1. This document (hereinafter referred to as the Policy) defines the personal data processing policy of Importex Limited Liability Company (hereinafter referred to as Importex, LLC).

  2. This Policy is in compliance with the requirements of Clause 2 of Parts 1 of Article 18.1 of Federal Law dated 27.07.2006 No. 152-FZ “On Personal Data” (hereinafter referred to as the Personal Data Law).

  3. This Policy applies to all operations carried out by Importex, LLC in relation to personal data with or without the use of automation aids.

  4. Terms and definitions used in this Policy shall be applied according to the meanings established by Article 3 of the Personal Data Law.

  5. Importex, LLC does not check the validity of the personal information provided by the User, although assumes that the User provides true and sufficient personal information.

  6. By furnishing personal information the User confirms that they provided this data voluntarily and consciously, of their own free will and for their benefit.


2.1. Importex, LLC has the right to:

  • receive from the User true information and/or documents containing personal data;

  • demand that the User update the furnished personal data in due time.

2.2. Importex, LLC is obliged to:

  • process the personal data in accordance with the applicable laws of the Russian Federation;

  • consider User’s (their legal representative’s) requests regarding personal data processing and give substantiated responses;

  • give the User (their legal representative) freedom of access to their personal data free of charge;

  • take actions to update or destroy User’s personal data based on their (their legal representative’s) legal and substantiated request;

  • arrange for protection of personal data in accordance with the requirements of the Russian Federation laws.

2.3. The User has the right to:

  • full information about their personal data processed by Importex, LLC;

  • access to their personal data, including the right to get a copy of any record containing their personal data, except as provided by the federal laws;

  • update, block or destroy their personal data if personal data is incomplete, outdated, inaccurate, illegally received or not necessary for the stated purpose of processing;

  • retract the consent to personal data processing;

  • take actions related to protection of their rights as provided by the law;

  • execute other rights as provided by the Russian Federation laws.

2.4. The User is obliged to:

  • provide only valid data about themselves to Importex, LLC;

  • furnish documents containing personal data to the extent required for the purpose of the processing;

  • advise Importex, LLC of updating (renewal, alteration) of their personal data.

2.5. Persons who provided Importex, LLC with false data about themselves or with data about another personal data subject without consent of the latter, shall be liable under the laws of the Russian Federation.


3.1. An operator can process personal data of the following personal data subjects:

  • employees of Importex, LLC, former employees, job candidates and employees’ relatives;

  • customers and business contacts of Importex, LLC (natural persons);

  • representatives/employees of customers and business contacts of Importex, LLC (legal entities);

  • visitors of website (websites) of Importex, LLC (hereinafter referred to as Website and Websites).

3.2. Personal data processed by Importex, LLC include as follows:

  • last name, first name, patronymic of the personal data subject;

  • place of residence (region/city);

  • specialization / area of professional interests;

  • mobile phone number;

  • electronic mail address (e-mail);

  • search and view history on the Website and its services (for Website visitors);

  • other information (the above list may be reduced or extended depending on a particular case and processing purposes).

3.3. Importex, LLC shall ensure that the content and extent of the processed personal data correspond to the stated processing purposes and, where necessary, take steps to remove its redundancy in relation to the stated processing purposes.

3.4. Importex, LLC shall process biometric personal data subject to a written consent of relevant personal data subjects and in other cases provided by the Russian Federation laws.

3.5. No processing shall be carried by Importex, LLC in respect of special personal data categories related to race, nationality, political views, religious or philosophical beliefs and private life.

3.6. Importex, LLC shall not perform cross-border transfer of personal data.


4.1. Personal data shall be processed by Importex, LLC in the following cases:

  • Users identification for conclusion of any contracts and their subsequent performance;

  • conduction of actions, polls, interviews, tests and researches by Importex, LLC on the Websites;

  • contact with a User, with whom a contract was made, including sending notifications, requests and information concerning its fulfillment, as well as processing of User’s requests and inquiries related to these contracts;

  • providing features and services of Importex, LLC for the Users, as well as information on new features and services developed by the Company, including promotion;

  • two-way communication with personal data subjects, including processing of their inquiries and requests, notification about the Website (Websites) work;

  • control and improvement of quality of features and services of Importex, LLC, including those offered on the Website (Websites);

  • staff management and arrangement for keeping track of Importex, LLC employees, regulation of labor and other relations directly connected therewith;

  • recruiting and selection of applicants for the job in the Company;

  • preparation of statistical reports;

  • carrying business activities;

  • execution of other functions, powers and duties imposed on Importex, LLC by the Russian Federation laws.


5.1. Personal data processing is made by Importex, LLC using the following methods:

  • non-automated personal data processing;

  • automated personal data processing with or without transfer of received information through information and telecommunication networks;

  • combined personal data processing.

5.2. List of personal data handling operations performed by Importex, LLC: collection, systematization, accumulation, storage, updating (renewal, alteration), use, distribution (including transfer), depersonalization, blocking, destruction, and carrying any other operations in accordance with the applicable laws of the Russian Federation.

5.3. Importex, LLC shall process personal data subject to consent of a personal data subject (hereinafter referred to as Consent), except where the Russian Federation laws provide that personal data processing can be carried without such Consent.

5.4. The User shall make a decision on provision of their personal data and give Consent freely, of their own will and for their own benefit.

5.5. Filling-in of a relevant form on the Website means User’s unconditional agreement with the conditions of processing User’s personal data specified in this Policy.

5.6. Conditions for termination of personal data processing may be achievement of the personal data processing purposes, expiration of the validity period of the Consent or retraction of the Consent by the User, as well as detection of unlawful personal data processing.

5.7. The Consent may be retracted by a written notice sent to Importex, LLC by registered mail.

5.8. When processing personal data, Importex, LLC shall take or arrange for taking of necessary legal, organizational and technical measures for protection of personal data against unlawful or accidental access thereto, destruction, alteration, blocking, copying, provision, distribution of personal data, as well as against other unlawful actions in relation to personal data.

5.9. Personal data shall be stored in a form allowing to identify a personal data subject, for the period not longer than is required by personal data processing purposes, except when the personal data storage period is established by federal laws or a contract, to which the personal data subject is a party, beneficiary or guarantor.

5.10. When storing personal data, Importex, LLC shall use databases located in the Russian Federation.


6.1. If inaccuracy of personal data or unlawfulness of its processing is confirmed, the personal data shall be updated by Importex, LLC or its processing shall be ceased, respectively.

6.2. The inaccuracy of personal data or the unlawfulness of its processing can be determined either by the User or competent public authorities of the Russian Federation.

6.3. Upon written request of the User or their representative, Importex, LLC shall provide information about the processing of personal data of the specified subject it performs. The request shall contain the number of the primary personal identification document of the User and their representative, information on the date of issue of this document and the issuance authority, information confirming User’s participation in relationship with Importex, LLC (contract number, contract date, conditional verbal designation and (or) other details), or the information otherwise confirming the fact of personal data processing by Importex, LLC, signature of the User or their representative.

6.4. If all necessary information is not reflected in the personal data subject’s request or if the subject does not have rights of access to the requested information, a substantiated refusal is sent to them.

6.5. The User has the tight to demand from Importex, LLC to update their personal data, block or destroy it if the personal data is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated processing purpose, and to take right protection measures provided by the law.

6.6. Upon achievement of the personal data processing purposes and in case of retraction of the Consent by the personal data subject, the personal data shall be destroyed, unless:

  • Importex, LLC is entitled to carry out processing without Consent of the personal data subject;

  • otherwise provided by a contract, to which the personal data subject is a party, beneficiary or guarantor;

  • otherwise is provided by other agreement between Importex, LLC and the User.


7.1. All relations in connection with personal data processing that are not reflected in this Policy, shall be governed in accordance with provision of the Russian Federation laws.

7.2. Importex, LLC has the right to amend this Policy. In case of amendment, the latest renewal date shall be indicated in the current version. The new version of the Policy shall enter into force upon its posting on the Website, unless otherwise provided by the new version of the Policy. The current version is always available on the Website at: