Personal Data and Privacy Policy

Port and Logistics Company “Caspy” LLC

1. General provisions

1.1. This Policy sets out the procedure for processing personal data and the measures to ensure its security applied by Port and Logistics Company “Caspy” Limited Liability Company (hereinafter, the Operator).

1.2. The Operator’s primary goal is to respect human rights and freedoms when processing personal data, including the protection of the rights to privacy and personal and family confidentiality.

1.3. This Policy applies to all information that the Operator may obtain about visitors to the website caspyplc.ru.

1.4. The Operator ensures the confidentiality of personal data. The Operator and other persons who have obtained access to personal data must not disclose it to third parties or distribute it without the consent of the data subject, unless otherwise provided by federal law.

2. Key terms

2.1. Personal data means any information relating to a directly or indirectly identified or identifiable individual (data subject).

2.2. Processing of personal data means any action (operation) performed with personal data, including collection, recording, systematisation, accumulation, storage, clarification, use, transfer, depersonalisation, blocking, deletion and destruction.

3. Categories of data subjects and data processed

3.1. The Operator processes data of the following categories of data subjects:

  • website visitors;
  • persons who have submitted a request or enquiry via the website forms;
  • representatives of counterparties.

3.2. Data processed:

  • full name;
  • name of the organisation on whose behalf the user is contacting us;
  • phone number or email address;
  • the text of the task (message) the user describes in the request form;
  • technical data: IP address, cookies, browser and device information (collected automatically when visiting the website).

4. Purposes of processing

4.1. Personal data is processed for the following purposes:

  • handling requests and providing feedback to the user;
  • concluding and performing service contracts;
  • improving the website and analysing user behaviour (depersonalised data).

5. Legal grounds

5.1. The legal grounds for processing are:

  • the data subject’s consent to the processing of their personal data;
  • performance of a contract to which the data subject is a party;
  • requirements of the legislation of the Russian Federation.

6. Procedure and conditions of processing

6.1. Processing is carried out both with and without the use of automation tools.

6.2. The Operator takes the necessary legal, organisational and technical measures to protect personal data against unauthorised access, destruction, modification, blocking, copying and distribution.

6.3. Data is stored no longer than required by the purposes of processing. Requests are stored for up to 1 year from the date of the last contact.

6.4. Database localisation. Recording, systematisation, accumulation, storage, clarification and retrieval of personal data of citizens of the Russian Federation are carried out using databases located in the Russian Federation.

7. Use of cookies

7.1. The website uses cookies and web analytics services to analyse visitor behaviour and improve the website.

7.2. Cookies are pieces of data sent by a server and stored on the user’s device. Technical data (IP address, browser information, date and time of visit) is processed in depersonalised form.

7.3. Users may block or restrict cookies in their browser settings. If cookies are disabled, some website functions may not work correctly.

8. Transfer of data to third parties

8.1. The Operator may transfer data to third parties in the following cases:

  • to provide services (transfer of data to a CRM or a service used to process requests), subject to mandatory confidentiality;
  • at the request of authorised government bodies in accordance with the procedure established by law.

8.2. Personal data is not transferred outside the Russian Federation.

9. Rights of the data subject

9.1. The data subject has the right to:

  • receive information about the processing of their data;
  • demand that data be clarified, blocked or destroyed if it is incomplete, outdated or inaccurate;
  • withdraw consent to processing;
  • appeal against the Operator’s actions to Roskomnadzor or in court.

10. Final provisions

10.1. The Operator may amend this Policy. The current version is always available at https://caspyplc.ru/en/privacy.

10.2. Operator contact details for enquiries: plc@caspyplc.ru.