The current version is available at: https://cargolink.pro/policy.
2. Who processes the information
3. What is the purpose of this Policy
The protection of your Personal Information and your privacy is extremely important to Cargolink. Therefore, when you use the Sites and Services, Cargolink protects and processes your Personal Information in strict accordance with applicable law.
Consistent with our responsibility to protect your Personal Information, we would like to inform you as transparently as possible about the following points in this Policy:
(a) why and how Cargolink collects and uses (“processes”) your Personal Information when you use the Sites and/or Services;
(b) what are the roles and responsibilities of Cargolink as the legal entity deciding why and how to process your Personal Information;
(c) what tools you can use to reduce the amount of Personal Information Cargolink collects about you;
(d) what are your rights in relation to the ongoing processing of Personal Information.
Personal information collected during the operation of the Sites and/or provision of Services, as well as during the use of sites, programs, products or services of Partners, may vary depending on whether you use your account to access them or not. When you log into your account, Personal Information collected about you by Cargolink during your use of the Sites and Services may be matched and linked to other Personal Information collected by Cargolink as part of your use of your account (for example, information about your identity, contact details, age and gender, if they were provided to Сargolink).
Cargolink may collect the following categories of Personal Information about you during your use of the Sites and Services:
(i) Personal information provided by you when registering (creating an account), such as your name, telephone number, address and age;
(ii) electronic data (HTTP headers, IP address, cookies, web beacons/pixel tags, browser ID data, hardware and software information, wi-fi network data);
(iii) date and time of access to the Sites and/or Services;
(iv) information about your activity while using the Sites and/or Services (for example, search query history, data about purchases in the Services, data about visited organizations, likes and preferences, email addresses of those with whom you correspond, telephone data books, information about interactions with other users, as well as files and content stored in Cargolink systems);
(v) geolocation information;
(vi) other information about you necessary for processing in accordance with the conditions governing the use of specific Cargolink Sites or Services;
(vii) information about you that we receive from our Partners in accordance with the terms of the agreements concluded between you and the relevant Partner, and the agreements concluded between Cargolink and the Partner;
(viii) details of your payment cards, other payment information provided by you, as well as received from Partners or other persons participating in the payment transaction using the Sites or Services of Cargolink and/or in connection with the provision of paid services by Cargolink.
Cargolink does not purposefully collect sensitive personal information (such as racial origin, political opinions, health information and biometric data), except as provided in the user agreements of individual Services. However, you may provide them to Cargolink yourself, in which case Cargolink will process them as part of providing you with the Services (for example, if you make search queries related to your health). However, you should take into account that Cargolink cannot request your consent to such processing, since it is not aware in advance of the potentially sensitive nature of the Personal Information that you may provide to Cargolink.
Cargolink does not collect data for the purpose of compiling a “portrait” of the user to the extent that this could significantly affect your rights and freedoms in accordance with applicable law.
(ii) processing is necessary to comply with legal obligations;
(iii) when provided for by applicable law, processing is necessary to ensure the legitimate interests of Cargolink in the event that such processing does not have a significant impact on your interests, your fundamental rights and freedoms. Please note that when processing your personal information on this basis, Cargolink will always strive to maintain a balance between its legitimate interests and the protection of your privacy.
Cargolink processes your Personal Information to ensure its legitimate interests, for example, in the following cases:
(a) to better understand how you interact with our Sites and/or Services;
(b) to improve, change, personalize or otherwise improve the Sites and Services for the benefit of all users;
(c) to offer you other products and services of Cargolink or other companies that we think may be of interest to you (i.e., show you advertising tailored to your interests);
(iv) for specific purposes or as required by applicable law, we may request your specific consent to process your Personal Information. For jurisdictions where consent is recognized as a separate legal basis, your commencement of use of the Cargolink Sites and/or Services constitutes your consent to such processing. We hereby inform you, and you acknowledge, that you have no obligation to provide us with any Personal Information when you use the Sites or Services, and such provision is based solely on your free will. However, you understand that without providing Personal Information, we will not be able to provide you with the opportunity to use the Services, and your use of the Sites will be limited.
Cargolink always processes your Personal Information for specific purposes and only that Personal Information that is relevant to achieving such purposes. In particular, we process your Personal Information for the following purposes:
(i) providing you with access to the Sites and/or Services (including providing search results in response to your search queries, taking into account your preferences, search history and other Personal information about you available to Cargolink);
(ii) providing access to your account, including the Cargolink email account and file storage, if you are registered in the relevant Services;
(iii) communicating with you to send you notices, requests and information related to the operation of the Sites and Services, fulfilling agreements with you and processing your requests and applications;
(iv) personalization of advertising and offers based on your preferences, search history and other Personal Information about you available to Cargolink;
(v) improving the usability of the Sites and Services, including by displaying the most relevant search results and providing more personalized Sites and Services, as well as improving other Cargolink products, applications and Services;
(vi) creation of new products, utilities and offers of Cargolink;
(vii) protection of your rights and the rights of Сargolink;
(viii) collection, processing and presentation of statistical data, big data and other research;
(ix) identifying security threats to the Sites and Services, users, Cargolink and/or third parties, including checking your reliability when concluding contracts using the Sites and Services;
(x) organizing the acceptance of your payments, your payment for goods and services using the Sites and Services.
The use of information received from the Google API (hereinafter referred to as the “Received Data”) in the Cargolink Services is carried out in accordance with the provisions
Google API Disclosure subject to the limitations specified therein, namely:
The received data is used solely for the purpose of providing you with the functions of the email client. The received data cannot be used for transfer to third parties, for displaying advertising materials and other purposes related to unauthorized access to the content of your correspondence.
In most cases, Personal Information is processed automatically without any of Cargolink’s employees having access to it. If such access is needed, it can be provided only to those Cargolink employees who need it to perform their tasks. To protect and ensure the confidentiality of data, all employees must comply with internal policies and procedures regarding the processing of Personal Information. They must also follow all technical and organizational security measures in place to protect your Personal Information.
Cargolink has also implemented sufficient technical and organizational measures to protect Personal Information from unauthorized, accidental or unlawful destruction, loss, alteration, unfair use, disclosure or access, as well as other unlawful forms of processing. These security measures have been implemented taking into account the current state of technology, the cost of their implementation, the risks associated with the processing and the nature of Personal Information.
7. Who else has access to your Personal Information and with whom it may be shared
7.1 Within the Сargolink Group
Cargolink may transfer your Personal Information to its employees (to the extent specified in Section 6 of this Policy). Cargolink may also share your Personal Information with its affiliates, including other companies from the group of entities to which Cargolink belongs (“Cargolink Group”). Please note that the level of protection of Personal Information in some countries may not be the same as in your jurisdiction, and by using the Cargolink Services you consent to such transfer.
Cargolink may also transfer Personal Information to third parties outside the Cargolink Group to achieve the purposes specified in Section 5 of this Policy. Please note that the level of protection of Personal Information in some countries may not be the same as in your jurisdiction, and by using the Cargolink Services you consent to such transfer.
Such third parties may include:
(i) Partners, such as site and application owners, advertising networks and other partners who provide Cargolink with services related to the placement and display of advertising on sites, programs, products or services that are owned or controlled by such partners; companies providing transportation services (taxi);
(ii) advertisers or other Partners who display advertisements for you on the Sites and/or Cargolink Services, as well as such Partners as information service providers or consultants;
(iii) persons providing information to identify security threats to the Sites and Services, users, Cargolink and/or third parties, including when checking your reliability when concluding contracts using the Sites and Services;
(iv) persons involved in organizing the acceptance of your payments and conducting payment transactions using the Sites and Services (international payment systems, payment instrument providers, banks and other financial organizations, etc.).
Cargolink may also transfer Personal Information to third parties outside the Cargolink Group:
(i) third parties to whom rights or obligations have been assigned under contracts related to the provision of Services to users, or who otherwise exercise control over persons providing Services as a result of their acquisition (through the acquisition of legal entities, intellectual property, property, property rights and otherwise);
(ii) any national and/or international regulatory authority, law enforcement authorities, central or local executive authorities, other official or government bodies or courts in respect of which Cargolink is required to provide information in accordance with applicable law upon request;
(iii) to third parties, if you have consented to the transfer of your Personal Information or the transfer of Personal Information is required to provide you with the relevant Service or to fulfill a specific agreement or contract concluded with you;
(iv) to any third party in order to provide legal protection to Cargolink or third parties in case of your violation of the User Agreement for Cargolink services, this Policy or the conditions governing the use of individual Services, or in a situation where there is a threat of such a violation.
8. Where is your Personal Information stored and processed
Your Personal Information will be stored in the Russian Federation and/or the EEA.
For Russian users: Cargolink records, systematizes, accumulates, stores, refines (updates, changes), and retrieves personal data of citizens of the Russian Federation using databases located on the territory of the Russian Federation.
For users from the EEA, Switzerland or Israel: Russia is a jurisdiction outside the European Economic Area that has not been recognized by the European Commission as providing an adequate level of protection for personal data. Cargolink has therefore taken appropriate measures to ensure that such transfers are carried out in accordance with current EU data protection regulations.
In particular, Cargolink follows the Standard Contractual Clauses approved by the European Commission to ensure an adequate level of protection for your Personal Information transferred to Russia. A copy of these Standard Contractual Clauses is available upon request.
If you are located in a territory where your consent is required for the transfer of your Personal Information to another jurisdiction, then by using the Sites or Services, you give Cargolink your explicit and unambiguous consent to such transfer or storage, and/or processing of information in other specified jurisdictions, including Russia.
9. How long do we store your Personal Information
Cargolink will retain your Personal Information for as long as necessary to fulfill the purpose for which it was collected or to comply with laws and regulations.
Unless otherwise required by law or by agreement with You, emails and documents that You store on Cargolink's systems as part of the Service will be retained for as long as You have an account, but they may be deleted by You at any time.
If provided for by applicable law, you have the right to access your Personal Information processed by Cargolink in accordance with this Policy.
If you believe that any information that Cargolink holds about you is incorrect or incomplete, you can log into your account and correct your Personal Information yourself.
If provided by applicable law, you have the right to:
Cargolink will comply with these requests in accordance with applicable law.
To the extent permitted by applicable law, you may also have other rights not listed above.
When you use the Services, the transfer of Personal Information is carried out with your consent, expressing your free will and your interest (in particular, on the basis of an agreement with you) and is not a legal obligation.
10.2 How can you exercise your rights
To exercise the above rights, please log in to your account, and if there is no special function in the interface, contact Cargolink (see section 13 of this Policy).
If you are not satisfied with the way Cargolink processes your Personal Information, please let us know and we will look into your complaint. If you are not satisfied with Cargolink's response, you have the right to file a complaint with the competent authority.
11.1 What cookies and why does Cargolink use them
The following types of cookies are used on the Sites:
11.2 How long are cookies stored on your device
11.3 Who else has access to the information contained in cookies
Personal information collected through cookies placed on your device may be transferred to and available to Cargolink and/or third parties specified in Section 7 of this Policy. The use of Personal Information outside of the Sites for promotional purposes, if any, may be subject to separate user agreements available on third party websites.
Cargolink may also use web beacons (pixel tags) to access cookies previously placed on your device for the following purposes:
(i) determining your actions on the Sites and while using the Services by accessing and using cookies stored on your device;
(ii) collection of statistical information related to the operation of the Sites, Services or Cargolink products, utilities and offerings.
12. Update of this Policy
This Policy may be subject to change. Cargolink has the right to make changes at its discretion, including, but not limited to, in cases where the corresponding changes are related to changes in applicable legislation, as well as when the corresponding changes are related to changes in the operation of the Sites and Services.
Cargolink undertakes not to make significant changes, not to impose additional burdens or restrictions on your rights established by this Policy without your notice.
You will be notified of such changes. Appropriate notices may be displayed on the Site or Services (for example, via a pop-up window or banner) prior to such changes becoming effective, or may be sent to you through other communication channels (for example, by email if you have provided us with your Contact details).
13. Questions and suggestions
Cargolink welcomes your questions and suggestions regarding the implementation or modification of this Policy. Please use our feedback form located at https://cargolink.pro/support. You can also use this address to send requests for the exercise of your rights or complaints regarding the incorrectness of your Personal Information or the illegality of its processing.