Last updated: 10 June 2022
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.
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.
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;
- 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.
6. Storage periods
7. Basic rights of data subjects
The data subjects, in respect of their personal data, have rights to:
(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.)
(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.)
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.)
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.)
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.)
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.)
8. Withdrawal of consent
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
11. Sources of personal data
RouteQ collects personal data from the data subjects themselves.