1. General provisions
This Policy defines the procedure for processing personal data (hereinafter — PD) of visitors and clients of the website kdltrade.ru (hereinafter — the «Website») and is drafted in accordance with Federal Law No. 152-FZ of 27 July 2006 «On Personal Data».
By submitting the parts sourcing request form, the User consents to processing of the PD specified in it under the terms of this Policy. If the User does not agree with the Policy — the request should not be submitted.
This Policy applies to all information that the Operator receives from the User through Website forms, Telegram channels, email, or other means of communication listed on the Website.
2. Personal Data Operator
The Operator that decides on personal data processing is:
Name: Индивидуальный предприниматель Наливайко Олег Владимирович
Tax ID (INN): 253204515402
OGRNIP: 326253600004097
Mailing address: 692519, г. Уссурийск, ул. Плеханова, д. 14, кв. 24
Email for personal data inquiries: privacy@kdltrade.ru
3. What personal data we process
Via the parts sourcing form (/parts/request) we receive:
When the request is submitted, the User's IP address (used for spam protection and rate-limiting) and technical timestamps are also processed automatically.
VIN and body/engine numbers are not personal data within the meaning of 152-FZ; however, they are processed jointly with contact information and fall under the terms of this Policy.
- name (or first and last name — as the User specifies);
- phone number;
- email address;
- company name (optional, for wholesale clients);
- preferred contact channel (Telegram, WhatsApp, call, email);
- vehicle information (make, model, year, VIN, body or engine number);
- information about the requested part (name, OEM number, description, photos, lead-time wishes);
- any other information the User voluntarily enters in the «Description» field.
4. Purposes of processing
We do not use PD for marketing mailings or advertising targeting and do not transfer it to other parties for those purposes.
- contacting the User to clarify request parameters and agree on supply terms;
- sourcing the part with PRC suppliers and preparing a commercial offer;
- concluding and performing a supply contract (including logistics, document flow, settlements);
- internal accounting of requests and client history;
- improving the Website based on anonymized visit statistics.
5. Legal basis for processing
- User's consent, expressed by ticking the checkbox upon form submission (cl. 1 part 1 art. 6 of 152-FZ);
- conclusion and performance of a contract to which the User is a party (cl. 5 part 1 art. 6 of 152-FZ);
- performance of the Operator's obligations under the tax and accounting legislation of the Russian Federation.
6. Retention periods
PD obtained via the request form is stored until the purposes of processing are achieved or until the User withdraws consent, but in any case no longer than periods set by applicable law. For requests that resulted in a contract, the retention period is 3 years from the last interaction — corresponding to requirements of the Russian Tax Code and the general civil statute of limitations.
After the retention period expires or consent is withdrawn, PD is destroyed or anonymized within a reasonable time.
9. Rights of the personal data subject
In accordance with Article 14 of 152-FZ, the User has the right:
Requests should be sent to the email listed in section 2 with the subject «Personal Data Inquiry». We respond within 30 calendar days from receipt.
- to obtain information on which of their PD is processed, its source, and processing purposes;
- to require correction, blocking or destruction of PD if it is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose;
- to withdraw consent for PD processing at any time;
- to appeal the Operator's actions or inaction with Roskomnadzor or in court.
10. Security measures
We apply organizational and technical measures reasonable given current state of the art and the nature of processed PD: restricted access to work chats and email, storage of access keys in secure vaults, protection from automated spam (honeypot, time checks, IP rate-limit), and TLS encryption of data transfer between User and Website.
11. Changes to the Policy
The Operator may amend this Policy. The current redaction is published on this page; the date of redaction is indicated at the top of the document. By continuing to use the Website after changes are published, the User confirms agreement with the new redaction.
12. Contacts
Personal data processing inquiries and requests to exercise data subject rights should be directed to the Operator's contacts listed in section 2.
For other questions about the «Parts» section you can write on Telegram: @kdl_zapchasti.