Privacy Notice

This Privacy Notice (the “Notice”) explains how ООО "Караван" (“Karavan”, “we”, “our”) collects, uses and protects personal data of visitors to https://karavan-ved.ru (the “Website”), our clients and any other individuals whose information becomes available to us in the course of our advisory work.

The Notice has been prepared in accordance with Federal Law No. 152-FZ of 27 July 2006 “On Personal Data” and other applicable Russian legislation. It applies to all processing operations carried out by Karavan, whether automated or manual.

By using the Website you confirm that you have read this Notice and accept the processing of your personal data on the terms set out below.

The following terms are used throughout this Notice:

Personal data

any information relating, directly or indirectly, to an identified or identifiable natural person.

Processing

any operation performed with personal data, including collection, recording, storage, use, transfer, anonymisation, blocking and erasure.

Operator

ООО "Караван" acting as the controller of the personal data processed under this Notice.

User

any individual visiting the Website or submitting an enquiry through the forms made available on it.

We process personal data on the basis of the following principles:

• lawfulness and fairness of processing;
• collection only for specified, predetermined and legitimate purposes;
• adequacy of the data collected to the purposes pursued;
• accuracy of data and their relevance to the stated purposes;
• retention no longer than required by the relevant purpose and by law;
• confidentiality and security at every stage of processing.

We process personal data exclusively for the following purposes:

• handling enquiries submitted through the Website and preparing a substantive response;
• negotiating, concluding and performing engagements relating to advisory and execution support in cross-border trade and international payments;
• maintaining business correspondence and operational coordination on current and prospective matters;
• complying with applicable tax, currency-control, accounting and anti-money-laundering requirements;
• maintaining the technical operation of the Website and analysing aggregated traffic statistics.

We do not use personal data to take decisions producing legal effects on the basis of automated processing alone.

Within the purposes set out above, we may process the following categories of data:

• full name (first name, family name, patronymic where applicable);
• company name and position;
• email address, telephone number, messenger handle (Telegram, WhatsApp);
• information voluntarily provided in the contact form or correspondence: description of the situation, country and currency of settlement, and other context required to assess your matter;
• de-identified technical information: IP address, device and browser type, referring source, pages visited and time of visit.

We do not request or process special categories of personal data or biometric data.

We process personal data on the following legal grounds:

• consent given by the data subject through submission of a form or another active action on the Website;
• conclusion and performance of an agreement to which the data subject is a party, or pre-contractual steps taken at the data subject’s request;
• compliance with statutory obligations imposed on Karavan by Russian law;
• protection of our legitimate interests in conducting business communication and operating the Website.

Processing is carried out by both automated and non-automated means on servers located within the Russian Federation, under conditions that prevent access by unauthorised persons.

Data retention periods are aligned with the underlying purpose:

• data submitted via Website forms: until the purpose of the enquiry is fulfilled and for 12 months after the last contact;
• data of clients and counterparties: for the term of the engagement and for five years after its termination, unless a longer period is required by law;
• aggregated analytics: stored in de-identified form without a fixed retention period.

Once retention periods expire, the relevant purpose is fulfilled, or consent is withdrawn, the data is destroyed or anonymised in accordance with our internal procedures.

We do not disclose personal data to third parties except where such disclosure is necessary to achieve the stated purposes and is carried out in accordance with applicable law.

Recipients of the data may include:

• service providers engaged by Karavan (hosting, email infrastructure, accounting and legal advisers) — on the basis of agreements containing confidentiality obligations;
• state authorities, banks and other authorised bodies — in the cases and in the manner provided by law;
• our counterparties — to the extent necessary to perform arrangements with the data subject and only with their knowledge.

We do not carry out cross-border transfers of personal data received through the Website contact forms. External content management and database services are used solely to host and administer public Website content and are not intended for storing personal data of users.

The Website uses cookies and similar technologies to ensure proper functioning, retain language and user preferences, and collect aggregated traffic statistics.

A detailed description of the cookies used, their categories and the way you can manage them is set out in our separate Cookie Policy.

In relation to your personal data you have the right to:

• request information about the processing of your data and confirmation that such processing takes place;
• request the correction, blocking or deletion of data that is incomplete, inaccurate or no longer relevant;
• withdraw your consent to processing at any time;
• lodge a complaint with the Federal Service for Supervision of Communications, Information Technology and Mass Media (Roskomnadzor) or in court.

Requests should be sent to info@karavan-ved.ru together with information sufficient to identify you. We respond to verified requests within thirty days of receipt.

The Operator implements organisational and technical measures to protect personal data from unauthorised access, alteration, disclosure, blocking or destruction. Personal data submitted through the Website is processed using services and communication channels that ensure storage and processing of such data within the territory of the Russian Federation, together with the necessary organisational and technical safeguards.

The measures applied include, in particular:

• appointment of a person responsible for personal data processing;
• access controls based on staff role and necessity;
• use of secure channels and encryption for data transmission;
• regular review of protection mechanisms and incident response procedures.

We may update this Notice from time to time. The current version is always available at https://karavan-ved.ru/en/privacy. The effective date is shown at the top of the document. Continued use of the Website after the changes take effect constitutes acceptance of the updated Notice.

For any question relating to the processing of personal data or to exercise your rights, please contact us using one of the channels below:

• email: info@karavan-ved.ru;
• telephone: +7 922 550-22-12.