Personal Data Processing Policy

1. General Provisions
This Personal Data Processing Policy is prepared in accordance with the requirements of Federal Law No. 152-FZ of July 27, 2006 "On Personal Data" (hereinafter referred to as the "Personal Data Law") and determines the procedure for processing personal data and measures to ensure the security of personal data undertaken by Profi (Nanjing) Trading Co., Ltd. (hereinafter referred to as the "Operator").
1.1. The Operator's primary goal in carrying out its activities is to uphold the rights and freedoms of individuals and citizens when processing their personal data, including the protection of the rights to privacy, personal, and family secrets.
1.2. This Policy applies to all information that the Operator may obtain about visitors to the website https://profi-global.com.
2. Basic Concepts 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 processing of personal data (except when processing is necessary to clarify personal data).
2.3. Website – a collection of graphic and informational materials, as well as computer programs and databases, ensuring their availability on the internet at the network address https://profi-global.com.
2.4. Personal data information system – a set of personal data contained in databases and the information technologies and technical means ensuring their processing.
2.5. Anonymization of personal data – actions that make it impossible to determine ownership of personal data to a specific User or other personal data subject without using additional information.
2.6. Processing of personal data – any action (operation) or set of actions (operations) performed with or without the use of automation tools on personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), retrieval, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
2.7. Operator – a state body, municipal body, legal entity or individual, independently or jointly with others, organizing and/or carrying out the processing of personal data, as well as determining the purposes of processing, the composition of personal data to be processed, and the actions (operations) performed with personal data.
2.8. Personal data – any information relating directly or indirectly to a specific or identifiable User of the website https://profi-global.com.
2.9. Personal data permitted for distribution by the personal data subject – personal data to which an unrestricted circle of persons has been granted access by the personal data subject by giving consent to the processing of personal data permitted for distribution in the manner prescribed by the Personal Data Law (hereinafter referred to as "personal data permitted for distribution").
2.10. User – any visitor to the website https://profi-global.com.
2.11. Provision of personal data – actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Distribution of personal data – any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or making personal data available to an unlimited circle of persons, including publishing personal data in the media, posting in information and telecommunications networks, or providing access to personal data in any other way.
2.13. Cross-border transfer of personal data – the transfer of personal data to the territory of a foreign state to a foreign government authority, a foreign individual, or a foreign legal entity.
2.14. Destruction of personal data – any actions as a result of which personal data are irrevocably destroyed with the impossibility of further restoring the content of personal data in the personal data information system and/or the physical media of personal data are destroyed.
3. Basic Rights and Obligations of the Operator
3.1. The Operator has the right to:
· Receive from the personal data subject accurate information and/or documents containing personal data;
· If the personal data subject withdraws consent to the processing of personal data or sends a request to stop processing, the Operator has the right to continue processing without the consent of the personal data subject if there are grounds specified in the Personal Data Law;
·Independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of duties provided for by the Personal Data Law and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.
3.2. The Operator is obliged to:
· Provide the personal data subject, upon their request, with information relating to the processing of their personal data;
· Organize the processing of personal data in the manner established by the current legislation of the Russian Federation;
· Respond to inquiries and requests from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
· Notify the authorized body for the protection of the rights of personal data subjects, upon its request, of the necessary information within 10 days from the date of receipt of such request;
· Publish or otherwise provide unrestricted access to this Policy regarding the processing of personal data;
· Take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, alteration, blocking, copying, provision, distribution, as well as from other unlawful actions;
· Stop the transfer (distribution, provision, access) of personal data, stop processing, and destroy personal data in the manner and cases provided for by the Personal Data Law;
· Perform other duties provided for by the Personal Data Law.
4. Basic Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects have the right to:
· Receive information concerning the processing of their personal data, except in cases provided for by federal laws. The information is provided by the Operator in an accessible form and must not contain personal data relating to other subjects, unless there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
· Request that the Operator update, block, or destroy their personal data if it is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, as well as take measures provided by law to protect their rights;
· Impose a condition of prior consent when processing personal data for the purpose of marketing goods, works, and services;
· Withdraw consent to the processing of personal data, or send a request to stop processing;
· Appeal to the authorized body for the protection of the rights of personal data subjects or to court against unlawful actions or inaction of the Operator when processing their personal data;
· Exercise other rights provided for by the legislation of the Russian Federation.
4.2. Personal data subjects are obliged to:
· Provide the Operator with accurate data about themselves;
· Inform the Operator of any clarification (updating, change) of their personal data.
4.3. Persons who provide the Operator with false information about themselves or information about another personal data subject without the latter's consent are liable in accordance with the legislation of the Russian Federation.
5. Principles of Personal Data Processing
5.1. Processing of personal data is carried out on a lawful and fair basis.
5.2. Processing of personal data is limited to achieving specific, predetermined, and lawful purposes. Processing of personal data incompatible with the purposes of collection is not allowed.
5.3. Combining databases containing personal data processed for incompatible purposes is not allowed.
5.4. Only personal data that meet the purposes of processing are subject to processing.
5.5. The content and scope of processed personal data correspond to the stated purposes of processing. Redundancy of processed personal data in relation to the stated purposes is not allowed.
5.6. When processing personal data, the Operator ensures the accuracy, sufficiency, and, where necessary, relevance of personal data. The Operator takes necessary measures to remove or clarify incomplete or inaccurate data.
5.7. Personal data is stored in a form that allows identification of the data subject for no longer than required by the purposes of processing, unless the storage period is established by federal law or a contract to which the data subject is a party, beneficiary, or guarantor. Processed personal data is destroyed or anonymized upon achievement of processing purposes or in case of loss of the need to achieve these purposes, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing



7. Conditions for Processing Personal Data
7.1. Processing is carried out with the consent of the personal data subject.
7.2. Processing is necessary to achieve the goals provided for by an international treaty of the Russian Federation or by law, or to carry out the functions, powers, and duties assigned to the Operator by Russian legislation.
7.3. Processing is necessary for the administration of justice, execution of a judicial act, an act of another body or official, subject to execution in accordance with Russian legislation on enforcement proceedings.
7.4. Processing is necessary for the performance of a contract to which the data subject is a party, beneficiary, or guarantor, as well as for entering into a contract at the request of the data subject or a contract under which the data subject will be a beneficiary or guarantor.
7.5. Processing is necessary to exercise the rights and legitimate interests of the Operator or third parties, or to achieve socially significant goals, provided that the rights and freedoms of the data subject are not violated.
7.6. Processing is carried out for personal data to which access by an unlimited circle of persons is provided by the data subject or at their request (hereinafter referred to as "publicly available personal data").
7.7. Processing is carried out for personal data subject to publication or mandatory disclosure in accordance with federal law.
8. Procedure for Collection, Storage, Transfer, and Other Types of Processing of Personal Data
The security of personal data processed by the Operator is ensured by implementing legal, organizational, and technical measures necessary to fully comply with the requirements of current legislation in the field of personal data protection.
8.1. The Operator ensures the safety of personal data and takes all possible measures to prevent unauthorized access.
8.2. The Operator does not transfer the User's personal data to third parties, except as required by applicable law or when the data subject has given consent to the Operator to transfer data to a third party to fulfill obligations under a civil law contract.
8.3. If the User identifies inaccuracies in their personal data, they can update it independently by sending a notification to the Operator's email address Profi.trading.ch@gmail.com with the subject line "Personal Data Update".
8.4. The period for processing personal data is determined by the purposes for which it was collected, unless a different period is provided for by contract or current legislation. The User may withdraw their consent to the processing of personal data at any time by sending a notification to the Operator via email at Profi.trading.ch@gmail.com with the subject line "Withdrawal of Consent to Personal Data Processing".
8.5. All information collected by third-party services, including payment systems, communication means, and other service providers, is stored and processed by those third parties in accordance with their own user agreements and privacy policies. The personal data subject should familiarize themselves with these documents. The Operator is not responsible for the actions of such third parties.
8.6. Prohibitions on transfer (except for providing access), as well as on processing or conditions of processing (except for obtaining access) of personal data permitted for distribution, established by the data subject, do not apply in cases where processing is carried out for state, public, or other publicly beneficial interests defined by Russian legislation.
8.7. When processing personal data, the Operator ensures the confidentiality of personal data.
8.8. The Operator stores personal data in a form that allows identifying the data subject for no longer than required by the purposes of processing, unless the storage period is established by federal law or a contract to which the data subject is a party, beneficiary, or guarantor.
8.9. The termination of personal data processing may be conditioned upon achievement of the processing purposes, expiration of the data subject's consent, withdrawal of consent by the data subject, a request to stop processing, or the discovery of unlawful processing.
9. List of Actions Performed by the Operator with Obtained Personal Data
9.1. The Operator performs collection, recording, systematization, accumulation, storage, clarification (updating, changing), retrieval, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
9.2. The Operator performs automated processing of personal data with or without receiving and/or transmitting the obtained information over information and telecommunications networks.
10. Cross-Border Transfer of Personal Data
10.1. Before commencing activities related to cross-border transfer of personal data, the Operator must notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out such transfer (this notification is sent separately from the notification of the intention to process personal data).
10.2. Before submitting the aforementioned notification, the Operator must obtain relevant information from the foreign government authorities, foreign individuals, and foreign legal entities to whom the cross-border transfer of personal data is planned.
11. Confidentiality of Personal Data
The Operator and other persons who gain access to personal data are obliged not to disclose or distribute personal data to third parties without the consent of the personal data subject, unless otherwise provided for by federal law.
12. Final Provisions
12.1. The User may obtain any clarification on issues concerning the processing of their personal data by contacting the Operator via email at Profi.trading.ch@gmail.com.
12.2. 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.
12.3. The current version of the Policy is freely available on the internet at http://profi-global.com/privacy-policy.