Privacy Policy

Effective as of December 27, 2023

1. General Provisions

This Personal Data Processing Policy (hereinafter referred to as the Policy or the Privacy Policy) is compiled in accordance with the requirements of Federal Law No. 152–FZ dated 27.07.2006 "On Personal Data" and defines the procedure for processing personal data and measures to ensure the security of personal data of AvantaTrading, LLC (hereinafter referred to as the Operator).

1.1 The operator sets as its most important goal and condition for the implementation of its activities the observance of the rights and freedoms of man and citizen in the processing of their personal data, including protection of the rights to privacy, personal and family secrets.

1.2 This Operator's Policy regarding processing of personal data shall apply to all information that the Operator may receive about visitors to the Website

1.3 This Policy is incorporated by reference into the User Agreement of the Website, posted at

2. Basic concepts used in the Policy

2.1 Automated processing of personal data – processing of personal data using computer technology;

2.2 Blocking of personal data – temporary termination of processing of personal data (except in cases where processing is necessary to clarify personal data);

2.3 The Website is a collection of graphic and informational materials, as well as computer programs and databases that ensure their availability on the Internet at:;

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 shall mean actions as a result of which it is impossible to determine, without the use of additional information, the identity of personal data to a specific User or other subject of personal data;

2.6 Personal data processing shall mean any action (operation) or set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data;

2.7 The Operator shall mean a state body, municipal body, legal entity or an individual, independently or jointly with other persons organizing and (or) processing personal data, as well as determining the purposes of processing personal data, the composition of personal data to be processed, actions (operations) performed with personal data;

2.8 The Personal Data shall mean any information related directly or indirectly to a specific or identifiable User of the Website;

2.9 The User shall mean any visitor to Website;

2.10 The Account (User Account) shall mean an account containing the information necessary to identify the User when connecting to the system, the information for authorization and accounting. This is the user ID (login, e-mail) and the User's password.

2.11 Provision of personal data shall mean actions aimed at disclosure of personal data to a certain person or a certain circle of persons;

2.12 Dissemination of personal data shall mean any actions aimed at disclosure of personal data to an indefinite circle of persons (transfer of personal data) or familiarization with personal data of an unlimited circle of persons, including publication of personal data in the media, posting in information and telecommunications networks or providing access to personal data in any other way;

2.13 Cross–border transfer of personal data shall mean transfer of personal data to the territory of a foreign state to the authority of a foreign state, a foreign individual or a foreign legal entity;

2.14 Destruction of personal data shall mean any actions as a result of which personal data is permanently destroyed with the impossibility of further restoration of the content of personal data in the personal data information system, and (or) as a result of which the material carriers of personal data are destroyed.

3. The Operator may process the following personal data of the User:

3.1 Name;

3.2 Email address;

3.3 Year, month, date of birth;

3.4 Photos;

3.5 Country, city of residence;

3.6 Presence/absence of the diagnosis of "atopic dermatitis";

3.7 The Website also collects and processes anonymous data about visitors (including cookies) using Internet statistics services (Yandex Metrika and Google Analytics and others).

3.8 The above data, hereinafter referred to in the text of the Policy, are combined by the general concept of Personal Data.

4. Purposes of personal data processing

4.1 The purpose of processing the User's personal data is to inform the User by sending emails; to provide the User with access to services, information and/or materials contained on the Website.

4.2 The Operator also shall have the right to send information letters to the User, including notifications about new products and services, special offers and various events. The User can always refuse to receive information messages by sending an email to the Operator marked "Withdrawal of consent to receive information letters".

4.3 The Users' depersonalized data collected using Internet statistics services are used to collect information about the User's actions on the Website, improve the quality of the Website and its content.

5. Legal grounds for processing personal data

5.1 The Operator processes the User's personal data only if they are filled in and/or sent by the User independently through special forms located at . By filling out the appropriate forms and/or sending their personal data to the Operator, the User agrees with this Policy.

5.2 The Operator processes depersonalized data about the User, if this is allowed in the User's browser settings (the saving of cookies and the use of JavaScript technology are enabled).

6. Procedure for collection, storage, transfer and other types of personal data processing

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 applicable legislation in the field of personal data protection.

6.1 The Operator shall ensure the safety of personal data and take all possible measures to exclude access to the personal data by unauthorized persons.

6.2 The User's personal data shall never, under any circumstances, be transferred to third parties, except in cases related to implementation of the applicable legislation.

6.3 In case of identification of inaccuracies in personal data, the User can update them independently by sending a notification to the Operator to the Operator's email address marked "Personal Data Update", or by making changes to the relevant forms at

6.4. The period for processing personal data is unlimited. The Users can withdraw their consent to processing of personal data at any time by sending a notification to the Operator via e-mail to the Operator's e-mail address marked "Withdrawal of consent to personal data processing". However, in case of withdrawal of consent or deletion of personal data, the Operator cannot guarantee high-quality and comprehensive provision of information and/or services, and it shall have the right to delete the User's Account unilaterally.

7. Cross-border transfer of personal data

7.1 Before the start of the cross-border transfer of personal data, the Operator shall make sure that the foreign state to which territory the transfer of personal data is supposed to be carried out provides reliable protection of the rights of personal data subjects.

7.2 The cross-border transfer of personal data on the territory of foreign states that do not meet the above requirements may be carried out only if the personal data subject has written consent to the cross-border transfer of their personal data and/or the execution of the contract to which the personal data subject is a party.

8. Final Provisions

8.1 The User can receive any clarifications on issues of interest concerning processing of their personal data by contacting the Operator via e-mail

8.2 This document will specify any changes to the Operator's personal data processing policy. The policy shall be valid indefinitely until it is replaced by a new version.

8.3 The Operator reserves the right to unilaterally change this Policy at its discretion. The Operator does not notify users of a change in the Policy.

8.4 The current version of the Policy is freely available at