Privacy Policy

1. General Provisions

This personal data processing policy has been compiled in accordance with the requirements of Federal Law No. 152-FZ of July 27, 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 taken by VELMO RUS LLC (hereinafter referred to as the Operator).
1.1. The Operator's primary goal and condition for carrying out its activities is to respect the rights and freedoms of individuals and citizens when processing their personal data, including the protection of privacy, personal and family secrets.
1.2. This Operator policy regarding 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://valmo.trade.ru.

2. Key Concepts Used in the Policy

2.1. Automated processing of personal data is the processing of personal data using computer technology.
2.2. Blocking of personal data is the temporary cessation of the processing of personal data (except in cases where processing is necessary to clarify the personal data).
2.3. Website is a collection of graphic and informational materials, as well as computer programs and databases, ensuring their availability on the internet at the network address https://valmo.trade.ru.
2.4. Personal data information system is a collection of personal data contained in databases and the information technologies and technical means that ensure their processing.
2.5. Anonymization of personal data is actions that make it impossible to determine the ownership of personal data to a specific User or another personal data subject without the use of additional information.
2.6. Personal data processing means any action (operation) or set of actions (operations) performed with or without the use of automated tools with personal data, including the collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, or destruction of personal data.
2.7. Operator means a government agency, municipal body, legal entity, or individual that, independently or jointly with other persons, organizes and/or carries out the processing of personal data, and determines the purposes of processing personal data, the composition of personal data to be processed, and the actions (operations) performed with personal data.
2.8. Personal data means any information relating directly or indirectly to an identified or identifiable User of the website https://valmo.trade.ru.
2.9. Personal data permitted for distribution by the personal data subject means personal data, access to which by the general public is granted by the personal data subject by consenting to the processing of personal data, permitted by the personal data subject to be distributed in the manner prescribed by the Law on Personal Data (hereinafter referred to as personal data permitted for distribution).
2.10. User — any visitor to the website https://valmo.trade.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. Dissemination of personal data means any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or making personal data available to an indefinite number of persons, including publishing personal data in the media, posting it on information and telecommunications networks, or providing access to personal data in any other way.
2.13. Cross-border transfer of personal data means the transfer of personal data to a foreign government agency, foreign individual, or foreign legal entity.
2.14. Destruction of personal data means any actions resulting in the irreversible destruction of personal data, making it impossible to restore the contents of the personal data in the personal data information system, and/or the destruction of tangible storage media for the personal data.

3. Main Rights and Obligations of the Operator

3.1. The Operator has the right to:
— receive reliable information and/or documents containing personal data from the personal data subject;
— in the event of the personal data subject's revocation of consent to the processing of personal data, or if an application is submitted with a request to cease processing personal data, the Operator has the right to continue processing personal data without the consent of the personal data subject if there are grounds specified in the Law on Personal Data;
— independently determine the composition and a list of measures necessary and sufficient to ensure the fulfillment of obligations stipulated by the Personal Data Law and regulatory legal acts 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 personal data subject, upon request, with information concerning the processing of his or her personal data;
— organize the processing of personal data in the manner established by the current legislation of the Russian Federation;
— respond to inquiries and requests from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
— notify the authorized body for the protection of the rights of personal data subjects, upon request of such body, of the necessary information within 10 days from the date of receipt of such request;
— publish or otherwise provide 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, modification, blocking, copying, provision, distribution, as well as from other illegal actions in relation to personal data;
— cease the transfer (distribution, provision, access) of personal data, cease processing, and destroy personal data in the manner and cases stipulated by the Law on Personal Data;
— fulfill other obligations stipulated by the Law on Personal Data.

4. Basic Rights and Obligations of Personal Data Subjects

4.1. Personal data subjects have the right to:
— receive information regarding the processing of their personal data, with the exception of cases stipulated by federal laws. The Operator shall provide the personal data subject with information in an accessible form and shall not contain personal data relating to other personal data subjects, except in cases where there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Law on Personal Data;
— request that the Operator clarify their personal data, block or destroy it if the personal data is incomplete, outdated, inaccurate, illegally obtained, or is not necessary for the stated purpose of processing, and also take measures provided by law to protect their rights;
— require prior consent when processing personal data for the purpose of promoting goods, works, and services on the market;
— revoke consent to the processing of personal data, as well as request the termination of the processing of personal data;
— appeal to the authorized body for the protection of the rights of personal data subjects or in court against the Operator's unlawful actions or inactions when processing their personal data;
— exercise other rights stipulated by Russian legislation.
4.2. Personal data subjects are obligated to:
— provide the Operator with accurate information about themselves;
— notify the Operator of any clarifications (updates, changes) to their personal data.
4.3. Persons who provide the Operator with inaccurate information about themselves, or information about another personal data subject, without the latter's consent, are liable in accordance with Russian legislation.

5. Principles of Personal Data Processing

5.1. Personal data shall be processed lawfully and fairly.
5.2. The processing of personal data shall be limited to achieving specific, predetermined, and legitimate purposes. Processing of personal data incompatible with the purposes for which it was collected is prohibited.
5.3. Combining databases containing personal data processed for incompatible purposes is prohibited.
5.4. Only personal data that meets the purposes for which it is processed may be processed.
5.5. The content and volume of processed personal data correspond to the stated purposes of processing. Excessive amounts of processed personal data in relation to the stated purposes of processing are not permitted.
5.6. When processing personal data, the accuracy, sufficiency, and, where necessary, relevance of the personal data in relation to the purposes of processing the personal data are ensured. The Operator takes the necessary measures and/or ensures their adoption to delete or clarify incomplete or inaccurate data.
5.7. Personal data shall be stored in a form that allows identification of the subject of personal data, for no longer than is required for the purposes of processing personal data, unless the storage period for personal data is established by federal law, an agreement to which the subject of personal data is a party, beneficiary, or guarantor. Processed personal data shall be destroyed or anonymized upon achievement of the processing purposes or in the event that the need to achieve these purposes is no longer necessary, unless otherwise provided by federal law.

6. Purposes of Personal Data Processing
Purpose of processing: providing the User with access to services, information, and/or materials contained on the website.
Personal data: last name, first name, patronymic | email address | telephone numbers.
Legal basis: agreements concluded between the operator and the personal data subject.
Types of personal data processing: collection, recording, systematization, accumulation, storage, destruction, and depersonalization of personal data.

7. Terms of Personal Data Processing

7.1. Personal data is processed with the consent of the personal data subject to the processing of their personal data.
7.2. The processing of personal data is necessary to achieve the purposes stipulated by an international treaty of the Russian Federation or by law, for the performance of the functions, powers, and duties 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, the execution of a judicial act, or the 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 performance of an agreement to which the personal data subject is a party, beneficiary, or guarantor, as well as for the conclusion of an agreement at the initiative of the personal data subject or an agreement under which the personal data subject will be a beneficiary or guarantor.
7.5. The processing of personal data is necessary to exercise 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 personal data subject are not violated.
7.6. The processing of personal data is carried out if access to which is granted to an unlimited number of persons by the personal data subject or at his or her request (hereinafter referred to as publicly available personal data).
7.7. Personal data subject to publication or mandatory disclosure in accordance with federal law is processed.

8. Procedure for the Collection, Storage, Transfer, and Other 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 on personal data protection.
8.1. The Operator ensures the security of personal data and takes all possible measures to prevent unauthorized persons from accessing it.
8.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to compliance with current legislation or if the personal data subject has consented to the Operator's transfer of data to a third party for the fulfillment of obligations under a civil law contract.
8.3. If any inaccuracies in personal data are discovered, the User may update them independently by sending a notification to the Operator's email address info@valmo.trade with the subject line "Personal data update."
8.4. The processing period for personal data is determined by the achievement of the purposes for which the personal data was collected, unless another period is provided by the agreement or applicable law.
The User may revoke their consent to the processing of personal data at any time by sending a notification to the Operator via email to info@valmo.trade with the subject line "Revocation of consent to the processing of personal data."
8.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by the specified persons (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data and/or with the specified documents. The Operator shall not be liable for the actions of third parties, including the service providers specified in this paragraph.
8.6. The prohibitions established by the subject of personal data on the transfer (except for providing access), as well as on the processing or conditions of processing (except for obtaining access) of personal data permitted for distribution, shall not apply in cases of processing personal data in state, public and other public interests defined by the legislation of the Russian Federation.
8.7. The Operator ensures the confidentiality of personal data when processing personal data.
8.8. The Operator stores personal data in a form that allows for identification of the subject of personal data, for no longer than required for the purposes of processing the personal data, unless the storage period of personal data is established by federal law, an agreement, or a party of which the personal data subject is the beneficiary or guarantor.
8.9. The termination of personal data processing may be conditional upon the achievement of the personal data processing purposes, expiration of the personal data subject's consent, revocation of consent by the personal data subject, or a request to cease processing, as well as the detection of unlawful processing of personal data.

9. List of actions performed by the Operator with received personal data

9.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), retrieves, uses, transfers (disseminates, provides, accesses), depersonalizes, blocks, deletes, and destroys personal data.
9.2. The Operator carries out automated processing of personal data with or without the receipt and/or transmission of the received information via information and telecommunications networks.

10. Cross-border transfer of personal data

10.1. Before commencing any cross-border transfer of personal data, the Operator is obligated to notify the authorized body for the protection of personal data subjects' rights of its intention to carry out such cross-border transfer (such notification is sent separately from the notification of intent to process personal data).
10.2. Prior to submitting the above notification, the Operator is obligated to 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 or distribute personal data to third parties without the consent of the personal data subject, unless otherwise provided by federal law.

12. Final Provisions

12.1. The User may obtain any clarification on any questions regarding the processing of their personal data by contacting the Operator by email at info@valmo.trade.
12.2. This document will reflect any changes to the Operator's personal data processing policy. This Policy is valid indefinitely until replaced by a new version.
12.3. The current version of the Policy is publicly available online at https://valmo.trade/cookie-policy.