1. Preamble

Valuing Customers’ trust and understanding the importance of ensuring the confidentiality of Customers’ Personal Data, as well as that of the Informational Materials posted by Customers on the Website in the course of fulfilling the provisions of the Terms and Conditions, the Administrator puts into effect this Policy to define the order for performing operations involving the Parties’ Confidential Information when using the Website and the System’s Services.

Every Customer should be familiar with the terms of this Policy before starting to use the System's Services.

The Privacy Policy was last updated on: March 8th, 2017 

2. Definitions of Terms

Unless it is otherwise explicitly stated in or follows from the main text of the Terms and Conditions, the following words and phrases shall be used in the meanings as specified below:

2.1. Cookie is a piece of Data that does not contain any Personal Data, which is created by the Website and stored on the Customer’s computer as one file or multiple files. If the Customer chooses to block a Cookie file, the Customer may experience difficulty or find it impossible to use the Website.

2.2. Informational Materials (Data) are any text, graphic, audio, video, and mixed-type materials of informational nature.

2.3. Confidential Information is any information that is not Public Data, which is considered confidential under the Parties’ agreement or in accordance with the applicable laws.

2.4. Confidentiality is accessibility of information solely to its owner, as well as any parties to which such information can and/or must be provided under law and/or under agreement with this party.

2.5. Public Data is any data (including Personal Data) to which the owner of such data provides access to an unlimited number of parties (including by means of publishing data on any website without restricting access to such data) or to which, in accordance with this Appendix and/or the effective laws, confidentiality requirements do not apply.

2.6. Personal Data is any information related, directly or indirectly, to a specific or identifiable individual person (the subject of personal data).

2.7. Receiving Party is the Party receiving Confidential Information.

2.8. Compromise of Confidential Information is one of the Parties’ actions or inaction resulting in the Confidential Information becoming known or available to third parties without the permission of the owner of such confidential information. The format of the information compromise (orally, in writing, via any technical devices, etc.) is immaterial.

2.9. Disclosing Party is a Member, in relation to the Confidential Information disclosed by the Administrator; and, it is the Administrator, in relation to the Confidential Information disclosed by a Member.

2.10. Disclosure of Confidential Information is transfer to any third party of any Confidential Information in compliance with the requirements of this Appendix, including leaking, stealing, losing, distorting, corrupting, destroying, modifying, copying, or blocking Confidential Information resulting from failure to comply or improper compliance with the terms of this Appendix by the Receiving Party.

2.11. The terms that are not defined in this section shall be used further in the text in the meanings as specified (in the order of priority) in bilateral agreements signed by the Parties and in the current version of the Terms and Conditions approved by the Administrator and all Appendixes thereto.

3. General Provisions

3.1. By using any part of the Website and/or the Services, the Customer gives the Administrator the right to receive, store, process, and use the Customer’s Personal Data and other Informational Materials in compliance with the terms of this Appendix.

3.2. This Appendix does not apply to, nor is the Administrator responsible for, any methods of receiving, storing, processing, using, and disclosing the Customer’s Personal Data and other Informational Materials by external companies and organizations that are not owned or managed by the Administrator and by individuals that are not the Administrator’s employees, even though the Customer may obtain access to such parties’ and persons’ websites, software and/or GWS via the Website.

3.3. The main purpose of receiving, storing, processing, and using the Customer’s Personal Data, Public Data, and other data is to protect the Customer’s interests, as well as to improve the quality of the personalized and general services provided by the Administrator to the Customer.

3.4. This Policy is not an independent document and serves only as an addition to the Terms and Conditions; it does not supersede or nullify any of the provisions included in the main text of the Terms and Conditions, in particular, Sections 10-14 of the Terms and Conditions related to the subject of this Policy.

3.5. The provisions contained in this document and the term ‘Confidential Information’ shall not apply to the information that:

3.5.1. was, is or is made available to the Receiving Party on the non-confidential basis from a party that, to the Receiving Party’s knowledge, is not bound by any confidentiality agreement with the other Party or by any other restriction related to disclosing confidential information to the Receiving Party, or

3.5.2. was in lawful possession of the Receiving Party prior to the other Party’s disclosing it as Confidential Information, or

3.5.3. is developed by or for the Receiving Party;

3.5.4. is not in any way protected by the Disclosing Party to ensure confidentiality;

3.5.5. is made available due to the requirements of the effective laws and regulations;

3.5.6. is publicly available and known due to the Disclosing Party’s actions and decisions;

3.5.7. was available to the Receiving Party on the non-confidential basis prior to the other Party’s disclosing such information, or

3.5.8. has to be disclosed in accordance with the effective laws or under orders issued by the governmental agencies or any other competent authorities.

4. Collection of Information

4.1. The Administrator can gather and process the following information about the Customer:

4.2. For the purpose of fulfilling mandatory legal obligations related to anti-fraud and anti-money laundering requirements, the Administrator will receive information related to the Customer from third parties, including information about the Customer’s financial history, any decisions of local district courts, bankruptcy, information provided by credit bureaus and anti-fraud agencies, when the Customer opens a Wallet or at any other time when the Administrator may deem it necessary to prevent fraud and minimize financial risks. More detailed information can be found in Appendix 02 to these Terms and Conditions.

4.3. During the Customer’s Registration in the System and when the Customer is creating a Wallet, the Customer has to provide their Authorization Data, as well as other details (mandatory or optional). After the Customer has created and used their Wallet, the Administrator is able to identify the Customer every time this Customer uses the System and visits the Website.

4.4. The Administrator may install cookies to Customers’ computers (unless the Customer purposely restricts this option in their browser), as well as receive, store, process, and use the information created through cookies.

4.5. When the Customer visits the Website, the Administrator automatically stores, processes, and uses the Customer’s data that is not their Personal Data, for example: Customer’s IP address, Customer’s location identifiable with their IP address, Customer’s computer’s technical parameters, presence or absence of specific software on the Customer’s computer, such software’s settings, cookies, as well as statistics on the Customer’s activities.

4.6. Besides visiting the Website, the Customer also provides information to the Administrator when using the System (if possible) via applications for mobile devices, social media applications, payment terminals, etc., contacting and submitting requests by phone, mail, email, or via other means of communication; the Administrator also receives information about the Customer from other sources when verifying the information previously provided by the Customer.

5. Use of Information

The Administrator shall use the available information related to Customers for the following purposes:

6. Disclosure of Information

6.1. The Administrator shall not provide any Personal Data to any third parties for commercial purposes without the permission of the Customer to whom this information is related.

6.2. Personal Data can be disclosed to such third parties in the following circumstances:

6. Disclosure of Information

6.1. The Administrator shall not provide any Personal Data to any third parties for commercial purposes without the permission of the Customer to whom this information is related.

6.2. Personal Data can be disclosed to such third parties in the following circumstances:

6.3. Unless otherwise agreed upon in writing with a specific Customer, the Administrator can publicly disclose the fact of the existence of the Administrator’s business relationship with this Customer.

6.4. The Administrator reserves the right to disclose confidential information when it is required by the business conduct practices.

6.5 No provision contained in this Appendix shall restrict either Party’s right to disclose any Confidential Information in accordance with any court order or decision, any other legitimate obligation or requirement under the effective laws and regulations if such information disclosure is mandatory and on the condition that, if possible, the other Party is notified of such information disclosure in advance.

6.6. All Confidential Information shall remain the property of the Party disclosing such information; no rights or licenses are granted with regard to such Confidential Information, unless otherwise specifically stipulated in this Appendix.

6.7. Either Party shall return to the other Party and/or securely destroy all Confidential Information (including any part of it that may be undergoing processing, analysis, or translation, including also all copies, written notes, drawings, charts, computer programs in any and all formats, on any type of a data storage device) on the other Party’s written request, unless such documents have to be stored under the effective laws and regulations, and, if required, shall confirm in writing, with the authorized person’s signature, that such Confidential Information was duly returned or securely destroyed.

6.8. The Customer has the right to request that the Administrator restrict third parties’ access to the Customer’s Personal Data for marketing purposes, provided that it does not contradict the applicable laws and the Terms and Conditions, by sending a relevant written request to the Administrator using the Administrator’s Contact Details.

7. Processing of Information

7.1. By providing their Personal Data during the Registration in the System, the Customer agrees to data processing, with or without the use of automation technology and/or devices, in particular, information gathering, storage, transfer to third parties, and use by the Administrator for the purpose of providing the Services to the Customer and for other purposes specified in the Terms and Conditions.

7.2. If the Customer does not wish for their Personal Data to be processed, the Customer should contact the Administrator using the Administrator’s Contact Details or the feedback form on the Website. In this case, all the information received from the Customer will be deleted from the Administrator’s client database, and the Customer will not be able to use the Services.

8. Access to Information

8.1. For the purpose of exercising Customers’ rights and the Administrator’s proper fulfillment of its obligations under the Terms and Conditions and the agreements signed by the Parties, the Administrator may review Customers’ Informational Materials (for the purpose of timely resolution of technical problems and prevention of unlawful activities that violate the rights of either Party, other Customers, etc.).

8.2. The Administrator provides limited access to Customers’ information only to the employees that, in the Administrator’s opinion, need to use such information to provide services to the Customers or perform their professional duties.

8.3. The Customer has the right to request, edit, or delete their Personal Data stored by the Administrator and/or on the Website. The Customer may independently edit, change, or delete their Personal Data using the relevant features of the Website and their Wallet.

8.4. The applicable laws on personal data protection give the Customer the right of access to any information related to the Customer. Any request for access to information may result in charges to cover any and all expenses involved in providing the Customer with detailed information stored by the Administrator and/or third parties.

9. Sending Messages to Publicly Accessible Pages

9.1. A publicly accessible page is any page of the Website to which unlimited access is open to any party and which can be indexed by search engine systems.

9.2. The Administrator allows the Customers to send messages and exchange Data on publicly accessible pages.

9.3. The Customer should exercise caution and common sense when disclosing their information that allows identifying the Customer on publicly accessible pages. It is important to remember that this information may remain on publicly accessible pages of the Website for an indefinite period of time. Besides, depending on a specific Service, other Customers may also view such information.

9.4. The Customer is solely responsible for any information that the Customer discloses and distributes on publicly accessible pages.

9.5. If the Customer has any concerns regarding information that allows identifying the Customer which the Customer provided on any publicly accessible page, the Customer cannot delete or edit such information; in such cases, the Customer should contact the Customer Support Service.