Personal Data Processing Policy

1.1. This Personal Data Processing Policy (hereinafter — the Policy) defines the procedure for processing and protecting the personal data of users of the website https://gts24.com/ (hereinafter — the Website), owned by Limited Liability Company "GLOBALTRADSNAB" (hereinafter — the Operator).

1.2. The Policy has been developed in accordance with:

• • the Constitution of the Russian Federation;
• • Federal Law No. 152-FZ of July 27, 2006 "On Personal Data";
• • Federal Law No. 149-FZ of July 27, 2006 "On Information, Information Technologies and Protection of Information";
• • other regulatory legal acts of the Russian Federation governing the processing and protection of personal data.

1.3. This Policy is a publicly available document and shall be posted on the Website in accordance with the requirements of Article 18.1 of Federal Law No. 152-FZ "On Personal Data".

1.4. The Operator ensures the lawfulness, fairness and security of personal data processing and takes the necessary legal, organizational and technical measures to protect personal data from unauthorized access, destruction, modification, blocking, copying, dissemination and other unlawful actions.

1.5. The Operator processes only such personal data as are necessary to achieve predetermined and lawful processing purposes. Personal data processing incompatible with the stated purposes is not carried out.

1.6. Use of the Website, registration of a personal account, placement of orders, submission of inquiries through feedback forms, use of the online chat, subscription to informational materials, as well as other actions involving the transfer of personal data to the Operator, constitutes the user's acknowledgment of this Policy.

1.7. If the user does not agree with the provisions of this Policy, they must cease using the Website services that involve providing personal data.

Full name: Limited Liability Company "GLOBALTRADSNAB"

Abbreviated name: LLC "GLOBALTRADSNAB"

OGRN: 1242400008388

INN: 2466298869

Legal address: 660048, Krasnoyarsk Territory, Krasnoyarsk, 2nd Bryanskaya St., bldg. 53V

Email for inquiries regarding personal data processing: info@gts24.com

The Operator independently organizes personal data processing, determines processing purposes, the scope of processed personal data, and the list of actions performed with them in accordance with the requirements of the legislation of the Russian Federation.

3.1. The Operator processes personal data solely to achieve specific, predetermined and lawful purposes.

3.2. Personal data of Website users are processed for the following purposes:

3.2.1. User identification when using Website services.

3.2.2. Registration and maintenance of the user's personal account.

3.2.3. Processing applications, requests, inquiries and other messages received through feedback forms, online chat, email, messengers and other communication channels.

3.2.4. Placement, support and fulfillment of orders, conclusion and execution of contracts, as well as performance of other obligations to users and clients.

3.2.5. Providing information about goods, services, commercial offers, product availability, delivery terms, service maintenance and other matters related to the Operator's activities.

3.2.6. Providing technical and advisory support to Website users.

3.2.7. Improving Website performance, enhancing usability, analyzing user experience and improving the services provided.

3.2.8. Conducting analytical, statistical and marketing research using anonymized data.

3.2.9. Ensuring Website security, preventing fraudulent actions, detecting technical errors, unauthorized access and other unlawful actions.

3.2.10. Compliance with the requirements of the legislation of the Russian Federation.

3.2.11. Sending informational messages, notifications, company news, information about new products, services, special offers and other materials, subject to separate user consent where required by the legislation of the Russian Federation.

3.3. The Operator does not process personal data for purposes incompatible with those specified.

3.4. If personal data processing purposes change, the Operator makes corresponding changes to this Policy.

4.1. The legal grounds for personal data processing are:

• • the Constitution of the Russian Federation;
• • Federal Law No. 152-FZ of July 27, 2006 "On Personal Data";
• • the Civil Code of the Russian Federation;
• • other regulatory legal acts of the Russian Federation;
• • this User Agreement (if any);
• • this Policy;
• • contracts concluded between the Operator and the personal data subject;
• • consent of the personal data subject to personal data processing in cases provided for by the legislation of the Russian Federation.

4.2. The Operator processes personal data:

• • with the consent of the personal data subject;
• • where processing is necessary for the performance of a contract or conclusion of a contract at the initiative of the personal data subject;
• • where processing is necessary to fulfill obligations imposed by the legislation of the Russian Federation;
• • in other cases provided for by the legislation of the Russian Federation.

4.3. Personal data processing is carried out on the principles of lawfulness, good faith, fairness, minimization of the volume of processed data and limitation of processing to the achievement of specific lawful purposes.

The Operator processes personal data of the following categories of subjects:

• • Website users;
• • registered users (personal account holders);
• • clients and potential clients;
• • representatives of legal entities, individual entrepreneurs and other counterparties;
• • persons who submitted inquiries through feedback forms, email, online chat, messengers and other means of communication;
• • persons who placed orders for goods or services through the Website;
• • persons who subscribed to receive informational materials (with appropriate consent).

5.2. List of Processed Personal Data

Depending on processing purposes, the Operator may process the following personal data:

• • last name, first name, patronymic;
• • organization name;
• • position;
• • phone number;
• • email address;
• • delivery address;
• • postal address;
• • information required to place an order;
• • user inquiry history;
• • order history;
• • user login;
• • personal account password (in encrypted form);
• • IP address;
• • browser and device information;
• • information about user actions on the Website;
• • Cookie files;
• • other information voluntarily provided by the user when filling out forms or communicating with the Operator.

6.1. Personal data processing is carried out both with and without the use of automation tools.

6.2. When processing personal data, the Operator may perform the following actions:

• • collection;
• • recording;
• • systematization;
• • accumulation;
• • storage;
• • refinement (updating, modification);
• • extraction;
• • use;
• • transfer (provision, access) in cases provided for by the legislation of the Russian Federation;
• • depersonalization;
• • blocking;
• • deletion;
• • destruction.

6.3. The Operator receives personal data:

• • directly from the personal data subject;
• • through Website forms;
• • upon personal account registration;
• • when placing an order;
• • through online chat;
• • via email;
• • by phone;
• • via messengers;
• • automatically when using the Website (within the operation of Cookie files and web analytics services).

6.4. The Operator takes necessary measures to ensure the accuracy, adequacy and relevance of personal data.

6.5. The user is responsible for the accuracy of the personal data provided.

6.6. Personal data of citizens of the Russian Federation are processed using databases located in the territory of the Russian Federation, unless otherwise provided by the legislation of the Russian Federation.

6.7. The Operator does not make decisions that entail legal consequences for the personal data subject solely on the basis of automated personal data processing.

7.1. The Operator does not disclose or disseminate personal data to third parties without the consent of the personal data subject, except in cases provided for by the legislation of the Russian Federation.

7.2. Transfer of personal data is permitted only to the extent necessary to achieve processing purposes.

7.3. Personal data may be transferred to:

• • organizations ensuring the operation of the Website;
• • organizations providing hosting and technical support services;
• • delivery services;
• • government authorities in cases provided for by the legislation of the Russian Federation;
• • other persons where there are lawful grounds.

7.4. When entrusting personal data processing to third parties, the Operator ensures their compliance with the requirements of the legislation of the Russian Federation in the field of personal data protection.

7.5. Cross-border transfer of personal data is carried out only in cases and in the manner provided for by the legislation of the Russian Federation.

8.1. Personal data are stored no longer than required for processing purposes, unless a different retention period is established by the legislation of the Russian Federation.

8.2. The retention period for personal data is determined by:

• • the term of the contract with the personal data subject;
• • the term of consent for personal data processing;
• • requirements of the legislation of the Russian Federation;
• • the need to protect the lawful interests of the Operator.

8.3. Upon achievement of processing purposes or when they are no longer necessary, personal data shall be deleted or destroyed, unless otherwise provided by the legislation of the Russian Federation.

8.4. If the personal data subject withdraws consent to personal data processing, the Operator ceases processing and destroys personal data within the timeframes established by the legislation of the Russian Federation, unless there are other lawful grounds for further processing.

9.1. The Operator takes necessary legal, organizational and technical measures to ensure the security of personal data.

9.2. For the purpose of protecting personal data, the Operator:

• • restricts access to personal data to authorized persons only;
• • applies information security tools;
• • uses secure data transmission channels;
• • ensures protection of information systems from unauthorized access;
• • performs data backup;
• • conducts internal control of compliance with the requirements of the legislation of the Russian Federation in the field of personal data;
• • takes measures to prevent unauthorized access, modification, deletion, copying, dissemination and other unlawful actions regarding personal data.

9.3. Upon detection of personal data security breaches, the Operator takes measures to eliminate the consequences of the incident in accordance with the requirements of the legislation of the Russian Federation.

10.1. The personal data subject has the right to:

• • receive information about the processing of their personal data;
• • require clarification, updating or correction of their personal data;
• • require blocking or destruction of personal data in cases provided for by the legislation of the Russian Federation;
• • withdraw consent to personal data processing;
• • restrict personal data processing in cases provided for by law;
• • file a complaint against the Operator's actions or inaction with Roskomnadzor or in court;
• • exercise other rights provided for by the legislation of the Russian Federation.

10.2. To exercise their rights, the personal data subject may submit an inquiry to the Operator.

10.3. The request must contain information allowing identification of the applicant, as well as a description of the requirements.

10.4. The Operator reviews inquiries from personal data subjects and provides a response within the timeframes established by the legislation of the Russian Federation.

11.1. The Website uses Cookie files necessary for the proper operation of the Website, improving user experience, saving user settings, analyzing traffic and improving the quality of the services provided.

11.2. When using the Website, web analytics services may be used to obtain anonymized statistical information about the operation of the Website.

11.3. The user may change their browser settings to limit the use of Cookie files or completely refuse to use them. In this case, some Website features may not function properly.

11.4. Detailed information about the use of Cookie files is posted in the Cookie Policy.

For questions regarding personal data processing, exercise of personal data subject rights, or submission of inquiries, the user may contact the Operator in the following ways:

Operator: LLC "GLOBALTRADSNAB"

Legal address: 660048, Krasnoyarsk Territory, Krasnoyarsk, 2nd Bryanskaya St., bldg. 53V

Email: info@gts24.com

Inquiries are reviewed in the manner and within the timeframes established by the legislation of the Russian Federation.

13.1. This Policy is effective indefinitely until a new version is approved.

13.2. The Operator may amend this Policy in case of changes in the legislation of the Russian Federation, Website functionality or internal personal data processing procedures.

13.3. A new version of the Policy takes effect upon posting on the Website, unless otherwise provided in the new version.

13.4. Users are advised to familiarize themselves with the current version of the Policy before using Website services.

13.5. In all matters not regulated by this Policy, the Operator is guided by the legislation of the Russian Federation.