The Russian Federation, Moscow
This Privacy Policy has been developed in accordance with Federal Law No. 152-FZ dated July 27, 2006, "On Personal Data", and establishes the terms and conditions for the processing of personal information by AgroBroker JSC, a company registered and operating under the laws of the Russian Federation.
1. Definitions
In this Privacy Policy, unless otherwise specified, the following terms have the following meanings:
- "Operator": AgroBroker JSC (AgroBroker), registered under OGRN number 1217700615110 and TIN number 9731086673. Its address is 121205, Moscow, Skolkovo Innovation Center, Bolshoy Boulevard, 42, p. 1. The operator is represented by the General Director, Roman Dmitrievich Lebedev.
- "Processing of personal data": The collection, storage, use, disclosure, modification, or deletion of personal information obtained from individuals who visit the website https://trade.agro.broker/.
Any action (operation) or set of actions (operations) performed with or without the use of automated tools, with personal data including collection, recording, organization, accumulation, storage, updating, extraction, use, transmission (distribution, access), de-identification, blocking, removal, and destruction of personal information.
An "agreement" is any contract or agreement concluded with a user, information about which is accessible on the website and/or web application.
A "user" is a person who registers on the https://trade.agro.broker website and accepts the offer to enter into a user agreement.
Personal data is any information directly or indirectly related to a user and/or third parties that is provided by a user through the application, website, or authorized email address.
The "user agreement" is the contract between the user and the company that governs their relationship regarding the use of the application and website.
This is a User Agreement, the text of which is always available on the website and/or in the web app, and at the internet address https://agro.broker/privacy\_policy.
"Providing personal data" means sharing personal information with a specific person or a group of people.
A "web app" is a program for computer devices that users access after signing the User Agreement.
The "website" is a collection of information, including text, graphics, design, images, videos, and other intellectual property, as well as software programs, hosted on an online system accessible at https://trade.agro.broker/.
"Transferring personal data across borders" refers to sending personal information to another country to a government agency, individual, or business entity.
Finally, "destroying personal data" means deleting it from all systems.
As a result of actions that make it impossible to restore personal data content in the personal information system, or that destroy material carriers of personal data, the following applies:
1.2. All other terms and definitions in this Privacy Policy are understood in accordance with current Russian legislation and the usual rules for interpreting relevant terms.
1.3. Headings (paragraphs) in the Privacy Policy serve only for convenience in reading the text and have no legal significance.
1.4. This Privacy Policy was developed in accordance with Russian law.
1.5. By using the Application or Site, you agree to this Privacy Policy and its terms.
2.1 The Operator collects and uses Personal Data, technical information, and other information related to Users and/or third parties who use the Application or Site. This includes information provided by the User or related to their activity on the Application or Website.
2.2 Technical information is not considered Personal Data. However, the Operator may use cookies to identify Users. Cookies are small text files that allow the Operator to track User activity, such as which pages were visited and how long the User spent on each page. Users have the option to disable cookies in their browser settings.
2.3 The Operator only processes Personal Data that has been provided directly to the Operator by the User through the Application or Website, or as part of an Agreement or Contract. Personal Data may include, but is not limited to, the following information: surname, first name, patronymic, INN, email address.
Contact phone number; information about bank accounts; geolocation information (device data and location); photo; user's contacts.
Geolocation information is collected by the Operator in the background and transferred to the server to monitor the location and movement of cargo.
The Operator processes the User's personal data, technical information, and other information prior to withdrawal from the relevant user agreement.
Personal data
The User gives their consent to the Operator to process personal data, including transferring such personal data to third parties in accordance with the terms of the agreement and/or contract, even if such transfer occurs on the territory of other countries (cross-border transfer).
3.2 The User agrees to receive newsletters and promotional materials from the Operator or from other individuals on behalf of the Operator at the e-mail address and/or contact phone number provided by the User during registration on the Website or in the Application.
3.3 In order to comply with the terms of this Agreement and/or other agreements, use the features of the Site and/or Application, and the interaction between the Operator and User, the User hereby agrees to receive electronic communications and notifications generated and sent in the form of SMS messages, HLR requests, push notifications, as well as communications and notifications sent through Software Products, including push notifications, email, Telegram, and WhatsApp.
3.4 Before transferring personal data to the operator, the user must take all necessary steps provided by law to ensure compliance with the rights of individuals whose personal data they are transferring. This includes obtaining permission from those individuals to transfer and process their personal data. If the user fails to obtain such permission and causes losses to the operator as a result, they must compensate for those losses within 10 calendar days of receiving a written request from the operator.
4. Purpose of using information provided by user
4.1 The information provided by users is used solely for the following purposes:
4.1.1. Fulfillment by the Operator of obligations to the User and third parties under the terms of the Agreement;
4.1.2. Establishing and maintaining communication with the User;
4.1.3. Sending informational and other messages to the User's email address;
4.1.4. Improving the quality of service and updating the Site and/or Application;
4.1.5. Registration and identification of Users in the Application and/or website;
4.1.6. Administration of justice in case the Operator receives a request from authorized bodies;
4.1.7. Compliance with the current Russian laws;
4.1.8. Providing answers to requests submitted by individuals;
4.1.9. Sending electronic messages and notifications in the form of SMS, HLR, Push notifications, and messages sent via E-mail, Telegram, and WhatsApp.
5. Measures Taken to Protect the Information Provided by the User and the Operator's Guarantees
5.1 The Operator takes all necessary and reasonable legal, organizational, and technical measures to ensure the protection of the information provided by the user from unauthorized or unintentional access, alteration, deletion, blocking, duplication, distribution, or any other unlawful activities by third parties. This includes restricting access to this information to other users of the site, employees, partners, and third parties (except for those necessary for the operator to fulfill its obligations towards the user), and complying with current Russian laws. Additionally, the operator imposes sanctions on any individuals who violate the confidentiality of such data.
5.2 The Operator ensures that the information provided by the User will not be combined with statistical data and will not be shared with third parties, except as specified in the Privacy Policy.
5.3 The Operator does not sell or transfer user information independently. Such information may only be transferred in the event of a partial or complete restructuring of the Operator.
5.4 The Operator takes technical and organizational measures to ensure that the User has access to and the ability to edit the information they provide.
6. Operator's Rights
The Operator has the right to conduct statistical and other research based on the User's information. The User has given consent to this by adopting the Privacy Policy. The Operator may share this information with third parties.
The Operator also has the right to share information about the User with law enforcement agencies or other government bodies in the context of legal proceedings, investigations, or cooperation as required by current Russian laws.
Additionally, the Operator may disclose information about the User in order to prevent fraud or address technical or security issues.
6.4 The Operator has the right to share User information with third parties if such sharing is necessary for the Operator to fulfil its obligations to the User under contracts and/or agreements concluded with the User.
6.5 Other rights and responsibilities of the Operator related to the processing of Personal Data are defined by the laws of the Russian Federation on personal data.
7 User Rights
7.1 The User may delete or change information provided by the User at any time by performing the necessary actions on the website and/or application, and if such an opportunity is not available, by contacting the operator at the email address info@agro.broker. At the same time, the user understands that the operator has the right to continue using such information in cases allowed by current Russian law.
7.2. The User may revoke their consent to receive newsletters and promotional materials at any time by sending the Operator a corresponding notification in the same manner.
8. Updates
8.1. The Operator reserves the right to make changes to this Privacy Policy. It is the User's responsibility to familiarize themselves with the updated text of this Privacy Policy each time they access the Site and/or Application.
8.2. A new version of this Privacy Policy will come into effect from the moment it is published on the Website and/or within the Application. If a User continues to use the Site and/or Application after a new version of this Privacy Policy has been published, they are deemed to have accepted its terms and conditions.
8.3. If you do not agree with the terms and conditions of this Privacy Policy, we recommend that you do not use the Website or Application.
9.1 In the event that the terms and conditions of the agreement between the Operator and the User include provisions on the use of personal information and/or personal data, these provisions of the Privacy Policy shall apply, to the extent they do not conflict with the Privacy Policy.