PRIVACY POLICY This Privacy Policy (the Policy) is drawn up pursuant to the requirements of the Federal Law No. 152-FZ of 27.07.2006 «On Personal Data» and establishes Personal Data security measures and Personal Data processing procedure (the Initiator) 1. Basic Policy Definitions: 1. Website means a set of graphic and information materials, as well as computer programs and databases ensuring their availability on the Internet at https://carely.group/ or http://loyalty-program.carely.group. 2. Depersonalization of personal data means actions resulting in the impossibility to determine, without additional information, whether Personal Data belongs to a particular User or another personal data subject; 3. Personal data processing means any action (operation) or a series of actions (operations) performed with or without means of automation, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (dissemination, provision, access), depersonalization, blocking, deletion, destruction of personal data. 4. Personal data means any information directly or indirectly relating to a specific or identifiable User. 5. User means any client who uses the Initiator’s services. 6. Provision of personal data means actions aimed at disclosing Personal Data to a certain person or group of persons. 2. General: 1. The Initiator’s primary goal and condition for its activities is to observe human and civil rights and freedoms when processing Personal Data, including the protection of rights to privacy, personal and family secrets. 2. The Initiator shall process the User’s personal data if they are filled in and/or sent by the User himself/herself through the Website special forms, or in the course of implementation of the provisions of the agreements with the User. By filling in the relevant forms and/or sending personal data to the Initiator, the User expresses his/her consent to this Policy (the Consent), as well as gives consent to receive informational newsletters. 3. Purpose of Personal Data Processing: 1. The purpose of the User’s Personal Data processing is to carry out the Promotion in accordance with these Rules and the legislation of the Russian Federation. The person willing to participate in the Promotion as well as the Participant agrees that the Initiator is entitled to transfer the personal data to third parties if it is necessary to fulfill the conditions of the Promotion. 2. By allowing Users to use the Website, the Initiator, acting reasonably and in good faith, considers that the User has all the necessary rights to transfer Personal Data, to grant the consent to the processing thereof. 3. The Initiator will not verify the accuracy of the information received (collected) about the Users, except in cases when such verification is necessary in order to fulfill the provisions of applicable legislation in force and/or obligations to the User. 4. The Initiator will collect and store only such Personal Data as is necessary for: ● performing the Initiator’s duties within the framework of the Promotion; ● mailing out information materials. 4. Data Processed by the Initiator: 1. The list of personal data provided by the person willing to participate in the Promotion and processed by the initiator or persons engaged by the latter includes all data specified during the Participant’s sign-up. 2. Other information processed by the Initiator: ● information about the pages visited on the Website; ● information automatically collected when accessing the Website using cookies ● data on hardware (devices): Host IP address, operating system type, browser type, geographic location, Internet service provider, data obtained by accessing the camera, microphone, other devices. 5. Personal Data Security 1. When processing Personal Data, the Initiator shall take necessary legal, organizational and technical measures to protect Personal Data from unauthorized or accidental access, destruction, change, blocking, copying, provision, distribution, as well as from other unlawful actions in relation thereto, as follows: ● ensures Personal Data security and takes all possible measures to prevent access thereto by unauthorized persons; ● defines threats to Personal Data security in the course of processing in information systems; ● evaluates the efficiency of measures taken to ensure the Personal Data security prior to the commissioning of the personal data information system; ● keeps records of the Personal Data storage media; ● detects unauthorized access to personal data and takes appropriate measures. 2. The Initiator is entitled to transfer the User’s Personal Data without the User’s consent to the following persons: ● State bodies, including law enforcement agencies, central or local executive bodies, other official, state or judicial bodies, in respect of which the Initiator is obliged to provide information in accordance with the applicable legislation upon the relevant request; ● Employees of the Initiator to fulfill the Initiator’s obligations to the User. 3. The Initiator is entitled to transfer the User’s Personal Data to its affiliates and (or) third parties exclusively for the purposes specified in Section 3 hereof. By becoming a Promotion participant, the User agrees to such transfer. The Initiator is not responsible for the compliance of third parties with personal data protection legislation. 6. Request / revocation handling procedure: 1. If the Organizer receives a request/revocation of consent to the Personal Data processing, the Initiator shall respond to the request/discontinue processing, except in cases where continued processing is expressly permitted by the legislation. 2. In this regard, the User is entitled to send to the Initiator a request / revocation of consent to the Personal Data processing provided for in Section 4, in writing to the following address: 426009, Izhevsk, Republic of Udmurtia, 20 Parkovaya str., apt. 200 or in the form of an electronic document signed by a qualified electronic signature in accordance with the legislation of the Russian Federation by e-mail to info@carely.group 3. The request/revocation sent by the User shall contain the following information: ● the number of the main identity document of the User or his/her representative; ● information on the date of issue of the specified document and the issuing authority; ● information confirming the relations of the User with the Initiator; ● signature of the User or his/her representative. 4. The Initiator shall consider and send a response to the User’s request within 30 days from the receipt. 5. The user can unsubscribe from the newsletter by following the link at the end of the newsletter. 7. Miscellaneous 1. This Policy and the relations between the Participant and the Initiator arising in connection with the Policy application are governed by the legislation of the Russian Federation. 2. All possible disputes shall be resolved in accordance with the legislation at the Initiators place of incorporation. The User shall follow the mandatory pre-trial procedure and send the corresponding claim in writing to the Initiator before applying to the court. The deadline for responding to a claim is 30 (thirty) business days. 3. The Initiator reserves the right to amend the Policy. The User shall read the Policy each time he/she uses the Website again. 4. The new Policy revision becomes effective upon publication in the appropriate section of the Website. Any amendments to the Policy from the effective date shall apply equally to all Users, including those who joined the Policy earlier than the effective date of the amendments. If the User does not agree with the amendments and additions made, he/she is entitled to send the revocation of consent to the Initiator according to the procedure stipulated in Section 6 hereof. The absence of the User’s actions specified in this clause shall be construed as acceptance of the new revision and other amendments to the Policy in accordance with clause 2, Article 438 of the Civil Code of the Russian Federation. 5. The user undertakes to independently monitor amendments to the Privacy Policy by reading the current revision.