11. Use of Company’s Website

11.1. The Company processes PD of users of the website http://way-trade.ru, including those received via various landing forms as a part of provision of services to personal data subjects (Company Clients, counterparties) through the web interface of Company's website.
The Company uses cookies, including processes information about website users, necessary for proper operation of the website, as well as for the purpose of analyzing traffic and user activity, optimizing the operation of the website and its convenience for website users. Some functions of the website can be used without providing personal data.
To use special features of the website, you are to provide user data, including personal data. By checking a box or clicking a button in the electronic confirmation form provided on the website, the personal data subject expresses its consent for the processing of its personal data by the Company under the conditions provided for in this Policy.
A personal data subject does not use Company’s website and does not provide the Company with its personal data if it does not agree with the provisions of this section of the Policy.

11.2. To maintain statistics and analyze operation of the website, the Company processes such data as: - IP address; - information about the browser; - data from cookies; - access time; - referrer (address of the previous page) using Yandex.Metrika metric services.
Yandex.Metrika service available at the address http://api.yandex.com/metrika, allows various User’s services and applications to interact with Yandex.Metrika service by Yandex, LLC.
Yandex.Metrika works with cookies and creates pseudonymous usage profiles that allows to analyze how users use the website. The information stored in such cookies (for example, browser type/version, operating system used, referrer URL, host name of the accessing computer, time of the server request) is usually transmitted and stored on Yandex servers.
To block Yandex.Metrika, you can download and install the add-in at https://yandex.com/support/metrica/general/opt-out.html?lang=ru. Additional information can be obtained in the privacy policy of Yandex: https://yandex.ru/legal/confidential/?lang=ru.
After Yandex.Metrica blocking, some website functions can become unavailable.
The Processor does not verify the accuracy of information provided by the user of the website and assumes that the user provides reliable and sufficient information and controls its relevance.

11.1. Общество осуществляет обработку ПДн пользователей интернет-сайта https://waytrade.tilda.ws, в том числе
полученных через различные
лэндинг формы в рамках
предоставления услуг субъектам
персональных данных (Клиентам,
контрагентам Общества) через веб-
интерфейс сайта Общества.

Общество использует файлы cookies,
в том числе обрабатывает сведения
о пользователях интернет-сайта,
необходимые для правильной работы интернет-сайта, а также в целях
анализа посещаемости,
пользовательской активности,
оптимизации работы сайта
и удобства пользователей интернет-сайта. Некоторая часть функционала интернет-сайта может
быть использована без предоставления персональных
данных.

Для использования специальных возможностей интернет-сайта
необходимо предоставить
пользовательские данные, включая персональные данные. Проставляя
галочку (чек-бокс) или нажимая
кнопку в электронной форме
подтверждения, предоставляемой
интернет-сайтом, субъект персональных данных выражает свое
согласие на обработку своих
персональных данных Обществом
на условиях, предусмотренных
настоящей Политикой.

Субъект персональных данных
не использует интернет-сайт Общества и не предоставляет
Обществу свои персональные
данные, если он не согласен
с положениями данного раздела
настоящей Политики.

11.2. Для ведения статистики
и анализа работы сайта Общество обрабатывает с использованием
метрических сервисов
Яндекс.Метрика такие данные, как:
- IP-адрес; - информация о браузере;
- данные из файлов cookie;
- время доступа; - реферер (адрес
предыдущей страницы).

Сервис Яндекс.Метрики, доступный
по адресу http://api.yandex.com/
metrika позволяет различным
сервисам и приложениям
Пользователя взаимодействовать
с сервисом Яндекс.Метрики ООО
«Яндекс».

Яндекс.Метрика работает с файлами
cookie и создает псевдонимные
профили использования, которые
позволяют анализировать
использование пользователями
сайта. Информация, хранящаяся
в таких файлах cookie (например,
тип / версия браузера, используемая операционная система, URL-адрес
реферера, имя хоста компьютера,
получающего доступ, время запроса
к серверу), обычно передается
и сохраняется на серверах Яндекс.

Для блокировки Яндекс.Метрики
можно скачать и установить
надстройку по ссылке https://yandex.com/support/metrica/
general/opt-out.html?lang=ru Дополнительную информацию можно получить в политике конфиденциальности Яндекс: https://yandex.ru/legal/confidential/?lang=ru.

При блокировке Яндекс.Метрики некоторые функции cайта могут стать недоступны.
Оператор не проверяет достоверность информации, предоставляемой пользователем сайта, и исходит из того, что пользователь предоставляет достоверную и достаточную информацию, контролирует ее актуальность.

5. Principles of Personal Data Processing

Personal data in the Company are processed based on the following principles:
- processing of personal data is carried out on a legitimate and fair basis;
- processing of personal data is limited to the achievement of specific, predefined and legitimate purposes. Processing of personal data that is incompatible with the purposes of collection of personal data is prohibited;
- it is not allowed to combine databases with personal data the processing of which is carried out for purposes that are incompatible with each other;
- only personal data meeting the purposes of their processing are subject to processing;
- the content and volume of personal data being processed shall correspond to the stated purposes of processing. Personal data being processed shall not be redundant in relation to the stated purposes of their processing;
- when processing personal data, it is necessary to ensure the accuracy of personal data, their sufficiency, and, if necessary, relevance in relation to the purposes of personal data processing. The Company must adopt required measures or ensure their adoption in order to delete or specify incomplete or inaccurate data;
- storage of personal data is carried out in a form that makes it possible to identify the personal data subject for no longer than is required for the purposes of personal data processing, unless a period for personal data storage is established by a federal law or an agreement to which the personal data subject is a party or a beneficiary. Personal data being processed are subject to destruction or depersonalization upon achievement of the goals of processing or in case of no further need to achieve such goals, unless otherwise provided for by the RF laws.
Personal data processing in the Company is based on the principles of ensuring the protection of human and civil rights and freedoms, including the protection of the rights to personal and family privacy.

1. Purpose of the Policy

1.1. The policy in the field of personal data processing and protection in WAY-TRADE, LLC (hereinafter – “the Policy”) is a fundamental top-level document.

1.2. This Policy has been developed to implement in WAY-TRADE, LLC (hereinafter – “the Company”) of the requirements of the RF laws in the field of personal data, as well as to ensure the protection of individuals’ rights when processing their personal data.

1.3. This Policy has been developed in accordance with the requirements of the RF Federal Law “On Personal Data” and is intended for familiarization by an unlimited number of persons by means of publication at the official website of the Company – http://way-trade.ru

1.4. The policy discloses the categories of personal data subjects’ personal data processed in the Company, the purposes, methods and principles of processing, the rights of personal data subjects, as well as a list of measures taken by the Company in order to ensure the security of personal data.

1.5. The provisions of this Policy form the basis for the development and updating of administrative and organizational and legal documents (hereinafter – “regulatory documents”) of WAY-TRADE, LLC regulating the processes of processing of personal data of various categories of personal data subjects, as well as the procedure for the implementation of measures to protect personal data being processed.

1.6. This Policy is mandatory for application and fulfillment by all employees and all workers of WAY-TRADE, LLC having access to personal data, including employees from separate subdivisions.

1.7. Policies on functional areas of activity, as well as administrative and regulatory local and other internal documents shall not contradict this Policy.

2. Terms and Definitions

Personal Data – any information directly or indirectly relating to an identified or identifiable individual (personal data subject) (hereinafter – “PD”).

Personal Data Subject – an individual who is directly or indirectly identified or identifiable using personal data.

Personal Data Processor – WAY-TRADE, LLC, a legal entity that independently or together with other persons organizes and (or) carries out personal data processing, as well as determines the purposes of personal data processing, the composition of personal data to be processed, and actions (operations) performed with personal data.

Personal Data Processing – any action (operation) or a series of actions (operations) with personal data performed using automation tools or without them. Personal data processing includes, but is not limited to, collection; recording; systematization; accumulation; storage; specification (updating, changing); extraction; use; transmission (distribution, provision, accessing); depersonalization; blocking; deletion; destruction.

Distribution of Personal Data – actions aimed at disclosure of personal data to an indefinite number of persons.

Provision of Personal Data – actions aimed at disclosure of personal data to a definite person or a definite number of persons.

Blocking of Personal Data – temporary cessation of personal data processing (except for cases when processing is necessary to specify personal data).

Destruction of Personal Data – actions as a result of which it becomes impossible to restore the content of personal data in the personal data information system and (or) as a result of which material media with personal data are destroyed.

Depersonalization of Personal Data – actions as a result of which it becomes impossible, without the use of additional information, to determine the ownership of personal data by a particular personal data subject.

Personal Data Information System – a set of personal data contained in databases, as well as information technologies and technical means ensuring their processing.

Cross-Border Transfer of Personal Data – transfer of personal data to the territory of a foreign state to an authority of a foreign state, a foreign individual or a foreign legal entity.

Personal Data Security – the state of security of personal data characterized by the ability of users, technical means and information technologies to ensure the confidentiality, integrity and availability of personal data being processing in information systems.

Confidentiality of Personal Data – a mandatory requirement not to disclose to third parties and not to allow the distribution of personal data without the consent of personal data subjects or another legal ground.

Protection of Personal Data – actions aimed at preventing leakage of protected personal data, as well as unauthorized and unintentional impacts on protected personal data.

3. Purposes of Personal Data Processing

The Company carries out processing of personal data for the following purposes:
- implementation of contracts for the provision of freight forwarding services, contracts for cargo transportation and provision of additional services during performance of obligations under such contracts;
- implementation of sale and purchase agreements;
- implementation of contracts for the provision of warehousing and storage services;
- ensuring transportation security;
- improvement in quality of service and availability of services;
- provision of information about services provided, development of new services, as well as about services provided by subsidiaries and associates of the Company;
- collection and generation of ideas aimed at improving the management of the process of provision of freight forwarding services and the process of cargo transportation;
- implementation of sale and purchase agreements;
- appraisal of investment and start-up projects;
- conducting promotions, surveys, as well as marketing, statistical and other research activities;
- maintenance of an official website;
- consideration of clients’ and counterparties’ requests;
- implementation of contracts concluded with individuals who are in contractual and other civil-law relations with the Company;
- ensuring the fulfillment of contractual relations with Company’s employees and fulfillment of social obligations;
- ensuring the compliance with legal requirements when reflecting information in reporting statements and maintaining corporate documents of the Company;
- performing personnel work, including attraction and selection of candidates for work to subsidiaries and associates of the Company;
- fulfillment and performance of other functions, powers and duties imposed by the current RF laws, as well as achievement of goals provided for by international treaties of the Russian Federation and legislation.

When processing personal data, WAY-TRADE, LLC is governed by the following legal grounds:
- 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. 115-FZ as of 07.08.2001 “On Countering the Legalization (Laundering) of Proceeds from Crime and Financing of Terrorism”;
- Federal Law No. 152-FZ as of 27.07.2006 “On Personal Data”;
- Federal Law No. 229-FZ as of 02.10.2007 “On Enforcement Proceedings”;
- Federal Law No. 14-FZ as of 08.02.1998 “On Limited Liability Companies”;
- Federal Law No. 402-FZ as of 06.12.2011 “On Accounting”;
- Federal Law No. 44-FZ as of 05.04.2013 “On the Contract System in the Sphere of Procurement of Goods, Works and Services for Provisioning Governmental and Municipal Needs”;
- Federal Law No. 223-FZ as of 18.07.2011 “On Procurement of Goods, Works and Services by Certain Types of Legal Entities”;
- Federal Law No. 87-FZ as of 30.06.2003 “On Forwarding Activities”;
- RF Law No. 2300-1 as of 07.02.1992 “On the Protection of Consumers’ Rights”;
- Articles of Association of WAY-TRADE, LLC;
- contracts executed between WAY-TRADE, LLC and personal data subjects, including public offers and a user agreement published on the Company’s Website;
- other legislative acts of the Russian Federation.

6. Main Rights and Obligations of Personal Data Processor and Subjects

Within the frames of personal data processing, the following rights are defined for PD subjects and the Company.

6.1. A PD subject is entitled to:
- obtain information regarding the processing of its personal data in the manner, form and within the time limit established by the legislation on personal data;
- require to specify its personal data, block or destruct its personal data if they are incomplete, outdated, unreliable, illegally obtained, not necessary for the stated purpose of processing or used for purposes not stated before when the PD subject gave its consent to personal data processing;
- take measures provided by the law to protect its rights;
- withdraw its consent for personal data processing.

6.2. WAY-TRADE, LLC is entitled to:
- process personal data of the PD subject in accordance with the stated purpose;
- require the PD subject to provide reliable personal data necessary for the implementation of a contract, provision of a service, identification of the PD subject, as well as in other cases provided for by the legislation on personal data;
- process publicly available personal data of individuals;
- process personal data subject to publication or mandatory disclosure in accordance with the RF laws;
- entrust personal data processing to another person with the consent of the personal data subject.

7. The Procedure and Terms for Processing of Personal Data Subjects’ Personal Data

7.1. The Processor receives personal data of PD subjects as follows:
- by means of personal communication by clients and counterparties of their data when filling out a request for the provision of services, when executing contracts for the provision of services (performance of works), etc.;
- by means of entering by clients/users of their data on the Website;
- from third parties (counterparties).

7.2. The Processor receives and starts processing personal data of a PD subject upon emergence of a legal ground for their processing.

7.3. Consent for the processing of personal data can be given by a PD subject in any form that allows to confirm the fact of receipt of such consent, unless otherwise established by a federal law: in a written, verbal or other form provided for by the current legislation, including by way of performance of implicative actions by the PD subject.

7.4. If a PD subject enters its data on the Website, consent for the processing of its personal data is considered to be given by the PD subject by performing the following implicative actions in the aggregate: putting a special sign - a “tick” or a “web tag” in a special field on the Website ordering a callback, applying in the feedback form, registering in its personal account, filling out an order for the provision of services and clicking the corresponding button are expressly regarded as the provision of consent for personal data processing in the amount, for the purposes and in the manner provided for in the text proposed for familiarization before putting a special sign. Consent is considered to be obtained from the moment the special sign is put and is valid until the PD subject files a corresponding request to terminate PD processing to the Processor’s location.

7.5. If a PD subject fills out requests for the provision of services and puts its signature, the PD subject expresses his consent to accept the terms of the public offer set out in the contracts for the provision of services or purchase and sale, and the terms of the provision of services published on the Website, which means, among other things, its consent to personal data processing. The contract is valid from the moment of its execution until the moment of its termination. Refusal to perform under the contract can be sent by the PD subject to the Processor’s location.

7.6. If personal data are received from third parties (clients, counterparties), the responsibility for obtaining consent for the processing and transfer of such personal data lies with such third parties. If there is no legal ground for PD processing, no processing of PD subject’s personal data is carried out.

7.7. PD cannot be used for the purpose of causing property and moral harm to PD subjects or impeding the exercise of rights and freedoms of RF citizens.

7.8. The Company ensures collection, recording, systematization, accumulation, storage, specification (updating, changing), extraction, use, transfer (provision, accessing), depersonalization, blocking, deletion and destruction of PD using databases located on the territory of the Russian Federation.

7.9. The Company, in the course of its activities, entrusts PD processing to third parties with the consent of PD subjects, unless otherwise provided for by the current legislation of the Russian Federation, provided that the person processing PD on behalf of the Company complies with the principles and rules of processing and ensuring the security of PD established by the RF laws.

7.10. An order for the processing of personal data shall define the following:
- a list of personal data, a list of actions that will be performed with personal data by the person processing personal data and purposes of their processing, whereby, the list of actions shall not contradict the goals and actions stated to the Personal Data Subject in the agreement executed with the Company, consent and other documents;
- the obligation of such person to maintain confidentiality of personal data and ensure the security of personal data during their processing;
- the obligation, at the request of the Company during the validity period of the order, to provide documents and other information confirming the adoption of measures and compliance with the requirements established by law in order to execute the order;
- the obligation to ensure security of personal data during their processing;
- the procedure and terms for notifying the Processor about incidents with personal data;
- liability.

7.11. In order to ensure security of PD during their processing, the Company takes necessary and sufficient legal, organizational and technical measures to protect PD from unauthorized or accidental access to them, destruction, modification, blocking, copying, provision or distribution, as well as from other unlawful actions in relation to PD.

7.12. The Company has a person responsible for the organization of PD processing, who receives instructions directly from the Company Director and is accountable to it.

7.13. A list of persons allowed to process PD is determined by the order of the Executive Body and internal local regulatory acts of the Company. Before getting to work, these persons shall familiarize themselves with the following documents:
- with the provisions of the RF laws on PD, including the requirements for the procedure for PD protection;
- with documents defining Processor’s actions regarding PD processing, including this Policy;
- with local acts regarding PD processing.

7.14. Access to PD subjects’ personal data is provided to Processor’s employees in accordance with their job responsibilities.
Processor’s employees in charge of processing of PD subjects’ personal data must be informed of the fact of such processing and the features and rules of such processing established by regulations and internal documents of the Processor.

7.15. A Company employee having the right to process PD subjects’ personal data is assigned with a unique login and password in order to have access to the relevant information system in the prescribed manner.
Information about the identifiers assigned to the employee (login and password) is confidential and cannot be transferred by the employee to third parties. The employee ensures compliance with the confidentiality requirements and bears the risk of consequences associated with violation of such requirements.

7.16. The authentication procedure is carried out by Processor’s technical center when the employee gains access to the information system by comparing the login and password entered with the corresponding login and password assigned to the employee, information about which is recorded in the information system.
If the authentication procedure is successfully completed, the employee gets an opportunity to carry out operations with PD subject’s personal data in the information system.

7.17. Processor’s employee having access to personal data in connection with the performance of its job duties ensures the storage of information containing PD subjects’ personal data excluding third-party access to them. In the absence of an employee, there shall be no documents containing PD at its workplace. When an employee goes on a leave or a business trip and in other cases of its long-term absence from the workplace, it shall transfer documents and other media containing PD to the person who will be entrusted with the performance of its job duties by a local act of the Processor. If such person is not appointed, then documents and other media containing the Subjects’ PD shall be transferred to another employee having access to PD at the direction of the head of the corresponding structural subdivision of the Processor. Upon dismissal of the employee having access to PD, documents and other media containing PD shall be transferred to another employee having access to PD at the direction of the head of the structural subdivision, subject to notification of the person in charge of personal data processing.

7.18. Storage of PD subjects’ personal data the purposes of processing of which are different is carried out separately within the information system or, in case of storage on tangible media, within the framework of business structure of the corresponding subdivision of the Processor.

7.19. Storage of PD subjects’ personal data is carried out by the Company in a form that makes it possible to identify the personal data subject.

7.20. Processing and storage of PD is carried out for no longer than is required for the purposes of PD processing, if there are no legal grounds for further their processing, for example, if the period of storage of PD is established by the RF laws or an agreement to which the PD subject is a party, a beneficiary or a guarantor, or with the consent of the PD subject.

PD being processed are subject to destruction upon achievement of the work goals or in case of no further need to achieve such goals. The Processor does not perform actions aimed at disclosing PD to an indefinite number of persons.

8. Categories of Personal Data Subjects, Volume and Category of Personal Data Being Processed

8.1. When carrying out its activities, the Company processes personal data of the following categories of personal data subjects:
- of Company employees (personal data required to the Company in connection with labour relations and relating to a particular employee);
- of Company applicants (personal data necessary for the Company to make a decision on candidate’s compliance with the requirements established by the RF laws and the Company);
- of Company employees with whom labour relations have been terminated (personal data that shall be processed by the Company in cases established by the RF laws after termination of the labour contract with the employee);
- of affiliated persons, managers, members (shareholders) or employees of a legal entity who are affiliated with the Company (personal data necessary for the Company to carry out its activities, including for their reflection in reporting documents on Company’s activities in accordance with the requirements of current legislation of the Russian Federation);
- of Company’s Clients, as well as managers, members (shareholders) or employees of legal entities that are the Company’s Clients (personal data necessary for the Company to fulfill its obligations within the framework of contractual relations with the Client and statutory requirements of the Russian Federation);
- of potential Clients, counterparties or contractors (personal data required to the Company for the purpose of considering issues on the execution of contracts, conducting transactions with a potential Client, counterparty or contractor, and fulfilling the statutory requirements of the Russian Federation);
- of representatives of Clients, counterparties, contractors, beneficiaries or beneficial owners (personal data necessary for the Company to fulfill its obligations within the framework of contractual relations with the Client and the statutory requirements of the Russian Federation);
- of other individuals who have expressed their consent for the Company to process their personal data or individuals whose personal data shall be processed by the Company in order to achieve the goals provided for by an international treaty of the Russian Federation or the law, to perform and fulfill functions, powers and responsibilities imposed on the Company by the RF laws, as well as personal data subjects whose personal data are processed by the Company without the consent of such personal data subject in cases provided for by the RF laws.

8.2. The volume of personal data being processed is determined based on the purposes of processing. Personal data processing in the Company is carried out on a legal fair basis and is limited to the achievement of specific, predetermined and legitimate goals.

8.3. Personal data include any information directly or indirectly related to an identified or identifiable individual (personal data subject) and processed by the Company in order to achieve predetermined goals.
The Company does not process special categories of personal data related to race, nationality, political opinions, religious or philosophical beliefs and intimate life.
The Company processes special personal data only with the written consent of the personal data subject, with the exception of cases defined by the Federal Law No. 152-FZ “On Personal Data”.

9. Company Employees Dealing with Processing and Use of Personal Data

Only those Company employees who need such access to perform their job duties and who are legally vested with the corresponding powers and rights of access to personal data and means of their processing have access to personal data being processed. Access of other persons to personal data being processed by the Company is possible only in cases provided for by the law and in the manner prescribed by the law.

A person in charge of organization of personal data processing shall be appointed by the order of Company Director.

The Legal Department, within the framework of its control procedures, evaluates the efficiency of measures taken to ensure compliance with the requirements of the present Policy, as well as approved regulatory documents of the Company related to personal data.

The Legal Department monitors legislation and brings to the attention of interested subdivisions information about changes in legal norms, provides legal protection of Company’s interests in courts and government bodies in disputes related to personal data processing, as well as during consideration of administrative cases related to violations of legislation in this sphere.

10. Implementation by the Company of the Requirements for Personal Data Protection

The Company implements the requirements for personal data protection from unauthorized or accidental access to personal data, their destruction, modification, blocking, copying, distribution, as well as from other unlawful actions with personal data, using legal, organizational and technical measures in accordance with the RF laws, including in accordance with by-laws and regulatory requirements of authorized governmental bodies. A list of measures established by this Policy is not exhaustive.

10.1 Legal Measures:
Mandatory inclusion into agreements on the transfer of personal data executed by the Company with interacting organizations and individuals of requirements for maintenance of confidentiality (including the nondisclosure obligation) and ensuring the security of personal data during their processing: in accordance with Article 7 of the Federal Law No. 152-FZ as of 27.07.2006 “On Personal Data”, a person who has gained access to personal data is obliged not to disclose to third parties and not to distribute personal data without the consent of the personal data subject, unless otherwise provided for by a federal law.
Documentation of requirements for the security of data being processed.

10.2. Organizational Measures:
- familiarization of Company employees with the requirements of the RF laws and Company's regulatory documents in the field of processing and ensuring the security of personal data;
- establishing personal responsibility of Company's employees for ensuring the security of data being processed;
- monitoring of compliance by Company subdivisions, officials and employees with the requirements of the law and regulatory documents on the protection of personal data;
- classification of personal data according to the provisions and requirements of the law;
- timely identification of threats to personal data security, development and approval of models of threats to personal data security in accordance with legal requirements;
- accounting of computer personal data storage media;
- organization of access control to Company’s premises and buildings during working and non-working hours;
- organization and implementation of a system for control/isolation of users’ (service personnel) access to documents, information resources, computer storage media, information systems and works related to their use;
- systematic analysis (monitoring) of personal data security, regular checks and improvement of the system for their protection.

10.3. Technical Measures:
These measures are developed and adopted by the Company in accordance with legal requirements, including relevant by-laws and regulatory requirements of authorized governmental bodies, based on developed and approved models of threats to personal data security. Information about particular technical measures used to protect personal data is confidential and is disclosed by the Company only in cases and in the manner prescribed by the law.

12. Updating, Correction, Deletion and Destruction of Personal Data

12.1. If it is confirmed that PD are inaccurate or that their processing is unlawful, the PD shall be updated by the Company and their processing must be stopped.

12.2. When the goals of PD processing are achieved, as well as in the event that the PD subject withdraws its consent for their processing, the PD shall be subject to destruction:
- unless otherwise provided for by an agreement to which the PD subject is a beneficiary;
- if the Company does not have the right to carry out processing without the consent of the PD subject on the grounds provided for by the Federal Law No. 152-FZ or other federal laws;
- unless otherwise arranged in another agreement between the Company and the PD subject.
The destruction of PD is carried out by the Company in accordance with the procedure for personal data destruction in WAY-TRADE, LLC.

12.3. The Company is obliged to provide a PD subject or its representative with information about processing of such subject’s PD upon request.
The procedure for filing such requests by the PD subject is defined by the requirements of the Federal Law No. 152-FZ and is carried out in accordance with Company’s internal documents regulating the processing of requests of PD subjects in the Company. The PD subject/representative can draw up a request independently, taking into account the requirements of Art. 14 of the Federal Law No. 152-FZ, or ask a Company employee in charge of processing requests of the PD subject/representative to provide a request form for filling out.
A request from the PD subject shall contain the following information:
- series and number of the document proving the identity of the PD subject/representative, information on the date of issue of such document and the issuing authority;
- information proving the fact of PD subject’s participation in relations with the Company (agreement number and date and/or other information), or information otherwise confirming the fact of PD processing by the Company;
- PD subject’s/representative’s signature.

12.4. Processing of requests from the PD subject is carried out in accordance with the internal documents of the Company regulating the processing of requests from the PD subject in the Company.

13. Final Provisions

13.1. This Policy is subject to revision and, if necessary, updating in the event of changes in the RF laws on personal data. The Company has the right to change the terms of the privacy policy unilaterally.

13.2. In case of adoption of new or changes in existing legislative, regulatory legal acts and other documents governing the procedure for personal data processing, this Policy shall be valid to the extent that does not contradict them until the corresponding changes and additions are introduced.

13.3. The current version of this Policy is publicly available and published on the Internet on the official website of the Company - http://way-trade.ru, as well as in a publicly accessible place in Company's offices where client services are provided.