Privacy Policy

1. Controller

The data controller is SFERA LLC, INN 9715479324, OGRN 1247700281685, registered office Dezhnev Passage 1/2-1, 127081 Moscow, Russian Federation. Contact for privacy enquiries: sales@sfera-rusexport.ru with subject line "Privacy enquiry".

2. Data we collect

We collect the following categories of personal data:

• Contact data — name, work email, phone, country, company name, voluntarily submitted via our public forms (LOI, Consultation, Buyer Registration, Partner Application).
• KYC data — for verified buyers and partners, company registration documents, beneficial ownership disclosures, signatory identification, Proof of Funds.
• Trade data — for active trades, product enquiries, quantities, destinations, payment instructions, Bills of Lading, and related commercial correspondence.
• Technical data — IP address, user agent, locale, session timestamps.
• Cookie data — see Cookie Policy.

3. How we use your data

We process your data to: respond to your enquiries; verify your eligibility under our KYC and sanctions framework; execute, document, and audit trades; comply with Russian Federation export regulations, anti-money laundering law, and any applicable foreign sanctions regime; communicate operational updates about your trades; and improve our Platform.

4. Legal basis

We process your data on the legal bases of: (a) performance of a contract or steps preliminary to a contract; (b) compliance with a legal obligation (sanctions screening, AML, export documentation); (c) our legitimate interest in operating, securing, and improving the Platform; and (d) your consent (cookies and marketing communications, where applicable).

5. Recipients

We share your data with: banks issuing APRGs and processing MT103 wires; SGS and other pre-shipment inspection agencies; CCI for trade registration; sanctions screening providers; our infrastructure providers (Supabase, Brevo, Cloudflare); our authorised intermediaries where you have engaged through one; and regulators or courts where legally compelled.

6. International transfers

SFERA is established in the Russian Federation and trades internationally. Your data may be transferred to and processed in jurisdictions outside your country of residence. Where we transfer personal data of EU or UK residents outside those territories, we rely on Standard Contractual Clauses or equivalent safeguards.

7. Retention

We retain contact data for as long as you have an active account plus one year. Trade data is retained for ten years following the trade close date for tax, audit, and regulatory purposes. KYC data is retained for five years after the last trade for AML compliance. Technical data is retained for 90 days.

8. Your rights

Depending on your jurisdiction, you may have rights to: access the personal data we hold about you; request correction of inaccurate data; request deletion (subject to our legal retention obligations); object to or restrict certain processing; withdraw consent where processing relies on consent; and lodge a complaint with your local data protection authority. To exercise these rights, email sales@sfera-rusexport.ru with subject "Data subject request".

9. Security

We protect your data with TLS in transit, encryption at rest, role-based access control, audit logging, and routine security review of our infrastructure. No system is perfectly secure; if we become aware of a breach affecting your personal data, we will notify you and any required authority without undue delay.

10. Changes

Material changes to this Privacy Policy will be notified via the email address on your account. See also Terms of Service and Cookie Policy.