Personal data

Personal data processing policy

This document explains what data ETX receives through the website, why it is processed, how long it is kept and how it is protected.

Last revised: 30 July 2026

1. General provisions

This personal data processing policy (the “Policy”) is drawn up in line with Russian Federal Law No. 152-FZ of 27 July 2006 “On Personal Data” and sets out how ETX (the “Operator”) processes personal data and secures it. For enquiries from the European Union the Operator also follows Regulation (EU) 2016/679 (GDPR).

1.1. The Operator treats respect for human and civil rights and freedoms in the processing of personal data — including the right to privacy and to personal and family confidentiality — as a core condition of its activity.

1.2. The Policy applies to all information the Operator may obtain about visitors to etx-capital.com.

2. Key definitions

Operator: ETX, the company that organises and carries out the processing of personal data and determines its purposes and scope.
Website: the graphic and information materials, software and databases made available on the internet at etx-capital.com.
User: any visitor to the Website.
Personal data: any information relating directly or indirectly to an identified or identifiable User of the Website.
Processing of personal data: any operation performed on personal data: collection, recording, organisation, storage, updating, retrieval, use, transfer, blocking, deletion, destruction.
Automated processing: processing of personal data by means of computing equipment.

3. Data processed

The Operator processes data only for the purposes listed below and only to the extent each purpose requires.

Purpose: operating the Website

Categories of data

the IP address of the User’s device
browser type, version and language
operating system version
the requested page address, date and time of the request

The Website uses no analytics cookies, pixels, web beacons or third-party analytics services. Fonts and images are served from the Operator’s own domain, with no calls to external services. The technical data listed above is recorded in hosting logs and is not used to build a profile of the User.

Data subjects: Visitors to the Website.
Legal basis: the legitimate interests of the Operator — keeping the Website functional and secure.
Methods, retention and erasure: Automated processing. Hosting logs are kept for no longer than 12 months from the date of the request and are then deleted automatically.

Purpose: handling enquiries, recruitment and hiring

Categories of data

name
phone number
email address — if the User provided one
the message text and any details the User chose to include in it

The Operator does not request identity document details, bank details, health information or other special categories of personal data through the Website. Please do not enter such data in the free-text message field.

Data subjects: Candidates for open roles and people enquiring about investment services.
Legal basis: the User’s consent. By submitting the form the User confirms consent to the processing of their data as set out in this Policy. Consent may be withdrawn at any time.
Methods, retention and erasure: Automated and non-automated processing. Enquiry data is kept until the purpose of the enquiry is met and for no longer than 1 year; data of candidates added to the talent pool is kept for no longer than 3 years from the date of the enquiry. Once the purposes are met, or at the User’s request, the data is destroyed within 30 days unless retention is required by law.

4. Collection, storage, transfer and other processing

4.1. The Operator processes personal data by collecting, recording, organising, accumulating, storing, updating, retrieving, using, transferring (granting access to), blocking, deleting and destroying it. The Operator does not disseminate personal data and does not pass it to third parties for advertising purposes.

4.2. The security of personal data is ensured through legal, organisational and technical measures required to meet applicable data protection law in full.

4.3. The Operator takes every reasonable measure to prevent access to personal data by unauthorised persons.

4.4. The Operator may engage service providers that support the Website and the handling of enquiries to process personal data on its behalf — only to the extent required to deliver those services and subject to confidentiality.

4.5. Transfer of personal data to any other third party is possible only where the law expressly provides for it.

4.6. The User may request information about the processing of their data, ask for it to be corrected, blocked or destroyed, and withdraw consent to processing.

5. Final provisions

5.1. The User may obtain clarification on the processing of their personal data by contacting the Operator at info@etx-capital.com.

5.2. Any change to the Operator’s personal data processing policy is reflected in this document. The Policy is valid indefinitely until replaced by a new version.

5.3. The current version of the Policy is freely available at etx-capital.com/en/privacy.