1. General provisions
This Personal Data Processing Policy has been prepared in accordance with Federal Law No. 152-FZ of 27 July 2006, “On Personal Data” (the “Personal Data Law”), and sets out the procedures for processing personal data and the measures taken by Kogmi Trading LLC (the “Operator”) to ensure the security of personal data.
1.1. The Operator considers respect for human and civil rights and freedoms in the processing of personal data, including protection of privacy and personal and family confidentiality, to be its primary objective and a condition of carrying out its activities.
1.2. This Policy of the Operator concerning the processing of personal data (the “Policy”) applies to all information that the Operator may obtain about visitors to the website kogmitrading.com.

2. Key terms used in the Policy
2.1. Automated processing of personal data means processing personal data using computer technology.
2.2. Blocking of personal data means temporarily suspending the processing of personal data, except where processing is necessary to clarify the personal data.
2.3. Website means the collection of graphic and information materials, computer programs and databases that make them available online at kogmitrading.com.
2.4. Personal data information system means the personal data contained in databases and the information technologies and technical means used to process them.
2.5. Depersonalisation of personal data means actions that make it impossible to identify the specific User or other personal data subject to whom the data relates without using additional information.
2.6. Processing of personal data means any action (operation) or set of actions (operations) performed on personal data, with or without automated tools, including collection, recording, systematisation, accumulation, storage, clarification (updating or modification), retrieval, use, transfer (dissemination, provision or access), depersonalisation, blocking, deletion and destruction.
2.7. Operator means a state authority, municipal authority, legal entity or individual that, independently or jointly with others, organises and/or carries out the processing of personal data and determines the purposes of processing, the personal data to be processed and the actions (operations) to be performed on such data.
2.8. Personal data means any information relating directly or indirectly to an identified or identifiable User of the website kogmitrading.com.
2.9. Personal data authorised by the data subject for dissemination means personal data to which the data subject has granted access to an unlimited number of persons by consenting to the processing of personal data authorised for dissemination in the manner prescribed by the Personal Data Law (the “personal data authorised for dissemination”).
2.10. User means any visitor to the website kogmitrading.com.
2.11. Provision of personal data means actions intended to disclose personal data to a specific person or a specific group of persons.
2.12. Dissemination of personal data means any actions intended to disclose personal data to an unspecified group of persons (transfer of personal data) or to make it available to an unlimited number of persons, including publication in the media, placement on information and telecommunications networks or provision of access by any other means.
2.13. Cross-border transfer of personal data means transferring personal data to the territory of a foreign state, to a foreign state authority, foreign individual or foreign legal entity.
2.14. Destruction of personal data means any actions that irreversibly destroy personal data so that its contents cannot be restored in a personal data information system and/or destroy physical media containing personal data.

3. Main rights and obligations of the Operator
3.1. The Operator has the right to:
— obtain accurate information and/or documents containing personal data from the data subject;
— continue processing personal data without the data subject’s consent where grounds specified in the Personal Data Law exist, if the data subject withdraws consent or requests that processing be discontinued;
— independently determine the measures necessary and sufficient to fulfil the obligations established by the Personal Data Law and regulations adopted pursuant to it, unless otherwise provided by that Law or other federal laws.
3.2. The Operator must:
— provide the data subject, upon request, with information concerning the processing of their personal data;
— organise the processing of personal data in the manner established by applicable legislation of the Russian Federation;
— respond to enquiries and requests from data subjects and their legal representatives in accordance with the Personal Data Law;
— provide the authorised body responsible for protecting data subjects’ rights with the necessary information within 10 days of receiving its request;
— publish this Policy or otherwise provide unrestricted access to it;
— take legal, organisational and technical measures to protect personal data against unlawful or accidental access, destruction, modification, blocking, copying, provision, dissemination and other unlawful actions;
— discontinue the transfer (dissemination, provision or access) and processing of personal data and destroy such data in the cases and manner prescribed by the Personal Data Law;
— fulfil other obligations established by the Personal Data Law.

4. Main rights and obligations of personal data subjects
4.1. Data subjects have the right to:
— obtain information concerning the processing of their personal data, except in cases provided for by federal laws. The Operator must provide this information in an accessible form. It must not contain personal data relating to other data subjects unless there are lawful grounds for disclosing such data. The information to be provided and the procedure for obtaining it are established by the Personal Data Law;
— require the Operator to clarify, block or destroy their personal data if it is incomplete, outdated, inaccurate, unlawfully obtained or unnecessary for the stated purpose of processing, and take measures provided for by law to protect their rights;
— require prior consent for the processing of personal data for the promotion of goods, works and services;
— withdraw consent to the processing of personal data and request that such processing be discontinued;
— appeal against the Operator’s unlawful actions or inaction in the processing of their personal data to the authorised body responsible for protecting data subjects’ rights or to a court;
— exercise other rights provided for by legislation of the Russian Federation.
4.2. Data subjects must:
— provide the Operator with accurate information about themselves;
— notify the Operator of any clarification, update or change to their personal data.
4.3. Persons who provide the Operator with inaccurate information about themselves or information about another data subject without that person’s consent are liable in accordance with legislation of the Russian Federation.

5. Principles of personal data processing
5.1. Personal data is processed lawfully and fairly.
5.2. Processing is limited to achieving specific, predetermined and lawful purposes. Processing that is incompatible with the purposes for which personal data was collected is prohibited.
5.3. Databases containing personal data processed for mutually incompatible purposes must not be combined.
5.4. Only personal data relevant to the purposes of processing may be processed.
5.5. The content and volume of personal data processed must correspond to the stated purposes of processing. Processing excessive personal data in relation to those purposes is prohibited.
5.6. Personal data must be accurate, adequate and, where necessary, up to date for the purposes of processing. The Operator takes and/or ensures the implementation of the necessary measures to delete or clarify incomplete or inaccurate data.
5.7. Personal data is stored in a form that allows the data subject to be identified for no longer than required for the purposes of processing, unless a retention period is established by federal law or by an agreement to which the data subject is a party, beneficiary or guarantor. The data is destroyed or depersonalised when the purposes of processing have been achieved or are no longer necessary, unless otherwise provided by federal law.

6. Purposes of personal data processing

7. Conditions for processing personal data
7.1. Personal data is processed with the data subject’s consent to the processing of their personal data.
7.2. Processing is necessary to achieve purposes established by an international treaty of the Russian Federation or by law, or to perform functions, exercise powers and fulfil obligations imposed on the Operator by legislation of the Russian Federation.
7.3. Processing is necessary for the administration of justice or enforcement of a judicial act, an act of another authority or an official that is enforceable under legislation of the Russian Federation on enforcement proceedings.
7.4. Processing is necessary to perform an agreement to which the data subject is a party, beneficiary or guarantor, or to enter into an agreement at the data subject’s initiative or an agreement under which the data subject will be a beneficiary or guarantor.
7.5. Processing is necessary to exercise the rights and legitimate interests of the Operator or third parties, or to achieve socially significant objectives, provided that the data subject’s rights and freedoms are not violated.
7.6. Personal data to which the data subject has granted access to an unlimited number of persons, or for which such access has been granted at the data subject’s request, is processed (the “publicly available personal data”).
7.7. Personal data subject to publication or mandatory disclosure under federal law is processed.

8. Procedures for collecting, storing, transferring and otherwise processing personal data
The security of personal data processed by the Operator is ensured through legal, organisational and technical measures necessary to comply fully with applicable legislation on personal data protection.
8.1. The Operator safeguards personal data and takes all possible measures to prevent unauthorised persons from accessing it.
8.2. The User’s personal data will never be transferred to third parties under any circumstances, except where required to comply with applicable legislation or where the data subject has consented to the Operator transferring data to a third party to fulfil obligations under a civil-law agreement.
8.3. If inaccuracies are found in personal data, the User may update it by sending a notification to the Operator’s email address info@kogmitrad.com with the subject “Personal data update”.
8.4. The processing period is determined by the achievement of the purposes for which the personal data was collected, unless a different period is provided for by an agreement or applicable legislation.
The User may withdraw their consent to the processing of personal data at any time by sending a notification to the Operator’s email address info@kogmitrad.com with the subject “Withdrawal of consent to personal data processing”.
8.5. All information collected by third-party services, including payment systems, communications services and other service providers, is stored and processed by those persons (operators) in accordance with their User Agreement and Privacy Policy. The personal data subject and/or the aforementioned documents. The Operator is not responsible for third parties’ actions, including those of the service providers referred to in this clause.
8.6. Prohibitions imposed by the data subject on transfer (other than granting access), processing or processing conditions (other than obtaining access) of personal data authorised for dissemination do not apply where processing is carried out in state, social or other public interests defined by legislation of the Russian Federation.
8.7. The Operator ensures the confidentiality of personal data during processing.
8.8. The Operator stores personal data in a form that allows the data subject to be identified for no longer than required for the purposes of processing, unless a retention period is established by federal law or by an agreement to which the data subject is a party, beneficiary or guarantor.
8.9. Processing may be discontinued when its purposes have been achieved, the data subject’s consent has expired or been withdrawn, the data subject has requested that processing cease, or unlawful processing has been identified.

9. Actions performed by the Operator on the personal data received
9.1. The Operator collects, records, systematises, accumulates, stores, clarifies (updates and modifies), retrieves, uses, provides access to, blocks, deletes and destroys personal data.
9.2. The Operator carries out automated processing of personal data with or without receiving and/or transmitting the information obtained over information and telecommunications networks.

10. Cross-border transfer of personal data
10.1. Before carrying out cross-border transfers of personal data, the Operator must notify the authorised body responsible for protecting data subjects’ rights of its intention to make such transfers. This notification is submitted separately from the notification of the intention to process personal data.
10.2. Before submitting the above notification, the Operator must obtain the relevant information from the foreign state authorities, foreign individuals and foreign legal entities to which cross-border transfers of personal data are planned.

11. Confidentiality of personal data
The Operator and other persons who have obtained access to personal data must not disclose it to third parties or disseminate it without the data subject’s consent, unless otherwise provided by federal law.
12. Final provisions
12.1. The User may obtain clarification on any questions concerning the processing of their personal data by contacting the Operator by email at info@kogmitrad.com.
12.2. Any changes to the Operator’s personal data processing policy will be reflected in this document. This Policy remains in effect indefinitely until replaced by a new version.
12.3. The current version of the Policy is freely available online at kogmitrading.com/en/privacy.