution of a court order, or an order issued by another authority or official that must be executed in accordance with the law.
7.4. The processing of personal data is necessary for the performance of a contract to which the data subject is a party, beneficiary, or guarantor, as well as for concluding a contract on the initiative of the data subject or a contract under which the data subject will be a beneficiary or guarantor.
7.5. The processing of personal data is necessary for the exercise of the rights and legitimate interests of the Operator or third parties, or for achieving socially significant purposes, provided that the rights and freedoms of the data subject are not violated.
7.6. Personal data are processed, access to which is provided by the data subject or at their request to an unlimited number of persons (hereinafter referred to as "publicly available personal data").
7.7. Personal data are processed that are 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 the 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 exclude 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 the execution of current legislation or in cases where the 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. If inaccuracies in personal data are identified, the User may update them independently by sending a notification to the Operator via email to the Operator's email address hpgtn1@gmail.com with the subject line "Update of personal data."
8.4. The period for processing personal data is determined by the achievement of the purposes for which the personal data were collected, unless a different period is provided for by the contract or current legislation.
The User may at any time withdraw their consent to the processing of personal data by sending a notification to the Operator via email to the Operator's email address hpgtn1@gmail.com with the subject line "Withdrawal of consent to the processing of personal data."
8.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by said persons (Operators) in accordance with their User Agreement and Privacy Policy. The data subject is obliged to independently familiarize themselves with the specified documents. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this clause.
8.6. The prohibitions established by the data subject on the transfer (except for providing access), as well as on the processing or conditions of processing (except for obtaining access) of personal data permitted for dissemination, do not apply in cases of processing personal data in state, public, and other public interests as defined by the legislation.
8.7. The Operator, when processing personal data, ensures the confidentiality of personal data.
8.8. The Operator stores personal data in a form that allows identification of the data subject for no longer than required by the purposes of personal data processing, unless the storage period for personal data is established by federal law, an agreement to which the data subject is a party, beneficiary, or guarantor.
8.9. The condition for terminating the processing of personal data may be the achievement of the purposes of processing personal data, the expiration of the data subject's consent, the withdrawal of consent by the data subject, a request to cease the processing of personal data, or the identification of unlawful processing of personal data.
9. List of Actions Performed by the Operator with the Received Personal Data
9.1. The Operator performs collection, recording, systematization, accumulation, storage, clarification (updating, modification), 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 the receipt and/or transmission of the obtained information via information and telecommunication networks or without it.
10. Cross-Border Transfer of Personal Data
10.1. Before commencing activities related to the cross-border transfer of personal data, the Operator is obliged to notify the authorized body for the protection of the rights of data subjects of its intention to carry out cross-border transfer of personal data (such notification is sent separately from the notification of intention to process personal data).
10.2. Before submitting the aforementioned notification, the Operator is obliged to obtain relevant information from the authorities of the foreign state, foreign individuals, foreign legal entities to whom 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 to third parties and not to distribute personal data without the consent of the data subject, unless otherwise provided by federal law.
12. Final Provisions
12.1. The User can obtain any clarifications on questions of interest regarding the processing of their personal data by contacting the Operator via email at hpgtn1@gmail.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://firstmile-spc.com/