POLICY for Processing and Protection of Personal Data in AP Trade LLC

1. General Provisions and Basic Terms

This personal data processing policy is drawn up in accordance with Federal Law No. 152-FZ of 27.07.2006 "On Personal Data" (hereinafter – Personal Data Law) and defines the procedure for processing personal data and measures to ensure the security of personal data taken by AP Trade LLC (hereinafter – Operator).

The Operator's primary goal and condition for carrying out its activities is the observance of rights and freedoms of individuals when processing their personal data, including the right to privacy, personal and family secrets.

This Operator's personal data processing policy (hereinafter – Policy) applies to all information the Operator may obtain about visitors to the website https://aptrade.ru/ (hereinafter – Site).

This Personal Data Processing Policy applies only to the Site https://aptrade.ru/. The Site does not control and is not responsible for third-party websites the User may access through links available on the Site.

The Operator processes the User's personal data only if filled in and/or submitted by the User independently through special forms on the Site. By filling in the relevant forms and/or sending personal data to the Operator, the User expresses consent to this Policy.

The Operator processes anonymized User data if permitted in the User's browser settings (saving cookies and using JavaScript technology is enabled).

The Policy applies to all personal data processed by AP Trade LLC (hereinafter – Operator).

The Policy covers relations in the field of personal data processing that arose both before and after the approval of this Policy.

In fulfillment of Part 2, Art. 18.1 of the Personal Data Law, this Policy is published in open access on the Internet on the Operator's website.

2. Definitions 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 cessation of personal data processing (except where processing is necessary to clarify personal data).

2.3. Website — a collection of graphic and information materials as well as software and databases ensuring their availability on the Internet at https://aptrade.ru/.

2.4. Personal Data Information System — a set of personal data contained in databases and the information technologies and technical means that ensure their processing.

2.5. Depersonalisation of Personal Data — actions that make it impossible, without additional information, to identify the personal data as belonging to a specific User or other data subject.

2.6. Processing of Personal Data — any action (operation) or set of actions performed with personal data using automation tools or without, including collection, recording, systematisation, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalisation, blocking, deletion, destruction.

2.7. Operator — a state or municipal body, legal entity or individual that, independently or jointly with others, organises and/or carries out the processing of personal data, and determines the purposes, composition, and actions performed with personal data.

2.8. Personal Data — any information relating directly or indirectly to a specific or identifiable User of this Site.

2.9. Personal Data Permitted for Distribution — personal data to which an unlimited number of persons are granted access by the data subject through consent, in the manner prescribed by the Personal Data Law (hereinafter – "personal data permitted for distribution").

2.10. User — any visitor to the Site https://aptrade.ru/.

2.11. Provision of Personal Data — actions aimed at disclosing personal data to a specific person or group of persons.

2.12. Dissemination of Personal Data — any actions aimed at disclosing personal data to an indefinite circle of persons or making it available to an unlimited number of persons, including publication in the media, posting on networks, or providing access in any other way.

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 further recovery in the information system and/or the destruction of physical media containing personal data.

3. Main Rights and Obligations of the Operator

3.1. The Operator has the right to:

3.1.1. Receive from the personal data subject reliable information and/or documents containing personal data.

3.1.2. If the personal data subject withdraws consent, continue processing personal data without consent where grounds exist as specified in the Personal Data Law.

3.1.3. Independently determine the composition and list of measures necessary and sufficient to fulfil obligations stipulated by the Personal Data Law and related regulations, unless otherwise provided by federal law.

3.1.4. Entrust the processing of personal data to another person under a contract. The person processing personal data on behalf of the Operator must comply with the principles and rules of personal data processing under the Personal Data Law, maintain confidentiality, and take necessary measures to fulfil obligations under the Personal Data Law.

3.2. The Operator must:

3.2.1. Provide the personal data subject, upon request, with information concerning the processing of their personal data.

3.2.2. Organise personal data processing in accordance with applicable Russian legislation.

3.2.3. Respond to requests from personal data subjects and their legal representatives in accordance with the Personal Data Law.

3.2.4. Provide the authorised personal data protection authority, upon request, with necessary information within 30 days of receiving such a request.

3.2.5. Publish or otherwise ensure unrestricted access to this Personal Data Processing Policy.

3.2.6. Take legal, organisational, and technical measures to protect personal data from unauthorised or accidental access, destruction, alteration, blocking, copying, provision, dissemination, and any other unlawful actions.

3.2.7. Cease transfer (distribution, provision, access) of personal data, terminate processing and destroy personal data in the cases and manner provided for by the Personal Data Law.

3.2.8. Perform other duties stipulated by the Personal Data Law.

4. Main Rights and Obligations of Personal Data Subjects

4.1. Personal data subjects have the right to:

4.1.1. Obtain information concerning the processing of their personal data, except as provided by federal law. Information is provided by the Operator in an accessible form and must not contain personal data of other data subjects, except where there are lawful grounds for disclosure. The list of information and the procedure for obtaining it are established by the Personal Data Law.

4.1.2. Request that the Operator clarify, block, or destroy personal data that is incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the stated processing purpose, and take measures provided by law to protect their rights.

4.1.3. Require prior consent for processing personal data for marketing goods, works, or services.

4.1.4. Withdraw consent to the processing of personal data.

4.1.5. Appeal to the authorised personal data protection authority or in court against unlawful actions or inactions of the Operator in processing their personal data.

4.1.6. Exercise other rights provided for by Russian law.

4.2. Personal data subjects must:

4.2.1. Provide the Operator with accurate data about themselves.

4.2.2. Notify the Operator of any clarification (update, modification) of their personal data.

4.3. Persons who provide the Operator with inaccurate information about themselves or information about another data subject without their consent bear responsibility in accordance with Russian law.

5. Volume and Categories of Personal Data Processed, Categories of Personal Data Subjects

5.1. Last name, first name, patronymic; year, month, and date of birth; place of birth; marital status; social status; financial status; income; gender; email address; residential address; registration address; phone number; SNILS; TIN; citizenship; identity document data; driver's license data; identity document data valid outside the Russian Federation; birth certificate data; bank card details; current account number; personal account number; profession; position; employment information (including length of service, current employment data with organisation name and account number); military registration status; data collected through metric programs; education information; photo and video images; voice data.

5.2. The Site also collects and processes anonymized visitor data using internet statistics services permitted by Russian law.

5.3. The data listed above are collectively referred to in this Policy as Personal Data.

5.4. The Operator does not process special categories of personal data relating to racial or ethnic origin, political views, religious or philosophical beliefs, or intimate life.

5.5. Processing of personal data permitted for distribution from among the special categories specified in Part 1, Art. 10 of the Personal Data Law is permitted if the prohibitions and conditions of Art. 10.1 of the Personal Data Law are observed.

5.6. The User's consent to the processing of personal data permitted for distribution is formalised separately from other consents for personal data processing, in compliance with the conditions of Art. 10.1 of the Personal Data Law.

5.6.1. Consent to the processing of personal data permitted for distribution is provided by the User directly to the Operator.

5.6.2. The Operator must, within no later than three working days from receipt of such User consent, publish information about the processing conditions, prohibitions and conditions for processing by an unlimited number of persons of personal data permitted for distribution.

5.6.3. Transfer (distribution, provision, access) of personal data permitted for distribution must be stopped at any time upon the request of the personal data subject. The request must include the surname, first name, patronymic (if any), contact information (phone number, email or postal address) of the data subject, and a list of personal data whose processing is to be stopped. The personal data specified in such a request may only be processed by the Operator to whom it was sent.

5.6.4. Consent to the processing of personal data permitted for distribution ceases to be valid upon receipt by the Operator of the request specified in clause 5.6.3 of this Policy.

6. Principles of Personal Data Processing

6.1. Personal data shall be processed on a lawful and fair basis.

6.2. Processing of personal data is limited to achieving specific, pre-defined, and lawful purposes. Processing incompatible with the purposes of data collection is not permitted.

6.3. It is not permitted to combine databases containing personal data processed for mutually incompatible purposes.

6.4. Only personal data that meets the purposes of their processing is subject to processing.

6.5. The content and scope of personal data processed must correspond to the stated purposes. Excessive processing of personal data in relation to the stated purposes is not permitted.

6.6. Accuracy, sufficiency, and, where necessary, relevance of personal data shall be ensured during processing. The Operator takes necessary measures to delete or clarify incomplete or inaccurate data.

6.7. Personal data are stored in a form that allows identification of the data subject for no longer than required by the processing purposes, unless a longer period is prescribed by federal law or contract. Upon achieving the processing purposes, data are destroyed or depersonalised.

7. Purposes of Personal Data Processing

7.1. Processing of personal data is limited to specific, pre-defined, and lawful purposes. Processing incompatible with the purposes of data collection is not permitted.

7.2. Only personal data that meets the purposes of their processing is subject to processing.

7.3. The Operator processes personal data for the following purposes:

7.3.1. Informing the User by sending emails.

7.3.2. Conclusion, execution and termination of civil law contracts.

7.3.3. Providing Users with access to services, information and/or materials on the Site.

7.4. The Operator may also send the User notifications about new products and services, special offers and various events. The User may opt out of information messages at any time by writing to ap@aptrade.ru.

7.5. Anonymized User data collected through internet statistics services is used to collect information about User actions on the Site and to improve Site quality and content.

7.6. Carrying out activities in accordance with the charter of AP Trade LLC, including conclusion and execution of contracts with counterparties.

7.7. Compliance with labour legislation within employment and directly related relations, including: assisting employees in employment, recruiting and selecting candidates, ensuring personal safety of employees, monitoring quantity and quality of work, ensuring property safety, maintaining HR and accounting records, completing and submitting required reporting forms, organising individual (personalised) registration of employees in mandatory pension and social insurance systems.

7.8. Processing of employees' personal data may be carried out exclusively for the purpose of ensuring compliance with laws and other regulatory acts.

8. Legal Bases for Processing Personal Data

8.1. The legal bases for the Operator's processing of personal data are:

8.1.1. Federal Law No. 152-FZ of 27.07.2006 "On Personal Data"; Federal Law No. 402-FZ of 06.12.2011 "On Accounting"; Constitution of the Russian Federation; Civil Code of the Russian Federation; Labour Code of the Russian Federation; Tax Code of the Russian Federation; Federal Law No. 14-FZ of 08.02.1998 "On Limited Liability Companies"; Federal Law No. 167-FZ of 15.12.2001 "On Mandatory Pension Insurance in the Russian Federation"; other regulatory legal acts governing relations related to the Operator's activities.

8.1.2. The Operator's charter documents.

8.1.3. Contracts concluded between the Operator and the personal data subject.

8.1.4. Federal laws and other regulatory acts in the field of personal data protection.

8.1.5. Users' consents to the processing of their personal data, including data permitted for distribution.

8.2. The Operator processes the User's personal data only if filled in and/or submitted by the User independently through special forms on the Site or sent to the Operator by email. By filling in the forms and/or sending personal data, the User expresses consent to this Policy.

8.3. The Operator processes anonymized User data if permitted in the User's browser settings (saving files and using JavaScript technology is enabled).

8.4. The personal data subject independently decides to provide their personal data and gives consent freely, of their own will and in their own interest.

9. Procedure and Conditions for Processing Personal Data

9.1. Processing of personal data is carried out with the consent of the personal data subject. Personal data is processed by the Operator in accordance with the requirements of the legislation of the Russian Federation.

9.2. Processing is necessary to achieve the purposes provided by international treaties or Russian law, or to carry out functions and duties assigned to the Operator by legislation.

9.3. Processing is required for the administration of justice or execution of a judicial act or an act of another authority or official under Russian enforcement law.

9.4. Processing is necessary for the performance of a contract to which the data subject is a party, beneficiary or guarantor, or for the conclusion of such a contract at the initiative of the data subject.

9.5. Processing is necessary for the legitimate interests of the Operator or third parties, or for the achievement of socially significant goals, provided the rights and freedoms of the data subject are not violated.

9.6. Processing is carried out on personal data made publicly available by the subject or at their request (hereinafter — publicly available personal data).

9.7. Processing is carried out on personal data subject to publication or mandatory disclosure under federal law.

9.8. Processing of personal data for each processing purpose specified in clause 7 of the Policy is carried out by: automated processing of personal data with or without transmission of the received information over information and telecommunication networks; mixed processing of personal data; receipt of personal data in oral and written form directly from personal data subjects; entry of personal data into the Operator's journals, registers and information systems; use of other methods of processing personal data.

9.9. Disclosure to third parties and dissemination of personal data without the consent of the personal data subject is not permitted, unless otherwise provided by federal law. Consent to the processing of personal data permitted for distribution by the personal data subject is formalised separately from other consents of the personal data subject. Requirements for the content of such consent are approved by the Order of Roskomnadzor No. 18 of 24.02.2021.

9.10. Transfer of personal data to inquiry and investigation bodies, the Federal Tax Service, the Social Fund of Russia and other authorised executive authorities and organisations is carried out in accordance with the requirements of Russian legislation.

9.11. The Operator takes necessary legal, organisational and technical measures to protect personal data from unauthorised or accidental access, destruction, modification, blocking, distribution and other unauthorised actions, including: identifying threats to personal data security during processing; adopting local regulations and other documents governing the processing and protection of personal data; designating persons responsible for personal data security in departments and information systems; creating the necessary conditions for working with personal data; organising accounting of documents containing personal data; organising work with information systems processing personal data; storing personal data in conditions ensuring its safety and preventing unauthorised access; organising training of the Operator's employees who process personal data.

9.12. The Operator stores personal data in a form allowing identification of the personal data subject for no longer than required by each processing purpose, unless a longer period is stipulated by federal law or contract.

9.13. Personal data on paper media are stored at AP Trade LLC for the periods established by Russian legislation on archival affairs (Federal Law No. 125-FZ of 22.10.2004 "On Archival Affairs in the Russian Federation", the List of Standard Management Archival Documents generated during state and municipal bodies and organisations' activities, indicating retention periods (approved by Order of Rosarchive No. 236 of 20.12.2019)).

9.14. The retention period for personal data processed in personal data information systems corresponds to the retention period for personal data on paper media.

9.15. The Operator ceases processing personal data in the following cases: unlawful processing has been identified (within three working days from the date of detection); the processing purpose has been achieved; the personal data subject's consent has expired or been withdrawn where the Personal Data Law permits processing only with consent.

9.16. Upon achieving the personal data processing purposes, or upon withdrawal of consent, the Operator ceases processing such data, unless: otherwise provided by a contract to which the data subject is a party, beneficiary or guarantor; the Operator may not process without consent on grounds under the Personal Data Law or other federal laws; otherwise provided by another agreement between the Operator and the personal data subject.

9.17. Upon a request from the personal data subject to cease processing, processing shall be stopped within no more than 10 working days from the date of receipt of the request, except as provided by the Personal Data Law. This period may be extended, but by no more than five working days. To do so, the Operator must send the data subject a reasoned notice indicating the reasons for the extension.

9.18. When collecting personal data, including via the Internet, recording, systematisation, accumulation, storage, clarification (updating, modification) and retrieval of personal data of Russian Federation citizens using databases located outside the Russian Federation is not permitted, except as specified in the Personal Data Law.

10. Procedure for Collection, Storage, Transfer, Destruction and Other Types of Personal Data Processing

10.1. The Operator ensures the safety of personal data and takes all possible measures to exclude access to personal data by unauthorised persons.

10.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to the implementation of applicable legislation, or if the personal data subject has given the Operator consent to transfer data to a third party for the performance of obligations under a civil law contract.

10.3. If inaccuracies in personal data are identified, the User may update them independently by sending the Operator a notification to the Operator's email address marked "Personal Data Update".

10.4. The period for processing personal data is determined by the achievement of the purposes for which the personal data were collected, unless a different period is stipulated by contract or applicable law. The User may at any time withdraw consent to the processing of personal data by sending the Operator a notification by email to the Operator's email address marked "Withdrawal of Consent to Personal Data Processing".

10.5. All information collected by third-party services, including payment systems, communication services and other service providers, is stored and processed by those persons (Operators) in accordance with their User Agreement and Personal Data Processing Policy. The personal data subject and/or User is obliged to independently and timely review those documents. The Operator is not responsible for the actions of third parties, including the service providers referred to in this clause.

10.6. Restrictions established by the personal data subject on the transfer (other than access), and on the processing or conditions of processing (other than access) of personal data permitted for distribution, do not apply in cases of processing personal data in state, public and other public interests as defined by Russian legislation.

10.7. The Operator ensures the confidentiality of personal data when processing it.

10.8. The Operator stores personal data in a form that allows identification of the personal data subject for no longer than required by the processing purposes, unless a longer period is stipulated by federal law or a contract to which the data subject is a party, beneficiary or guarantor.

10.9. Grounds for termination of personal data processing include: achievement of the processing purpose; expiry or withdrawal of the personal data subject's consent; or identification of unlawful processing of personal data.

10.10. Conditions and timelines for destruction of personal data by the Operator: achievement of the processing purpose or loss of the necessity to achieve it — within 30 days; reaching the maximum retention periods for documents containing personal data — within 30 days; submission by the personal data subject (or their representative) of confirmation that the personal data were obtained unlawfully or are no longer necessary for the stated processing purpose — within seven working days; withdrawal of consent to the processing of personal data when retention for the processing purpose is no longer required — within 30 days.

10.11. Upon achieving the personal data processing purpose, or upon withdrawal of the personal data subject's consent, personal data shall be destroyed, unless: otherwise provided by a contract to which the data subject is a party, beneficiary or guarantor; the Operator may not process without consent on grounds under the Personal Data Law or other federal laws; otherwise provided by another agreement between the Operator and the personal data subject.

11. List of Actions Performed by the Operator with Personal Data

11.1. The Operator performs collection, recording, systematisation, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalisation, blocking, deletion and destruction of personal data.

11.2. The Operator carries out automated processing of personal data with or without the transmission of the received information over information and telecommunication networks.

12. Cross-Border Transfer of Personal Data

12.1. Prior to cross-border transfer of personal data, the Operator must ensure that the foreign state to which the transfer is intended provides reliable protection of the rights of personal data subjects.

12.2. Cross-border transfer of personal data to states that do not meet the above requirements may only be carried out with the written consent of the personal data subject to cross-border transfer of their personal data and/or for the performance of a contract to which the personal data subject is a party.

13. Confidentiality of Personal Data

13.1. The Operator and other persons who have gained access to personal data must not disclose or disseminate personal data to third parties without the consent of the personal data subject, unless otherwise provided by federal law.

14. Final Provisions

14.1. The User may obtain any clarifications on matters of interest regarding the processing of their personal data by contacting the Operator at ap@aptrade.ru.

14.2. The current version of the Policy is freely available on the Internet at https://aptrade.ru/.

14.3. Any changes to the Operator's personal data processing policy will be reflected in this document. The Policy is valid indefinitely until replaced by a new version.