Privacy Policy Regarding the Processing of Personal Data

1. General Provisions

This personal data processing policy is formulated in accordance with the requirements of the Federal Law dated July 27, 2006, No. 152-FZ "On Personal Data” (hereinafter referred to as the Personal Data Law) and defines the procedure for processing personal data and measures for ensuring the security of personal data taken by LLC "Kredo” (hereinafter referred to as the Operator).

1.1. The Operator's primary goal and condition for carrying out its activities is to respect and ensure the rights and freedoms of individuals and citizens when processing their personal data, including protection of the right to privacy, personal, and family secrets.

1.2. This Policy of the Operator concerning the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator may receive about visitors to the website https://newroadtrade.ru.

2. Basic Concepts Used in the Policy

2.1. Automated processing of personal data – processing of personal data using computing equipment.

2.2. Blocking of personal data – temporary cessation of personal data processing (except in cases where processing is necessary to clarify personal data).

2.3. Website – a collection of graphic and informational materials, as well as software and databases that ensure their availability on the Internet at the network address https://newroadtrade.ru.

2.4. Information system of personal data – a collection of personal data contained in databases and ensuring their processing using information technologies and technical means.

2.5. Anonymization of personal data – actions resulting in the inability to determine without using additional information the belonging of personal data to a specific User or another subject of personal data.

2.6. Processing of personal data – any action (operation) or a set of actions (operations) performed using automation means or without such means with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, destruction of personal data.

2.7. Operator – a state body, municipal body, legal entity, or individual carrying out independently or jointly with other persons the organization and/or processing of personal data, as well as determining the purposes of processing personal data, the composition of personal data subject to processing, actions (operations) performed with personal data.

2.8. Personal data – any information related directly or indirectly to a specific or identifiable User of the website https://newroadtrade.ru.

2.9. Personal data authorized by the subject of personal data for distribution – personal data to which access is provided to an unlimited number of persons by the subject of personal data by giving consent to the processing of personal data authorized by the subject for distribution in the manner provided by the Personal Data Law (hereinafter, personal data authorized for distribution).

2.10. User – any visitor to the website https://newroadtrade.ru.

2.11 Provision of personal data refers to actions aimed at disclosing personal data to a specific person or a defined group of persons.

2.12. Distribution of personal data includes any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or making personal data accessible to an unlimited number of persons, including the publication of personal data in mass media, placement on information and telecommunications networks, or providing access to personal data in any other way.

2.13 Cross-border transfer of personal data refers to the transfer of personal data to the territory of a foreign state to an authority of a foreign state, a foreign individual, or a foreign legal entity.

2.14 Destruction of personal data involves any actions that result 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 physical carriers of personal data.

3. Key Rights and Obligations of the Operator

3.1. The Operator has the right to:

— receive accurate information and/or documents containing personal data from the subject of personal data;

— in the event of the subject of personal data withdrawing consent for the processing of personal data, as well as submitting a request to cease processing personal data, the Operator has the right to continue processing personal data without the consent of the subject if there are grounds specified in the Personal Data Law;

— independently determine the composition and list of measures necessary and sufficient to ensure compliance with the obligations specified in the Personal Data Law and applicable regulations adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.

3.2. The Operator is obliged to:

— provide the subject of personal data, upon request, with information regarding the processing of their personal data;

— organize the processing of personal data in accordance with the current legislation of the Russian Federation;

— respond to requests and inquiries from subjects of personal data and their legal representatives in accordance with the requirements of the Personal Data Law;

— notify the authorized body for the protection of subjects' rights regarding personal data of the necessary information at their request within 10 days from the date of receiving such a request;

— publish or otherwise ensure unrestricted access to this Policy regarding the processing of personal data;

— 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 from other unlawful actions regarding personal data;

— cease the transfer (distribution, provision, access) of personal data, stop processing, and destroy personal data in the manner and cases provided for by the Personal Data Law;

— fulfill other obligations stipulated by the Personal Data Law.

4. Key Rights and Obligations of Subjects of Personal Data

4.1. Subjects of personal data have the right to:

— receive information regarding the processing of their personal data, except in cases provided for by federal laws. The information is provided to the subject of personal data by the Operator in an accessible form and must not contain personal data related to other subjects of personal data, except when there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it is established by the Personal Data Law;

— demand from the Operator clarification of their personal data, blocking, or destruction of their personal data 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;

— set a condition for prior consent when processing personal data for the purposes of promoting goods, work, and services;

— withdraw consent for the processing of personal data, as well as submit a request to cease processing personal data;

— appeal to the authorized body for the protection of subjects' rights regarding personal data or in court against illegal actions or inaction of the Operator during the processing of their personal data;

— exercise other rights provided for by the legislation of the Russian Federation.

4.2. Subjects of personal data are obliged to:

— provide the Operator with accurate data about themselves;

— inform the Operator about the clarification (updating, modification) of their personal data.

4.3. Individuals who provided the Operator with inaccurate information about themselves or information about another subject of personal data without the latter's consent are liable in accordance with the legislation of the Russian Federation.

5. Principles of Personal Data Processing

5.1. Personal data processing is carried out on a lawful and fair basis.

5.2. The processing of personal data is limited to achieving specific, predetermined, and lawful purposes. The processing of personal data incompatible with the purposes of data collection is not allowed.

5.3. The combination of databases containing personal data, for which processing is carried out for incompatible purposes, is not allowed.

5.4. Only personal data that meet the purposes of their processing shall be processed.

5.5. The content and scope of processed personal data correspond to the stated purposes of processing. The redundancy of processed personal data concerning the stated purposes is not allowed.

5.6. When processing personal data, the accuracy, adequacy, and, when necessary, relevance of personal data concerning the purposes of processing are ensured. The Operator takes necessary measures and/or ensures their adoption to delete or clarify incomplete or inaccurate data.

5.7. The storage of personal data is carried out in a form that allows the identification of the subject of personal data, no longer than is necessary for the purposes of processing, unless the storage period for personal data is established by federal law, a contract, a party to which, a beneficiary, or an agent of which is the subject of personal data. Processed personal data is destroyed or anonymized upon achieving the processing goals or in the case of loss of necessity in achieving these goals, unless otherwise provided by federal law.

6. Purposes of Personal Data Processing

The purpose of processing is to inform the User by sending electronic emails.

  • Last name, first name, patronymic
  • Email address
  • Phone numbers

Legal grounds

  • Charter (founding) documents of the Operator

Types of personal data processing

  • Collection, recording, systematization, accumulation, storage, destruction, and anonymization of personal data
  • Sending informational letters to the email address

7. Conditions for Processing Personal Data

7.1. The processing of personal data is carried out with the consent of the subject of personal data for the processing of their personal data.

7.2. The processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, to exercise the functions, powers, and obligations imposed on the operator by the legislation of the Russian Federation.

7.3. The processing of personal data is necessary for the administration of justice, enforcement of a judicial act, an act of another body or official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.

7.4. The processing of personal data is necessary for the fulfillment of a contract, one party to which or the beneficiary or guarantor under which is the subject of personal data, as well as for concluding a contract at the initiative of the subject of personal data or a contract under which the subject of personal data will be the beneficiary or guarantor.

7.5. The processing of personal data is necessary to protect 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 subject of personal data are not violated in this process.

7.6. The processing of personal data is carried out, the access of an unlimited number of persons to which is provided by the subject of personal data or at their request (hereinafter referred to as publicly available personal data).

7.7. The processing of personal data is carried out, which is subject to publication or mandatory disclosure in accordance with federal law.

8. Procedure for Collection, Storage, Transfer, and Other Types of Processing of Personal Data

The security of personal data processed by the Operator is ensured by implementing legal, organizational, and technical measures necessary to fully comply with the requirements of current legislation in the field of personal data protection.

8.1. The Operator ensures the security of personal data and takes all possible measures to prevent unauthorized access to personal data by third parties.

8.2. The personal data of the User will never, under any circumstances, be transferred to third parties, except in cases related to the enforcement of current legislation or if the subject of personal data has given consent to the Operator for the transfer of data to a third party for fulfilling obligations under a civil law contract.

8.3. In case of identifying inaccuracies in personal data, the User can update them independently by sending a notification to the Operator’s email address info@newroadtrade.ru with the subject line “Update of Personal Data.”

8.4. The duration of personal data processing is determined by the achievement of the purposes for which the personal data was collected unless a different term is provided by the contract or current legislation. The User can withdraw their consent to the processing of personal data at any time by sending a notification to the Operator via email at info@newroadtrade.ru with the subject line “Withdrawal of Consent to Personal Data Processing.”

8.5. All information collected by third-party services, including payment systems, communication means, and other service providers, is stored and processed by these entities (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data and/or are familiar with these documents. The Operator is not responsible for the actions of third parties, including those suppliers mentioned in this paragraph.

8.6. The prohibitions established by the subject of personal data on the transfer (except for granting access) as well as on the processing or conditions of processing (except for obtaining access) of personal data permitted for dissemination do not apply in cases of processing personal data in the state, public, and other public interests determined by the legislation of the Russian Federation.

8.7. The Operator ensures the confidentiality of personal data during the processing of personal data.

8.8. The Operator stores personal data in a form that allows identifying the subject of personal data no longer than is required for the purposes of personal data processing unless the storage period for personal data is established by federal law, a contract, a party to which, a beneficiary, or an agent of which is the subject of personal data.

8.9. The cessation of personal data processing may occur upon the achievement of the purposes of personal data processing, expiration of the consent of the subject of personal data, withdrawal of consent by the subject of personal data, or a request for the cessation of personal data processing, as well as identifying unlawful processing of personal data.

9. List of Actions Performed by the Operator with Obtained Personal Data

9.1. The Operator carries out the collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.

9.2. The Operator conducts automated processing of personal data by receiving and/or transferring the obtained information via information and telecommunication networks or without it.

10. Cross-Border Transfer of Personal Data

10.1. Before initiating activities related to the cross-border transfer of personal data, the Operator must notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out the cross-border transfer of personal data (such notification is to be sent separately from the notification about the intention to process personal data).

10.2. Prior to submitting the aforementioned notification, the Operator must obtain the relevant information from the authorities of the foreign state, foreign individuals, and foreign legal entities to whom the cross-border transfer of personal data is planned.

11. Confidentiality of Personal Data

The Operator and other persons who have gained access to personal data are obligated not to disclose personal data to third parties and not to distribute personal data without the consent of the subject of personal data, unless otherwise provided by federal law.

12. Final Provisions

12.1. The User may obtain any clarifications regarding questions related to the processing of their personal data by contacting the Operator via email at info@newroadtrade.ru.

12.2. This document will reflect any changes to the policy regarding the processing of personal data by the Operator. The policy is valid indefinitely until it is replaced by a new version.

12.3. The current version of the Policy is freely available on the Internet at the address https://newroadtrade.ru/policy.

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