Privacy Policy

1. General Provisions
This personal data processing policy has been developed in accordance with the requirements of the Federal Law No. 152-FZ "On Personal Data" dated 27.07.2006 (hereinafter referred to as the Personal Data Law) and defines the procedure for processing personal data and measures to ensure the security of personal data undertaken by LATAMMERCADO SRL de SV (hereinafter referred to as the Operator).
1.1. The Operator considers the observance of human and civil rights and freedoms in the processing of personal data, including the protection of the right to privacy, personal and family secrets, as a key objective and condition for carrying out its activities.
1.2. This Policy regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator may obtain about visitors to the website http://latammercado.com/.

2. Key Terms Used in the Policy
2.1. Automated Processing of Personal Data — the processing of personal data using computer technology.
2.2. Blocking of Personal Data — the temporary cessation of personal data processing (except when processing is necessary for the clarification of personal data).
2.3. Website — a collection of graphical and informational materials, as well as software and databases, ensuring their availability on the internet at the network address http://latammercado.com/.
2.4. Personal Data Information System — a set of personal data contained in databases and information technologies and technical means that ensure their processing.
2.5. Depersonalization of Personal Data — actions that result in the impossibility of determining the identity of personal data to a specific User or other subject of personal data without the use of additional information.
2.6. Processing of Personal Data — any action (operation) or a set of actions (operations) performed with or without the use of automation tools with personal data, including the collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
2.7. Operator — a state body, municipal body, legal entity, or individual that, independently or jointly with other persons, organizes and/or carries out the processing of personal data, as well as determines the purposes of personal data processing, the composition of personal data to be processed, and actions (operations) performed with personal data.
2.8. Personal Data — any information related directly or indirectly to an identified or identifiable User of the website http://latammercado.com/.
2.9. Personal Data Permitted by the Subject of Personal Data for Distribution — personal data that the subject of personal data has consented to make available to an unlimited number of persons in the manner prescribed by the Personal Data Law (hereinafter — personal data permitted for distribution).
2.10. User — any visitor to the website http://latammercado.com/.
2.11. Provision of Personal Data — actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Distribution of Personal Data — any actions aimed at disclosing personal data to an undefined group of persons (transfer of personal data) or at making personal data available to an unlimited number of persons, including publicizing personal data in the media, placing it in information and telecommunication networks, or providing access to personal data in any other way.
2.13. Cross-Border Transfer of Personal Data — the transfer of personal data to the territory of a foreign state, a foreign state authority, a foreign individual, or a foreign legal entity.
2.14. Destruction of Personal Data — any actions that result in the irreversible destruction of personal data with no possibility of further recovery of the content of personal data in the personal data information system and/or the destruction of tangible personal data storage media.

3. Main Rights and Obligations of the Operator
3.1. The Operator has the right to:

• Obtain accurate information and/or documents containing personal data from the subject of personal data;
• Continue processing personal data without the consent of the subject of personal data if the subject withdraws consent for processing or submits a request for the cessation of personal data processing, provided there are grounds specified in the Personal Data Law;
• Independently determine the composition and list of measures necessary and sufficient to ensure compliance with the obligations provided by the Personal Data Law and related regulatory legal acts, unless otherwise stipulated by the Personal Data Law or other federal laws.

3.2. The Operator is obligated to:

• Provide the subject of personal data, upon request, with information regarding the processing of their personal data;
• Organize the processing of personal data in accordance with the current legislation of the Russian Federation;
• Respond to inquiries and requests from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
• Provide the authorized body for the protection of the rights of personal data subjects with the necessary information within 10 days from the date of receiving such a request;
• Publish or otherwise provide unrestricted access to this Policy regarding the processing of personal data;
• Take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, distribution, as well as from other unlawful actions concerning personal data;
• Cease the transfer (distribution, provision, access) of personal data, halt processing, and destroy personal data in the manner and cases provided for by the Personal Data Law;
• Fulfill other obligations as prescribed by the Personal Data Law.

4. Main Rights and Obligations of Personal Data Subjects
4.1. Personal Data Subjects have the right to:

• Obtain information regarding the processing of their personal data, except in cases provided for by federal laws. The information is provided to the personal data subject by the Operator in an accessible form and should not contain personal data related to other personal data subjects, unless there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
• Request the Operator to clarify, block, or destroy their personal data if the data is incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the stated purpose of processing, as well as to take legal measures to protect their rights;
• Set a condition for prior consent when processing personal data for the purpose of promoting goods, works, and services on the market;
• Withdraw consent to the processing of personal data and submit a demand to cease the processing of personal data;
• File a complaint with the authorized body for the protection of personal data subjects' rights or in court against unlawful actions or inactions of the Operator during the processing of their personal data;
• Exercise other rights provided by the legislation of the Russian Federation.

4.2. Personal Data Subjects are obligated to:

• Provide the Operator with accurate information about themselves;
• Inform the Operator of any clarification (updates, changes) to their personal data.

4.3. Persons who provide the Operator with inaccurate information about themselves or information about another personal data subject without that subject's consent are liable in accordance with the legislation of the Russian Federation.

5. Principles of Personal Data Processing
5.1. Personal data processing is carried out on a lawful and fair basis.
5.2. The processing of personal data is limited to the achievement of specific, predetermined, and lawful purposes. The processing of personal data that is incompatible with the purposes of collecting personal data is not permitted.
5.3. The merging of databases containing personal data, where the processing is carried out for purposes that are incompatible with each other, is not allowed.
5.4. Only personal data that meets the purposes of its processing is subject to processing.
5.5. The content and scope of the processed personal data correspond to the stated purposes of processing. Excessive personal data in relation to the stated purposes of its processing is not permitted.
5.6. When processing personal data, the accuracy of personal data, its sufficiency, and, where necessary, its relevance to the purposes of personal data processing are ensured. The Operator takes necessary measures and/or ensures that they are taken to delete or clarify incomplete or inaccurate data.
5.7. Personal data is stored in a form that allows identifying the personal data subject for no longer than the purposes of personal data processing require, unless a longer storage period is established by federal law, a contract to which the personal data subject is a party, beneficiary, or guarantor. Processed personal data is destroyed or depersonalized upon achieving the purposes of processing or if there is no longer a need to achieve these purposes unless otherwise provided by federal law.

6. Purposes of Personal Data Processing

• Purpose of Processing: Informing the User by sending emails.
• Personal Data
• Legal Basis: Federal Law "On Information, Information Technologies, and Information Protection" dated 27.07.2006 No. 149-FZ.
• Types of Personal Data Processing: Transmission of personal data.

7. Conditions for Personal Data Processing
7.1. The processing of personal data is carried out with the consent of the personal data subject to the processing of their personal data.
7.2. The processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, to fulfill the functions, powers, and obligations imposed on the Operator by the legislation of the Russian Federation.
7.3. The processing of personal data is necessary for the administration of justice, the execution of a judicial act, or an act of another authority or official to be enforced in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. The processing of personal data is necessary for the performance of a contract to which the personal data subject is a party, beneficiary, or guarantor, as well as for the conclusion of a contract at the initiative of the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor.
7.5. The processing of personal data is necessary for the exercise of the rights and legitimate interests of the Operator or third parties or to achieve socially significant goals, provided that this does not violate the rights and freedoms of the personal data subject.
7.6. The processing of personal data is carried out for personal data that has been made publicly available by the personal data subject or at their request (hereinafter referred to as publicly accessible personal data).
7.7. The processing of personal data is carried out for personal data subject to publication or mandatory disclosure in accordance with federal law.

8. Procedure for Collecting, Storing, Transferring, and Other Types of Personal Data Processing
The security of personal data processed by the Operator is ensured through the implementation of legal, organizational, and technical measures necessary to fully comply with the requirements of the current legislation in the field of personal data protection.
8.1. The Operator ensures the confidentiality of personal data and takes all possible measures to prevent unauthorized access to personal data.
8.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to compliance with applicable law or if the personal data subject has given consent to the Operator to transfer data to a third party to fulfill obligations under a civil law contract.
8.3. If inaccuracies in personal data are identified, the User can update them independently by sending a notification to the Operator via email at hola@latammercado.com with the subject line "Personal Data Update."
8.4. The period of personal data processing is determined by the achievement of the purposes for which the personal data was collected unless a different period is provided by contract or applicable law. The User may revoke their consent to the processing of personal data at any time by sending a notification to the Operator via email at hola@latammercado.com with the subject line "Revocation of Consent to Personal Data Processing."
8.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by those entities (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject must familiarize themselves with these documents. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this clause.
8.6. Restrictions imposed by the personal data subject on the transfer (excluding provision of access) or processing conditions (excluding access) of personal data permitted for distribution do not apply in cases of processing personal data in state, public, and other public interests as defined by the legislation of the Russian Federation.
8.7. The Operator ensures the confidentiality of personal data during its processing.
8.8. The Operator stores personal data in a form that allows identifying the personal data subject for no longer than required by the purposes of personal data processing, unless a longer storage period is established by federal law, a contract to which the personal data subject is a party, beneficiary, or guarantor.
8.9. The condition for the termination of personal data processing may include the achievement of the personal data processing purposes, the expiration of the consent given by the personal data subject, the revocation of consent by the personal data subject, a request to cease personal data processing, or the detection of unlawful personal data processing.

9. List of Actions Performed by the Operator with the Received Personal Data
9.1. The Operator performs the collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
9.2. The Operator carries out automated processing of personal data with the receipt and/or transmission of the obtained information through information and telecommunication networks or without such networks.

10. Cross-Border Transfer of Personal Data
10.1. Before commencing activities related to the cross-border transfer of personal data, the Operator is required to notify the authorized body for the protection of personal data subjects' rights of its intention to carry out such a transfer (this notification is submitted separately from the notification of intent to process personal data).
10.2. Prior to submitting the aforementioned notification, the Operator must obtain relevant information from the foreign state authorities, foreign individuals, or foreign legal entities to whom the cross-border transfer of personal data is planned.

11. Confidentiality of Personal Data
The Operator and other persons who have gained access to personal data are obligated not to disclose or distribute the personal data to third parties without the consent of the personal data subject, unless otherwise provided by federal law.

12. Final Provisions
12.1. The User can obtain any clarifications on questions of interest regarding the processing of their personal data by contacting the Operator via email at hola@latammercado.com.
12.2. Any changes to the Operator's personal data processing policy will be reflected in this document. The policy is effective indefinitely until it is replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet at http://latammercado.com/policy-en.