1. General provisions
1.1. This document defines the procedure for obtaining, using, storing, protecting and otherwise handling personal data of users of the exchange service (hereinafter referred to as the Service), as well as establishes measures aimed at ensuring the security of such information.
1.2. The Policy has been drawn up in accordance with the Constitution of the Russian Federation, Federal Law No. 152-FZ “On Personal Data” and other applicable regulations of the Russian Federation.
1.3. The Service proceeds from the need to respect the rights and legitimate interests of citizens when processing their personal data, including the right to privacy and confidentiality of personal information.
1.4. This Policy applies to all information that the Service receives about users during the provision of services.
2. Terms and definitions
2.1. Personal data is any information that directly or indirectly identifies a specific individual.
2.2. Personal data processing is any action or set of actions with personal data, including collection, recording, systematization, accumulation, storage, clarification, use, transfer, blocking, deletion and destruction.
2.3. The User is an individual using the functionality of the Service.
3. Grounds for processing personal data
3.1. The Service processes personal data in cases where there are legitimate grounds for this, including:
obtaining user consent;
the need to conclude, execute, or terminate a contractual relationship;
fulfillment of duties established by the legislation of the Russian Federation;
implementation of the rights and legitimate interests of the Service, subject to the rights of the personal data subject.
3.2. By submitting their data, the user confirms consent to their processing within the framework of the conditions set out in this Policy.
4. What personal data is used for
The Service processes users’ personal data for the following purposes:
creating and confirming a user account;
user identification during transactions;
fulfillment of obligations related to exchange services;
compliance with the requirements of Russian legislation;
accounting, financial and tax accounting;
fraud prevention and transaction protection;
processing of requests, requests and user requests;
informing about the progress and status of operations;
ensuring stable and safe operation of the Service.
5. What data can be processed
5.1. Depending on the nature of user interaction, the Service may receive and use the following information:
last name, first name and patronymic;
email address;
contact phone number;
details of bank cards, accounts, and electronic wallets;
passport data — in cases where it is required for identification;
residential address;
IP address;
coоkie data;
information about user actions on the site;
information about the history of operations performed.
5.2. The Service does not process special categories of personal data, except in situations directly provided for by the legislation of the Russian Federation.
6. Processing procedure and protection measures
6.1. Personal data can be processed both with the use of automated means and without their use.
6.2. The Service takes the necessary legal, organizational and technical measures to prevent the misuse of personal data, including to protect against:
unauthorized access;
destruction;
changes;
blockages;
copying;
Distribution;
other illegal actions.
6.3. Access to personal data is provided only to those persons who need it to perform their official duties and who are required to comply with the confidentiality regime.
7. Transfer of personal data to other persons
7.1. The Service has the right to transfer personal data to third parties in cases where it is required to perform its functions and obligations, including:
banks and other payment organizations;
hosting providers;
contractors responsible for technical support;
state bodies — to the extent and in the manner prescribed by law.
7.2. The transfer of data to third parties is allowed provided that such persons comply with the requirements of the legislation of the Russian Federation regarding the processing and protection of personal data.
8. Personal data retention period
8.1. Personal data of users may be stored:
during the term of the contractual relationship;
during the periods stipulated by tax, financial and other mandatory legislation;
until the achievement of the purposes for which the data was collected;
until the user withdraws consent, unless otherwise provided by law or other legal grounds for processing.
8.2. After the purposes of processing have been achieved, or if there is no need for further storage, personal data must be deleted, destroyed, or depersonalized in accordance with legal requirements.
9. The rights of the user as a subject of personal data
The User has the right to:
to request information about the fact of processing his personal data;
request clarification, correction, restriction of processing, blocking or destruction of data;
revoke previously given consent at any time;
file complaints with authorized bodies or defend their rights in court.
10. Localization of personal data
10.1. When collecting personal data of citizens of the Russian Federation, the Service ensures their recording, systematization, accumulation, storage, clarification and extraction using databases located on the territory of the Russian Federation.
11. Personal Data Protection
11.1. To ensure the security of personal data, the Service uses a set of technical and organizational measures, including:
the use of secure data transmission channels (SSL/TLS);
antivirus tools;
firewalls and other network protection devices;
access differentiation and control;
creating backups;
regular security check.
12. Final provisions
12.1. The Service reserves the right to change and supplement this Policy without separate prior notification to users.
12.2. The new version of the Policy becomes effective from the moment of its publication on the Service’s website, unless otherwise specified in the editorial itself.
12.3. The current version of the Policy is publicly available on the Service’s website.