Privacy Policy

Last updated: 10 June 2022

This Privacy Policy (the “Privacy Policy”) is designed to provide data subjects (individuals) with information on the processing of their personal data (any information relating to them) in the context of RouteQ service (https://routeq.com) (“Service”).

This Privacy Policy is based on the provisions of data protection laws, which may be applicable in the country of your residence.

1. Controller

Data controller with regard to personal data processed under this Policy is Intertech Services AG (Werftestrasse 4, 6005 Luzern, Switzerland) or Yandex Inc. (10 State street, Newburyport, MA 01950, United States) (“RouteQ”), depending on which legal entity provides you Service under the main Agreement. If you receive RouteQ service from other entity, it shall be considered a controller with regard to your personal data.

Data subjects can contact RouteQ on any questions relating to the processing of their personal data under this Privacy Policy via email gdpr@routeq.com.

2. Purposes and legal bases for the processing

RouteQ processes personal data to provide the Service to its customers; to comply with applicable laws; to market the Service; to improve the Service; to protect its legal rights.

When doing so, RouteQ relies on (1) the necessity of the processing for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract; (2) the necessity of the processing of personal data to comply with its legal obligations; (3) the necessity of the processing of personal data for the purposes of the legitimate interests pursued by RouteQ. In some cases, RouteQ relies on (4) a consent of a data subject to process his or her personal data.

The legitimate interests of RouteQ consist of (1) compliance with applicable laws and regulations; (2) promoting the Service (except for the cases, where consent is required); (3) improvement of the Service; (4) protection of RouteQ’s legal rights. Data subjects can get more information on the legitimate interests pursued by RouteQ and relevant balancing tests by sending a request with the use of contact details specified in section 1 of this Privacy Policy.

3. Categories of personal data concerned

RouteQ processes the following categories of personal data related to its customers, their employees and representatives:

  • full name;
  • email address;
  • phone number;
  • other registration/authentication data (if applicable);
  • order details;
  • requests to RouteQ and information contained in them;
  • automatically collected information about usage of the Service collected through cookies or similar technologies.

RouteQ may also receive personal data related to couriers, goods receivers and logistic specialists. However, RouteQ processes such data solely on behalf of its customers and upon their instructions. If this is the case, customer shall be responsible for ensuring lawfulness of processing with regard to data subject’s personal data.

4. Recipients of personal data

RouteQ discloses certain personal data to the following recipients to the extent required or permitted by applicable law and/or based on their legitimate and reasonable requests:

  • affiliate entities of RouteQ which are a part of the same group of companies;
  • providers of CRM, ERP, billing and other systems required for administrating RouteQ business processes;
  • partners assisting in provision of the Service by RouteQ and achievement of other purposes mentioned in the section 2 of this Privacy Policy;
  • various state and municipal authorities if strictly required to respond to their legitimate formal inquiries;
  • other third parties when it is required for compliance with applicable laws.

5. Transfers to third countries

RouteQ may transfer personal data of the data subjects to third countries, including those that do not provide the same level of data protection as in the country of your residence. When doing so, RouteQ ensures implementation of security measures aimed at protection of your personal data in an appropriate manner. This may include, but not limited to, entering into Standard Contractual Clauses for international data transfers in the form approved by the European Commission.

The data subjects can get more information on the mechanisms of transfers to third countries by RouteQ by sending a request with the use of contact details specified in section 1 of this Privacy Policy.

6. Storage periods

RouteQ stores personal data as long as it is required to achieve the purposes of the processing specified in section 2 of this Privacy Policy, unless there are specific periods defined in applicable laws.

7. Basic rights of data subjects

The data subjects, in respect of their personal data, have rights to:

  1. access;

    (The data subject can ask RouteQ to confirm whether or not RouteQ processes his/her personal data. If so, the data subject can access these personal data and can ask RouteQ to explain certain details of the processing.)

  2. rectification;

    (The data subject can ask RouteQ to correct inaccurate personal data concerning him or her. If it complies with the purposes of the processing, the data subject can ask RouteQ to complete incomplete personal data.)

  3. erasure (‘right to be forgotten’);

    (The data subject can ask RouteQ to erase personal data concerning him or her under applicable law. For example, this applies if (1) the personal data are no longer necessary in relation to the purposes for which they were processed; (2) the data subject withdraws consent to the processing and there is no other legal ground for the processing; (3) the personal data have been unlawfully processed.)

  4. restriction on processing;

    (The data subject can ask RouteQ to mark the stored personal data with the aim to limit their processing in the future under applicable law. This applies if (1) the data subject contests the accuracy of the personal data; (2) the data subject asks to restrict the use of the personal data when their processing is unlawful; (3) the data subject needs personal data to protect their rights when RouteQ no longer needs the personal data; (4) the data subject has objected the processing based on the legitimate interests pursued by RouteQ or by a third party.)

  5. objection to processing (only if personal data processing is subject to the GDPR);

    (The data subject can object, on grounds relating to their particular situation, at any time to processing of personal data concerning him or her which is based on the legitimate interests pursued by RouteQ or by a third party. RouteQ shall no longer process the personal data unless RouteQ demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defense of legal claims.)

  6. portability (only if personal data processing is subject to the GDPR);

    (When the processing is based on consent of the data subject or on a contract with the data subject, the data subject can receive the personal data concerning him or her, which he or she has provided to RouteQ, in a structured, commonly used and machine-readable format and can freely transmit those data to another controller. Where technically feasible, the data subject can also ask RouteQ to transmit the personal data directly to another controller.)

To exercise their rights, data subjects can contact RouteQ with the use of contact details specified in section 1 of this Privacy Policy.

8. Withdrawal of consent

Where processing is based on consent (or explicit consent), the data subject has the right to withdraw consent at any time. The withdrawal of consent does not affect the lawfulness of the processing based on consent before its withdrawal. To withdraw consent, the data subject can contact RouteQ with the use of contact details specified in section 1 of this Privacy Policy.

9. Right to lodge a complaint with a supervisory authority

Data subject has the right to lodge a complaint with a supervisory authority in the area of data protection in the country of his/her residence.

10. Necessity to provide personal data

There are no general statutory or contractual requirements for data subjects to provide RouteQ with personal data processed under this Privacy Policy.

11. Sources of personal data

RouteQ collects personal data from the data subjects themselves.

12. Changes to this Privacy Policy

RouteQ may change this Privacy Policy from time to time at its sole discretion. If so, RouteQ may notify the data subjects about these changes by an appropriate method. If there is no explicit notification, the data subjects may always review the up-to-date version of this Privacy Policy located at https://routeq.com/legal/privacy.