1. PREAMBLE

Administrator, valuing the trust of its Clients and realizing the importance of ensuring the confidentiality and inviolability of the Personal Data of its Clients, as well as the Information Materials posted on the Website. inviolability of the Personal Data of its Clients, as well as Information materials placed by the Clients on the Website, introduces this Policy to determine the order of confidentiality and inviolability of Personal Data of its Clients Customers on the Site within the framework of the Rules execution, introduces this Policy to determine the order of the Parties' confidential data transactions when using the Site and the Website. operations with confidential data of the Parties when using the Website and Services of the System. Familiarization with the provisions of this Policy before using the Services provided by the System, is mandatory for all Clients.

2. TERMINES

In this document, unless the main text of the Regulations expressly indicates otherwise, the following words and expressions will shall have the meanings indicated below:

Cookie - a fragment of Data, not containing Personal Data, created by the Site and stored in the Client's computer. Client in the form of one or more files. Blocking of Cookie by the Client will lead to difficulties in using the Site or to complete impossibility of its use. use of the Site or to the complete impossibility of its use.
Information materials (Data) - any text, graphic, audio, video and mixed materials of informational nature of informational nature.
Confidential Information means any non-Public Data that the Parties have agreed or applicable law requires to be treated as confidential. have agreed or are required by applicable law to treat as confidential.
Confidentiality - availability of information only to its owner, as well as to persons to whom this information can and (or) must be provided by law and (or) by contract with this person.
Publicly available data - data (including Personal Data) to which the person in possession of such data has provided access to an unlimited number of persons (including by publication on any Internet site). data (including Personal Data) - data (including Personal Data) to which the person in possession of such data has provided access to an unlimited number of persons (including by publication on any Internet site without restricting access to such data) or which are not subject to confidentiality requirements under this Schedule and/or applicable law. under this Annex and/or applicable law is not subject to confidentiality requirements.
Personal data - any information relating to directly or indirectly defined or identifiable natural person (subject of personal data). natural person (subject of personal data).
Disclosure of Confidential Information - an act or omission of one of the Parties, as a result of which the Confidential Information becomes known to third parties without the consent of the Parties. as a result of which the Confidential Information becomes known to third parties without the consent of the owner of the Confidential Information. the owner of the confidential information. In this case, the form of disclosure (oral, written, with the use of technical means, etc.) does not matter.
Disclosing Party: with respect to Confidential Information disclosed by the Administrator - the Participant; with respect to Confidential Information disclosed by the Participant - the Administrator.
Disclosure of Confidential Information means the disclosure to third parties of any information that is Confidential in accordance with the requirements of this Annex, including leakage, theft, loss, distortion, falsification, destruction, modification, copying, blocking of Confidential Information as a result of failure to fulfill or improper fulfillment of the requirements of this Annex. information as a result of failure to fulfill or improper fulfillment of the terms of this Schedule by the Receiving Party. Receiving Party.
The terms, the meaning of which is not specifically specified in this section, shall be used hereinafter with the meanings, disclosed (in order of priority) in bilateral agreements between the Parties and in the current version of the Rules and Appendices thereto adopted by the Administrator. adopted by the Administrator of the Rules and Appendices thereto.

3. GENERAL PROVISIONS

Using any part of the Site and (or) using any Services, the Customer grants the Administrator the right to to receive, store, process, use Personal Data and other Information Materials of the Customer on the terms and conditions of this Application.
This Appendix does not regulate and the Administrator is not responsible for the procedure of receiving, storing, processing, use and disclosure of Personal Data and other Information Materials of the Client third-party enterprises and organizations that are not owned or managed by the Administrator, and individuals who are not employees of the Administrator Administrator, and individuals who are not employees of the Administrator, even if the Customer has has accessed the sites, software and (or) TRU of such persons through the Site.
The main purpose of receiving, storing, processing and using Personal, Public and other data of the Customer is to protect the Customer's interests and to improve the quality of services provided to the Customer. data of the Client is to protect the Client's interests, as well as to improve the quality of personalized and general services provided by the Administrator to the Client. personalized and general services provided by the Administrator.
This Policy has no independent character and is only a supplement to the Rules and does not supersede any provision of the main text of the Rules. It does not supersede any provision of the main text of the Rules.
The provisions of this document and the term “Confidential Information” shall not apply to information, which:

was, is or becomes available to the Receiving Party on a non-confidential basis from a person who to the Receiving Party's knowledge, is not bound by any confidentiality agreement with another Party or otherwise prohibited from disclosing confidential information to the Receiving Party, or
was in the lawful possession of the Receiving Party prior to disclosure to it by the other Party as Confidential Information, or Confidential Information, or
for which the Disclosing Party fails to take measures to protect its confidentiality;
to which you have access by virtue of the requirements of applicable laws and regulations;
is publicly known as a result of the actions and decisions of the Disclosing Party itself;
was available to the Receiving Party on a non-confidential basis prior to disclosure by the other Party, or
must be disclosed in accordance with the law or upon a lawful request by the by governmental or other competent authorities.

4. INFORMATION GATHERING

The Administrator may collect and process the following information about the Customer:

full name and surname, occupation, address, e-mail address, telephone number, date of birth and details of the Customer's bank or payment card, as well as documents confirming the identity and address of the of the Customer, upon our request;
information about the Transactions that the Client performs through the System using the Wallet, and about execution of the Client's Orders;

In order to fulfill its legal obligations to combat fraud and money laundering, The Administrator will obtain information concerning the Client from third parties, including information about the Client's financial history, local court decisions and bankruptcies, credit bureaus and agencies. financial history, local court decisions and bankruptcies, credit bureaus and fraud prevention agencies, when the Client opens the Client's account. fraud prevention agencies, when Customers open a Wallet, and at any other time it deems it necessary to prevent fraud and minimize its financial risks. Further information is contained in Appendix 02 to these Rules.
When registering in the System and creating a Wallet, the Customer shall specify his Authorization data, as well as other data (mandatory or optional). (mandatory or optional) other data. After creation and use of the Wallet by the Client, the Administrator gets an opportunity to identify the Client each time he uses the System and each time he visits the Website. Website.
The Administrator shall have the right to download cookies to the Clients' computers (unless the Client has independently unless the Client has independently restricted this possibility in his/her web browser), as well as to receive, store, process and use the information generated by cookies.
When the Client visits the Website, the Administrator automatically saves, processes and uses the Client's data. Client's non-Personal data, such as, for example: the Client's IP address, data on the Client's Client's location, which can be determined by means of his IP-address, technical parameters of the Client's of the Customer's computer, the presence or absence of specific software on the Customer's computer, settings of this software, cookie files, as well as statistical information about the Customer's Client's activity.
In addition to the Client's visit to the Website, the Client provides the Administrator with information also when using the System (eventual) through applications for mobile devices, applications for social networks, payment terminals, etc., during appeals and inquiries by phone, mail, e-mail and other channels, as well as the Administrator receives information about the Client from other sources. channels, as well as the Administrator receives information about the Client from other sources in the process of verifying information previously provided by the Client.

5. INFORMATION USAGE

The Administrator shall use the information concerning the Clients, which is in its possession, in the following ways in the following ways:

to service the Clients' Wallets and provide the Services requested by them;
to execute Clients' Orders to make Funds Transfers and receive Payments, and to execute Transactions using Services Transactions using the Services;
to inform the Clients about changes in the Services and the System, the Rules and the Software, etc;
to comply with applicable laws and regulations, and in particular the requirements of the anti-money laundering laws and procedures (“Know Your Customer”);
to verify the financial condition, identity and creditworthiness of the Customers;
to perform checks to prevent fraud and money laundering;
for Customer service, including responding to questions, comments and Claims;
to enhance the security of the Services;
to present the content of the Site (including its interactive features) in the most effective manner for Customers and their computers;
to provide Customers with TRUs that they request or that the Administrator believes may be of interest to them; and interest;
to assist in the development, provision and improvement of the System Services, as well as informational content of the Website and informing the Clients;
for the Administrator's internal purposes, such as auditing, analytical processing of data, and evaluation of the quality of the Services, etc. assessing the quality of the Services provided, etc.

6. INFORMATION DISCLOSURE

The Administrator undertakes not to provide Personal Data to third parties for commercial purposes without the Client's consent of the Client to whom these data relate.
The transfer of Personal Data to third parties is permitted in the following cases:

after obtaining the consent of the Customer to whom the information relates;
at the reasonable requests of public authorities that have the right to receive such data;
providing data to agents and third parties acting on the basis of an agreement with the Administrator, to fulfill obligations to the Client
(including, but not limited to, acquirers , payment card issuing banks, international card systems, providers of telecommunication services, billing or delivery companies, affiliates of the Administrator, etc.). service providers, billing or delivery companies, affiliates of the Administrator, etc.)

They maintain appropriate security measures to protect confidential information from unauthorized access or use;

To potential creditors, investors, acquirers, Partners, shareholders, auditors Admin;
companies that can offer their products and services to Customers;
sharing information with other companies and organizations to protect against fraud and reduce financial risk; and mitigating financial risk;
if, in the Administrator's opinion, the Client violates the terms of this Appendix and (or) other contracts and agreements between the Administrator and the Client and (or) internal regulations and other contracts and agreements between the Administrator and the Client, and (or) internal regulations and Administrator's rules and regulations, or if in the Administrator's opinion, such provision is necessary to in order to investigate, prevent or take action against illegal acts, suspected fraud, potential threats to the physical safety of any person, violations of the terms of the Rules or bilateral agreement, or is required by law;
in other cases in accordance with the provisions of the Rules and applicable law.

Unless otherwise agreed in writing with this Client, the Administrator shall have the right to publicly disclose the fact of the existence of its business relationship with this Client.
The Administrator reserves the right to disclose confidential information when it is required by the rules of business turnover.
Nothing in this Schedule shall limit either Party's right to disclose any Confidential Information pursuant to a judicial or other legitimate legal or regulatory obligation, if such disclosure is necessary and provided that, where possible, the disclosure of the Confidential Information shall be made in accordance with a judicial or regulatory obligation, if such disclosure is necessary and provided that, where possible, the fact of such disclosure is not disclosed to the other Party. of such disclosure to the other Party shall be informed in advance.
All Confidential Information will remain the property of the disclosing Party, and no rights or licenses with respect to such Confidential Information shall be granted. licenses with respect to such Confidential Information shall not be granted except as specifically except as specifically provided in this Annex.
Each Party will return to the other Party and/or securely destroy all Confidential Information (including that part which may be in processing, research or translation, as appropriate, with all copies, including recordings, drawings, diagrams, computer programs, in whatever form and on whatever media they may be found) upon Upon written request of the other Party, unless the retention of these documents is required by any law or regulation. required by any statutory or regulatory obligations, and, if necessary, certify in writing, signed by an authorized person, that this has been done.
The Client has the right to request the Administrator to restrict access of third parties to his Personal Data for marketing purposes marketing purposes, if it does not contradict the provisions of the applicable legislation and the Rules, by sending a the relevant request to the Administrator at the Administrator's Requisites.

7. INFORMATION PROCESSING

By submitting his/her Personal Data when registering in the System, the Customer agrees to their processing both with the use of automation means and without the use of automation means, in particular, collection, storage, transfer to third parties and use by the Administrator for the purposes of rendering Services to the Customer and other purposes, storage, transfer to third parties and use by the Administrator in order to provide Services to the Client and for other purposes specified in the Rules. purposes specified in the Rules.
If the Customer does not wish his/her Personal Data to be processed, he/she should contact the Administrator at Requisites. In this case, all information received from the Client is deleted from the Administrator's client database and the Client will not be able to use the Services. Administrator's client database and the Client will not be able to use the Services.

8. ACCESS TO INFORMATION

In order to realize the rights of the Clients, as well as the proper performance by the Administrator of its obligations, provided by the Rules and agreements of the Parties, the Administrator may study the Information materials of the Clients (for the purpose of timely resolution of technical problems, suppression of unlawful actions, etc.). Clients (for the purpose of timely resolution of technical problems, suppression of illegal actions, violating the rights of any of the Parties, other Clients, etc.).
The Administrator provides limited access to the Clients' Personal Data only to those of its employees who, in its opinion, really need to use this information to Employees who, in its opinion, really need to use this information in order to provide services to Clients or to fulfill their official duties, in order to provide services to Clients or to fulfill their official duties.
The Customer has the right to request, change or delete his Personal Data, which is held by the Administrator and (or) on the Site. The Client may independently change or delete his/her Personal Data using the appropriate functions of the Site and his/her Wallet. data using the corresponding functions of the Website and his/her Wallet.
Applicable legislation on personal data protection gives the Customer the right to access information about him. In this case, any request for access may become a reason for charging a fee to cover the costs of providing the Client with detailed information about him stored by the Administrator and (or) third parties. providing the Client with detailed information about him stored by the Administrator and (or) third parties.

9. DATA PROTECTION

The Parties guarantee confidentiality of the information received in the course of fulfillment of the requirements of the Rules information, except as expressly provided for in the Rules and other agreements of the Parties.
The Client, who violated the obligation to maintain confidentiality of information, shall be obliged to reimburse all losses (including lost profit), received by third parties and (or) the Administrator as a result of these actions of the Client. these actions of the Client.
Confidentiality conditions are contained in these Rules and are accepted by the Client in full upon acceptance of the Rules. acceptance of the Rules.
The Parties undertake NOT to disclose information about the System operation conditions, as well as other information, received by the Parties in the course of fulfillment of their obligations under the Rules, except for cases, when the Party is obliged to provide such information in accordance with the applicable legislation.
The Parties are obliged to inform each other within 1 (one) working day about the fact of disclosure or threat of disclosure or unlawful receipt or unlawful use of the information the fact of disclosure or threat of disclosure, unlawful receipt or unlawful use of Confidential Information by third parties. Confidential Information by third parties.
The Parties shall not have the right to unilaterally terminate the confidentiality of this information, provided by these Rules, including in the case of its reorganization (merger, consolidation, merger, consolidation, division, separation, transformation or any other form of change of legal status) or (in cases stipulated by the legislation) liquidation, stipulated by the legislation) liquidation.
It is not a breach of confidentiality to provide Confidential Information at the lawful request of law enforcement and other authorized state bodies and (or) officials in the cases and in the manner provided for by applicable law. in cases and in the manner provided for by applicable law.
As set forth elsewhere in these Terms, Customers are responsible for keeping confidentiality of their Authentication Data. The Administrator is not responsible for operations, made as a result of improper storage or loss of this information by Clients.

10. OTHER TERMS

The Administrator shall have the right to retain Personal and other Customer Data for as long as necessary, for the realization of the purpose specified in this Schedule, or for the periods established by applicable law, or until the Client deletes this data. legislation, or until the Client deletes such data.
The Client is responsible for providing accurate information, as well as for updating the previously provided data in case of any changes. the previously provided data in case of any changes.
The Client allows the Administrator to authorize other persons with whom the Administrator has concluded to receive, store and process data about the Client (except Personal Data and Information Materials), such as the Client's IP address, cookie files and statistical data. Personal Data and Information Materials), such as the Client's IP address, cookies, as well as statistical information about the Client's activity, in order to improve the quality of services provided by these persons and to provide the Client's services. information on the Client's activity, in order to improve the quality of services provided by these persons and to provide advertising information.
The Client agrees that the confidentiality of the data transmitted via the Internet is not guaranteed and in case the data is accessed by third parties outside the technical means of communication. if access to this data is obtained by third parties outside the area of technical means of communication, Administrator, and the latter shall not be liable for any damage caused by such access. access.
In case when using the Site and (or) the System, the Client in any way became aware of information regarding the Administrator and (or) third parties, which according to the applicable law refers to confidential and (or) commercial secret, the Client is prohibited to keep it. legislation refers to confidential and (or) commercial secret, the Client is prohibited to store, use and distribute such information.