PERSONAL INFORMATION PROTECTION POLICY

This Information Protection Policy (hereinafter referred to as the Privacy Policy) applies to all information that the Website Administration can receive about a user during the website use.

The Website Administration respects the confidentiality of users of its products and services, as well as the provisions of existing laws on the protection of privacy, including Federal Law No. 152-FZ "On Personal Data" for the Russian Federation and the General Data Protection Regulation (GDPR) for the European Union. This Privacy Policy is regulated by the law of the Russian Federation, and for the European Economic Area residents — by the General Data Protection Regulation (GDPR).

1. KEY TERMS

The following terms and concepts are used in this Privacy Policy:

"WEBSITE ADMINISTRATION" (hereinafter referred to as the Website Administration) — authorized website management employees who organize and (or) perform personal data processing, as well as determine the purposes of processing personal data, the scope of personal data to be processed, the actions (operations) performed with personal data.

"PERSONAL DATA" — any information related to a determined/determinable by such information private/legal person using the website. In addition, personal data includes data automatically transmitted to the website when using software installed on user's device, including IP address, cookies, information about user's browser (or other program used to access the website).

"PERSONAL DATA PROCESSING" — collection, systematization, accumulation, storage, clarification (updating, modification), use, distribution (including transfer), depersonalization, blocking, destruction of user's personal data.

"USER (YOU)" — a person using the website in the manner specified by the Website Administration.

2. WHY THE WEBSITE ADMINISTRATION COLLECTS AND PROCESSES DATA

2.1 The Website Administration collects and processes Personal Data for the following reasons:

a) when it is necessary to fulfill the agreement with you in order to provide a full-service experience and a relevant content and features;

b) when it is necessary to comply with appropriate legal obligations;

c) when it is necessary to carry out the legitimate interests of the Website Administration or a third party (for example, interests of other clients) unless such interests are outweighed by your prevailing legitimate interests and rights; or

d) when you agreed to this.

2.2 These reasons for the Personal Data collection and processing determine and limit the types of Personal Data that the Website Administration collects and the ways of using them, the retention period, the persons who have the right to access this data, and the rights and other control methods available to You as a user.

2.3 If you request the Website Administration to provide the services in the interests of a third party, you must have a legal permission from a third party to disclose its personal information to the Website Administration. This permission must cover personal information, including, but not limited to, the name, address, telephone number, email address, credit card, and third-party delivery information. You agree that you bear all the risks associated with the use of personal information of third parties transmitted by you and that in no case will the Website Administration be liable for any personal information or for any loss or damage of any kind, incurred as a result of the use of any personal information of third parties. The Website Administration does not bear any obligations or liabilities regarding the personal information of any third party transferred by you.

3. WHAT DATA THE WEBSITE ADMINISTRATION COLLECTS AND PROCESSES

3.1 Basic credentials.

The Website Administration requests your email address, mobile phone number. Your email address and mobile phone number serve as a ground for entering the website. Providing such information is necessary to use the website services.

3.2 Transactions and payment data.

To make transactions, you need to provide the Website Administration with payment data in order to enable conducting a transaction. If you use a credit card for payment, you need to provide the Website Administration with credit card information (name, address, credit card number, expiration date, and security code) that the Website Administration processes and transmits to the payment system operator of your choice to conduct a transaction and perform checks to prevent fraud. Similarly, the Website Administration will receive data from your payment system operator for the same reasons.

3.3 Other explicit data provided by you.

We collect and process Personal Data you send to the Website Administration in an explicit form (for example, in chat rooms, reviews, or other materials created by the user). These data include the following:

- information you publish or indicate in the comments for any content and services;

- information sent in the chat, feedback form;

- information you provide when you request information, or technical support, or purchase content and services including information required to process your orders using an appropriate payment method;

- information you provide by participating in contests, lotteries, promotions or surveys, for example, your contact information.

3.4 Website use.

The Website Administration collects various data during your interaction with the site, content, and services provided by the Website Administration.

Personal data collected by the Website Administration includes, among others, information about the browser and device, data collected during an automated interaction, and data on using of applications.

In addition, the Website Administration will track your actions on websites and in applications to make sure that you are not a robot and to optimize the site's services.

3.5 Data tracking and cookies.

The Website Administration uses cookies — text files hosted on your computer — which help the Website Administration to analyze how users use the site's services, and similar technologies (for example, web beacons, device IDs, pixel and ad tags) to recognize You and/or connect your devices when you use different devices and services. In addition, these data help the Website Administration to improve their services, marketing, analytics, or website functionality. Using cookies is a standard practice on the Internet. Although most web browsers automatically accept cookies, the final decision whether to accept them or not is yours. You can configure the browser settings to avoid receiving cookies or to get a notification every time you receive a cookie file. You can prohibit the use of cookies by selecting the appropriate options in your web browser. However, please note that in this case, you will not be able to use all the website functionality.

When you visit any of the site services, the Website Administration servers log your global IP address, which is a number automatically assigned to the network part of which is your computer.

3.6 Google Analytics and Yandex.Metrika.

The site is using Google Analytics and Yandex.Metrika web analytics services. Google Analytics and Yandex.Metrika use cookies hosted on visitors’ computers that help website operators analyze how visitors use the site. The information about the website use created with cookies is usually transmitted and stored on the servers of Google and Yandex.

Google and Yandex will not associate the IP address transmitted in the context of Google Analytics and Yandex.Metrika with any other data stored in Google and Yandex. You can prohibit using cookies by selecting the appropriate options in your web browser. However, please note that in this case, you will not be able to use the full website functionality.

Moreover, users can prohibit the collection of data on how they use the website (including the IP address data) carried out using cookies.

3.7 Content recommendations.

The Website Administration can process information collected in accordance with the Privacy Policy in order to adapt content, products, and services displayed on the website pages according to your preferences and update messages and display relevant recommendations and suggestions therein. We do it to improve your service level.

In accordance with your consent or in cases where it is expressly permitted by applicable laws on electronic mailings, the Website Administration can send you marketing messages about products and services offered by the Website Administration to your email address. In this case, the Website Administration can also use your collected data to set up such marketing messages, and also collect information about whether you opened the messages and which link in the text you clicked on.

You can cancel or withdraw your consent to receive marketing emails at any time by withdrawing your consent on the same page where you previously confirmed your consent, or by clicking the "Unsubscribe" link in each marketing message.

3.8 Information required to identify violations.

The Website Administration collects certain data necessary to identify, investigate, and prevent fraud and other violations of the current legislation. Such data are only used for the purpose of identifying, investigating, and preventing violations and, where appropriate, taking action against such violations, and are stored for the minimum time necessary for these purposes. If these data indicate that a violation has occurred, the Website Administration will continue to store such data for the establishment, implementation, or protection of legal requirements during the applicable limitation period or until a judgment is rendered. Please note that specific data stored for this purpose will not be disclosed to you if such disclosure compromises the scheme used by the Website Administration to identify, investigate, and prevent such violations.

4. DATA RETENTION PERIOD

The Website Administration stores your data only for the period necessary to achieve the purposes in which such information is collected and processed, or (if the current legislation provides for a longer retention period) during the retention period required by law. After this time period, your Personal Data is deleted, blocked or anonymized, as stipulated by the current legislation.

More specifically,

- If you withdraw your consent to the processing of your Personal Data or Personal Data of your child, the Website Administration deletes your Personal Data or your child’s Personal Data without undue delay, to the extent that the collection and processing of personal data are based on the withdrawal of consent.

- If you use the right to object to your Personal Data processing, the Website Administration will review your objection and without undue delay delete your Personal Data processed for the purpose you object to unless there is another legal basis for processing and storing this data or retaining these data or the retention of this data is not required in accordance with applicable law.

- Please note that the Website Administration may store certain transaction data in accordance with statutory commercial and tax rules for up to ten (10) years.

5. WHO HAS ACCESS TO THE DATA

5.1 The Website Administration and its service providers (including payment channels) may provide each other with access to your Personal Data and use them as necessary to achieve the objectives set forth above in the Privacy Policy. In case of reorganization, sale, or merger, the Website Administration may transfer the Personal Data to the appropriate third party in accordance with applicable law.

5.2 The Website Administration also provides your Personal Data to third-party service providers providing customer support services in connection with goods, content, and services distributed through the website. Your Personal Data will be used in accordance with this Privacy Policy and only to the extent necessary to provide customer support services.

5.3 In accordance with Internet standards, the Website Administration also has the right to provide certain information (including your IP address and identification of the content you want to access) to third-party network service providers that render content delivery services and servers.

5.4 The site has a feedback form and/or chat rooms where users can provide the requested information to the Website Administration. Please note that after the message publication, this message becomes publicly available on the Internet, and you realize that you are doing it at your own peril and risk. If your personal data is published in one of the sections of the site against your will, use the website support to request their removal.

5.5 The Website Administration may disclose Personal Data in accordance with court orders or rules that require disclosure of such information.

6. YOUR RIGHTS AND MONITORING MECHANISMS

Data protection laws in the European Economic Area and in other territories grant their citizens certain Personal Data rights. While other jurisdictions may grant fewer rights to their citizens, the Website Administration creates tools designed to realize the rights of its customers around the world.

As a resident of the European Economic Area, you have the following Personal Data rights:

6.1 Access right.

You have the right to access your Personal Data stored by the Website Administration, i.e. the right to claim for free 1) information on whether your Personal Data is stored, 2) accessing and/or 3) duplicating stored Personal Data. You may use this right to access your Personal Data through the site.

6.2 Right to rectification.

By processing your Personal Data, the Website Administration will take appropriate measures to maintain the accuracy and relevance of your Personal Data for the purposes they are collected for. If your Personal Data is inaccurate or incomplete, you can change it in the appropriate website section.

6.3 Right to erasure.

You have the right to request your Personal Data removal.

As a result of deleting your account, you will lose access to the website services including the account, subscriptions, and other information related to the account, as well as the ability to access other services for which the account is used.

6.4 Right to object.

Where processing of Personal Data is based solely on legitimate interests in accordance with Article 6 (1) (f) of the GDPR / this Privacy Policy, you may exercise your right to object. If you express your objection the Website Administration does not process your Personal Data when there are no convincing and prevailing legal grounds for such processing, as described in Article 21 of the GDPR; in particular, when data are needed to establish, implement, or protect legal requirements.

You also have the right to file a complaint with the control authority.

7. CHILDREN.

The minimum age for creating an account is 16 years. The Website Administration does not consciously collect Personal data from children under this age. In some countries, a greater age of consent to collect Personal Data is established, so the Website Administration requires parental consent before using the website and the related Personal Data collection. The Website Administration encourages parents to give their children instructions that they should never open their personal data on the Internet.

8. LINKS TO OTHER WEBSITES.

The website may contain links to other websites. A link to a third party website does not mean that the Website Administration approves it or that the Website Administration is associated with it. The Website Administration does not control third party websites. You are accessing such third party websites or content at your own risk. You should always read the privacy policy of a third party website before submitting any information to the website.

9. PRIVACY POLICY CHANGES.

Any changes the Website Administration may make to the Privacy Policy in the future will be published on this page, and if necessary or in case of significant changes to this policy, the Website Administration will notify you about these changes through the website. It is expected that you will from time to time revisit this page to find out about any changes that the Website Administration makes, as they are legally binding on you.

This Privacy Statement was last updated on 09/10/2018