Privacy Policy

(Last updated on 17 May 2016) (hereinafter, the “Platform”) is an electronic export sales platform primarily used by legal entities and intended to promote electronic trade; such use, as a rule, does not involve any collection of personal data of private individuals but may involve collection of personal data of private individuals registered on the Platform. The Platform is aware of the importance of privacy and the importance of maintaining confidentiality of personal data. This Privacy Policy applies to all goods and services provided by the Platform and governs the collection, use, and disclosure of any data related to the Platform Users.

The Users may receive the services of the Platform via mobile devices, mobile applications or mobile versions of the website. Such use of the Platform's goods and services is also governed by this Privacy Policy. All the capitalized terms not defined herein are defined by the Platform's Terms of Use.

A. Data Collection

User privacy is important to the Platform, therefore, the Platform has taken steps to ensure that the quantity of the data collected from a User is only sufficient for the Platform to provide the services and protect Users’ accounts.

During registration, the Platform may collect, inter alia, the following data: user name, address, phone number, fax number, e‑mail address (hereinafter, the “Registration Information”).

For the purposes of any payment-related service or transaction or services provided on the Platform and for the purposes of buyer protection, the following data, inter alia,: bank account numbers, payment details, information on delivery locations, credit/debit card numbers and their expiry dates, check and payment instruction data (hereinafter, “Banking Information”), may be collected together with other information to assist in sales and purchases, and to coordinate the purchase price of the goods and services sold or ordered on the Platform.

The Platform records and stores consumer activity details. The information related to such activity includes, inter alia, types and properties of the goods, prices, delivery information and any records of trade requests (jointly, “Activity Information”), and may be collected during sell-and-purchase transactions on the Platform.

The Platform may, from time to time, collect data on its existing and potential users at exhibitions, industry or other events. Such data collected at such events, may include, inter alia, the following: user name, address, phone number, fax number, and e‑mail address (jointly, the “Information from Events”).

The Platform records and stores the data on user activity related to buying and searching, including, inter alia, buyer’s IP-addresses, search models, conduct models. The Platform also collects statistical data, such as: users’ IP-addresses, internet browsers, operating systems, soft- and hardware, visited pages, number of visits and visitors etc. (jointly, the “Search Information”).

The Registration Information, Banking Information, Activity Information, Information from Events, and Search Information are primarily related to legal entities and hereinafter are jointly referred to as the “Commercial Information”. To the extent and only to the extent such data constitute personally identifiable data of an individual, such data are hereinafter jointly referred to as the “Personal Data”.

Users shall submit certain Commercial Data and Personal Data subject to the requirements indicated during collection. Where a user fails to submit any mandatory Commercial and/or Personal Data, the Platform will not be able to complete the registration of such user or provide it with goods or services.

B. Use of Personal Data

By submitting its Personal Data to the Platform, the User thereby confirms that it agrees that its Personal Data may be collected, stored and used for the following purposes:

•   to identify the User;

•   to confirm User’s right to register as a Platform user;
•   to process User registration in the appropriate manner, provide the User with an account to access the Platform, and maintain and manage User registration;

•   to provide the User with customer service, respond to User’s questions, feedback, claims or complaints;

•   to ensure interaction between the buyers and sellers on the Platform;

•  to carry out surveys and statistical analysis to improve the content and appearance of the Platform, improve the offer of goods and services on the Platform for promotion and marketing purposes;

•  provided that the User gives its consent in the form required by applicable law, the Platform may use the User’s name, phone number, residence address, e‑mail address and fax number (jointly, “Marketing Data”) to offer the User letters with information, surveys, information on new goods, content or advertising material related to the goods and services offered on the Platform;

•  where the User willingly provides the Platform with any information for publication on the Platform using publication tools, including, inter alia, Company Details, Sales Catalogue, Documents, the User is deemed to have given its consent that such information may be published on the Platform (hereinafter,  “Voluntary Information”); and

•   to disclose the information required for any of the above purposes or required by law, relevant to existing or potential lawsuits against the Platform.

C. Disclosure of Personal Data

The User also agrees that the Platform may disclose and submit User’s Personal Data to service providers employed by the Platform to assist in providing the User with the Platform services (including, inter alia, the following services: data input, data base management, promotion, notification on new products and services, delivery, deferral of payment, identification and authentication (hereinafter, “Service Providers”). Such Service Providers are subject to the privacy terms of the Platform and may use User’s Personal Data exclusively for the purposes above but not for their personal purposes (including direct marketing).

The User agrees that the Platform may disclose and submit User’s Personal Data for the purposes above to other affiliates of B2B-Export Group, which consists of companies that manage online and mobile international trade platforms, and provide other services.

Where necessary, the Platform may disclose and submit User’s Personal Data to its professional advisors, law enforcement agencies, insurers, governments and regulating authorities, as well as any other entities for the purposes above.

Any Personal Data submitted by the User will be saved and made available to the Platform employees, Service Providers, and third parties for the above purposes.

All Voluntary Information may be available to the public on the Platform and, therefore, is accessible by any Internet user. Any Voluntary Information disclosed by the User to the Platform becomes public information and the User waives any proprietary rights (including, inter alia, privacy rights and copyright) with regard to such information. The User shall be careful when choosing whether to include any personal or sensitive information in Voluntary Information submitted to the Platform.

The Platform may submit User’s Banking Information to banks or suppliers to ensure the execution of the User’s transactions on the Platform. Furthermore, the Platform may use User’s Banking Information to determine the User’s solvency and in doing so the Platform may require access to such Banking Information, banks or credit institutions. Though the Platform has state-of-the-art technologies and internal procedures to protect User’s Banking Information from third party interference, the Platform does not guarantee that such technologies and procedures eliminate all the risks related to theft, loss or illegal use.

The Platform may submit statistical information to third parties but in doing so it does not submit any identifiable Personal Data without the User’s consent.

The Platform has relationships with third parties in order to offer the User the benefits of the goods and services that the Platform does not provide. The Platform provides the Users with access to such third parties and their web sites either through the links to such web sites published on the Platform, or by providing access to joint websites where the Platform, jointly with third parties, uses a unified resource index, domain name or page within an Internet domain.

In some cases, the User is required to provide Personal Information to register or order goods and services supplied by such third parties or partners. This Privacy Policy does not apply to such third party websites or joint electronic resources. Third party privacy policies may differ from the Privacy Policy of the Platform, and the Platform does not control the information that the User submits to such third parties. The User shall read such relevant third party privacy policies carefully.

D. Access/Personal Data Correction Rights

Subject to applicable law, the User may access the personal data stored on the Platform and require that such data be corrected. 
Where a User has any questions regarding this Privacy Policy or where the User wishes to access or correct its Personal Data, the User may send a written request to the Platform at: Office 20, Novinsky Blvd. 25/1, Moscow.

E. Cookies

The Platform uses cookies to store certain User information and track its visits to the Platform. Use of cookies is a usual practice of the internet Platform in order to improve its user identification.

Cookies are a small amount of data sent to the User’s Internet browser and stored on the hard disk of its computer. Unless the User blocks or deletes the cookies, each time the User accesses the Platform from the same computer, the Platform web servers will be notified of the User’s access to the Platform, and the Platform will receive the User’s visit data and usage model.

As a rule, the Platform uses cookies to identify the User and enable the Platform in order to: 1) provide access to the User’s Registration Information or Banking Information to avoid recurrent input by the User; 2) collect statistical information on usage; 3) examine visit models and assist with aligning advertisements with the User’s interests; 4) help Platform’s partners track visits to the Platform and process orders; and 6) track progress and participation in advertising campaigns.

The User may define how and when to accept cookies by setting up the internet browser options installed on the computer used by the User to access the Platform. The user may always changes such settings as it so wishes. By setting up its browser options, the User may accept all the cookies or prefer to be notified that cookies have been sent to User’s internet browser, or the User may reject all the cookies. Where the User rejects all the cookies by choosing the relevant cookies blocking option in its browsers, the User may have to re-enter its information on the Platform more frequently and some services may be unavailable to the User.

F. Under-age Individuals

The Platform and its contents are not intended for use by under-age persons (individuals below the age of 18), and the Platform does not intend to sell any goods or services to such persons. Nevertheless, the Platform is unable to define the age of the Platform visitors. Where an under-age person submits its personal information to the Platform without parents’ or legal guardians' consent, such parents or legal guardians shall contact the Platform’s Legal Department using the address indicated in Section D hereof, to remove such information.

G. Security Measures

The Platform uses commercially reasonable security measures to prevent unauthorized access, maintain the correctness of the stored data and ensure the correct use of the information stored on the Platform.
Registered users of the Platform may view and edit Registration and Banking Information via their password protected accounts. We strongly recommend that you never disclose your User password to anyone. Platform employees will never request that a User provide its password via unsolicited calls or e‑mails. Where the User uses a computer jointly with another person, the User should not store the login information (such as user name and password) on this computer. The User shall remember to log out of its account and close the browser window on completion of its browsing session. 

No single transfer of data via the Internet or wireless networks may be fully safe. Therefore, despite the Platform’s efforts to protect the information stored for the User, the Platform cannot guarantee secure data transfer and the User assumes all the risks related to such transfer.

H. Modifications to This Privacy Policy

Any changes hereto will be notified to the User by publishing additions to or new version of the Security Policy on the Platform. A new Security Policy enters into force immediately upon being published on the Platform. The User confirms that the latest version of the Security Policy will govern all the issues related to any User data stored on the Platform (as described in this Privacy Policy whether collected prior to or after the effective date of the new security policy).

I. User Feedback

The Platform welcomes Users’ contributions to the Security Policy of the Platform and any comments regarding the services provided by the Platform. Users may send their comments and feedback to: Office 20, Novinsky Blvd., 25/1, Moscow.