Version of 19 August 2026
1. General provisions
This is a translation provided for convenience. The Russian version of this document, published at gmeurasia.com, is the legally binding one; in case of any discrepancy, the Russian text prevails.
1.1. This Privacy Policy (the “Policy”) sets out how personal data is processed and secured by Golden Min Import LLC (the “Operator”) and is issued pursuant to clause 2, part 1, article 18.1 of Federal Law No. 152-FZ of 27 July 2006 “On Personal Data” of the Russian Federation.
1.2. The Operator: Golden Min Import LLC, registration number (OGRN) 1202300033242, tax number (INN) 2315216920, registered address: 8 Kutuzovskaya Street, unit 2, Novorossiysk 353907, Russia. For any question about personal data: info@gmeurasia.com, phone +7 988 765-38-27.
1.3. The Policy covers personal data the Operator receives from visitors of gmeurasia.com, as well as through correspondence, phone calls and the performance of contracts.
1.4. The current version is published at https://gmeurasia.com/ru/legal/politika-konfidencialnosti/ and is available to anyone without restriction.
1.5. Using the site and sending a request mean that the visitor has read this Policy. Consent to the processing of personal data is given by a separate act — by ticking the box in the request form.
2. What personal data is processed
2.1. When a request is sent through the site, the Operator processes what the visitor provides: name, company name, phone number, email address, messenger handle, the description of the job and whatever is contained in the files attached to the request.
2.2. Automatically, on any visit: IP address, date and time of the request, browser and operating system details, and the address of the page the request was sent from. This is used solely to protect the site from automated submissions and to investigate failures.
2.3. The Operator does not process special categories of personal data (racial or ethnic origin, political opinions, religious or philosophical beliefs, health, sex life) or biometric personal data.
2.4. The site is not addressed to persons under 18, and the Operator does not knowingly collect their data. Any such data found is deleted.
2.5. The visitor is responsible for ensuring that files attached to a request contain no personal data of third parties that they have no legal basis to share.
3. Purposes of processing
3.1. Reviewing the request and preparing a reply, a cost estimate and a commercial proposal.
3.2. Contacting the visitor through the channels they provided, about the substance of their enquiry.
3.3. Entering into and performing a contract to which the data subject is a party, including purchasing, shipping, customs clearance and settlements.
3.4. Protecting the site from automated submissions and abuse.
3.5. Meeting obligations imposed on the Operator by Russian law, including tax, accounting, currency control and customs legislation.
3.6. The Operator does not use personal data for marketing mailings, profiling, or decisions based solely on automated processing.
4. Legal grounds
4.1. Consent of the data subject to the processing of their personal data (clause 1, part 1, article 6 of Federal Law No. 152-FZ).
4.2. Necessity for the performance of a contract to which the data subject is a party, and for entering into a contract at their initiative (clause 5, part 1, article 6).
4.3. Necessity for compliance with the Operator’s legal obligations (clause 2, part 1, article 6).
4.4. The Operator’s legitimate interest in protecting the site and its infrastructure, provided this does not override the rights and freedoms of the data subject (clause 7, part 1, article 6).
5. How processing is carried out
5.1. Processing includes collection, recording, systematisation, accumulation, storage, updating, retrieval, use, transfer (provision, access), blocking, deletion and destruction of personal data.
5.2. Processing is carried out both by automated means and without them.
5.3. Recording, systematisation, accumulation, storage, updating and retrieval of personal data of Russian citizens are carried out using databases located within the Russian Federation (part 5, article 18 of Federal Law No. 152-FZ).
5.4. The Operator does not take decisions producing legal effects concerning the data subject based solely on automated processing.
6. Retention periods
6.1. Personal data is kept no longer than the purposes of processing require.
6.2. A request that does not lead to a contract is kept for one year from the last contact — the length of a normal cross-border trade cycle, within which a visitor usually returns to a job they postponed.
6.3. Data related to the performance of a contract is kept for the term of the contract and five years after it is completed, as required by accounting and currency control legislation.
6.4. Server logs are kept for no longer than six months.
6.5. If consent is withdrawn, personal data is destroyed within thirty days, except where the law requires the Operator to keep it.
7. Sharing with third parties
7.1. The Operator does not sell personal data and does not share it for advertising purposes.
7.2. Personal data may be shared with the providers of the site hosting and email services, to the extent needed for the site to work, under confidentiality terms.
7.3. In the course of performing a contract, personal data may be shared with parties engaged to perform it: carriers, freight forwarders, customs brokers, insurers and banks — to the extent needed for shipping, clearance and settlement.
7.4. Personal data is provided to state authorities on the grounds and in the manner prescribed by Russian law.
7.5. Everyone the Operator shares personal data with undertakes to keep it confidential and secure.
8. Cross-border transfer
8.1. The Operator’s business is international trade and freight, so in the course of performing a contract personal data may be transferred to counterparties located abroad, including in the People’s Republic of China, the European Union and the CIS countries.
8.2. Only the minimum needed is transferred: the name and contact details of the person receiving the cargo, and the details required for shipping and customs documents.
8.3. Cross-border transfers are carried out in accordance with article 12 of Federal Law No. 152-FZ. Before any such transfer the Operator notifies the Russian data protection authority and, where the law requires it, obtains separate consent from the data subject.
9. Security measures
9.1. A person responsible for organising the processing of personal data has been appointed.
9.2. Access to personal data is granted only to employees who need it to do their job.
9.3. Traffic between the visitor’s browser and the site is encrypted (HTTPS).
9.4. Files attached to a request are stored outside the public directory of the site and cannot be reached by a direct link.
9.5. Backups are kept so that data can be restored if it is accidentally altered or destroyed.
9.6. The organisational and technical measures required by articles 18.1 and 19 of Federal Law No. 152-FZ are applied, including an assessment of the harm that could be caused to data subjects and monitoring of the measures taken.
10. Rights of the data subject
10.1. The data subject has the right to obtain information about the processing of their personal data: confirmation that processing takes place, the legal grounds and purposes, the methods used, the periods of processing and storage, and who the data may be shared with.
10.2. The data subject has the right to require that their personal data be updated, blocked or destroyed if it is incomplete, outdated, inaccurate, unlawfully obtained, or no longer necessary for the stated purpose.
10.3. The data subject may withdraw consent to the processing of personal data at any time.
10.4. To exercise these rights it is enough to write to info@gmeurasia.com or by post to the Operator’s address in clause 1.2. The Operator replies within thirty days of receiving the request.
10.5. The data subject may lodge a complaint about the Operator with the Federal Service for Supervision of Communications, Information Technology and Mass Media (Roskomnadzor) or bring a claim in court.
11. Cookies
11.1. The site uses only the technical cookies needed for the request form to work. No advertising or analytics cookies are used.
11.2. The details are set out in the Cookie policy published on the site.
12. Changes to this Policy
12.1. The Operator may amend this Policy. A new version is published on the site and takes effect when it is published.
12.2. The version date is given at the top of the document. Earlier versions are available on request to info@gmeurasia.com.