Effective Date: January 20, 2024
1. PREAMBLE
The Administrator, valuing the trust of its Clients and understanding the importance of ensuring the privacy and inviolability of their Personal Data, as well as the Information Materials placed by Clients on the Website in accordance with the Rules, introduces this Policy to define the procedures for handling confidential data of the Parties when using the Website and System Services. Familiarization with the provisions of this Policy before the use of the Services provided by the System is mandatory for all Clients.
2. TERMS
In this document, unless the main text of the Rules expressly states otherwise, the following words and expressions shall have the meanings given below:
- Cookie: A fragment of Data, not containing Personal Data, created by the Website and stored on the Client’s computer in the form of one or more files. Blocking Cookies by the Client may lead to difficulties in using the Website or complete inability to use it.
- Information Materials (Data): Any text, graphic, audio, video, and mixed informational materials.
- **Confidential Information: Any data, not considered Public Data, that the Parties have agreed to treat as confidential or which applicable law requires to be considered confidential.
- Confidentiality: The availability of information only to its owner and to persons who may or must receive it by law and/or contract with that person.
- Public Data:** Data (including Personal Data) to which the owner has provided access to an unlimited number of persons (including by publishing on any Internet site without access restrictions) or to which the confidentiality requirement does not apply according to this Appendix and/or applicable law.
- Personal Data: Any information relating to an identified or identifiable natural person (data subject).
- Disclosure of Confidential Information: An action or inaction by one of the Parties resulting in Confidential Information becoming known to third parties without the consent of the owner of the confidential information. The form of disclosure (oral, written, using technical means, etc.) does not matter.
- Disclosing Party: In relation to Confidential Information disclosed by the Administrator - Participant; in relation to Confidential Information disclosed by the Participant - Administrator.
- Disclosure of Confidential Information: The transfer of any information that is Confidential under the terms of this Appendix to third parties, including leakage, theft, loss, distortion, forgery, destruction, modification, copying, blocking of Confidential Information due to failure or improper performance of the conditions of this Appendix by the Receiving Party.
Terms not specifically defined in this section are used in the meanings disclosed (in order of priority) in bilateral agreements between the Parties and in the current version of the Rules adopted by the Administrator and the Appendices thereto.
3. GENERAL PROVISIONS
By using any part of the Website and/or any Services, the Client grants the Administrator the right to receive, store, process, and use the Client's Personal Data and other Information Materials under the conditions of this Appendix.
This Appendix does not regulate and the Administrator is not responsible for the procedures for obtaining, storing, processing, using, and disclosing the Client's Personal Data and other Information Materials by third-party companies and organizations that are not owned or controlled by the Administrator, and by individuals who are not employees of the Administrator, even if the Client has gained access to the websites, software, and/or services of these persons through the Website.
The main purpose of obtaining, storing, processing, and using the Client’s Personal, Public, and other data is to protect the Client's interests and to improve the quality of personalized and general services provided to the Client by the Administrator.
This Policy is not standalone and is merely an addition to the Rules and does not cancel the effect of any provision from the main text of the Rules.
The provisions of this document and the concept of "Confidential Information" do not apply to information that:
- was, is, or becomes available to the Receiving Party on a non-confidential basis from a person who, to the knowledge of the Receiving Party, is not bound by any confidentiality agreement with the other Party or any other restriction prohibiting the disclosure of confidential information to the Receiving Party, or
- was lawfully in the possession of the Receiving Party before disclosure by the other Party as Confidential Information, or
- in respect of which the Disclosing Party does not take measures to protect its confidentiality;
- which is accessible by virtue of the requirements of applicable 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 before the moment of disclosure by the other Party, or
- must be disclosed according to the law or upon lawful request from governmental or other competent authorities.
4. COLLECTION OF INFORMATION
The Administrator may collect and process the following information about the Client:
- Full name, occupation, address, email address, phone number, date of birth, and the Client’s bank or payment card details, as well as documents confirming the Client's identity and address, upon our request.
- Information about transactions that the Client conducts through the System using the Wallet, and the execution of the Client's Orders.
To fulfill its legal obligations related to anti-fraud and anti-money laundering, the Administrator will obtain information about the Client from third parties, including information about the Client’s financial history, local court decisions, and bankruptcies from credit bureaus and fraud prevention agencies, when Clients open a Wallet and at any other time deemed necessary to prevent fraud and minimize financial risks. More detailed information is contained in Appendix 02 to these Rules.
When registering in the System and creating a Wallet, the Client must provide their Authorization Data, as well as (mandatory or optional) other data. After creating and using the Wallet, the Administrator will be able to identify the Client each time they use the System and visit the Website.
The Administrator has the right to upload cookies to the Clients’ computers (unless the Client has independently restricted this option in their web browser), as well as to receive, store, process, and use information created using cookies.
When the Client visits the Website, the Administrator automatically stores, processes, and uses non-Personal data about the Client, such as the Client’s IP address, location data (which can be determined using their IP address), technical parameters of the Client’s computer, the presence or absence of specific software on the Client’s computer, the settings of this software, cookies, and statistical information about the Client’s activity.
In addition to visiting the Website, the Client provides information to the Administrator when using the System (potentially) through mobile applications, social network applications, payment terminals, etc., when making inquiries and requests by phone, mail, email, and other channels, and the Administrator receives information about the Client from other sources in the process of verifying the information previously provided by the Client.
5. USE OF INFORMATION
The Administrator uses the information concerning Clients, which is at its disposal, in the following ways:
- To service the Clients’ Wallets and provide the Services they request;
- To execute Clients’ Orders for Fund Transfers and receiving Payments, and conducting Transactions using the Services;
- To inform Clients about changes in Services and the System, in the Rules, and in the Software, etc.;
- To comply with the requirements of applicable laws and regulations, particularly anti-money laundering laws and "KYC" ("Know Your Customer") procedures;
- To verify the financial status, identity, and creditworthiness of Clients;
- To conduct checks to prevent fraud and money laundering;
- To provide customer support, including responding to questions, comments, and Claims;
- To enhance the security of the Services;
- To present the content of the Website (including its interactive features) in the most effective way for Clients and their computers;
- To provide Clients with Products and Services that they request or that the Administrator believes may be of interest to them;
- To assist in the development, provision, and improvement of the System's Services, as well as the content of the Website and Client information;
- For the Administrator's internal purposes, such as conducting audits, data analysis, and quality assessment of the Services provided, etc.
6. DISCLOSURE OF INFORMATION
The Administrator undertakes not to provide Personal Data to third parties for commercial purposes without the consent of the Client to whom the data pertains. The transfer of Personal Data to third parties is permitted in the following cases:
- After obtaining the consent of the Client to whom the information relates;
- In response to justified requests from governmental authorities that have the right to obtain such data;
- Providing data to agents and third parties acting under a contract with the Administrator to fulfill obligations to the Client (including, but not limited to, acquirers, card-issuing banks, international card systems, telecommunications 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 of the Administrator;
- To companies that may offer their products and services to Clients;
- In the course of exchanging information with other companies and organizations to protect against fraud and reduce financial risk;
- If, in the opinion of the Administrator, the Client violates the terms of this Appendix and/or other agreements between the Administrator and the Client and/or internal regulations and rules of the Administrator, or if, in the opinion of the Administrator, such disclosure is necessary to investigate, prevent, or take action against illegal activities, suspected fraud, potential threats to the physical safety of any person, violations 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 the Client, the Administrator has the right to publicly disclose the fact of its business relationship with this Client. The Administrator reserves the right to disclose confidential information when required by business practices.
Nothing in this Appendix shall limit either Party’s right to disclose any Confidential Information in accordance with a court order or other legitimate legal or regulatory obligation if such disclosure is necessary, provided that, where possible, the other Party is informed of such disclosure in advance.
All Confidential Information shall remain the property of the disclosing Party, and no rights or licenses in respect of such Confidential Information are granted except as expressly provided in this Appendix.
Each Party shall return to the other Party and/or securely destroy all Confidential Information (including any part that may be in processing, research, or translation, along with all copies, including records, drawings, diagrams, computer programs, in whatever form and on whatever media they may be) upon written request of the other Party, unless the retention of such documents is required by any legal or regulatory obligations, and, if necessary, shall 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 to their Personal Data by third parties for marketing purposes if this does not contradict the provisions of applicable law and the Rules, by sending a corresponding request to the Administrator’s Contact Details.
7. PROCESSING OF INFORMATION
By providing their Personal Data during Registration in the System, the Client agrees to its processing both with and without the use of automation tools, including but not limited to collection, storage, transfer to third parties, and use by the Administrator for the purpose of providing Services to the Client and other purposes specified in the Rules.
If the Client does not wish for their Personal Data to be processed, they must contact the Administrator using the Contact Details. In such a case, all information received from the Client will be deleted from the Administrator’s client database, and the Client will not be able to use the Services.
8. ACCESS TO INFORMATION
To exercise the rights of Clients, as well as to properly fulfill the obligations of the Administrator provided for in the Rules and agreements of the Parties, the Administrator may review Client Information Materials (for the timely resolution of technical issues, prevention of illegal actions that infringe on the rights of either Party, other Clients, etc.).
The Administrator provides limited access to the Personal Data of Clients only to those of its employees who, in its opinion, genuinely need to use this information to provide services to Clients or to perform their job duties.
The Client has the right to request, modify, or delete their Personal Data held by the Administrator and/or on the Site. The Client can independently modify or delete their Personal Data using the corresponding functions of the Site and their Wallet.
Applicable data protection law gives the Client the right to access information about them. Any access request may be subject to a fee to cover the costs of providing detailed information about the Client stored by the Administrator and/or third parties.
9. INFORMATION PROTECTION
The Parties guarantee the confidentiality of the information obtained during the execution of the Rules, except in cases expressly provided for in the Rules and other agreements between the Parties.
A Client who violates the obligations of maintaining the confidentiality of information is obliged to compensate for all losses (including lost profits) incurred by third parties and/or the Administrator as a result of the Client's actions.
The confidentiality conditions are contained in these Rules and are fully accepted by the Client upon acceptance of the Rules.
The Parties undertake NOT to disclose information about the System's working conditions, as well as other information received by the Parties in the course of fulfilling their obligations under the Rules, except when a Party is required to provide such information in accordance with applicable law.
The Parties are obliged to notify each other within 1 (one) working day of any fact of disclosure or threat of disclosure, illegal obtaining, or illegal use of Confidential Information by third parties, either committed by themselves or known to them.
The Parties are not entitled to unilaterally terminate the protection of the confidentiality of this information as provided by these Rules, including in the case of their reorganization (merger, acquisition, division, separation, transformation, or any other form of change in legal status) or (in cases provided for by law) liquidation.
Disclosure of Confidential Information at the lawful request of law enforcement and other authorized government bodies and/or officials in the cases and manner prescribed by applicable law is not considered a breach of confidentiality.
As stated in other sections of these Rules, Clients are responsible for maintaining the confidentiality of their Authentication Data. The Administrator is not responsible for transactions made as a result of improper storage or loss of this information by Clients.
10. OTHER PROVISIONS
The Administrator has the right to retain the Client's Personal and other data for as long as necessary to achieve the purpose indicated in this Appendix, or for the periods established by applicable law, or until the Client deletes this data.
The Client is responsible for providing accurate information and for updating the information previously provided in the event of any changes.
The Client allows the Administrator to permit other persons with whom the Administrator has concluded the relevant agreements to obtain, store, and process data about the Client (except for Personal Data and Information Materials), such as the Client's IP address, cookies, as well as statistical information about the Client's activity, to improve the quality of services provided by these persons and to provide advertising information.
The Client agrees that the confidentiality of data transmitted over the Internet is not guaranteed, and in the event that this data is accessed by third parties outside the zone of technical communication facilities controlled by the Administrator, the latter is not responsible for the damage caused by such access.
If, while using the Website and/or the System, the Client somehow becomes aware of information about the Administrator and/or third parties that, according to applicable law, is considered confidential and/or a trade secret, the Client is prohibited from storing, using, and distributing such information.
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