1. General Provisions
1.1. This document defines Lux Express policy with regards to processing the personal data of Lux Express clients, i.e. the passengers of the regular international coach lines and Lux Express website users.
The personal data processing policy explained in this document shall be applied in any given country as long as it does not contradict the local laws.
In the territory of the Russian Federation the personal data processing shall meet the requirements of the Federal Law 152 “About personal data” of 27 July 2006.
1.2. The following terms have the appropriate definitions in the text of the document:
Personal data operator, Operator, Lux Express – are the following legal entities (jointly and individually): EUROLINES private limited company, registered and acting in accordance with the laws of the Russian Federation (OGRN 1027810259146, INN 7816121179, legal address 198095, St. Petersburg, Shkapina St., 10), and the following foreign legal entities: Lux Express Estonia AS (the Republic of Estonia), SIA Lux Express Latvia (the Republic of Latvia), Lux Express Lithuania UAB (the Republic of Lithuania), LUX EXPRESS POLSKA SP. Z O. O (Poland), that provide regular international passenger coach transportation under Lux Express brand;
Personal data owner, Client– is a person who wants to book or purchase or is booking or purchasing, or using Lux Express international coach service for their private purposes not related to business activity. Personal data owner is also a person whose personal data the Operator receives from an agent or a tourist operator who sells Lux Express coach services to the Personal data owner.
Personal data owners are also Lux Express Internet Website visitors who provide their personal data in order to use Lux Express Website and / or obtain information about Lux Express services.
Personal data processing is any action or a sequence of actions performed with the personal data by the Operator with or without automation facilities. The Personal data processing includes inter alia gathering, recording, systematisation, accumulation, storage, update, recovery, use, transmission (distribution, granting access to, supply), anonymization, blocking, deleting, destruction, computer-aid processing (automated personal data processing) by the Operator’s information technology system, personal data transmission abroad to foreign authorities, foreign individual or legal entity (trans-border personal data transmission).
Lux Express Websiteis the official Lux Express source of information on the Internet located at luxexpress.eu, simpleexpress.eu, or any other domain name including those that directly or indirectly relay a user to the above-mentioned domain names subject to geographical position.
1.3. Personal data owner may:
– request to improve, block or delete his/her personal data if the data are insufficient, outdated, false, illegally obtained, or not required for the declared goal of the processing, and use any legal means to protect his/her rights;
– request that Lux Express discloses the list of his/her personal data (processed by Lux Express) and its source;
– receive information about the time of his/her personal data processing including the time of storage;
– demand that all the entities that has earlier received his/her false or incomplete personal data were informed about any exclusion, correction, or amendment thereof;
– complain to a personal data owner’s rights protection body or litigate against any illegal actions or lack of actions related to the personal data processing;
– defend in the court his/her rights and legal interests and demand loss and / or moral compensation.
1.4. This Lux Express confidentiality policy covers the personal data obtained before and after the publication thereof.
2. Aims of the Personal Data Processing
The Operator will process the Client’s personal data with the aim to conclude, amend or terminate an international coach transportation agreement with the Client, fulfil such an agreement, and to allow the Operator to use the Client’s personal data again when the Client requests other Lux Express services.
The Operator will process the Client’s personal data in the course of issuing a ticket to the Client which is according to the law also a certificate confirming that a passenger transportation agreement has been concluded.
The Operator will process the Client’s personal data with the aim to inform the Client about Lux Express services, and at Lux Express Website with the aim to grant the Client general access to the Website options, and access to Lux Express electronic self-service ticket purchase system, and to keep a log of the Client’s activities at Lux Express Website.
The Operator will process the Client’s personal data with the aim to fulfil the laws on the state border, customs, and transportation, covering the state border control, customs control, transportation control, and other obligatory border crossing controls.
The Operator will process the Client’s personal data with the aim to fulfil the Russian Federation laws on transportation safety and to pass the data over to the United Governmental Transportation Security Informational System.
3. Legal Basics of the Personal Data Processing
In the Russian Federation
Federal Law no. 16 On Transportation Security of 09.02.2007.
Federal Law no. 127 On Governmental Control of International Road Transportation and on Liability for the Breach thereof of 24.07.1998.
Law of the Russian Federation no. 4730-1 On the State Border of the Russian Federation of 01.04.1993.
Federal Law no. 114 On the Procedures of Entering and Leaving the Russian Federation of 15.08.1996.
Customs Code of the Customs Union,
Federal Law no. 311 On the Customs Regulations in the Russian Federation of 27.11.2010.
In the states of the Operator’s business activity (in addition to the local laws):
Lux Express ticket selling rules.
Lux Express Rules for passenger and luggage transportation.
International passenger transportation agreement (conclusion of the agreement by and between the Operator and the Client is confirmed by the ticket issued by the Operator).
Client’s consent to process his/her personal data except for the cases when the personal data processing is permitted without the Client’s consent.
4. Contents of the Personal Data. Terms and Procedures for its Processing and Protecting.
4.1. In order to achieve the above mentioned aims the Operator will process the following Client’s Personal Data:
– surname, name, patronym
– date of birth
– type and number of the personal identification document used to purchase the ticket
– starting point, point of destination, type of the transportation rout (direct, transit)
– date of travel
– details of visa or any other document granting a foreign citizen or a person without citizenship the right to enter the country of destination or pass it in transit
– contact phone numbers, including mobile phone
– IP address
– cookies files information, including the Client’s location (city), Client’s communication equipment, Client’s behaviour at Lux Express Website, his/her interests and orders
– browser (or any other software used to access the Internet and the Lux Express Website) information, access time, target page address.
Within the scope of a specific personal data processing operation the Operator will process all the Client’s data or part of it.
The Client’s personal data processing will be done only to achieve the aims set in section 2 above.
4.2. Generally, the Operator will process the Client’s personal data using Operator’s computers (automated personal data processing) and third party’s informational systems, integrated with the Operator’s system for the following purposes: to sell a ticket to the Client, to change the ticket, to cancel the ticket, to settle the Client’s accounts under the transportation agreement, to inform the Client that the transportation agreement has been fulfilled, to perform any internal operations related to the Client’s transportation, to fulfil the transportation safety requirements, as well as border and customs control procedures.
In the course of processing, the Client’s personal data can be transmitted by Lux Express internal computer network based on the Internet.
4.3. Any personal data can be transmitted to the third party informational system, integrated with the Operator’s informational system, as a general rule, as anonymous data, and only for the purposes of and in connection with the operations mentioned in clause 4.2. above.
4.4. The Operator will transmit the Client’s personal data to a foreign territory only to another Lux Express legal entity covered by the “Personal data operator” definition as defined by clause 1.2 above and using the internal network based on the Internet.
Any trans-border transmission of the Client’s personal data to a foreign authority will be done subject to the obligatory requirements of the local laws and a request of the foreign authority which is binding for the Operator.
4.5. The Operator shall pass the Client’s personal data to investigation and court authorities or other authorised governmental bodies subject to their request and other reasons as defined by the local laws.
If the Client is a plaintiff or a party of a legal process, then the Operator may pass the documents or information containing the Client’s personal data as an evidence to the court, governmental authority or an official.
4.6. In order to use the Client’s personal data for the later Client’s requests and to inform the Client about the Operator’s services the Operator will keep the Client’s personal data for five (5) years after the last Client’s request and then delete the data.
4.7. The Operator will stop processing the Client’s personal data after the expiration of the Client’s consent period or if the Client revokes the consent for the personal data processing, or if an illegal personal data processing is detected.
4.8. The Operator and other persons duly authorised to access the personal data, will guarantee confidentiality of the personal data, not disclose it to third party and not distribute it without the personal data owner’s consent unless the laws require otherwise.
4.9. Lux Express will take all the legal, organisational and technical measures to protect the personal data from unauthorised or accidental access, deletion, amendment, blocking, copying, transmission or distribution, and other illegal actions in respect thereof.
Lux Express has appointed officials to coordinate the personal data processing and safety.
5. Personal Data Update and Amendment
5.1. The Operator will update and amend the Client’s personal data at the subsequent request of Lux Express service by the Client if any new data are provided, or if there is any other reason to amend the personal data.
The Client’s personal data may be updated and / or amended if the Client requests Lux Express service by phone (using the customer service line as published at Lux Express Website, section Info) if the data to be amended include evident technical errors and typos in any of the following Client’s personal details: surname, name, patronym, e-mail, telephone number, and if the Operator can (has a technical means to) unequivocally identify the Client by available true data of the Client.
5.2. The Operator will also update and amend the Client’s personal data by the latter’s written request submitted to the Operator using any of the following means:
– application to any Lux Express service office in any country where the Operator works;
– registered mail with delivery against signature sent to a registered mailing address of the Operator in any country where the Operator works;
– electronic letter sent by electronic mail to the Operator’s e-mail address.
The contact addresses for the applications on the personal data processing are published at Lux Express Website (section Info).
5.3. If the Operator has doubts that the personal data presented by the Client for update or amendment are true or if there is no documentary support of the data, then the Operator may require that the Client provides a documentary proof of the updated personal data (passport, marriage certificate, name change certificate or any other document).
5.4. The Operator will delete the Client’s personal data if the Client prohibits its further processing and communicate with the Client about his/her personal data subject to the procedures described in this section.
6. Information. Amendments of Lux Express Confidentiality Policy
6.1. When a Client visits Lux Express Website, Lux Express informs the Client about the opportunity to read Lux Express Confidentiality Policy, and any use of Lux Express Website thereafter by the Client means that the Client has approved this Lux Express Confidentiality Policy and agreed for his / her personal data to be processed.
6.2. Lux Express informs the Client about the opportunity to read Lux Express Confidentiality Policy before issuing a ticket to the Client or concluding, amending or terminating the passenger transportation electronic agreement, and the mentioned actions can be continued only subject to the Client’s consent to have his / her personal data processed in accordance with Lux Express Confidentiality Policy.
6.3. Lux Express reserves the right to amend this document. New Lux Express Confidentiality Policy will enter into force upon publication at Lux Express Website.
6.4. It is the Client’s responsibility to familiarise in due time with the amendments of this document at Lux Express Website.