1. General provisions
This Personal Data Processing Policy (hereinafter — the "Policy") is developed in accordance with Federal Law № 152-FZ of 27 July 2006 "On Personal Data" and defines the procedure for processing personal data of users of the VDole investment platform (hereinafter — the "Platform", the "Service").
The personal data operator is the owner of the Platform (hereinafter — the "Operator"). By using the Service, you confirm that you have read this Policy and agree with the terms of processing of your personal data.
2. Categories of data processed
The Operator processes the following categories of personal data:
- identification data: surname, first name, patronymic, date of birth;
- contact data: email address, phone number;
- verification data: taxpayer ID (INN), details of identity documents (to confirm legal capacity for transactions);
- external account data during OAuth sign-in (Google, Yandex, VK, Mail.ru, Telegram, MAX): identifier, name, email, profile picture;
- technical data: IP address, device type, browser, activity timestamps, authentication logs;
- financial data: payout and dividend bank details, transaction history on escrow accounts.
3. Purposes of processing
- user registration and identification on the Platform;
- performance of obligations in transactions between entrepreneurs (agents) and investors (contragents);
- escrow settlement and automatic dividend payouts;
- compliance with Russian Federation legislation (tax accounting, anti-money laundering);
- notifying users about changes in the Service and investment products;
- ensuring Platform security and fraud prevention.
4. Legal grounds
Personal data is processed on the basis of consent of the data subject (Art. 6 part 1 of 152-FZ), performance of a contract to which the subject is a party (Art. 6 part 5 of 152-FZ), and to fulfil obligations imposed on the Operator by Russian Federation law.
5. Transfer to third parties
The Operator does not transfer personal data to third parties, except where necessary for:
- executing transactions between agents and contragents on the Platform;
- performing settlements through the acquiring bank and escrow agent;
- preparing tax reporting for the Federal Tax Service of Russia (ФНС);
- responding to lawful requests from government authorities.
6. Data storage and protection
Personal data is stored on servers located in the Russian Federation, in accordance with Art. 18 part 5 of 152-FZ. The Tantor DBMS (FSTEC certificate) is used to meet personal data protection requirements.
Data is retained no longer than necessary to achieve processing purposes, or as prescribed by Russian Federation law. After processing ends, data is destroyed or anonymised.
Data protection measures include:
- HTTPS connection encryption (TLS 1.3);
- HMAC-signed session tokens with the httpOnly flag;
- role-based access control and admin action logs;
- regular backups and security event monitoring.
7. Rights of the data subject
Under Art. 14 of 152-FZ you have the right to:
- obtain information on the fact and composition of the data being processed;
- request correction, blocking, or deletion of data;
- withdraw consent to processing at any time;
- appeal the Operator's actions to Roskomnadzor or the courts.
Requests should be sent to info@vdole.it-joy.ru. A response will be provided within 30 days.
8. Cookies and technical data
The Platform uses cookies to maintain user sessions (HttpOnly, SameSite=Strict), to save interface settings, and to collect anonymised visit statistics through Yandex.Metrica. You may disable cookies in your browser settings — this may limit Service functionality.
9. Changes to the Policy
The Operator may amend this Policy. The current version is always available at /en/privacy. Material changes are communicated to users by email or via a notification in their dashboard.
10. Contacts
Questions regarding personal data processing should be sent to info@vdole.it-joy.ru.