1. General Provisions
This Personal Data Processing Policy has been drawn up in accordance with the requirements of the Federal Law of July 27, 2006, No. 152-FZ "On Personal Data" (hereinafter referred to as the "Law on Personal Data") and defines the procedure for processing personal data and the measures taken by EU-TRANSIT (hereinafter referred to as the "Operator") to ensure the security of personal data.
1.1. The Operator’s primary goal and condition for its activities is the observance of the rights and freedoms of man and citizen when processing their personal data, including the protection of the right to inviolability of private life, personal and family secrecy.
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://eutransit.net.

2. Basic Terms Used in the Policy
2.1. Automated processing of personal data – processing of personal data using computer hardware and software.
2.2. Blocking of personal data – temporary cessation of the processing of personal data (except in cases where processing is necessary to clarify personal data).
2.3. Website – a set of graphic and informational materials, as well as computer programs and databases that ensure their availability on the Internet at the network address https://eutransit.net.
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. 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 to a specific User or other subject of personal data.
2.6. Processing of personal data – any action (operation) or set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
2.7. Operator – a state body, municipal body, legal entity, or individual who independently or jointly with other persons organizes and/or carries out the processing of personal data, as well as determines the purposes of processing personal data, the composition of personal data subject to processing, 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://eutransit.net.
2.9. Personal data permitted by the subject of personal data for distribution – personal data to which an unlimited circle of persons has been granted access by the subject of personal data by giving consent to the processing of personal data permitted by the subject of personal data for distribution in the manner prescribed by the Law on Personal Data (hereinafter referred to as "personal data permitted for distribution").
2.10. User – any visitor to the website https://eutransit.net.
2.11. Provision of personal data – actions aimed at disclosing personal data to a specific person or a specific circle of persons.
2.12. Distribution of personal data – any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or at acquainting an unlimited circle 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 – the transfer of personal data to the territory of a foreign state to a government 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 destroyed irretrievably, making it impossible to further restore the content of the personal data in the personal data information system, and/or the material carriers of personal data are destroyed.

3. Main Rights and Obligations of the Operator
3.1. The Operator has the right to:

• Receive from the subject of personal data reliable information and/or documents containing personal data;
• In the event of the withdrawal by the subject of personal data of consent to the processing of personal data, as well as the submission of a request to terminate the processing of personal data, the Operator has the right to continue processing personal data without the consent of the subject of personal data if there are grounds specified in the Law on Personal Data;
• Independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations provided for by the Law on Personal Data and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Law on Personal Data or other federal laws.

3.2. The Operator is obliged to:

• Provide the subject of personal data, upon their request, with information concerning 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 appeals and requests from subjects of personal data and their legal representatives in accordance with the requirements of the Law on Personal Data;
• Provide the authorized body for the protection of the rights of subjects of personal data, upon request of such body, with the necessary information within 10 days from the date of receipt of such request;
• Publish or otherwise ensure unlimited 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, modification, blocking, copying, provision, distribution of personal data, as well as from other unlawful actions in relation to personal data;
• Terminate the transfer (distribution, provision, access) of personal data, cease processing, and destroy personal data in the manner and cases provided for by the Law on Personal Data;
• Fulfill other obligations provided for by the Law on Personal Data.

4. Main Rights and Obligations of Subjects of Personal Data
4.1. Subjects of personal data have the right to:

• Receive information concerning the processing of their personal data, except in cases provided for by federal laws. Information is provided to the subject of personal data by the Operator in an accessible form, and it must not contain personal data relating to other subjects of personal data, except in cases where 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 from the Operator the clarification of their personal data, their blocking or destruction in case the personal data are incomplete, outdated, inaccurate, illegally obtained, or are not necessary for the stated purpose of processing, as well as to take measures provided by law to protect their rights;
• Set a condition of prior consent when processing personal data for the purpose of promoting goods, works, and services in the market;
• Withdraw consent to the processing of personal data, as well as submit a request to terminate the processing of personal data;
• Appeal to the authorized body for the protection of the rights of subjects of personal data or to court against unlawful actions or inaction of the Operator when processing their personal data;
• Exercise other rights provided for by the legislation of the Russian Federation.

4.2. Subjects of personal data are obliged to:

• Provide the Operator with accurate data about themselves;
• Inform the Operator about the clarification (updating, change) of their personal data.

4.3. Persons who have provided the Operator with inaccurate information about themselves, or information about another subject of personal data without the latter's consent, bear responsibility in accordance with the legislation of the Russian Federation.
5. Principles of Personal Data Processing
5.1. Processing of personal data is carried out on a lawful and fair basis.
5.2. Processing of personal data is limited to achieving specific, predetermined, and lawful purposes. Processing of personal data incompatible with the purposes of collecting personal data is not allowed.
5.3. Merging of databases containing personal data, the processing of which is carried out for purposes incompatible with each other, is not allowed.
5.4. Only personal data that meet the purposes of their processing are subject to processing.
5.5. The content and volume of processed personal data correspond to the stated purposes of processing. Excessiveness of processed personal data in relation to the stated purposes of their processing is not allowed.
5.6. When processing personal data, the accuracy of personal data, their sufficiency, and, in necessary cases, relevance to the purposes of processing personal data are ensured. The Operator takes necessary measures and/or ensures their adoption to delete or clarify incomplete or inaccurate data.
5.7. Storage of personal data is carried out in a form that allows identification of the subject of personal data, no longer than required by the purposes of processing personal data, unless the storage period of personal data is established by federal law, contract, party to which, beneficiary or surety under which is the subject of personal data. Processed personal data are destroyed or depersonalized upon achievement of the processing purposes or in case of loss of necessity in achieving these purposes, unless otherwise provided by federal law.

6. Purposes of Personal Data Processing
6.1. Processing Purpose: Providing the User with access to services, information, and/or materials contained on the website.
6.2. Personal Data: Name, phone number.
6.3. Legal Grounds: Federal Law "On Information, Information Technologies and on Protection of Information" dated July 27, 2006, No. 149-FZ.
6.4. Types of Personal Data Processing: Collection, recording, systematization, accumulation, storage, destruction, and depersonalization of personal data.

7. Conditions for Personal Data Processing
7.1. Processing of personal data is carried out with the consent of the subject of personal data to the processing of their personal data.
7.2. Processing of personal data is necessary to achieve the goals provided for by an international treaty of the Russian Federation or by law, for the exercise of functions, powers, and duties assigned to the operator by the legislation of the Russian Federation.
7.3. Processing of personal data is necessary for the administration of justice, execution of a judicial act, an act of another body or official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. Processing of personal data is necessary for the performance of a contract, to which the subject of personal data is a party, beneficiary, or surety, as well as for the conclusion of a contract at the initiative of the subject of personal data or a contract under which the subject of personal data will be a beneficiary or surety.
7.5. 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.
7.6. Processing of personal data is carried out, access to which by an unlimited circle of persons has been provided by the subject of personal data or at their request (hereinafter referred to as "publicly available personal data").
7.7. 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 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 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 compliance with current legislation, or in case the subject of personal data has given consent to the Operator to transfer data to a third party for the fulfillment of obligations under a civil law contract.
8.3. In case of inaccuracies in personal data, the User can update them independently by sending a notification to the Operator’s email address eutransit2015@gmail.com with the mark "Actualization of Personal Data".
8.4. The term of processing personal data is determined by the achievement of the purposes for which the personal data were collected, unless a different term is provided for by the 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 eutransit2015@gmail.com with the mark "Withdrawal of Consent to Personal Data Processing".
8.5. All information collected by third-party services, including payment systems, communication means, and other service providers, is stored and processed by said persons (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data and/or [agrees] with said documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this paragraph.
8.6. Prohibitions established by the subject of personal data on transfer (except for providing access), as well as on processing or conditions of processing (except for obtaining access) of personal data permitted for distribution, do not apply in cases of processing personal data for state, public, and other public interests defined by the legislation of the Russian Federation.
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 subject of personal data, no longer than required by the purposes of processing personal data, unless the storage period of personal data is established by federal law, contract, party to which, beneficiary or surety under which is the subject of personal data.
8.9. The condition for termination of personal data processing may be the achievement of the purposes of personal data processing, expiration of the consent of the subject of personal data, withdrawal of consent by the subject of personal data or a request to terminate the processing of personal data, as well as the detection of unlawful processing of personal data.

9. List of Actions Performed by the Operator with Received Personal Data
9.1. The Operator carries out 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 carries out automated processing of personal data with the receipt and/or transfer of the received information via information and telecommunication networks or without such transfer.

10. Cross-Border Transfer of Personal Data
10.1. Before commencing activities on the cross-border transfer of personal data, the Operator is obliged to notify the authorized body for the protection of the rights of subjects of personal data 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 above-mentioned notification, the Operator is obliged to obtain relevant information from the authorities of the foreign state, foreign individuals, and 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 them to third parties and not to distribute personal data without the consent of the subject of personal data, unless otherwise provided by federal law.

12. Final Provisions
12.1. The User can receive any clarifications on issues of interest concerning the processing of their personal data by contacting the Operator via email at eutransit2015@gmail.com.
12.2. This document will reflect any changes to the Operator’s personal data processing policy. The Policy is valid indefinitely until it is replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet at https://eutransit.net.