Privacy Policy

Last updated: September 4, 2024

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

We can provide services to you depending on your location on behalf of different legal entities. Please review your Agreement with RouteQ or contact the email below to find out your applicable data controller

RouteQ is the controller of personal data processed under this Privacy Policy. It means that RouteQ determines the purposes and means of the processing of these personal data. Depending on the specific purpose and other circumstances of data processing, we may act as a controller or a processor. When acting as a controller, we independently determine the purposes and means of the processing of personal data. At the same time, being a processor, we process personal data on behalf of the customer and under its instructions.

When the Service is a data controller, the data subjects can contact RouteQ on any questions relating to the processing of their personal data under this Privacy Policy by either of the following methods:

via email routing-global@routing.yandex.com

2. Purposes and legal bases for the processing

RouteQ use your personal data to operate, provide, and improve it’s Services. We use personal information for these purposes:

• Provide our Service. We use your personal data to provide and deliver Service to you and process transactions related to Service, including registrations, subscriptions, purchases, and payments.
• Support and improve Service. We use your personal information to measure use of, analyze performance of, fix errors in, provide support for, improve, and develop Service.
• Comply with legal obligations. In certain cases, we have a legal obligation to collect, use, or retain your personal information.
• Communicate with you. We use your personal information to communicate with you in relation to Service via different channels (e.g., by phone, email, chat) and to respond to your requests.
• Marketing, recommendations and personalization. We will use your personal data to market and promote RouteQ and its Service. Where required by applicable laws we will ask for your consent for such processing.
• Protection of RouteQ’s legal rights and interests. We may use personal data to protect the interests of the RouteQ, for example, in judicial proceedings.

When doing so, RouteQ relies on:

• Performance of the contract. We may process your personal data to provide you with our services under the contract between you / your company;
• Legal Obligations. When we must process your personal data to comply with applicable laws;
• Legitimate Interest. We may process your personal data when we (or a third party) have an interest in using your personal data in a certain way, which is necessary and justified in light of the possible risks. 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.;
• Consent. Where required by applicable laws, we will process your personal data based on your consent. Please note that if under applicable laws processing of your personal data can be justified only by consent or other relevant legal ground, we will obtain such consent or ensure presence of respective legal ground.

Please note that if under applicable laws processing of your personal data can be justified only by consent or other relevant legal ground, we will obtain such consent or ensure presence of respective legal ground.

3. Categories of personal data concerned

RouteQ, as a data controller, processes the following categories of personal data:

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.

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.

Depending on the scope of your interactions with Service, your personal data may be stored in or accessed from multiple countries, including foreign countries that do not provide adequate protection of personal data under applicable legislation. Whenever we transfer personal information to other jurisdictions, we will ensure that the information is transferred in accordance with applicable laws.

7. Basic rights of data subjects

The data subjects, in respect of their personal data, have rights to (if corresponding rights are provided by the applicable legislation):

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’ (if provided to the data subjects under applicable data protection laws));

   (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 (if provided to the data subjects under applicable data protection laws);;

   (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 ((if provided to the data subjects under applicable data protection laws););

   (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 ((if provided to the data subjects under applicable data protection laws););

   (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.)

This list of data subject’s rights is based on the provisions of data protection laws and may be changed in accordance with applicable law in the country of your residence.

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

When provided by applicable data protection laws, a 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 or automatically during usage of the Service.

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.

Previous version: https://routeq.com/legal/privacy/10062022