Personal Data Processing Policy
1. General Provisions
This personal data processing policy is prepared in accordance with the requirements of Federal Law No. 152-FZ "On Personal Data" dated July 27, 2006, as well as taking into account the requirements of Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (GDPR). It defines the procedure for processing personal data and the measures undertaken to ensure the security of personal data by the company AVBINVEST LIMITED (hereinafter referred to as the Operator).
1.1 The Operator's primary goal and condition for its activities is to ensure the rights and freedoms of individuals in the processing of their personal data, including the protection of rights to privacy, personal, and family secrets.
1.2 This Operator's personal data processing policy (hereinafter referred to as the Policy) applies to all information that the Operator may obtain about visitors to the website.
1.1 The Operator's primary goal and condition for its activities is to ensure the rights and freedoms of individuals in the processing of their personal data, including the protection of rights to privacy, personal, and family secrets.
1.2 This Operator's personal data processing policy (hereinafter referred to as the Policy) applies to all information that the Operator may obtain about visitors to the website.
2. Key Terms Used in the Policy
2.1 Automated processing of personal data – processing of personal data using computing technology.
2.2 Blocking of personal data – temporary cessation of personal data processing (except where processing is necessary to clarify personal data).
2.3 Website – a collection of graphic and informational materials, as well as computer programs and databases, that ensure their accessibility on the internet at the network address https://ru.tradersdiaries.com/.
2.4 Anonymization of personal data – actions that result in it becoming impossible to determine the ownership of personal data to a specific User or another subject of personal data without the use of additional information.
2.5 Processing of personal data – any action (operation) or set of actions (operations) performed with personal data using automation means or without such means, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transmission (distribution, provision, access), anonymization, blocking, deletion, destruction of personal data.
2.6 Personal data – any information related directly or indirectly to a specific or identifiable User of the Website.
2.7 Personal data permitted by the data subject for distribution – personal data to which the data subject has granted unrestricted access to an unlimited number of persons by consenting to the processing of personal data permitted for distribution in the manner specified by applicable law (hereinafter referred to as personal data permitted for distribution).
2.8 User – any visitor to the Website, including a user of products offered by the Operator on the Website.
2.9 Provision of personal data – actions aimed at disclosing personal data to a specific person or group of persons.
2.10 Distribution of personal data – any actions aimed at disclosing personal data to an indefinite group of persons (transmission of personal data) or familiarizing an unlimited number of persons with personal data, including the publication of personal data in the mass media, placement in information and telecommunication networks, or providing access to personal data by any other means.
2.11 Destruction of personal data – any actions resulting in the irreversible destruction of personal data, making it impossible to restore the content of personal data in the personal data information system and/or the destruction of tangible carriers of personal data.
2.2 Blocking of personal data – temporary cessation of personal data processing (except where processing is necessary to clarify personal data).
2.3 Website – a collection of graphic and informational materials, as well as computer programs and databases, that ensure their accessibility on the internet at the network address https://ru.tradersdiaries.com/.
2.4 Anonymization of personal data – actions that result in it becoming impossible to determine the ownership of personal data to a specific User or another subject of personal data without the use of additional information.
2.5 Processing of personal data – any action (operation) or set of actions (operations) performed with personal data using automation means or without such means, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transmission (distribution, provision, access), anonymization, blocking, deletion, destruction of personal data.
2.6 Personal data – any information related directly or indirectly to a specific or identifiable User of the Website.
2.7 Personal data permitted by the data subject for distribution – personal data to which the data subject has granted unrestricted access to an unlimited number of persons by consenting to the processing of personal data permitted for distribution in the manner specified by applicable law (hereinafter referred to as personal data permitted for distribution).
2.8 User – any visitor to the Website, including a user of products offered by the Operator on the Website.
2.9 Provision of personal data – actions aimed at disclosing personal data to a specific person or group of persons.
2.10 Distribution of personal data – any actions aimed at disclosing personal data to an indefinite group of persons (transmission of personal data) or familiarizing an unlimited number of persons with personal data, including the publication of personal data in the mass media, placement in information and telecommunication networks, or providing access to personal data by any other means.
2.11 Destruction of personal data – any actions resulting in the irreversible destruction of personal data, making it impossible to restore the content of personal data in the personal data information system and/or the destruction of tangible carriers of personal data.
3. Key Rights and Obligations of the Operator
3.1 The Operator has the right to:
– obtain reliable information and/or documents containing personal data from the data subject;
– in case the data subject withdraws consent to the processing of personal data, the Operator has the right to continue processing personal data without the consent of the data subject if there are grounds specified in applicable legislation;
– independently determine the composition and list of measures necessary and sufficient to ensure compliance with the obligations provided for by applicable legislation;
– transfer personal information of data subjects (including to organizations that carry out recording, systematization, accumulation, clarification, storage, extraction, and directly send special offers, information about new products and promotions to the User, process requests and appeals, as well as carry out the destruction of personal information) to third parties only to provide services to the data subject (fulfilling its obligations under the contract with the data subject), or if the transfer of such information is provided for by applicable legislation in accordance with the established legal procedure.
3.2 The Operator is obliged to:
– provide the data subject, upon request, with information regarding the processing of their personal data;
– organize the processing of personal data strictly in accordance with the requirements of Federal Law No. 152-FZ “On Personal Data” dated July 27, 2006, as well as the requirements of Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (GDPR);
– respond to requests and inquiries from data subjects and their legal representatives in accordance with the requirements of applicable law;
– inform the authorized body for the protection of the rights of data subjects upon request of this body (as well as on its own initiative in cases provided for by Federal Law No. 152 “On Personal Data” and GDPR) of the necessary information within the established time limits;
– ensure unrestricted access to this Policy;
– take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, alteration, blocking, copying, provision, distribution of personal data, as well as other unlawful actions regarding personal data;
– cease the transmission (distribution, provision, access) of personal data, stop processing, and destroy personal data in the manner and cases provided for by applicable law;
– fulfill other obligations stipulated by applicable legislation, including GDPR.
– obtain reliable information and/or documents containing personal data from the data subject;
– in case the data subject withdraws consent to the processing of personal data, the Operator has the right to continue processing personal data without the consent of the data subject if there are grounds specified in applicable legislation;
– independently determine the composition and list of measures necessary and sufficient to ensure compliance with the obligations provided for by applicable legislation;
– transfer personal information of data subjects (including to organizations that carry out recording, systematization, accumulation, clarification, storage, extraction, and directly send special offers, information about new products and promotions to the User, process requests and appeals, as well as carry out the destruction of personal information) to third parties only to provide services to the data subject (fulfilling its obligations under the contract with the data subject), or if the transfer of such information is provided for by applicable legislation in accordance with the established legal procedure.
3.2 The Operator is obliged to:
– provide the data subject, upon request, with information regarding the processing of their personal data;
– organize the processing of personal data strictly in accordance with the requirements of Federal Law No. 152-FZ “On Personal Data” dated July 27, 2006, as well as the requirements of Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (GDPR);
– respond to requests and inquiries from data subjects and their legal representatives in accordance with the requirements of applicable law;
– inform the authorized body for the protection of the rights of data subjects upon request of this body (as well as on its own initiative in cases provided for by Federal Law No. 152 “On Personal Data” and GDPR) of the necessary information within the established time limits;
– ensure unrestricted access to this Policy;
– take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, alteration, blocking, copying, provision, distribution of personal data, as well as other unlawful actions regarding personal data;
– cease the transmission (distribution, provision, access) of personal data, stop processing, and destroy personal data in the manner and cases provided for by applicable law;
– fulfill other obligations stipulated by applicable legislation, including GDPR.
4. Key Rights and Obligations of Data Subjects
4.1 Data subjects have the right to:
– receive information concerning the processing of their personal data. The information is provided to the data subject by the Operator in an accessible form, and it must not contain personal data relating to other data subjects, except in cases where there are legal grounds for disclosing such personal data;
– request the Operator to clarify their personal data, to block or destroy it ("right to be forgotten") if the personal data is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, as well as to take legal measures to protect their rights;
– require prior consent to be a condition for processing personal data for the purpose of marketing goods, works, and services;
– withdraw consent for the processing of personal data;
– appeal to the authorized body for the protection of the rights of data subjects or in court against unlawful actions or omissions of the Operator in the processing of their personal data;
– request electronic copies of their personal data in a machine-readable format;
– exercise other rights provided for by applicable legislation, including GDPR.
4.2 Data subjects are obliged to:
– provide the Operator with accurate information about themselves;
– provide documents containing personal data upon request of the Operator;
– inform the Operator of any clarifications (updates or changes) to their personal data.
4.3 Individuals who provide the Operator with information about another data subject without their consent are responsible for providing such third-party data.
4.4 The interaction of the data subject with the Operator is carried out through the personal appeal of the data subject or through the appeal of an authorized representative of the data subject. When an authorized representative of the data subject appeals, the Operator has the right to request a document confirming the representative's authority.
– receive information concerning the processing of their personal data. The information is provided to the data subject by the Operator in an accessible form, and it must not contain personal data relating to other data subjects, except in cases where there are legal grounds for disclosing such personal data;
– request the Operator to clarify their personal data, to block or destroy it ("right to be forgotten") if the personal data is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, as well as to take legal measures to protect their rights;
– require prior consent to be a condition for processing personal data for the purpose of marketing goods, works, and services;
– withdraw consent for the processing of personal data;
– appeal to the authorized body for the protection of the rights of data subjects or in court against unlawful actions or omissions of the Operator in the processing of their personal data;
– request electronic copies of their personal data in a machine-readable format;
– exercise other rights provided for by applicable legislation, including GDPR.
4.2 Data subjects are obliged to:
– provide the Operator with accurate information about themselves;
– provide documents containing personal data upon request of the Operator;
– inform the Operator of any clarifications (updates or changes) to their personal data.
4.3 Individuals who provide the Operator with information about another data subject without their consent are responsible for providing such third-party data.
4.4 The interaction of the data subject with the Operator is carried out through the personal appeal of the data subject or through the appeal of an authorized representative of the data subject. When an authorized representative of the data subject appeals, the Operator has the right to request a document confirming the representative's authority.
5. The Operator May Process the Following Personal Data of the User
5.1 The Operator has the right to process the following personal data:
– Last name, first name, patronymic;
– Address of residence (country);
– Identity document data;
– Email address;
– Username from the "Telegram" messenger;
– Phone number;
– Additionally, the website collects and processes anonymized data about visitors (including cookie files) using internet statistics services (Yandex Metrica, Google Analytics, and others).
5.2 The Operator processes personal data to the extent necessary for the purposes of processing personal data. The Operator has the right to request all personal data listed in paragraph 5.1 or to limit the scope to a smaller list depending on specific purposes.
5.3 The above-mentioned data is collectively referred to in this Policy as Personal Data.
5.4 The Operator does not process special categories of personal data concerning racial or ethnic origin, political opinions, religious or philosophical beliefs, sexual life.
5.5 Cookies are pieces of data automatically placed on the computer's hard drive upon each visit to the website. Cookies allow information to be stored on the server, help navigate the web space more easily, and facilitate website analysis and performance evaluation.
The Operator processes anonymized data about the User if allowed in the User's browser settings (including the saving of cookie files and the use of JavaScript technology). Cookies may be used on certain pages of the website to provide users with faster and more convenient access.
Web beacons. On certain web pages or in emails, the Company may use "web beacon" technology (also known as "tags" or "clear GIF technology").
Web beacons, cookies, and other monitoring technologies do not allow for the automatic collection of data. If a Site user voluntarily provides their data, then the automatic collection processes begin for the convenience of using the websites and/or improving user interactions.
5.6 Web beacons and cookies are not used to identify Users.
5.7 If a user does not wish to receive Cookies, and in case the User wants to refuse targeted advertising, they can change their browser settings to reject the use of cookies or track their distribution paths.
– Last name, first name, patronymic;
– Address of residence (country);
– Identity document data;
– Email address;
– Username from the "Telegram" messenger;
– Phone number;
– Additionally, the website collects and processes anonymized data about visitors (including cookie files) using internet statistics services (Yandex Metrica, Google Analytics, and others).
5.2 The Operator processes personal data to the extent necessary for the purposes of processing personal data. The Operator has the right to request all personal data listed in paragraph 5.1 or to limit the scope to a smaller list depending on specific purposes.
5.3 The above-mentioned data is collectively referred to in this Policy as Personal Data.
5.4 The Operator does not process special categories of personal data concerning racial or ethnic origin, political opinions, religious or philosophical beliefs, sexual life.
5.5 Cookies are pieces of data automatically placed on the computer's hard drive upon each visit to the website. Cookies allow information to be stored on the server, help navigate the web space more easily, and facilitate website analysis and performance evaluation.
The Operator processes anonymized data about the User if allowed in the User's browser settings (including the saving of cookie files and the use of JavaScript technology). Cookies may be used on certain pages of the website to provide users with faster and more convenient access.
Web beacons. On certain web pages or in emails, the Company may use "web beacon" technology (also known as "tags" or "clear GIF technology").
Web beacons, cookies, and other monitoring technologies do not allow for the automatic collection of data. If a Site user voluntarily provides their data, then the automatic collection processes begin for the convenience of using the websites and/or improving user interactions.
5.6 Web beacons and cookies are not used to identify Users.
5.7 If a user does not wish to receive Cookies, and in case the User wants to refuse targeted advertising, they can change their browser settings to reject the use of cookies or track their distribution paths.
6. Principles of Personal Data Processing
6.1 The processing of personal data is carried out on a lawful and fair basis.
6.2 The processing of personal data is limited to achieving specific, predetermined, and lawful objectives, as listed in this document. Processing personal data incompatible with the purposes of collection is not permitted.
6.3 The merging of databases containing personal data processed for purposes that are incompatible with each other is prohibited.
6.4 Only personal data that meets the objectives of processing shall be subject to processing.
6.5 The content and scope of the processed personal data correspond to the stated purposes of processing. Excessive processing of personal data concerning the stated objectives is not allowed.
6.6 When processing personal data, accuracy, sufficiency, and, where necessary, relevance concerning the purposes of processing are ensured. The Operator takes necessary measures and/or ensures that measures are taken to remove or clarify incomplete or inaccurate data.
6.7 Personal data is stored in a form that allows identification of the data subject for no longer than is required for the purposes of processing, unless a different retention period is established by applicable law, contract, or by which the data subject is a party or beneficiary. The processed personal data shall be destroyed or anonymized upon achieving the processing objectives or if the need to achieve those objectives is lost, unless otherwise provided by applicable law.
6.8 The Operator protects Personal Data in accordance with the requirements imposed on the protection of such information and is responsible for using secure methods of protection for such information.
6.2 The processing of personal data is limited to achieving specific, predetermined, and lawful objectives, as listed in this document. Processing personal data incompatible with the purposes of collection is not permitted.
6.3 The merging of databases containing personal data processed for purposes that are incompatible with each other is prohibited.
6.4 Only personal data that meets the objectives of processing shall be subject to processing.
6.5 The content and scope of the processed personal data correspond to the stated purposes of processing. Excessive processing of personal data concerning the stated objectives is not allowed.
6.6 When processing personal data, accuracy, sufficiency, and, where necessary, relevance concerning the purposes of processing are ensured. The Operator takes necessary measures and/or ensures that measures are taken to remove or clarify incomplete or inaccurate data.
6.7 Personal data is stored in a form that allows identification of the data subject for no longer than is required for the purposes of processing, unless a different retention period is established by applicable law, contract, or by which the data subject is a party or beneficiary. The processed personal data shall be destroyed or anonymized upon achieving the processing objectives or if the need to achieve those objectives is lost, unless otherwise provided by applicable law.
6.8 The Operator protects Personal Data in accordance with the requirements imposed on the protection of such information and is responsible for using secure methods of protection for such information.
7. Purposes of Personal Data Processing
7.1 The purpose of processing the User's personal data is:
– to fulfill the contracts concluded with the User by the Operator;
– to inform the User by sending emails;
– to provide the User with access to services, information, and/or materials contained on the Website;
– to display targeted advertising to the User;
– to conduct analytics and optimize advertising campaigns by the Operator based on the User's behavior on the Website.
7.2 The Operator also has the right to send the User notifications about new products and services, special offers, and various events. The User may refuse to receive informational messages at any time by sending an email to the Operator at support@fsr-develop.com, marked “Refusal of notifications about new products and services and special offers.”
7.3 Anonymized data of Users, collected using internet statistics services, is used to gather information about User actions on the site, improve the quality of the site, and its content.
– to fulfill the contracts concluded with the User by the Operator;
– to inform the User by sending emails;
– to provide the User with access to services, information, and/or materials contained on the Website;
– to display targeted advertising to the User;
– to conduct analytics and optimize advertising campaigns by the Operator based on the User's behavior on the Website.
7.2 The Operator also has the right to send the User notifications about new products and services, special offers, and various events. The User may refuse to receive informational messages at any time by sending an email to the Operator at support@fsr-develop.com, marked “Refusal of notifications about new products and services and special offers.”
7.3 Anonymized data of Users, collected using internet statistics services, is used to gather information about User actions on the site, improve the quality of the site, and its content.
8. Conditions for Processing Personal Data
8.1 Processing of personal data is carried out with the consent of the data subject to their processing. The data subject independently decides to provide their personal data and gives consent freely, of their own will, and in their own interests.
8.2 The Operator processes the personal data of the User only if it has been filled out and/or submitted by the User themselves through special forms located on the Website or sent to the Operator via email. By filling out the relevant forms and/or sending their personal data to the Operator, the User expresses their consent to this Policy.
8.3 The processing of personal data is necessary to achieve the rights and legitimate interests of the Operator or third parties or to achieve socially significant goals, provided that the rights and freedoms of the data subject are not violated.
8.4 The Operator does not verify the accuracy of the personal data provided by the User and does not monitor its relevance. The User bears all responsibility, as well as possible consequences for providing inaccurate or outdated information.
8.2 The Operator processes the personal data of the User only if it has been filled out and/or submitted by the User themselves through special forms located on the Website or sent to the Operator via email. By filling out the relevant forms and/or sending their personal data to the Operator, the User expresses their consent to this Policy.
8.3 The processing of personal data is necessary to achieve the rights and legitimate interests of the Operator or third parties or to achieve socially significant goals, provided that the rights and freedoms of the data subject are not violated.
8.4 The Operator does not verify the accuracy of the personal data provided by the User and does not monitor its relevance. The User bears all responsibility, as well as possible consequences for providing inaccurate or outdated information.
9. Procedure for Collection, Storage, Transfer, and Other Types of Personal Data Processing
9.1 The security of personal data processed by the Operator is ensured by implementing legal, organizational, and technical measures required to fully comply with the requirements of applicable legislation in the field of personal data protection.
9.2 The Operator ensures the safety of personal data and takes all possible measures to prevent unauthorized access to personal data.
9.3 The User's personal data will not be transferred to third parties, except in cases related to the enforcement of applicable law or if the data subject has given consent to the Operator to transfer data to a third party for the fulfillment of obligations under a civil law contract.
9.4 In case of inaccuracies in personal data, the User can update it independently by sending a notification to the Operator's email address: support@fsr-develop.com, marked "Update of Personal Data."
9.5 The period for processing personal data is determined by the achievement of the purposes for which the personal data was collected unless a different period is stipulated by the contract or applicable legislation. The User may withdraw their consent to the processing of personal data at any time by notifying the Operator via email at support@fsr-develop.com, marked "Withdrawal of Consent to Process Personal Data."
9.6 User data may be transferred to third-party advertising services such as Google and Yandex for the purpose of selecting advertisements based on the User's interests. Third-party services may also collect and process User data, with the collection and processing carried out in accordance with the relevant services' personal data processing policies.
9.7 All information collected by third-party services, including payment systems, communication services, and other service providers, is stored and processed by those parties (Operators) according to their user agreements and privacy policies. The personal data subject and/or User must familiarize themselves with these documents in a timely manner. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this paragraph.
9.8 The Operator ensures the confidentiality of personal data during processing. Confidentiality of personal data is a mandatory requirement for the Operator or any other party that has gained access to personal data, including not allowing its dissemination without the consent of the data subject or other legal grounds.
9.9 The Operator stores personal data in a form that allows identification of the data subject for no longer than is required for the purposes of processing, unless the storage period is established by law, contract, or by which the data subject is a party or beneficiary.
9.10 The termination of personal data processing may be conditioned upon achieving the processing purposes, expiration of the consent given by the data subject, withdrawal of consent by the data subject, or detection of unlawful processing of personal data.
9.2 The Operator ensures the safety of personal data and takes all possible measures to prevent unauthorized access to personal data.
9.3 The User's personal data will not be transferred to third parties, except in cases related to the enforcement of applicable law or if the data subject has given consent to the Operator to transfer data to a third party for the fulfillment of obligations under a civil law contract.
9.4 In case of inaccuracies in personal data, the User can update it independently by sending a notification to the Operator's email address: support@fsr-develop.com, marked "Update of Personal Data."
9.5 The period for processing personal data is determined by the achievement of the purposes for which the personal data was collected unless a different period is stipulated by the contract or applicable legislation. The User may withdraw their consent to the processing of personal data at any time by notifying the Operator via email at support@fsr-develop.com, marked "Withdrawal of Consent to Process Personal Data."
9.6 User data may be transferred to third-party advertising services such as Google and Yandex for the purpose of selecting advertisements based on the User's interests. Third-party services may also collect and process User data, with the collection and processing carried out in accordance with the relevant services' personal data processing policies.
9.7 All information collected by third-party services, including payment systems, communication services, and other service providers, is stored and processed by those parties (Operators) according to their user agreements and privacy policies. The personal data subject and/or User must familiarize themselves with these documents in a timely manner. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this paragraph.
9.8 The Operator ensures the confidentiality of personal data during processing. Confidentiality of personal data is a mandatory requirement for the Operator or any other party that has gained access to personal data, including not allowing its dissemination without the consent of the data subject or other legal grounds.
9.9 The Operator stores personal data in a form that allows identification of the data subject for no longer than is required for the purposes of processing, unless the storage period is established by law, contract, or by which the data subject is a party or beneficiary.
9.10 The termination of personal data processing may be conditioned upon achieving the processing purposes, expiration of the consent given by the data subject, withdrawal of consent by the data subject, or detection of unlawful processing of personal data.
10. List of Actions Taken by the Operator with the Received Personal Data
10.1 The Operator performs collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
10.2 The Operator carries out automated processing of personal data with the receipt and/or transmission of the obtained information via information and telecommunication networks or without it.
10.2 The Operator carries out automated processing of personal data with the receipt and/or transmission of the obtained information via information and telecommunication networks or without it.
11. Final Provisions
11.1 The User can obtain any clarifications regarding issues related to the processing of their personal data by contacting the Operator via email: support@fsr-develop.com.
11.2 Any changes to the Operator’s personal data processing policy will be reflected in this document. The Policy is valid indefinitely until replaced by a new version.
11.3 The current version of the Policy is freely accessible on the Internet at the Website.
11.2 Any changes to the Operator’s personal data processing policy will be reflected in this document. The Policy is valid indefinitely until replaced by a new version.
11.3 The current version of the Policy is freely accessible on the Internet at the Website.