Today’s Africa Consulting Group (Intercultural Intelligence) · tacgii.com
Version of: [EFFECTIVE DATE]
Translation for convenience. In case of discrepancy, the Russian version prevails.
1. General
1.1. This Policy is issued under Russian Federal Law No. 152-FZ of 27.07.2006 “On Personal Data” and sets out how personal data of users of https://tacgii.com (the “Site”) is processed and protected.
1.2. Data operator: [FULL LEGAL NAME], INN [INN], OGRN [OGRN], registered address: [REGISTERED ADDRESS] (the “Operator”).
1.3. Person responsible for personal data processing: [NAME AND POSITION OF RESPONSIBLE PERSON].
1.4. By using the Site and submitting data through its forms, the user confirms they have read this Policy. The Policy is publicly available on the Site.
2. Data we process
2.1. Company registration (access to restricted sections): company name, company registration number, country, representative’s first and last name, position in the company, email, phone number (if given), uploaded company documents, confirmation that the representative is authorised to act for the company.
2.2. Sign-in: email address, one-time verification code, technical session identifier (cookie ta_acc).
2.3. Contact form: name, email, topic and message, IP address (used only for spam protection and rate limiting).
2.4. Newsletter: email, name or business name, sign-up date and confirmation status.
2.5. Technical data: cookies needed for the Site to work, including the record of the user’s cookie-banner choice (ta_consent).
2.6. The Operator does not process special categories of personal data or biometric data.
3. Purposes
- reviewing company registration requests, verifying the representative’s authority and documents, granting access to restricted sections;
- identifying the user at sign-in;
- answering contact-form messages and protecting the Site from spam and abuse;
- sending the Today’s Africa newsletter to subscribers;
- keeping the Site working and secure.
4. Legal bases
- the data subject’s consent (Art. 6 and 9 of 152-FZ), given by ticking the box in the relevant form;
- conclusion and performance of an agreement to which the subject is a party (Terms of Use);
- the Operator’s legitimate interest in Site security;
- requirements of Russian law.
5. Processing operations
Collection, recording, systematisation, accumulation, storage, clarification (updating, changing), retrieval, use, blocking, deletion and destruction, with and without automation. Registration decisions are made by the Operator’s staff, not solely by automated means.
6. Registration and disclosure
6.1. Registration requests are sent for review to the Operator’s team at companyverification@tacgii.com. The Operator may approve or decline a request.
6.2. The Site is hosted on a virtual server of the hosting provider Timeweb Cloud (Russian Federation); databases are stored on servers in the Russian Federation, in line with Art. 18(5) of 152-FZ. Site emails are sent through a mail service provider located in the Russian Federation.
6.3. The Operator does not sell personal data or share it for advertising. Data is disclosed only where required by law or with the subject’s separate consent.
6.4. Cross-border transfer: [TO CONFIRM: whether data is transferred to partners in Africa/BRICS countries. If yes — list countries and purposes, notify Roskomnadzor (Art. 12 of 152-FZ) and obtain consent; if no — keep: “The Operator does not transfer personal data across borders.”]
7. Retention
- registered company and representative data — while the account is active and [PERIOD, e.g. 3 years] after deletion or rejection, unless the law requires otherwise;
- contact-form messages — [PERIOD, e.g. 1 year] after the last reply;
- IP addresses for spam protection — no more than [PERIOD, e.g. 30 days];
- subscriber data — until unsubscribing; afterwards only the email is kept as a “do not email” record with no other data. On request it is erased completely;
ta_acccookie — up to 90 days.
When purposes are achieved or consent is withdrawn, data is destroyed within 30 days unless the law provides otherwise.
8. Cookies
8.1. The Site uses only technical cookies needed for it to work:
ta_acc— keeps you signed in, up to 90 days, not accessible to scripts (HttpOnly);ta_consent— remembers your cookie-banner choice;- WordPress and language switcher (Polylang) service cookies.
8.2. The Site does not use analytics or advertising cookies. [IF YANDEX METRIKA IS ADDED — update this section.]
8.3. You can delete or block cookies in your browser; signing in may then stop working.
9. Your rights
You may: obtain information about the processing of your data; demand that it be clarified, blocked or destroyed if it is incomplete, outdated, inaccurate or unnecessary for the stated purpose; withdraw consent; complain to Roskomnadzor or a court. The Operator answers within 10 working days (extendable by 5 working days with notice).
10. Withdrawing consent
Write to [EMAIL FOR PERSONAL DATA REQUESTS, e.g. contact@tacgii.com] or to the Operator’s postal address. You can unsubscribe from the newsletter via the link in any email. After withdrawal, access to restricted sections may end.
11. Security
The Operator takes legal, organisational and technical measures under Art. 18.1 and 19 of 152-FZ: access limited to authorised staff, HTTPS, one-time code sign-in with no stored passwords, company documents kept in a private non-public folder, form rate limiting, backups, and monitoring of compliance with this Policy.
12. Changes
The Operator may amend this Policy. A new version takes effect when posted on the Site unless stated otherwise. English and French translations are for convenience; the Russian version prevails.
13. Contact
[FULL LEGAL NAME], [REGISTERED ADDRESS], email: [EMAIL FOR PERSONAL DATA REQUESTS].
Consent to Personal Data Processing
(text for the registration and contact form checkbox)
Short checkbox label:
☐ I consent to the processing of my personal data under the Privacy Policy and accept the Terms of Use.
Full text (linked):
By ticking this box and submitting a form on tacgii.com, I freely, of my own will and in my own interest, give [FULL LEGAL NAME] (INN [INN], OGRN [OGRN], address: [REGISTERED ADDRESS]) consent to process my personal data: first and last name, position, company name and registration number, country, email, phone number, information in uploaded documents, message text and IP address — to review the registration request, grant access to the Site, answer my message and protect the Site from spam. Consent covers collection, recording, systematisation, accumulation, storage, clarification, retrieval, use, blocking, deletion and destruction, with and without automation. It is valid until the purposes are achieved or until withdrawn by writing to [EMAIL FOR PERSONAL DATA REQUESTS]. I confirm I am authorised to provide information about the company.