Personal Data Processing Policy

We carry out cargo transportation in Russia and abroad, as well as develop and implement logistics schemes for cargo traffic that fully correspond to the specifics of the client's activities.

Version dated: 4 September 2026

1. Terms and Definitions

1.1. Automated processing of personal data — processing of personal data using computer technology.

1.2. Blocking of personal data — temporary suspension of personal data processing (except where processing is required to clarify personal data).

1.3. Personal data information system (PDIS) — a set of databases containing personal data, as well as information technologies and technical means that ensure their processing.

1.4. Confidentiality of personal data — the obligation of the Operator and other persons who have obtained access to personal data not to disclose them to third parties and/or disseminate them without the consent of the personal data subject or another lawful basis.

1.5. Depersonalization of personal data — actions as a result of which it becomes impossible, without additional information, to determine that personal data belong to a specific subject.

1.6. Processing of personal data — any action (operation) or set of actions performed with personal data, with or without the use of automation tools, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (dissemination, provision, access), including cross-border transfer, blocking, deletion, and destruction.

1.7. Personal data operator (Operator) — Transport and Logistics Center LLC (ООО «Транспортно-логистический центр») (INN 7811419211, KPP 781001001), address: 196084, Saint Petersburg, Moskovskaya Zastava, Moskovsky Prospekt, 97A, 12th floor.

1.8. Personal data — any information relating to a directly or indirectly identified or identifiable natural person (personal data subject).

1.9. Engagement for personal data processing — an engagement by the Operator of another person to process personal data under a contract concluded with that person, where provided by law.

1.10. Provision of personal data / access to personal data — actions aimed at disclosing personal data to a specific person or a specific circle of persons.

1.11. Dissemination of personal data — actions aimed at disclosing personal data to an indefinite circle of persons.

1.12. Website — a set of computer programs and other information accessible via the Internet under the domain name t-lc.ru and related addresses (including test and service mirrors of the Operator’s Website). The owner of the Website is Transport and Logistics Center LLC (ООО «Транспортно-логистический центр»).

1.13. Consent to personal data processing — an expression of will by the personal data subject confirmed by ticking the relevant field (checkbox) on the Website. The consent checkbox is not pre-selected (not checked by default); a form containing personal data cannot be submitted without an explicit checkbox mark. The specific list of personal data and the purpose of processing for each form are stated in the consent text linked next to the checkbox of the relevant form.

1.14. Cross-border transfer of personal data — transfer of personal data to the territory of a foreign state to a foreign state authority, a foreign natural person, or a foreign legal entity.

1.15. Destruction of personal data — actions as a result of which it becomes impossible to restore the content of personal data in the PDIS and/or material media containing personal data are destroyed.

1.16. Cookie file (“cookie”) — a small piece of data stored by the browser on the user’s device when visiting the Website.

1.17. Personal data subjects — natural persons who are visitors to the Operator’s Website.

1.18. Website visitor — a natural person who accesses the Website via the Internet, with or without registration.

2. General Provisions

2.1. This Policy on the processing of personal data of Website visitors (hereinafter, the Policy) is an internal document of the Operator and defines the procedure for processing and measures for protecting the personal data of Website visitors.

2.2. The Policy is published in open access on the Website pursuant to Part 2 of Article 18.1 of Federal Law No. 152-FZ of 27 July 2006 “On Personal Data” (hereinafter, Law No. 152-FZ).

2.3. The Policy has been developed taking into account:

Article 24 of the Constitution of the Russian Federation;
Law No. 152-FZ;
Federal Law No. 149-FZ of 27 July 2006 “On Information, Information Technologies and Protection of Information”;
Resolution of the Government of the Russian Federation No. 1119 of 1 November 2012;
other mandatory regulatory legal acts and clarifications of authorized bodies in the field of personal data protection.

2.4. Information on the Operator’s inclusion in the register of operators processing personal data is published on the official resource of Roskomnadzor: https://pd.rkn.gov.ru/operators-registry/operators-list/

2.5. Certain Website forms are accompanied by separate consent texts for personal data processing. In the event of a discrepancy between this Policy and the consent text for a specific form regarding the list of personal data and the purpose of processing, the consent text in effect at the time it was given shall prevail.

3. Rights and Obligations of the Operator and Personal Data Subjects

3.1. A personal data subject has the right:

to receive information about the processing of their personal data;
to access their personal data;
to clarification, blocking, or destruction of personal data if they are incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated processing purpose;
to withdraw consent to personal data processing;
to appeal the Operator’s actions (inaction) to Roskomnadzor or in court;
to protection of their rights and legitimate interests, including recovery of damages and/or compensation for moral harm.

3.2. A personal data subject is obliged:

to provide accurate personal data to the extent necessary for the processing purposes;
to promptly notify the Operator of changes to the personal data provided.

3.3. The Operator’s employees authorized to process personal data:

obtain access only to data necessary to perform their job duties;
must comply with the requirements of legislation and the Operator’s internal documents;
consider requests from personal data subjects within the time limits established by Law No. 152-FZ.

4. Purposes of Personal Data Processing

4.1. The Operator processes personal data of Website visitors for the following purposes:

considering callback requests submitted via the relevant Website form and providing a response (contacting the user);
considering inquiries, questions, and messages submitted via Website feedback forms and providing a response;
considering transportation cost calculation requests and providing a response;
considering cargo transportation requests (including container and other shipments) and providing a response / preparing a commercial proposal;
considering online applications submitted via the relevant Website forms and providing a response;
considering reviews and suggestions submitted via the Website form and providing a response (where necessary);
ensuring the technical operation, security, and availability of the Website;
analyzing user behavior, collecting Website visit statistics, and using web analytics tools (including Yandex Metrica) to assess the effectiveness of the Website and improve it;
analyzing the effectiveness of advertising campaigns (including via VK Ads) — subject to the user’s relevant consent.

4.2. In cases provided by law, processing may be carried out without separate consent of the personal data subject, including for concluding and performing a contract at the subject’s initiative.

5. Legal Grounds for Personal Data Processing

5.1. The legal grounds for processing personal data are:

consent of the personal data subject;
the need to perform a contract to which the personal data subject is a party (or a beneficiary or guarantor), as well as a contract at the initiative of the personal data subject;
other grounds provided by Part 1 of Article 6 of Law No. 152-FZ.

6. Categories of Subjects and Composition of Processed Personal Data

6.1. Category of subjects: Website visitors.

6.2. Depending on the Website form used, the Operator may process the following personal data (the specific list for each form is stated in the consent text for that form):

last name, first name, patronymic (if provided);
contact phone number;
email address;
text of an inquiry, review, suggestion, comment, or other message submitted via a Website form;
information entered by the user in cost calculation and transportation request forms (including points of origin and destination, cargo details, and other request parameters);
files and information contained in files voluntarily submitted by the user via Website forms.

6.3. Special categories of personal data and biometric personal data are not processed by the Operator. Users should not submit special categories of personal data via Website forms.

6.4. Technical and analytical data may be processed automatically:

IP address;
information from cookie files;
information about the browser, operating system, interface language, and screen parameters;
visited pages, session duration, sources and referral points;
aggregated information about the user’s country and region.

The procedure for obtaining consent to the use of cookies and analytics, as well as the composition of the relevant data, is additionally disclosed in the cookie notice and in the consent text for cookie/analytics data processing published on the Website.

6.5. Retention period for personal data specified in clause 6.2: until the processing purposes are achieved, but no longer than 1 (one) year from the date of the last interaction with the subject, or 30 (thirty) calendar days from the date of consent withdrawal — whichever occurs earlier.

6.6. Retention period for data specified in clause 6.4: up to 1 (one) year from the date of receipt, or 30 (thirty) calendar days from the date of withdrawal of consent to the use of cookies and analytical tools.

7. Procedure and Conditions for Personal Data Processing

7.1. Personal data are processed with the subject’s consent, unless otherwise provided by the legislation of the Russian Federation.

7.2. Processing is carried out primarily by automated means.

7.3. Access to personal data is granted only to authorized employees of the Operator.

7.4. Personal data are obtained:

via feedback, application, cost calculation, review, and other forms on the Website;
when voluntarily provided by the user;
automatically when visiting Website pages (cookies, analytics) — subject to the relevant legal grounds / consent.

7.5. Cookie files are used for the proper operation of the Website, analytics, and improving the user experience. The user may restrict the use of cookies in browser settings and/or via the Website cookie banner interface; in that case, certain Website functions may be unavailable.

7.6. Transfer of personal data to third parties is permitted only where there are lawful grounds and to the extent necessary to achieve the processing purposes. Processing may be entrusted to other persons under an engagement contract (including contractors providing technical support for the Website and handling inquiries), subject to the requirements of Law No. 152-FZ.

7.7. Personal data are stored within the territory of the Russian Federation.

7.8. Upon achievement of the processing purposes, as well as upon withdrawal of consent, personal data are subject to destruction within a period not exceeding 30 (thirty) calendar days, unless otherwise provided by law or contract.

7.9. The Website may use the Yandex Metrica web analytics service to analyze traffic and user behavior. The service is used on the basis of the user’s consent expressed via the cookie banner on the first visit to the Website. Until consent is obtained, non-essential cookies and analytical tools are not activated.
Service rules: https://yandex.ru/legal/metrica_termsofuse/ru/
Yandex Privacy Policy: https://yandex.ru/legal/confidential/ru/

7.10. The Website may use the VK Ads service to analyze the effectiveness of advertising campaigns. Use of the service is also based on the user’s consent via the cookie banner.
VK Privacy Policy: https://id.vk.com/privacy/

7.11. Cross-border transfer of personal data is not carried out by the Operator, except where such transfer is necessary to perform a contract with the personal data subject and/or is expressly provided for by the legislation of the Russian Federation.

8. Handling Requests from Personal Data Subjects

8.1. A personal data subject may send a request to the Operator:

by mail to: 196084, Saint Petersburg, Moskovskaya Zastava, Moskovsky Prospekt, 97A, 12th floor;
by email: admin@t-lc.ru.

8.2. The request must contain the information required by Article 14 of Law No. 152-FZ, including details of the identity document of the subject (or their representative) and information confirming the subject’s involvement in relations with the Operator.

8.3. The Operator considers requests and sends a response within the time limits established by Law No. 152-FZ.

8.4. If incompleteness, inaccuracy, or unlawfulness of processing is confirmed, the Operator amends, blocks, or destroys personal data within the time limits established by law.

8.5. Consent to personal data processing may be withdrawn by sending a written request to admin@t-lc.ru with the subject line “Withdrawal of consent to personal data processing”.
After receiving the withdrawal, the Operator ceases processing (or ensures that processing ceases by the person processing data under an engagement) and destroys personal data within a period not exceeding 30 (thirty) calendar days, unless there are other lawful grounds for further processing.

9. Personal Data Protection Measures

9.1. The Operator takes the necessary legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, alteration, blocking, copying, provision, dissemination, and other unlawful actions.

9.2. Such measures include:

approval of local acts on personal data processing and protection;
appointment of responsible persons;
restriction and accounting of access to personal data;
employee training;
internal control of compliance with legal requirements and internal procedures.

10. Liability. Final Provisions

10.1. The Operator and persons guilty of violating personal data legislation bear liability as established by the legislation of the Russian Federation, including administrative liability under Article 13.11 of the Code of Administrative Offences of the Russian Federation.

10.2. The Operator takes measures to minimize the volume of personal data processed and to destroy them in a timely manner upon achievement of the processing purposes.

10.3. The Operator may amend this Policy. The current version is always available on the Website. Continued use of the Website after a new version is published means the user has reviewed it to the extent that does not require separate consent; consents to personal data processing previously given by the subject remain in effect to the extent they do not conflict with the new version and Law No. 152-FZ, or must be obtained again if required by law or by a change in the purposes/composition of processing.

Transport and Logistics Center LLC (ООО «Транспортно-логистический центр»)
INN 7811419211, KPP 781001001
196084, Saint Petersburg, Moskovskaya Zastava, Moskovsky Prospekt, 97A, 12th floor
E-mail: admin@t-lc.ru