Privacy and Personal Data Protection Policy

Privacy Policy for Personal Data of Website Users

1. General Provisions

1.1 This Privacy Policy for Personal Data of Website Users (hereinafter referred to as the Policy) has been developed in compliance with the requirements of Art. 18.1 of the Federal Law of July 27, 2006 No. 152-FZ "On Personal Data", and other regulatory legal acts of the Russian Federation in the field of protection and processing of personal data.

1.2. VR LOGISTIC LLC (hereinafter referred to as the Operator) ensures the protection of processed personal data from unauthorized access and disclosure, unlawful use or loss in accordance with the requirements of the Federal Law of July 27, 2006 No. 152-FZ "On Personal Data".

1.3. The Policy is a publicly available document that applies only to the website located in the Internet information and communication network at the address: www.vr-logistic.ru (hereinafter referred to as the Website).

1.4. The Policy does not apply to third-party websites that the personal data subject may access through the Website.

1.5. The Policy establishes general requirements and rules for working with all types of information carriers containing personal data of personal data subjects using the Website, which are mandatory for the Operator's employees involved in the processing of personal data.

1.6. The Policy does not apply to issues of ensuring the security of personal data classified as information constituting a state secret of the Russian Federation.

1.7. The main objectives of the Policy are:

ensuring the protection of human and civil rights and freedoms when processing personal data, including the protection of the rights to privacy, personal and family secrets;
eliminating unauthorized actions by the Operator's employees and third parties to collect, systematize, accumulate, store, clarify (update, change) personal data, other forms of illegal interference in the information resources and local area network of the Operator;
ensuring the legal and regulatory regime of confidentiality of undocumented information of the Users of the Site;
protecting the constitutional rights of citizens to personal privacy, confidentiality of information constituting personal data, and preventing the emergence of a possible threat to the security of the Users of the Site.

1.8. Key concepts used in the Policy:

website - a set of software and hardware for computers that ensure the publication for public viewing of information and data united by a common purpose, by means of technical means used for communication between computers on the Internet;

User - a subject of personal data who has access to the Internet and uses the capabilities of the site;

personal data - any information related to a directly or indirectly determined or determinable individual (subject of personal data);

Manager - the sole executive body of the Operator;

personal data processing - any action (operation) or set of actions (operations) with personal data, performed with or without the use of automation tools. Processing of personal data includes, among other things:

collection;
recording;
systematization;
accumulation;
storage;
clarification (updating, modification);
extraction;
use;
transfer (provision, access);
depersonalization;
blocking;
deletion;
destruction.

automated processing of personal data - processing of personal data using computer technology.

dissemination of personal data - actions aimed at disclosing personal data to an indefinite circle persons;

provision of personal data - actions aimed at disclosing personal data to a specific person or a specific group of persons;

blocking of personal data - temporary cessation of processing of personal data (except in cases where processing is necessary to clarify personal data);

destruction of personal data - actions that make it impossible to restore the content of personal data in the personal data information system and (or) that make it impossible to destroy material carriers of personal data;

depersonalization of personal data - actions that make it impossible to determine the ownership of personal data by a specific personal data subject without using additional information;

personal data information system (hereinafter referred to as ISPD) - a set of personal data contained in databases and the information technologies and technical means that ensure their processing.

2. Processing principles

2.1. The Operator's employees are guided by the following principles of processing personal data:

personal data is processed on a lawful and fair basis;
personal data processing must be limited to achieving specific, predetermined and lawful goals. Processing of personal data that is incompatible with the purposes of collecting personal data is not permitted;
it is not permitted to combine databases containing personal data that are processed for purposes that are incompatible with each other;
the content and volume of personal data being processed must correspond to the stated purposes of processing. The personal data being processed must not be excessive in relation to the purposes of their processing;
when processing personal data, the accuracy and sufficiency of personal data must be ensured;
personal data must be stored for no longer than required by the purposes of processing personal data, unless the storage period for personal data is established by Federal Law or an agreement with the User;
processed personal data are subject to destruction or depersonalization upon achieving the purposes of processing or in the event of loss of the need to achieve these purposes, unless otherwise provided for by law.

2.2. Terms of personal data processing:

the personal data of the Users of the Site is processed in accordance with the requirements of the current legislation in the field of personal data protection;
the personal data on the Site is processed in compliance with the principles and rules stipulated by the Policy and the legislation of the Russian Federation.

2.3. The personal data of the Users of the Site is processed exclusively for the purposes of:

promoting goods, works, services on the market.

2.5. The personal data used on the Site are provided by the User independently by entering it in the appropriate form when registering an account, are considered confidential information and are processed exclusively using automation tools.

3. User Rights

3.1. The User has the right:

to receive information about the Operator, its location, whether the Operator has personal data related to the User, as well as to become familiar with such personal data, except for cases expressly provided for by law;
to receive from the Operator the following information regarding the processing of his personal data:
confirmation of the fact of processing of personal data by the Operator, as well as the purpose of such processing;
legal grounds and purposes of processing of personal data;
purposes and methods of processing of personal data applied by the Operator;
name and location of the Operator, information about persons who have access to personal data or to whom personal data may be disclosed on the basis of an agreement with the Operator or on the basis of current legislation;
the personal data processed relating to the relevant User, the source of their receipt;
the terms of processing personal data, including the terms of their storage;
the procedure for exercising the rights provided for by the Federal Law by the subject of personal data;
information on the completed or proposed cross-border transfer of data;
the name or surname, first name, patronymic and address of the person processing personal data on behalf of the Operator, if the processing is or will be entrusted to such person;
other information provided for by the current legislation of the Russian Federation;
require changes, clarifications, destruction of information about oneself;
appeal illegal actions or inaction in the processing of personal data and demand appropriate compensation in court;
to appoint representatives to protect their personal data;
to demand notification from the Operator of all changes made to them or exceptions from them;
to appeal to the authorized body for the protection of the rights of personal data subjects or in court against the actions or inaction of the Operator if he believes that the latter processes his personal data in violation of the requirements of Federal Law of July 27, 2006 No. 152-FZ "On Personal Data" or otherwise violates his rights and freedoms;
to protect his rights and legitimate interests, including compensation for damages or compensation for moral damage in court.

4. Duties of the Operator

4.1. In case of receiving a written request from the User, the Operator is obliged to process it and provide a response to it, in the manner prescribed by the Rules for consideration of appeals of personal data subjects and the current legislation of the Russian Federation.

4.2. In case of receiving a request from the authorized body for the protection of the rights of personal data subjects to provide information necessary for the implementation of the activities of the specified body, the Operator is obliged to provide such information within the timeframes established by law.

4.3. In case of detection of unlawful processing of personal data, the Operator is obliged to block the unlawfully processed personal data related to the User, from the moment such fact is established.

4.4. In case of achieving the goal of processing personal data, the Operator is obliged to stop processing personal data and destroy personal data in the manner prescribed by the Regulation on the procedure for the destruction of personal data and the current legislation of the Russian Federation.

4.5. The Operator is prohibited from making decisions based solely on automated processing of personal data that generate legal consequences with respect to the personal data subject or otherwise affect his rights and legitimate interests.

5. Confidentiality of personal data

5.1. The Operator ensures the confidentiality and security of personal data during their processing in accordance with the requirements of the Operator's local regulations and the requirements of current legislation.

5.2. The Operator does not disclose to third parties or distribute personal data without the User's consent, unless otherwise provided for by the requirements of the current legislation of the Russian Federation.

6. Processing of personal data

6.1. All personal data should be obtained from the User. In the event of obtaining consent to the processing of personal data from the User's representative, his authority must be confirmed in accordance with the procedure established by law.

6.2. The list of persons entitled to access personal data is determined in accordance with the Operator's local regulations and approved by the order of the Operator's Head.

6.2. The Operator stores the Users' personal data from the moment they are provided until the moment of withdrawal of consent to the processing of personal data, achievement of the processing goals, or expiration of the period for which consent was provided, as well as in other cases expressly provided for by the current legislation of the Russian Federation.

6.3. The Operator does not process the Users' personal data on paper media.

6.4. The Operator does not transfer personal data to third parties, including for the purposes of processing. The Users' personal data is processed exclusively by the Operator's employees.

6.5. Blocking and deletion of personal data on the Site is carried out on the basis of a written request from the User or an authorized body.

6.6. Personal data is destroyed by erasing information using certified software.

7. Protection of personal data

7.1. When processing personal data, the operator takes the necessary legal, organizational and technical measures or ensures their adoption to protect personal data from unauthorized or accidental access to them, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other illegal actions in relation to personal data.

7.2. The security of personal data is achieved in the following ways:

by identifying threats to the security of personal data when processing them in personal data information systems;
by using organizational and technical measures r to ensure the security of personal data when processing them in personal data information systems necessary to meet the requirements for the protection of personal data;
accounting for machine-readable media of personal data;
detection of facts of unauthorized access to personal data and taking measures;
restoration of personal data modified or destroyed as a result of unauthorized access to them;
establishment of rules for access to personal data processed in the personal data information system, as well as ensuring the registration and accounting of all actions performed with personal data in the personal data information system;
control over the measures taken to ensure the security of personal data and the level of protection of personal data information systems;
appointment of a person responsible for the processing of personal data;
setting individual passwords for employee access to the information system in accordance with their job responsibilities;
use of certified anti-virus software;
training the Operator's employees directly involved in the processing of personal data in the provisions of the Russian Federation legislation on personal data, including the requirements for the protection of personal data.

7.3. Protected information about the User on the Site includes data that allows identifying the User or obtaining additional information about him/her, as provided for by law and the Policy.

7.4. Protected personal data objects include:

information technology objects and technical means of automated processing of information containing personal data;
information resources containing information about information and telecommunications systems in which personal data are used, about events that have occurred with managed objects, about plans for ensuring uninterrupted operation and procedures for switching to management in emergency modes;
communication channels that are used to transmit personal data in the form of informative electrical signals and physical fields;
alienable machine-readable information carriers on a magnetic, magneto-optical and other basis, used to process personal data.

7.5. Technological information about information systems and elements of the personal data protection system subject to protection includes:

information about the access control system to information technology facilities where personal data is processed;
control information;
technological information about the means of access to control systems;
characteristics of communication channels that are used to transmit personal data in the form of informative electrical signals and physical fields;
information about the means of protecting personal data, their composition and structure, principles and technical solutions for protection;
service data that appears during the operation of software, messages and protocols of inter-network interaction, as a result of processing personal data.

7.6. The personal data protection system complies with the requirements of the RF Government Resolution of November 1, 2012 No. 1119 "On Approval of Requirements for the Protection of Personal Data When Processing Them in Personal Data Information Systems" and ensures:

timely detection and prevention of unauthorized access to personal data or their transfer to persons who do not have the right to access such information;
prevention of impact on technical means of automated processing of personal data, as a result of which their functioning may be disrupted;
the ability to immediately restore personal data modified or destroyed due to unauthorized access to them;
constant monitoring of the level of security of personal data.

8. Responsibility

8.1. All employees of the Operator who process personal data are required to keep information containing personal data confidential.

8.2. Persons guilty of violating the requirements for the processing of personal data are liable in accordance with the current legislation of the Russian Federation.

8.3. Responsibility for compliance with the personal data regime in relation to personal data located in the Site databases lies with the employees of the Operator responsible for the processing of personal data.

9. Final Provisions

9.1. The Policy was approved by the order of the Head of the Operator No. 1-PDn dated 04/25/2025, and is valid indefinitely until the new version of the Policy comes into force.

9.2. In the event of a change in the legislation of the Russian Federation in the field of personal data protection, the Operator accepts the new version of the Policy taking into account the changes. Until that moment, the Policy is valid to the extent that it does not contradict the current legislation of the Russian Federation.

9.3. The following contact information may be used to contact the Operator:

tel.: +7(495) 646-98-56;

e-mail: logistic@vr-logistic.ru;

mailing address: 119607, Moscow, Michurinsky Prospekt, 31, bldg. 7.

Personal Data Processing Policy

1. General Provisions

1.1. This Policy on the processing of personal data (hereinafter referred to as the Policy) has been developed in compliance with the requirements of clause 2, part 1, article 18.1 of the Federal Law of 27.07.2006 No. 152-FZ "On personal data" (hereinafter referred to as the Law) in order to ensure the protection of the rights and freedoms of man and citizen when processing his personal data, including the protection of the rights to privacy, personal and family secrets.

1.2. The Policy applies to all personal data processed by VR LOGISTIC LLC (hereinafter referred to as the Operator).

1.3. The Policy applies to relations in the field of personal data processing that arose with the Operator both before and after the approval of this Policy.

1.4. In compliance with the requirements of Part 2 of Article 18.1 of the Law, this Policy is published in the public domain by posting it on the Operator's website in the information and telecommunications network "Internet", at the address:www.vr-logistic.ru.

1.5. Key concepts used in the Policy:

personal data - any information related to a directly or indirectly identified or determinable individual (subject of personal data);

personal data operator (operator) - a government agency, municipal agency, legal entity or individual that 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, actions (operations) performed with personal data;

personal data processing - any action (operation) or set of actions (operations) with personal data performed with or without the use of automation tools. Processing of personal data includes, among other things:
collection;
recording;
systematization;
accumulation;
storage;
clarification (updating, modification);
extraction;
use;
transfer (provision, access);
depersonalization;
blocking;
deletion;
destruction.

automated processing of personal data - processing of personal data using computer technology;

dissemination of personal data - actions aimed at disclosing personal data to an indefinite number of persons;

Manager – the sole executive body of the Operator;

provision of personal data – actions aimed at disclosing personal data to a specific person or a specific group of persons;

blocking of personal data – temporary cessation of processing of personal data (except in cases where processing is necessary to clarify personal data);

destruction of personal data – actions as a result of which it becomes impossible to restore the content of personal data in the personal data information system and (or) as a result of which tangible carriers of personal data are destroyed;

depersonalization of personal data – actions as a result of which it becomes impossible to determine the ownership of personal data by a specific subject of personal data without the use of additional information;

personal data information system – a set of information containing x in personal data databases and information technologies and technical means that ensure their processing.

1.6. Basic rights and obligations of the Operator.

1.6.1. The Operator has the right:

independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations stipulated 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;
entrust the processing of personal data to another person with the consent of the personal data subject, unless otherwise provided by federal law, on the basis of an agreement concluded with this person. The person processing personal data on behalf of the Operator is obliged to comply with the principles and rules for processing personal data provided for by the Law on personal data, maintain the confidentiality of personal data, take the necessary measures aimed at ensuring the fulfillment of obligations stipulated by the Law on Personal Data;
if the personal data subject revokes their consent to the processing of personal data, the Operator has the right to continue processing personal data without the consent of the personal data subject if there are grounds specified in the Law on personal data.

1.6.2. The operator is obliged to:

organize the processing of personal data in accordance with the requirements of the Law on personal data;
respond to requests and inquiries from personal data subjects and their legal representatives in accordance with the requirements of the Law on personal data;
notify the authorized body for the protection of rights of personal data subjects (the Federal Service for Supervision of Communications, Information Technology and Mass Media (Roskomnadzor)) at the request of this body of the necessary information within 10 working days from the date of receipt of such a request. This period may be extended, but not more than by five working days. To do this, the Operator must send Roskomnadzor a reasoned notice indicating the reasons for extending the period for providing the requested information;
in the manner determined by the federal executive body authorized in the field of security, ensure interaction with the state system for detection, prevention and elimination of consequences of computer attacks on the information resources of the Russian Federation, including informing it of computer incidents that resulted in the illegal transfer (provision, distribution, access) of personal data.

1.7. Basic rights of the subject of personal data. The personal data subject has the right to:

receive information regarding the processing of his/her personal data, except for cases stipulated by federal laws. The information is provided to the personal data subject by the Operator in an accessible form, and it must not contain personal data related to other personal data subjects, except for cases where there are legal grounds for disclosing such personal data. List of information and the procedure for obtaining it is established Law on personal data;
require the operator to clarify his personal data, block or destroy it if the personal data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated purpose of processing, and also take measures provided by law to protect his rights;
give preliminary consent to the processing of personal data for the purpose of promoting goods, works and services on the market;
appeal in Roskomnadzor or in court illegal actions or inaction of the Operator when processing his personal data.

1.8. Control over compliance with the requirements of this Policy is carried out by an authorized person responsible for organizing the processing of personal data by the Operator.

1.9. Liability for violation of the requirements of the legislation of the Russian Federation and regulatory acts of the Operator in the field of processing and protection of personal data is determined in accordance with the legislation of the Russian Federation.

2. Purposes of collecting personal data

2.1. The processing of personal data is limited to achieving specific, predetermined and legitimate purposes. Processing of personal data that is incompatible with the purposes of collecting personal data is not allowed.

2.2. Only personal data that meets the purposes of their processing may be processed.

2.3. The Operator processes personal data for the following purposes:

maintaining personnel and accounting records;
recruiting personnel (applicants) for vacant positions of the Operator;
ensuring access control to the Operator's territory;
preparation, conclusion and execution of civil contracts;
ensuring the passage of introductory, industrial or pre-graduation practice on the basis of an agreement with an educational institution;
voluntary health insurance;
promotion of goods, works, services on market.

2.4. Personal data may be processed solely for the purpose of ensuring compliance with laws and other regulatory legal acts.

3. Legal grounds for processing personal data

1. The legal basis for processing personal data is a set of regulatory legal acts, pursuant to which and in accordance with which the Operator processes personal data, including:
Constitution of the Russian Federation;
Civil Code of the Russian Federation;
Labor Code of the Russian Federation;
Tax Code of the Russian Federation;
Federal Law of 27.07.2006 No. 152-FZ "On Personal Data";
Federal Law dated 06.12.2011 No. 402-FZ "On Accounting";
Federal Law of 15.12.2001 No. 167-FZ "On Compulsory Pension Insurance in the Russian Federation";
Federal Law of 27.07.2006 No. 149-FZ "On Information, Information Technologies and Information Protection";
RF Government Resolution of 27.11.2006 No. 719 "On approval of the Regulation on military registration";
RF Government Resolution of 15.09.2008 No. 687 "On approval of the Regulation on the specifics of personal data processing carried out without the use of automation tools";
other regulatory legal acts governing relations related to the Operator's activities.

3.2. The legal basis for the processing of personaldata are also:

Operator's Charter;
agreements concluded between the Operator and personal data subjects;
consent of personal data subjects to the processing of their personal data.

Volume and categories of personal data processed, categories of personal data subjects

4.1. The content and volume of personal data processed must correspond to the declared purposes of processing, provided in Section 2 of this Policy. The personal data processed must not be excessive in relation to the declared purposes of their processing.

4.2. The Operator may process personal data of the following categories of personal data subjects:

4.2.1. Dismissed employees, employees, as well as their relatives - for the purpose of maintaining personnel and accounting records, including the implementation of directly related legal relations, including labor, tax, pension and insurance:

last name, first name, patronymic;
year of birth;
month of birth;
date of birth;
place of birth;
marital status;
social status;
income;
gender;
e-mail address;
residential address;
registration address;
phone number;
SNILS;
TIN;
citizenship;
identity document details;
driver's license details;
identity document details outside the Russian Federation;
document details contained in the birth certificate;
bank card details;
current account number;
personal account number;
profession;
job title;
work experience details (including length of service, current employment details indicating the organization's name and current account);
relation to military service, military registration details;
education details.

4.2.2. Beneficiaries under agreements, clients and counterparties of the Operator, including their representatives - for the purpose of carrying out statutory activities, including the preparation, conclusion and execution of agreements:

last name, first name, patronymic;
year of birth;
month of birth;
date of birth;
place of birth;
gender;
e-mail address;
residential address;
registration address;
phone number;
TIN;
citizenship;
identity document details;
driver's license details;
identity document details outside the Russian Federation;
bank details cards;
account number;
personal account number;
profession;
job title;
information on work experience (including length of service, data on current employment with the name and account number of the organization).
2.3. Applicants - for the purpose of recruiting personnel for vacant positions of the Operator and forming a personnel reserve:
last name, first name, patronymic;
year of birth;
month of birth;
date of birth;
place of birth;
gender;
e-mail address;
residential address;
registration address;
phone number;
TIN;
citizenship;
identity document details;
driver's license details;
identity document details outside the Russian Federation;
profession;
position;
work experience information (including length of service, data on current employment with the name and bank account of the organization);
information on education.

4.2.4. Employees - for the purpose of ensuring access control to the Operator's territory:

last name, first name, patronymic;
identity document details;
driver details identity document;
data of the identity document outside the Russian Federation.

4.2.5. Students - for the purpose of ensuring the completion of introductory, industrial or pre-graduation practice on the basis of an agreement with an educational institution:

last name, first name, patronymic;
year of birth;
month of birth;
date of birth;
place of birth;
gender;
e-mail address;
residential address;
registration address;
telephone number;
TIN;
citizenship;
identity document details;
identity document details outside the Russian Federation;
profession;
education details.

4.2.6. Employees - for the purpose of voluntary health insurance:

last name, first name, patronymic;
year of birth;
month of birth;
date of birth;
place of birth;
gender;
e-mail address;
residential address;
registration address;
telephone number;
TIN;
citizenship;
identity document details;
identity document details outside the Russian Federation;
profession;
position.

4.2.7. Site visitors - for the purpose of promoting goods, works, services on the market:

last name, first name, patronymic;
e-mail address;
phone number;
information collected through metric programs.

4.3. The operator processes personal data in the following ways:

collection;
recording;
systematization;
accumulation;
storage;
clarification (updating, modification);
extraction;
use;
transfer (provision, access);
depersonalization;
blocking;
deletion;
destruction.

4.4. The Operator does not process special categories of personal data related to race, nationality, political views, religious or philosophical beliefs, health status, intimate life, with the exception of cases provided for by legislation of the Russian Federation.

5. Procedure and conditions for processing personal data

5.1. The processing of personal data is carried out by the Operator in accordance with the requirements of the legislation of the Russian Federation.

5.2. The processing of personal data is carried out with the consent of the subjects of personal data to the processing of their personal data, as well as without such consent in cases stipulated by the legislation of the Russian Federation.

5.3. The Operator shall process personal data for each purpose of their processing in the following ways:

non-automated processing of personal data;
automated processing of personal data with or without the transfer of the received information via information and telecommunications networks;
mixed processing of personal data.

5.4. The Operator's employees whose job responsibilities include the processing of personal data are allowed to process personal data.

5.5. Processing of personal data for each purpose of processing specified in p. 2.3 of the Policy, is carried out by:

receiving personal data in oral and written form directly from the subjects of personal data;
entering personal data into the Operator's journals, registers and information systems;
using other methods of processing personal data.

5.6. Disclosure to third parties and distribution of personal data is not permitted without the consent of the subject of personal data, unless otherwise provided by federal law. Consent to the processing of personal data, permitted by the subject of personal data for distribution, is drawn up separately from other consents of the subject of personal data. data for the processing of his personal data.

Requirements for the content of consent to the processing of personal data permitted by the subject of personal data for distribution are approved by Order of Roskomnadzor dated 02.24.2021 No. 18 "On approval of requirements for the content of consent to the processing of personal data permitted by the subject of personal data for dissemination".

5.7. The transfer of personal data to inquiry and investigation bodies, the Federal Tax Service, the Social Fund of Russia and other authorized executive bodies and organizations is carried out in accordance with the requirements of the legislation of the Russian Federation.

5.8. The Operator shall take the necessary legal, organizational and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, distribution and other unauthorized actions, including:

identifies threats to the security of personal data during their processing;
adopts local regulations and other documents governing relations in the field of processing and protecting personal data;
appoints persons responsible for ensuring the security of personal data in the structural divisions and information systems of the Operator;
creates the necessary conditions for working with personal data;
organizes the accounting of documents containing personal data;
organizes work with information systems in which personal data is processed;
stores personal data in conditions that ensure their safety and exclude unauthorized access to them;
organizes training for the Operator's employees who process personal data.

5.9. The Operator stores personal data in a form that allows the subject of personal data to be identified, no longer than required by each purpose of processing personal data, unless the storage period for personal data is established by federal law or agreement.

5.9.1. Personal data on paper media are stored by the Operator for the document storage periods for which these periods are stipulated by the legislation on archival affairs in the Russian Federation (Federal Law dated 22.10.2004 No. 125-FZ "On Archival Affairs in the Russian Federation", List of standard management archival documents generated in the course of activities of state bodies, local governments and organizations, indicating their storage periods (approved by Order of Rosarchive dated 20.12.2019 No. 236 "On approval of the List of standard management archival documents generated in the course of activities of state bodies, local governments and organizations, indicating their storage periods")).

5.9.2. The storage period of personal data processed in personal data information systems corresponds to the storage period of personal data on paper media.

5.10. The operator stops processing personal data in the following cases:

the fact of their illegal processing is detected. The term is within three working days from the date of detection;
the purpose of their processing is achieved;
the consent of the subject of personal data to the processing of the specified data has expired or has been revoked, when, according to the Law, the processing of this data is allowed only with consent.

5.11. Upon achieving the goals of personal data processing, as well as in the event of the personal data subject's withdrawal of consent to their processing, the Operator shall stop processing these data if:

otherwise not provided by the agreement to which the personal data subject is a party, beneficiary or guarantor;
The Operator shall not have the right to process personal data without the consent of the personal data subject on the grounds provided for by the Law or other federal laws;
otherwise not provided by another agreement between the Operator and the personal data subject.

5.12. If the personal data subject applies to the Operator with a request to stop processing personal data within a period not exceeding 10 business days from the date of receipt of the relevant request by the Operator, the processing of personal data shall be terminated, except for cases provided for by the Law. The specified period may be extended, but not more than by five business days. To do this, the Operator must send the personal data subject a reasoned notice indicating the reasons for the extension.

5.13. When collecting personal data, including via the Internet information and telecommunications network, the Operator ensures the recording, systematization, accumulation, storage, clarification (updating, modification), extraction of personal data of citizens of the Russian Federation using databases located on the territory of the Russian Federation, except for cases specified in the Law on personal data.

5.14. The operator uses the following information systems:

1C: Accounting;
1C: Salary and Personnel;
1C: UNF.

6. Updating, correcting, deleting, destroying personal data, responding to requests from subjects for access to personal data

6.1. Confirmation of the fact of personal data processing by the Operator, legal grounds and purposes of personal data processing, as well as other information specified in Part 7 of Article 14 of the Law, shall be provided by the Operator to the personal data subject or his/her representative within 10 business days from the date of the request or receipt of the personal data subject's or his/her representative's request. This period may be extended, but not more than by five business days. To this end, the Operator shall send the personal data subject a reasoned notice indicating the reasons for extending the deadline for providing the requested information.

The information provided shall not include personal data related to other personal data subjects, except in cases where there are legal grounds for disclosing such personal data.

The request shall contain:

the number of the main document certifying the identity of the personal data subject or his/her representative, information on the date of issue of the said document and the issuing authority;
information confirming the participation of the personal data subject in relations with the Operator (contract number, date of conclusion of the contract, conventional verbal designation and (or) other information), or information otherwise confirming the fact of processing of personal data by the Operator;
signature of the personal data subject or his/her representative.

The request may be sent in the form of an electronic document and signed with an electronic signature in accordance with the legislation of the Russian Federation.

The operator provides the information specified in h. 7 tbsp. 14 of the Law, to the subject of personal data or his representative in the form in which the relevant request or inquiry is sent, unless otherwise specified in the request or inquiry.

If the request (request) of the subject of personal data does not reflect in accordance with the requirements of the Law on personal data all the necessary information or the subject does not have the rights to access the requested information, then a reasoned refusal is sent to him.

The right of the subject of personal data to access his personal data may be restricted in accordance with Part 8 of Article 14 of the Law, including if the personal data subject's access to his/her personal data violates the rights and legal interests of third parties.

6.2. In the event that inaccurate personal data is discovered upon an application by the personal data subject or his/her representative or at their request or at the request of Roskomnadzor, the Operator shall block the personal data related to this personal data subject from the moment of such application or receipt of the specified request for the verification period, if blocking the personal data does not violate the rights and legitimate interests of the personal data subject or third parties.

In the event that the fact of inaccuracy of personal data is confirmed, the Operator, on the basis of information provided by the personal data subject or his/her representative or Roskomnadzor, or other necessary documents, shall clarify the personal data within seven working days from the date of submission of such information and remove the blocking of the personal data.

6.3. In the event of detection of unlawful processing of personal data upon an appeal (request) by a personal data subject or his/her representative or Roskomnadzor, the Operator shall block the unlawfully processed personal data related to this personal data subject from the moment of such appeal or receipt of the request.

6.4. If the Operator, Roskomnadzor or another interested party detects a fact of unlawful or accidental transfer (provision, distribution) of personal data (access to personal data) that has resulted in a violation of the rights of personal data subjects, the Operator:

within 24 hours - notifies Roskomnadzor of the incident that has occurred, the alleged reasons that resulted in the violation of the rights of personal data subjects, the alleged harm caused to the rights of personal data subjects, and the measures taken to eliminate the consequences of the incident, and also provides information about the person authorized by the Operator to interact with Roskomnadzor on issues related to the incident;
within 72 hours - notifies Roskomnadzor of the results of the internal investigation of the identified incident and provides information about the persons whose actions caused it (if any).

6.5. Procedure for the destruction of personal data by the Operator.

6.5.1. Conditions and terms for destruction of personal data by the Operator:

achievement of the purpose of processing personal data or loss of the need to achieve this purpose - within 30 days;
achievement of the maximum storage periods for documents containing personal data - within 30 days;
provision by the subject of personal data (his representative) of confirmation that the personal data were obtained illegally or are not necessary for the stated purpose of processing - within seven working days;
revocation by the subject of personal data of consent to the processing of his personal data, if their storage for the purpose of their processing is no longer required - within 30 days.

6.5.2. Upon achieving the purpose of processing personal data, as well as in the event of withdrawal of consent to their processing by the subject of personal data, personal data are subject to destruction if:

otherwise not provided by the agreement to which the subject of personal data is a party, beneficiary or guarantor;
The Operator has no right to process personal data without the consent of the subject on the grounds provided for by the Law on personal data or other federal laws;
unless otherwise provided by another agreement between the Operator and the personal data subject.

6.5.3. The destruction of personal data is carried out by a commission created by the order of the Head of the Operator.

6.5.4. The methods of destruction of personal data are established in local regulations of the Operator.

7. Final Provisions

7.1. The Policy was approved by order of the Head of the Operator No. 1-PDn dated 04/25/2025, and is valid indefinitely until the new version of the Policy comes into force.

7.2. In the event of a change in the legislation of the Russian Federation in the field of personal data protection, the Operator adopts a new version of the Policy taking into account the changes. Until that moment, the Policy is valid to the extent that it does not contradict the current legislation of the Russian Federation.

7.3. The following contact information may be used to contact the Operator:

tel. +7(495) 646-98-56;

e-mail: logistic@vr-logistic.ru;

mailing address: 11960 7, Moscow, Michurinsky Prospekt, 31, bldg. 7.

Consent to the processing of personal data

1. This consent to the processing of personal data (hereinafter referred to as the Consent) expresses the will of the user of the information and telecommunications network "Internet" (hereinafter referred to as the User), transmitting his/her personal data through the website located at www.vr-logistic.ru (hereinafter referred to as the Website) of VR LOGISTIC LLC (OGRN: 1067746859036, INN: 7701670782, address: 115172, Moscow, Narodnaya St., 14, building 3, floor 3, room II, Room 3; tel.: +7(495) 646-98-56; e-mail: logistic@vr-logistic.ru)

2. In accordance with the Federal Law of 27.07.2006 No. 152-FZ "On Personal Data", the User gives the Contractor specific, subject, informed, conscious and unambiguous consent to the processing of his personal data for the purpose of: promoting goods, works, services on the market.

3. The User gives the Contractor consent to the processing of the following personal data:

last name, first name, patronymic;
e-mail address;
phone number;
information collected through metric programs.

4. The User authorizes the Contractor to perform automated and non-automated processing of personal data in the following forms:

collection;
recording;
systematization;
accumulation;
storage;
clarification (update, change);
extraction;
use;
blocking;
deletion;
destruction.

5. Consent is valid from the date of its provision until the purpose of personal data processing is achieved. The User has the right to revoke Consent to the processing of personal data by notifying the Operator in writing.

Consent to the processing of cookies

1. This consent to the processing of cookies (hereinafter referred to as the Consent) expresses the consent of the user of the information and telecommunications network "Internet" (hereinafter referred to as the User) to the automated processing of personal data collected using metric programs on the site located at www.vr-logistic.ru (hereinafter referred to as the Site) of OOO "VR LOGISTIC" (OGRN: 1067746859036, INN: 7701670782, address: 115172, Moscow, Narodnaya St., 14, building 3, floor 3, room II, room 3; tel.: +7(495) 646-98-56; e-mail: logistic@vr-logistic.ru) (hereinafter referred to as the Operator).

2. The consent applies to technical cookies that allow you to determine the hardware and software device of the User, as well as analytical cookies that allow you to track the User's actions on the Site.

Analytical cookies are collected using the services:

Yandex.Metrica.

3. Data collected using metric programs is used by the Operator to improve the operation of the Site, in particular, saving the User's settings, correcting errors, etc., which allows for more convenient submission of applications on the Site.

4. The User authorizes the Contractor to perform automated processing of data collected using metric programs in the following forms: collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, blocking, deletion, destruction.

5. Consent is valid from the date of its provision until the moment the purpose of personal data processing is achieved. The User has the right to revoke Consent to the processing of personal data by notifying the Operator in writing.

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