Statement on observance of confidentiality of personal data
We, LOGOPER LLC, consider it necessary to protect the confidentiality and integrity of the information transmitted. In this regard, the Company undertakes to ensure the necessary protection and proper use of personal information (also referred to as “personal data”, “personally identifiable information”) received from you directly or through third parties authorized by you in electronic form or on tangible media and processed by the Company with or without the use of automation tools.
As a general rule, we only collect personal information that you provide to us voluntarily for the purpose of providing you or persons related to you in a civil legal relationship with information about the Company (including events and vacancies) and/or services, or to decide whether to cooperate and enter into contracts. Please read this Privacy Statement (the “Statement”) carefully to get a better understanding of the Company's procedures for collecting, using, transferring and protecting personal information received.
This Statement applies to information processed through the Company's electronic resources, including this website, as well as other websites and resources of the Company or the Company's third-party vendors that contain a link to this Company Statement.
1. Collection and use of personal information
1.1 The nature of the information we collect.
- We obtain personal information about you if you provide it to us of your own volition, either directly or through third parties authorized by you. In some cases, the Company may already have the personal information you provide (for example, if you are a former employee of the Company or have a pre-existing business relationship with the Company).
- When you register or submit your personal information to the Society, we will use that information in accordance with this Statement. Your personal information will not be used for any other purpose unless we obtain your authorization to use it for another purpose or such use is required or permitted by law or professional standards. For example, if you register on the Company's website and indicate your preferences, we are obligated to use your preference information for your account.
- Where, for recruitment purposes with the Society, you send us an email containing a personal resume or applicant CV, we use this information to provide you with details of available vacancies.
- On occasion, when you register for certain services, we will retain - temporarily - your e-mail address until we receive confirmation of the information you have provided to us by e-mail (i.e., to confirm your registration request or other action, we send an e-mail to the address you provided when you registered).
- 1.1.1 Information about employees and job applicants.
- We process personal data of our employees, persons with whom the employment contract has been terminated, as well as applicants for vacant positions. The specific set of data and the purposes of processing depend on the nature of your relationship with the Company and are described in the respective consents for the processing of personal data. If you belong to one of these categories, information about you may, where applicable, be added to the Company's talent pool, subject to your consent. In such a case, your data will be processed in accordance with the provisions applicable in the Company.
- 1.1.2 Information required for marketing activities
- In order to promote our services, we carry out various marketing activities: we organize events (including webinars), publish materials on relevant topics, send (potential) customers and related parties and event attendees information and promotional mailings, including about our services, events and publications. We strive to ensure that the information you receive is relevant and relevant to your interests. In order to accomplish these goals, we may need your personal information (name, surname, first name, patronymic, e-mail address, place of employment, job title, other contact information).
- In cases where you provide the Company with your personal data or act as a contact person for interaction with the Company, for example, under a service contract, we may enter information about you into the Company's (potential) customer information management system to maintain business relations, as well as send an invitation to complete a survey on the quality of our services. Only authorized employees who need such information to maintain business relations with the Company's customers (including potential customers) have access to the information contained in the information management system.
1.2 Legal grounds for using the personal information we collect.
- The Company will normally only collect personal information that is necessary to fulfill your request or fulfill our contractual obligations. If we need to obtain additional information, you will be notified at the time the information is collected.
- In order to comply with applicable laws that permit us to process personal information provided we have a legitimate reason to do so, we will be governed by one of the following processing conditions:
- Contract formation and performance: the processing of your personal information is necessary for the formation of a contract and/or the performance of our obligations thereunder;
- Statutory duty: we are required to process your personal information in order to fulfill a statutory duty, such as keeping records for tax purposes or providing information to a government or law enforcement agency;
- Your consent: on occasion we will seek your individual consent to process a block of your personal information, and we will only process your personal information if we obtain your consent. You may withdraw your consent at any time by contacting the Company at personal-data@logoper.ru and stating the purpose for which your contact details were provided to us.
- Special categories of personal data are defined in accordance with the law and are processed by the Company only in cases stipulated by applicable law.
1.3 Personal Data Processing and Security Policy.
- The Personal Data Processing and Confidentiality Policy is developed in the Company in accordance with the Federal Law dated 27.07.2006 No. 152-FZ “On Personal Data” and is a fundamental internal regulatory document of the Company, which determines the key areas of activity of each of the legal entities specified therein in the field of personal data processing and security.
1.3 Cookie technology.
We use different types of cookies (specialized files placed on your device):
- User input cookies
- Authorization cookies
- Cookies from analytics services
- You can configure your browser settings so that cookies are blocked or your system informs you whenever a website wants to set cookies. However, you should be aware that as a consequence of blocking cookies, you may no longer be able to use most of the functions of the Logoper Ltd We use various types of social add-ons on our websites.
A list of cookies embedded in our websites is available at https://logoper.ru/en/cookie/.
2. Sharing and transfer of personal information
2.1 Transfer of personal information to third parties.
- We do not share personal information with third parties unless it is necessary for the purposes of our professional activities, processing your requests, fulfilling contractual obligations and/or required or permitted by law or professional standards. For more information about these third parties, please refer to the Personal Data Processing and Privacy Policy.
- The Company does not carry out cross-border transfer of your personal data in the course of processing.
- The Company undertakes not to transfer the personal information provided by you to third parties for the purpose of its further use by such parties for direct marketing purposes.
3. Choice
The Company will ask you for your permission to use your personal information for certain purposes, and you can either give or refuse permission accordingly. If you subscribe to specific services or newsletters, such as information about the location of rolling stock, you may opt out of receiving them at any time by following the instructions provided. If you decide to opt-out of receiving mailings, we will endeavor to remove your contact from our mailing list as soon as possible, but we may require additional information from you before we can process your request.
As set out in the “Cookie Technology” section above, if you do not want cookies to track your navigation of our sites, you can set your browser to block all cookies or to alert you when a cookie is sent. In doing so, please be aware that some site resources may not be available as a result of blocking cookies.
4. Your rights
When the Company processes your personal information, you have the following rights:
- Access and correction of inaccuracies: you have the right to access your personal information. The document on the basis of which such access is granted is called a “Personal Data Subject Access Request”. Where the provision of personal information to you is required by applicable law, such information will be provided to you free of charge. Prior to providing you with personal information, we may ask you for proof of identity and the necessary amount of information about the nature of the interaction between us from which we can identify your personal information. If your personal information held by us is incorrect, you have the right to request that we correct the inaccuracies.
- Objection toprocessing: you have the right to object to the processing of your personal information if you believe that we may not use it in the future.
- Decision-making based solely on automated processing of personal data: decision-making in relation to you shall not be based solely on automated processing of your personal data, except as required by law where you have given your consent in writing.
- Right to withdraw consent and/or lodge a complaint with an authorized body: for more information, please refer to section 8 “Questions regarding the provisions of this policy and compliance measures”.
- Other rights: In addition, you have the right to request deletion of your personal information if you believe that we have unreasonably exceeded the retention period and, in certain circumstances, to request limited processing and/or to receive printouts of your personal information that we store electronically.
- You may make a request and exercise the above rights by contacting the Company at personal-data@logoper.ru and specifying the purpose for which you have provided us with your contact information, and we will use all reasonable and practicable efforts to comply with your request, provided that it does not contravene applicable law and professional standards.
5. Information security and data safety
The Company has adopted and implemented security measures and policies to protect personal information from loss, unauthorized use, modification or deletion. At the same time, in light of all existing threats to information security, it is impossible to provide an absolute guarantee of personal information security even despite all the efforts the Company will make. For our part, we do our best to ensure that access to your personal information is available only to those persons who need it for the performance of their official duties. Persons who have access to personal information are obliged to keep it confidential.
We endeavor to keep personal information for only as long as we need it to:
- a) fulfill requests and/or contractual obligations;
- b) to fulfill legal, regulatory, internal administrative or internal policy requirements, or
- c) until the person who provided the personal information requests us to delete such information.
The retention period for such data will depend on the specific events and circumstances under which the information was collected, but in accordance with the requirements of a) through c) above, personal information will not be retained longer than is required by applicable law.
6. Links to other websites
In most cases, the Company's Web sites will contain links to other sites that are subject to other privacy and personal information protection policies, often different from this Statement. Before disclosing any personal information, we encourage online visitors to review the privacy policy posted on each website.
By registering on any Company Web site and linking your account to a Web site maintained by the Company, you consent to the use of your personal information in accordance with the privacy statement of the Company Web site you are visiting at that time.
7. Changes to the Statement
The Company may amend this Statement from time to time to reflect the data security practices in effect at a particular time. Each time we make a change, we will include the date of the new revision at the top of this page. To learn exactly how the Company safeguards your personal information, we recommend that you review this Statement regularly to look for and learn about new provisions
8. Questions regarding the provisions of the adopted policy and measures to comply with it
The Company is committed to protecting the privacy of your personal information.
If you have any questions or comments regarding our handling of your personal information, please contact the Company's Privacy Officer at personal-data@logoper.ru. You may also use this address to report any concerns about our compliance with the Statement. We will acknowledge receipt of your email within 14 days and will take steps to resolve your concern within one month of receipt of the relevant email, unless a different timeframe is required by applicable law. In the event that the problem is complex or we are dealing with more than one problem at a particular time, we will notify you that it will take longer than one month to resolve your problem and that we will endeavor to resolve it within three months of your first report of the problem, but within the time limits provided by applicable law.
In any case, you always have the right to file a complaint with the regulatory authority responsible for the protection of personal information.