1. General Provisions
This Privacy Policy outlines the procedures for processing and protecting personal data that FXCI Limited (hereinafter referred to as the “Operator”) may obtain from users during their use of any software, services, websites, or content provided by the Operator (hereinafter referred to as the “Services”).
The Privacy Policy has been developed in accordance with the requirements of the Russian Federation’s personal data legislation and applicable regulations of the countries where FXCI operates.
2. Key Concepts
Personal Data – any information relating to an identified or identifiable individual (data subject).
Processing of Personal Data – any action or set of actions performed with personal data, including collection, recording, systematization, accumulation, storage, updating, extraction, use, transfer, anonymization, blocking, deletion, and destruction of personal data.
Operator – FXCI Limited, an organization that, independently or jointly with others, organizes and carries out the processing of personal data.
Data Subjects – individuals whose personal data is processed by the Operator.
3. Main Rights and Obligations of the Operator
Operator’s Rights:
- Independently determine the purposes, content, and methods of processing personal data;
- Entrust the processing of personal data to third parties with the consent of the subject;
- Deviation from personal data processing principles in cases provided by law;
- Carry out cross-border transfer of personal data.
Operator’s Obligations:
- Provide subjects with complete information about the purposes, methods, and terms of data processing;
- Ensure confidentiality and security in the processing of personal data;
- Take measures to eliminate violations of the law upon their detection;
- Cease processing or destroy personal data upon achieving the processing purpose;
- Respect the rights and legitimate interests of data subjects.
4. Main Rights and Obligations of Data Subjects
Data Subjects’ Rights:
- Obtain information about the processing of their personal data;
- Request clarification, blocking, or destruction of personal data if it is incomplete, outdated, or unlawfully used;
- Withdraw consent to the processing of personal data;
- Appeal the actions or inaction of the Operator in the processing of personal data.
Data Subjects’ Obligations:
- Provide accurate personal data;
- Notify of any changes to their personal data;
- Comply with the established rules for personal data processing.
5. Principles of Personal Data Processing
In the processing of personal data, FXCI is guided by the following principles:
- Legality– processing is based on compliance with laws and regulations;
- Data Minimization – only minimally necessary data is processed;
- Purpose Limitation – data is not processed for purposes incompatible with the initial purposes;
- Accuracy – reasonable measures are taken to ensure data accuracy;
- Storage Limitation – data is not stored longer than necessary;
- Integrity and Confidentiality – protection against unlawful processing.
6. Conditions for Personal Data Processing
FXCI has the right to process the personal data of subjects in the following cases:
- With the subject’s consent to the processing of their data;
- Within the framework of contractual relations with the subject to execute the contract;
- To comply with legal requirements;
- To protect the life, health, or other vital interests of subjects;
- To perform and exercise the Operator’s functions and powers;
- In other cases explicitly provided by the legislation of the Russian Federation and other countries.
Special categories of personal data (racial, ethnic origin, political views, religious and philosophical beliefs, health status, intimate life) are processed by FXCI only with the subject’s written consent.
7. Collection, Storage, Transfer, and Other Types of Processing
The personal data of subjects is processed by FXCI using databases located in the Russian Federation and other countries where the Operator’s or its partners’ data centers and servers are located. To improve efficiency and service quality, cross-border data transfer is possible based on the subject’s separately agreed consent.
FXCI has the right to entrust the processing of personal data of subjects to third parties under a contract. Persons processing personal data ensure the confidentiality and security of data during processing in accordance with Russian Federation law.
Personal data is stored on paper and electronic media using approved records management classifications, applying information protection measures and access restrictions.
Upon achieving the processing purposes, personal data is subject to destruction or anonymization if there are no other legal grounds for further processing.
8. Confidentiality of Personal Data
FXCI guarantees the confidentiality of processed personal data. Ensuring the confidentiality regime of personal data prohibits the transfer of such information to third parties without the subject’s consent or other legal grounds.
Access to subjects’ personal data is provided only to those employees or counterparties of FXCI who need this information to perform their job duties within their authority.
The company takes all reasonable organizational and technical measures to protect personal data from unlawful or accidental access, destruction, alteration, blocking, copying, dissemination, as well as from other unlawful actions.
9. Final Provisions
FXCI reserves the right to amend this Privacy Policy. When changes are made, the date of the last update is indicated in the heading.
Control over compliance with the requirements of this Policy is carried out by an employee responsible for ensuring the personal data protection regime at FXCI.
In the event of non-compliance with the provisions of the Policy, FXCI and its employees are liable in accordance with the current legislation of the Russian Federation and the terms of concluded contracts.