A. Introduction

  1. The privacy of our website users is of great importance to us, and we make every effort to ensure that it is protected. This policy explains how we use your personal information.
  2. By agreeing to the use of cookies on your first visit to our website, in accordance with the provisions of this Policy, you grant us permission to use cookies on each of your subsequent visits.

B. Intellectual property rights
This document was created using a template from the SEQ Legal website (seqlegal.com)

C. Collection of personal data

The following types of personal data are subject to collection, storage and use:

  1. Information about your computer, including your IP address, geographic location, browser type and version, and operating system;
  2. Information about your visits to and use of this website, including referral sources, length of visits, pages viewed, and site navigation paths;
  3. Information about your email address that you used to register on our website;
  4. Information you entered when you created a profile on our website, such as your name, profile picture, gender, date of birth, marital status, hobbies and interests, education and place of employment;
  5. Information, such as your name and email address, that you provided when you subscribed to our mailing lists and/or newsletters;
  6. Information you enter when using the services of our website;
  7. Information generated by your use of our website, including information about the time, frequency and conditions of its use;
  8. Information regarding any of your purchases, services used or transactions you have conducted through our website, including your name, address, telephone number, email address and credit card information;
  9. Information that you have posted on our website for the purpose of publishing it online, including your username, profile picture, and the content of your post;
  10. Information contained in any communications you have sent to us by email or through our website, including the content of the communication and the meta data;
  11. Any other personal information you have sent to us.

Before you disclose personal information of a third party to us, you must obtain the consent of that person to both disclose and process that information in accordance with this policy.

D. Use of your personal information

The personal information you provide to us through our website will be used for the purposes specified in these rules or on the relevant pages of the website. We may use your personal information for the following purposes:

  1. Administering our website and business;
  2. Personalizing our website for you;
  3. Enabling you to use the services available on our website;
  4. Sending you goods purchased through our website;
  5. Providing you with services purchased through our website;
  6. Sending you notices, invoices and payment reminders and receiving payments from you;
  7. Sending you non-marketing commercial communications;
  8. Sending you email communications that you have specifically requested;
  9. Sending you email newsletters if you have requested them (you may notify us at any time that you no longer wish to receive email newsletters from us);
  10. Sending you marketing communications about our business activities or the business activities of carefully selected third parties that we believe may be of interest to you, through publications or, if you have specifically consented to this, by sending you email or through the use of similar technologies (you may notify us at any time that you no longer wish to receive marketing communications);
  11. Providing third-party companies with statistical information about our users (however, these third-party companies will not be able to identify any individual user from this data);
  12. To handle inquiries and complaints made by or about you regarding our website;
  13. To ensure the security of our website and prevent fraud;
  14. To verify compliance with the terms and conditions governing the use of our website (including monitoring private messages sent through our website’s private messaging service);
  15. and for other purposes.

If you have provided personal information for publication on our website, we will publish it. Otherwise, we will use this information in accordance with the license you have granted us.

Your privacy settings can be used to limit the publication of your personal data on our website and can be adjusted through the privacy controls on the website.

Without your explicit consent, we will not share your personal information with any third-party company for direct marketing use by this or any other third-party company.

E. Disclosure of personal information

We reserve the right to disclose your personal information to any of our employees, officers, policyholders, professional advisors, agents, suppliers or subcontractors to the extent and for the purposes set out in this policy.

We reserve the right to disclose your personal information to any member of our group of companies (this includes our subsidiaries, our ultimate holding company and all of its subsidiaries) to the extent and for the purposes set out in this policy.

We reserve the right to disclose your personal information:

  1. In cases where we are required to do so by law;
  2. In connection with any current or future legal proceedings;
  3. To establish, exercise or defend our legal rights (including providing information to other parties for fraud prevention or credit risk mitigation purposes);
  4. To a buyer (or prospective buyer) of any business or assets we sell (or intend to sell);
  5. To any person who we reasonably believe may request that a court or other authorized body disclose such personal data and who, in our reasonable opinion, would be likely to be ordered by such court or authorized body to disclose such personal data.

We will not disclose your personal information to third parties, except as specified in this policy.

F. International transfers of personal information

  1. The information we collect may be stored, processed and transferred between any of the countries in which we operate to enable us to use that information in accordance with this policy.
  2. The information we collect may be transferred to the following countries that do not have data protection laws similar to those in the European Economic Area: USA, Russia, Japan, China and India.
  3. The personal information that you publish on our website, via the Internet, may be accessible worldwide.
  4. We cannot prevent its use or misuse for criminal purposes by unauthorized persons.
  5. By agreeing to these rules, you consent to the transfer of your personal information as described in Section F.

G. Retention of personal information

  1. Section G sets out the Company’s policies and procedures for the retention of personal information. These policies and procedures are designed to ensure that we comply with our legal obligations to retain and delete personal information.
  2. Personal information that we process for a particular purpose or purposes shall not be retained for longer than is necessary to achieve that purpose or purposes.
  3. Without limiting the provisions set forth in Section G-2, we generally delete personal information that falls into the following categories.
  4. Notwithstanding the other provisions of Section G, we will retain documents (including electronic documents) that contain personal information:
    1. where we are required to do so by law;
    2. if we believe that the documents may be relevant to any current or future legal proceedings;
    3. and in order to establish, exercise or defend our legal rights (including providing information to other parties for fraud prevention or credit risk mitigation).

H. Protection of your personal information

  1. We will take reasonable technical and organizational measures to prevent the loss, misuse or falsification of your personal information.
  2. We will store all personal information you provide on our secure (both password and firewall) servers.
  3. All electronic financial transactions made through our website will be protected by data encryption technology.
  4. You acknowledge that you are aware of the fact that the transmission of information over the Internet is inherently insecure and we cannot guarantee the protection of data sent over the World Wide Web.
  5. You are solely responsible for keeping your password to access our website confidential. We will never ask you for your password (except when you attempt to log in to your account on our site).

I. Changes and amendments

We reserve the right to make changes and amendments to these rules from time to time and to publish a new version on our website. You should check this web page periodically to make sure that you understand the content of the changes made to these rules. We may also inform you about changes to these rules by sending an e-mail or through the private messaging system of our website.

J. Your rights

You may instruct us to provide you with any personal information we hold about you. Such information will be provided in the following cases:

  1. Payment of fees;
  2. Providing appropriate proof of your identity.

We reserve the right to refuse to provide information at your request, within the limits of applicable law.

You have the right to instruct us not to process your personal information for marketing purposes.

In practice, you will usually either consent in advance to our use of your personal information for marketing purposes or we will provide you with the opportunity to opt-out of our use of your information for marketing purposes.

K. Third-party websites

Our website contains hyperlinks to, and details about, third-party websites and individuals. We have no control over, and assume no responsibility for, the privacy policies and practices of any third party companies or individuals.

L. Updating information

Please notify us in a timely manner if your personal information held by us needs to be updated or corrected.

M. Cookies

Our website uses cookies. A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and stored by the browser. Subsequently, the identifier is sent back to the server each time the browser requests a web page from the server. Cookies can be either “persistent” or “session” cookies: persistent cookies will be stored by the browser and will remain valid until the expiration date unless deleted by the user in advance; “session” cookies, on the contrary, will be deleted after the end of the session with the site or after the browser is closed. Cookies usually do not contain any information that identifies the user. However, your personal information that we hold may be linked to information stored and retrieved from cookies. On our website, we use only session cookies / only persistent cookies / both persistent and session cookies.

  1. The names of the cookies we use on our website and the purposes for which they are used are listed below:
    1. On our website, we use Google Analytics and Adwords to recognize a computer when a user visits the website / track user navigation on the website / allow the use of the user’s shopping cart on the website / improve the usability of the website / analyze the use of the website / administer the website / prevent fraud and improve the security of the website / personalize the website for each user / target advertising that may be of interest to individual users / ;
  2. Most browsers give you the option to refuse the use of cookies, for example:
    1. in Internet Explorer (version 10), you can block using the cookie management settings available in the menu “Tools” – “Internet Options” – “Privacy” – “Advanced” (“Tools,” “Internet Options,” “Privacy, ” “Advanced”);
    2. in Firefox (version 24), you can block all cookies by clicking on “Tools” – “Options” – “Privacy”: in the drop-down menu, select “Use custom log settings” and deselect “Accept cookies from websites”;
    3. and finally in Chrome (version 29), you can block all cookies by accessing the “Settings & Management” menu, selecting “Settings” – “Show Advanced Settings” and “Content Settings”, and then selecting “Prevent sites from sending any data” under the “Cookies” heading.

Blocking all cookies will have a negative impact on the user experience of many websites. If you block cookies, you may not be able to use many features of our website.

  1. You can delete cookies that are already stored on your computer, for example:
    1. in Internet Explorer (version 10), you must delete cookies manually (instructions on how to do this can be found at http://support.microsoft.com/kb/278835 );
    2. in Firefox (version 24), cookies can be deleted by going to the menu “Tools” – “Options” – “Privacy”: in the drop-down menu, select “Use custom log settings”, click “Show Cookies” and then “Delete all cookies”;
    3. in Chrome (version 29), you can delete all cookies by entering the “Settings and Management” menu, selecting “Settings” – “Show advanced settings” and “Clear browsing data”, and then select “Delete cookies and other data and site plugins”.
  2. Deleting cookies will have a negative impact on the user experience of many websites.