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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 dated 27.07.2006 "On Personal Data" (hereinafter referred to as the Personal Data Law) and defines the procedure for processing personal data and measures to ensure the security of personal data undertaken by LLC "TVP Trade" (hereinafter referred to as the Operator).
1.1. The Operator considers the observance of human and civil rights and freedoms during the processing of personal data, including the right to privacy, personal and family secrets, as its highest priority and condition for conducting its activities.
1.2. This Policy of the Operator regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator may obtain about visitors to the website https://twptrade.ru.
2. Key Terms Used in the Policy
2.1. Automated processing of personal data – processing of personal data using computer technology.
2.2. Blocking of personal data – temporary suspension of personal data processing (except where processing is necessary for personal data clarification).
2.3. Website – a collection of graphical and informational materials as well as software and databases ensuring their availability on the Internet at https://twptrade.ru.
2.4. Information system of personal data – a set of personal data contained in databases and information technologies and technical means that ensure their processing.
2.5. Depersonalization of personal data – actions resulting in the impossibility to determine, without additional information, the ownership of the personal data by a specific User or another data subject.
2.6. Processing of personal data – any action (operation) or set of actions (operations), performed with or without the use of automation tools, with personal data, including collection, recording, systematization, accumulation, storage, updating (modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
2.7. Operator – a government body, municipal body, legal or natural person, independently or jointly organizing and/or processing personal data, as well as determining the purposes of processing, the composition of personal data, and the actions (operations) performed with personal data.
2.8. Personal data – any information relating directly or indirectly to a specific or identifiable User of the website https://twptrade.ru.
2.9. Personal data permitted by the subject for distribution – personal data to which the data subject has granted access to an unlimited number of people by giving consent in accordance with the Personal Data Law.
2.10. User – any visitor of the website https://twptrade.ru.
2.11. Provision of personal data – actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Distribution of personal data – any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or at familiarizing an unlimited number of persons with the personal data.
2.13. Cross-border transfer of personal data – transfer of personal data to the territory of a foreign state, to a foreign authority, foreign individual, or foreign legal entity.
2.14. Destruction of personal data – any actions resulting in the irreversible destruction of personal data, with no possibility of restoring the content in the information system and/or the destruction of the material carriers of personal data.
3. Rights and Obligations of the Operator
3.1. The Operator has the right to:
– request reliable information and/or documents containing personal data from the data subject;
– continue processing personal data without the consent of the subject if there are legal grounds as specified in the Personal Data Law;
– independently determine the list of measures necessary to fulfill the requirements of the Personal Data Law unless otherwise provided.
3.2. The Operator is obligated to:
– provide information about the processing of personal data upon request;
– organize data processing in accordance with Russian legislation;
– respond to requests and inquiries from data subjects or their legal representatives;
– notify the authorized body upon request;
– publish or otherwise ensure unrestricted access to this Policy;
– take legal, organizational, and technical measures to protect personal data;
– stop the transfer and processing of data in cases prescribed by law;
– fulfill other obligations under the Personal Data Law.
4. Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects have the right to:
– obtain information about the processing of their personal data;
– request clarification, blocking, or destruction of their personal data if it is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the declared purpose;
– set a condition of prior consent for marketing;
– withdraw their consent at any time;
– appeal any unlawful actions or omissions to the authorized body or court;
– exercise other rights as provided by Russian law.
4.2. Personal data subjects must:
– provide accurate personal data;
– inform the Operator of updates or changes.
4.3. Individuals who have provided false information or disclosed data without consent are liable under Russian law.
5. Principles of Personal Data Processing
5.1. Processing must be lawful and fair.
5.2. Processing must aim to achieve specific, legal purposes.
5.3. Merging incompatible personal data databases is not permitted.
5.4. Only data relevant to the purpose is processed.
5.5. The content and scope must correspond to the declared purposes.
5.6. Data must be accurate, sufficient, and up to date.
5.7. Personal data is stored no longer than necessary. After the purpose is achieved, the data is deleted or anonymized unless otherwise required by law.
6. Purposes of Personal Data Processing
Conclusion, execution, and termination of civil-law contracts.
Personal data:
– Full name
– Email address
– Phone numbers
Legal basis:
– Contracts between the Operator and the data subject
Types of processing:
– Transmission of personal data
7. Conditions for Processing Personal Data
7.1. With the data subject’s consent.
7.2. For purposes under international treaties or laws of the Russian Federation.
7.3. For justice or execution of court rulings.
7.4. For contract execution involving the subject.
7.5. For lawful interests or public benefit, if rights and freedoms are not violated.
7.6. Processing of publicly available data.
7.7. Processing of data that must be published or disclosed by law.
8. Procedures for Collection, Storage, Transmission, and Other Types of Processing
The security of personal data is ensured through legal, organizational, and technical measures.
8.1. The Operator ensures data security and prevents unauthorized access.
8.2. Personal data is never transferred to third parties, except by law or with the subject’s consent.
8.3. Users may update their data by emailing info@twptrade.ru with the subject “Updating Personal Data.”
8.4. Data processing continues until the purpose is fulfilled, unless otherwise required by contract or law.
Users may withdraw consent by emailing “Withdrawal of Consent to Process Personal Data.”
8.5. Third-party services process data under their own policies. The Operator is not responsible for their actions.
8.6. Restrictions set by the data subject on distribution do not apply when processing for public interests under Russian law.
8.7. The Operator ensures confidentiality.
8.8. Data is stored only as long as needed.
8.9. Processing may cease when purposes are fulfilled, consent expires or is withdrawn, or processing is unlawful.
9. Actions Performed by the Operator with Personal Data
9.1. The Operator performs collection, recording, systematization, accumulation, storage, updating, extraction, use, transfer, depersonalization, blocking, deletion, and destruction.
9.2. The Operator uses automated processing with or without data transmission over telecommunication networks.
10. Cross-Border Transfer of Personal Data
10.1. Before beginning cross-border transfer, the Operator must notify the authorized body.
10.2. The Operator must obtain relevant information from the foreign recipient before notification.
11. Confidentiality of Personal Data
The Operator and others with access to personal data must not disclose or distribute it without consent unless otherwise required by law.
12. Final Provisions
12.1. Users may contact the Operator via email at info@twptrade.ru for any clarification.
12.2. Any changes to the Policy will be reflected in this document. The Policy is valid indefinitely until replaced.
12.3. The current version of the Policy is publicly available online at https://twptrade.ru/privacy.
This Personal Data Processing Policy is prepared in accordance with the requirements of Federal Law No. 152-FZ dated 27.07.2006 "On Personal Data" (hereinafter referred to as the Personal Data Law) and defines the procedure for processing personal data and measures to ensure the security of personal data undertaken by LLC "TVP Trade" (hereinafter referred to as the Operator).
1.1. The Operator considers the observance of human and civil rights and freedoms during the processing of personal data, including the right to privacy, personal and family secrets, as its highest priority and condition for conducting its activities.
1.2. This Policy of the Operator regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator may obtain about visitors to the website https://twptrade.ru.
2. Key Terms Used in the Policy
2.1. Automated processing of personal data – processing of personal data using computer technology.
2.2. Blocking of personal data – temporary suspension of personal data processing (except where processing is necessary for personal data clarification).
2.3. Website – a collection of graphical and informational materials as well as software and databases ensuring their availability on the Internet at https://twptrade.ru.
2.4. Information system of personal data – a set of personal data contained in databases and information technologies and technical means that ensure their processing.
2.5. Depersonalization of personal data – actions resulting in the impossibility to determine, without additional information, the ownership of the personal data by a specific User or another data subject.
2.6. Processing of personal data – any action (operation) or set of actions (operations), performed with or without the use of automation tools, with personal data, including collection, recording, systematization, accumulation, storage, updating (modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
2.7. Operator – a government body, municipal body, legal or natural person, independently or jointly organizing and/or processing personal data, as well as determining the purposes of processing, the composition of personal data, and the actions (operations) performed with personal data.
2.8. Personal data – any information relating directly or indirectly to a specific or identifiable User of the website https://twptrade.ru.
2.9. Personal data permitted by the subject for distribution – personal data to which the data subject has granted access to an unlimited number of people by giving consent in accordance with the Personal Data Law.
2.10. User – any visitor of the website https://twptrade.ru.
2.11. Provision of personal data – actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Distribution of personal data – any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or at familiarizing an unlimited number of persons with the personal data.
2.13. Cross-border transfer of personal data – transfer of personal data to the territory of a foreign state, to a foreign authority, foreign individual, or foreign legal entity.
2.14. Destruction of personal data – any actions resulting in the irreversible destruction of personal data, with no possibility of restoring the content in the information system and/or the destruction of the material carriers of personal data.
3. Rights and Obligations of the Operator
3.1. The Operator has the right to:
– request reliable information and/or documents containing personal data from the data subject;
– continue processing personal data without the consent of the subject if there are legal grounds as specified in the Personal Data Law;
– independently determine the list of measures necessary to fulfill the requirements of the Personal Data Law unless otherwise provided.
3.2. The Operator is obligated to:
– provide information about the processing of personal data upon request;
– organize data processing in accordance with Russian legislation;
– respond to requests and inquiries from data subjects or their legal representatives;
– notify the authorized body upon request;
– publish or otherwise ensure unrestricted access to this Policy;
– take legal, organizational, and technical measures to protect personal data;
– stop the transfer and processing of data in cases prescribed by law;
– fulfill other obligations under the Personal Data Law.
4. Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects have the right to:
– obtain information about the processing of their personal data;
– request clarification, blocking, or destruction of their personal data if it is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the declared purpose;
– set a condition of prior consent for marketing;
– withdraw their consent at any time;
– appeal any unlawful actions or omissions to the authorized body or court;
– exercise other rights as provided by Russian law.
4.2. Personal data subjects must:
– provide accurate personal data;
– inform the Operator of updates or changes.
4.3. Individuals who have provided false information or disclosed data without consent are liable under Russian law.
5. Principles of Personal Data Processing
5.1. Processing must be lawful and fair.
5.2. Processing must aim to achieve specific, legal purposes.
5.3. Merging incompatible personal data databases is not permitted.
5.4. Only data relevant to the purpose is processed.
5.5. The content and scope must correspond to the declared purposes.
5.6. Data must be accurate, sufficient, and up to date.
5.7. Personal data is stored no longer than necessary. After the purpose is achieved, the data is deleted or anonymized unless otherwise required by law.
6. Purposes of Personal Data Processing
Conclusion, execution, and termination of civil-law contracts.
Personal data:
– Full name
– Email address
– Phone numbers
Legal basis:
– Contracts between the Operator and the data subject
Types of processing:
– Transmission of personal data
7. Conditions for Processing Personal Data
7.1. With the data subject’s consent.
7.2. For purposes under international treaties or laws of the Russian Federation.
7.3. For justice or execution of court rulings.
7.4. For contract execution involving the subject.
7.5. For lawful interests or public benefit, if rights and freedoms are not violated.
7.6. Processing of publicly available data.
7.7. Processing of data that must be published or disclosed by law.
8. Procedures for Collection, Storage, Transmission, and Other Types of Processing
The security of personal data is ensured through legal, organizational, and technical measures.
8.1. The Operator ensures data security and prevents unauthorized access.
8.2. Personal data is never transferred to third parties, except by law or with the subject’s consent.
8.3. Users may update their data by emailing info@twptrade.ru with the subject “Updating Personal Data.”
8.4. Data processing continues until the purpose is fulfilled, unless otherwise required by contract or law.
Users may withdraw consent by emailing “Withdrawal of Consent to Process Personal Data.”
8.5. Third-party services process data under their own policies. The Operator is not responsible for their actions.
8.6. Restrictions set by the data subject on distribution do not apply when processing for public interests under Russian law.
8.7. The Operator ensures confidentiality.
8.8. Data is stored only as long as needed.
8.9. Processing may cease when purposes are fulfilled, consent expires or is withdrawn, or processing is unlawful.
9. Actions Performed by the Operator with Personal Data
9.1. The Operator performs collection, recording, systematization, accumulation, storage, updating, extraction, use, transfer, depersonalization, blocking, deletion, and destruction.
9.2. The Operator uses automated processing with or without data transmission over telecommunication networks.
10. Cross-Border Transfer of Personal Data
10.1. Before beginning cross-border transfer, the Operator must notify the authorized body.
10.2. The Operator must obtain relevant information from the foreign recipient before notification.
11. Confidentiality of Personal Data
The Operator and others with access to personal data must not disclose or distribute it without consent unless otherwise required by law.
12. Final Provisions
12.1. Users may contact the Operator via email at info@twptrade.ru for any clarification.
12.2. Any changes to the Policy will be reflected in this document. The Policy is valid indefinitely until replaced.
12.3. The current version of the Policy is publicly available online at https://twptrade.ru/privacy.
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