This Privacy Statement describes the collection, use, sharing and other processing of personally identifiable data (‘PID’, as defined below) by TC MS-Trade and its affiliates (collectively referred to as TC MS-Trade) pertaining to:
In this Privacy Statement, ‘Personally identifiable information’ or ‘PID’ means any data, a set of data, either alone or in combination with other Personally identifiable data processed by TC MS-Trade, that is sufficient to identify an individual directly or indirectly.
‘GDPR’ means the General Data Protection Regulation applicable in the EEA from May 25, 2018 onward.
Unless we specifically stipulate otherwise, TC MS-Trade is the controller of the PID data that we process, and therefore is responsible for ensuring that the systems and processes we use comply with data protection laws to the extent applicable to us.
TC MS-Trade personnel must comply with this Privacy Statement and thereto related TC MS-Trade’s personal data protection policies when working with PID, and should also be trained on data protection if it is relevant to their roles.
We may collect the following PID categories of Site visitors, customers, would-be customers, suppliers, individuals who are former, current and would-be employees and directors of TC MS-Trade and other third parties:
This information can be provided both directly by individuals/natural persons themselves and by the legal entity/person they are employed with (e.g., if they are contact persons with the management capacity of commercial relations with TC MS-Trade, vested in them by the employer).
The purposes for which we use PID and the legal basis for such processing are as follows:
We may not process PID unless we have a valid legal authority. Therefore, we process PID only if:
We may exchange PID with the following categories of recipients:
If you have questions about the parties with whom we exchange PID, please contact us at the addresses below.
When your personal data are processed by TC MS-Trade, this means that you are the data subject and you have various rights defined in the GDPR, inter alia, if you are a representative of a company established in the EEA (European Economic Area). For more information, please see the
You have the right to obtain confirmation from us as to whether personal data concerning you is being processed. If such data is processed, you may have access to the personal data and information referred to in Article 15 of the GDPR.
If personal data concerning you is inaccurate or incomplete, you have the right to have us rectify or update it without undue delay.
You have the right to request that we erase personal data concerning you without undue delay where one of the specific authorities applies and processing is not required pursuant to Art. 17 para. 3 of GDPR.
In certain circumstances, you have the right to request that we restrict processing.
Subject to the conditions referred to in the GDPR, you have the right to receive the personal data concerning you that you have provided to us in a structured, commonly used and machine-readable format and have the right to transfer this data to another controller without any hindrance from our side.
You have the right to object to the processing of personal data concerning you on authority relating to your particular situation at any time referring to (e) or (f) of Art. 6(1) GDPR. Thereafter, we will not process personal data unless we can demonstrate compelling legitimate authority for processing that overrides your interests, rights and freedoms, or to establish, exercise or defend legal claims.
If you believe that the processing of personal data concerning you breaches the GDPR, you will have the right (without prejudice to any other administrative or judicial remedy) to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement.
We have put in place technical and managerial procedures to protect the PID we maintain and control from unauthorized access, use or disclosure.
While we always strive to protect our systems, sites, operations, and information from unauthorized access, use, modification, and disclosure, due to the nature of the Internet as an open, global communications medium and other risk factors, we cannot guarantee that any information during transmission or storage in our systems will be absolutely protected from intrusion by unauthorized persons.
You also play an important role in protecting the PID. You must not share the username, password, or other authentication information handed over to you with any person, and we recommend that you do not use the same passwords on multiple websites or applications. If you have reason to believe that your username or password has been compromised, please contact us at the addresses below.
Our site may contain links to third-party sites owned and controlled by a third party independent of TC MS-Trade (“Third Party Site”). You bear all risks associated with accessing any links to or from a Third-Party Site. Your use of a Third-Party Site, or your provision of any information to such Site, is subject to the Third-Party Site’s terms and conditions for use, inter alia, those of non-disclosure, privacy, or security.
Unless otherwise agreed in writing, TC MS-Trade is in no way associated with the owner or operator of the Third-Party Site nor it is responsible for the goods or services offered thereby, or otherwise liable in connection therewith. TC MS-Trade does not accept or confirm, nor it provides any guarantees, representations or obligations in relation to the content of the Third-Party Site.
In addition to the terms and conditions of the
In case of discrepancies between the terms and conditions of this personal data protection statement/policy of TC MS-Trade and the policy of the Third-Party Site, the terms and conditions of this TC MS-Trade’s personal data protection statement/policy shall prevail.
When you visit Third-Party Sites, you acknowledge that you have read and agree to the terms and conditions of this Statement and the
We share PID into jurisdictions for the purposes described above, inter alia, those that may not offer the same level of data protection as your country of residence. In particular, some of our Sites are hosted on servers in Russia. If you are located outside of Russia, the transfer of the PID is necessary to provide you with the requested information and/or perform any requested operation. To the extent permitted by law, such provision also constitutes your consent to the cross-border transfer.
With regard to transfers originating from the European Economic Area (“EEA”) to Russia and other non-EEA jurisdictions, we apply appropriate solutions for cross-border transfers in line with the requirements and authorizations referred to in Articles 46 and 49 of the GDPR. Where required by applicable law, you may request a copy of the relevant arrangements we have in place by contacting us at the addresses below.
We will retain your PID for as long as necessary to fulfill the purposes for which we have collected it, inter alia, those to comply with any legal, accounting or reporting requirements.
The criteria we use to determine PID retention periods include: the purposes for which PID is collected, statutes of limitations on actions, storage periods required by law, applicable contractual requirements, and relevant industry standards.
We may update this