Administrator appreciating the trust of its Customers and realizing the importance of ensuring the confidentiality and security of Personal information of its Customers as well as Information posted by Customers on the Website in the execution of the Rules enacts this Policy to determine the order of performing operations with confidential data of the Parties when using the Website and Services. Knowing this Policy before using the Services provided by the System is mandatory for all Clients.
In this document, if from the main text of the regulation expressly requires otherwise,the following words and expressions shall have the following meanings:
2.1. A Cookie is a piece of Data not containing Personal data created by a Website and stored in the Client computer in the form of one or more files. The blocking Cookie the Client will lead to difficulties of using the Website or full impossibility of its use.
2.2. Informational materials (Data) are any text, image, audio, video and mixed materials of informational character.
2.3. Confidential information - any information not related to the Public data which the Parties have agreed or applicable law requires be treated as confidential.
2.4. Privacy - availability of information only to its owner and the persons to whom this information can and (or) must be provided by law and (or) the agreement with this person.
2.5. Public data – data (including Personal data) to which the person who owns these data, provided access to the public (including by posting on any Internet website without restricting access to this data) or that according to the Application and (or) current legislation subject to the confidentiality requirement.
2.6. Personal data - any information relating to an identified or identifiable natural person (personal data subject).
2.7. The receiving Party - the Party receiving Confidential information.
2.8. Disclosure - the act or omission of one party, which Confidential information has become known to third parties in the absence of the consent of the owner of the confidential information. The form of disclosure (oral, written, using technical means, etc.) doesn't matter.
2.9. Disclosing party in relation to the Confidential information disclosed by the Administrator, a Participant; with respect to Confidential information disclosed by the Party Administrator.
2.10. Disclosure of Confidential information, transfer to third parties any information which is Confidential in accordance with the requirements of this Annex, including leakage, plunder, loss, distortion, forgery, destruction, modification, copying, blocking of Confidential information as a result of default or improper performance of the terms of this Application by the Receiving party.
3.1. Using any part of the Site and (or) using any of the Services, the Client gives the Administrator the right to receive, store, process, use Personal data and other Informational materials of the Client on the terms and conditions of this Application.
3.2. This Application does not govern and Administrator shall not be responsible for the receipt, storage, processing, use and disclosure of Personal information and other Informational materials of the Client third party companies and organizations that are not in the possession or under the control of the Administrator, and individuals who are not employees of the Administrator, even if the Customer has accessed the Website.
3.3. The main purpose of the receipt, storage, processing and use of Personal, Public and other Customer data is to protect the interests of the Client, as well as improving the quality provide the Client with personalized services and General services provided by the Administrator.
3.4 this Policy has no independent nature and is a Supplement to the Rules and does not supersede any provision of the main text of the Rules.
3.5 the Provisions of this document and the concept of "Confidential information" shall not apply to information which:
3.5.1 was, is or becomes available to the Receiving Party on a non-confidential basis from a person who according to the information of the Receiving Party, not bound by any confidentiality agreement with the other Party or otherwise prohibited to disclose confidential information to the Receiving Party, or
3.5.2 was in lawful possession of the Receiving Party before disclosure to it by the other Party as Confidential information, or
3.5.3 developed by the Receiving Party or to her;
3.5.4. on which the Disclosing party fails to take measures to protect its confidentiality;
3.5.5. to which you have access in accordance with the requirements of existing legal acts;
3.5.6. is publicly known as a result of actions and decisions most of the Disclosing party;
3.5.7 was available to the Receiving Party on a non-confidential basis before the date of disclosure by the other Party, or
3.5.8. must be disclosed in accordance with law or by presenting legitimate demands of government or other competent authorities.
4.1. The administrator may collect and process the following Customer information: full name and surname, occupation, address, email address, telephone number, date of birth and Bank or payment card, as well as documents confirming the identity and address of the Client, at our request;
information about Transactions that the Client carries out through the System using the Purse, and the fulfillment of Customer Orders;
4.2. With the aim of fulfilling its legal obligations to combat fraud and money laundering, the Administrator will obtain Client-specific information from third parties, including information about his financial history, decisions of local and bankruptcies, from credit bureaus and agencies to prevent fraud, when you open the Customers Wallet and any other time when it deems it necessary to prevent fraud and minimize their financial risks.
4.3. When Registering in the System and creating a Wallet, the Client must specify its credentials, and (mandatory or optional) other data. After creating and using a Client Wallet, the Administrator can identify the Customer each time they use the System and every time you visit the Site.
4.4. The administrator has the right to load on the client computers cookies (if the Client does not itself have restricted this feature in your web browser), and to receive, save, process and use the information generated by the cookie.
4.5.When the Client visits the Site, the Administrator automatically saves, processes and uses the Client’s data that are not personal, such as, for example: the IP address of the Client, data on the location of the Client, which can be determined using his 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, as well as statistical information about the Client’s activity.
4.6. In addition to visiting the Site by the Client, the Client also provides information to the Administrator when using the System (eventually) through applications for mobile devices, applications for social networks, payment terminals, etc., when making calls and inquiries by phone, mail, e-mail and other channels , as well as the Administrator receives information about the Client from other sources in the process of checking the information provided earlier by the Client.
The Administrator uses the information concerning the Clients at his disposal in the following ways:
● for servicing Clients' Wallets and providing the Services requested by them;
● for fulfillment of Orders of Clients on making Transfers of Funds and receiving Payments and performing Transactions using the Services;
● to inform Customers about changes in the Services and in the System, in the Rules and in the software, etc .;
● to fulfill the requirements of applicable law and regulations, and in particular the requirements of anti-laundering legislation and KYC procedures (“Know Your Client”);
● to check the financial condition, identity and creditworthiness of Customers;
● to carry out checks to prevent fraud and money laundering;
● for customer service, including answers to questions, comments and complaints;
● to increase the security of the Services;
● to present the contents of the Site (including its interactive functions) in the most efficient way for Clients and their computers;
● to provide the goods/services to Clients that they request or which, in the opinion of the Administrator, may interest them;
● to assist in the development, provision and improvement of System Services, as well as the content of the Site and informing Customers;
● for the internal purposes of the Administrator, such as conducting an audit, analytical data processing and assessing the quality of the Services provided, etc.
6.1. The Administrator agrees not to provide Personal Data to third parties for commercial purposes without the consent of the Client to whom this data relates.
6.2. Transfer of Personal data to third parties is allowed in the following cases:
● after obtaining the consent of the Client to whom the information relates;
● at the reasonable request of government bodies entitled to receive such data;
● the provision of data to agents and third parties acting under contract with the Administrator, to fulfill obligations to the Customer (including, but not limited to, acquirers, issuers of payment cards, international card system, providers, billing or delivery companies, affiliated persons of the Administrator, etc.) and upon the conditions that:
1) they are informed of the confidential nature of such information;
2) they maintain appropriate security measures to protect confidential information from unauthorized access or use; potential lenders, investors, acquirers, Partners, shareholders, auditors of the Administrator; companies that can offer their products and services to Customers; in the exchange of information with other companies and organizations for fraud protectionand reduction of financial risk; if, in the opinion of the Administrator, the Client violates the terms of this Application and (or) other treaties and agreements between the Administrator and the Client, and (or) internal rules and rules of the Administrator, or if in the opinion of the Administrator, such provision is necessary in order to investigate, prevent, or take action against illegal activities, suspected fraud, potential threats to the physical safety of any person, violations of conditions, Rules orbilateral agreements or required by law; in other cases, in accordance with the provisions of the Rules and applicable law.
6.3. If not agreed otherwise in writing with the Client, the administrator has the right to publicly disclose the fact of their business relationship with a Client.
6.4. The administrator reserves the right to disclose confidential information when required by rules of business.
6.5 Nothing in this App will not limit any of the Parties in law to disclose any Confidential formation in accordance with judicial or other decision of a legitimate statutory or regulatory obligation, if such disclosure is necessary and provided that, where possible, of the fact of such disclosure to the other Party will be informed in advance.
6.6. All Confidential information will remain the property of disclosing its Hand, and no right or license with respect to such Confidential information is not provided, except for the cases specifically stipulated in this Appendix.
6.7. Each party will return will return to the other Party and (or) securely destroy all Confidential information (including the part that may be in the treatment, research or transfer, respectively, with all copies, including records, drawings, diagrams, computer programs in whatever form and on whatever media they were not) at the written request of the other Party, if the preservation of these documents will not require any legislative or regulatory obligations, and, if necessary, will testify in writing, signed by an authorized person, that it was done.
6.8. The customer is entitled to request the Administrator to restrict access of third parties to their Personal data for marketing purposes, if not inconsistent with the provisions of applicable laws and Regulations, by sending appropriate request to the Administrator address on the payment Details.
7.1. Providing his Personal data during Registration in the System, the Client agrees to its processing both using automation tools and without using automation tools, in particular, collection, 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.
7.2. If the Client does not want his Personal data to be processed, then he must contact the Administrator for Details. In this case, all information received from the Client is deleted from the Administrator’s client base and the Client will not be able to use the Services.
8.1. In order to exercise the rights of Clients, as well as the proper fulfillment by the Administrator of his obligations stipulated by the Rules and agreements of the Parties, the Administrator may study the Information Materials of the Clients (in order to timely resolve technical problems, suppress illegal actions that violate the rights of any of the Parties, other Clients, etc. .).
8.2. The Administrator provides limited access to the Personal Data of Clients only to those employees who, in his opinion, really need to use this information in order to provide Clients with services, or in order to fulfill their official duties.
8.3. The Client has the right to request, change or delete his Personal Data, which is located at the Administrator and (or) on the Site. The Client can independently change or delete his Personal Data using the appropriate functions of the Site and his Wallet.
8.4. The applicable legislation on the protection of personal data gives the Client the right to access information about him. Moreover, 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.
9.1. The parties guarantee the confidentiality of the information received during the execution of the requirements of the Rules, unless otherwise expressly provided for in the Rules and other agreements of the Parties.
9.2. The Client, who has violated the obligation to maintain confidentiality of information, is obligated to compensate all losses (including lost profits) received by third parties and (or) the Administrator as a result of these actions of the Client.
9.3. Confidentiality conditions are contained in these Rules and are accepted by the Client in full upon acceptance of the Rules.
9.4. The Parties undertake NOT to disclose information about the operating conditions of the System, as well as other information received by the Parties in the course of fulfilling their obligations under the Rules, unless the Party is obliged to provide such information in accordance with applicable law.
9.5. The parties are obliged to inform each other within 1 (one) business day of the fact of disclosure or threat of disclosure made by them or made known to them, illegal receipt or illegal use of Confidential Information by third parties.
9.6. The parties shall not have the right to unilaterally terminate the protection of the confidentiality of this information provided for by these Rules, including in the event of their reorganization (merger, accession, separation, separation, transformation or any other form of change in legal status) or (in cases provided by law) liquidation .
9.7. It is not a violation of confidentiality to provide Confidential information at the legal request of law enforcement and other authorized state bodies and (or) officials in cases and in the manner prescribed by applicable law.
9.8. In the event that the Confidential Information is disclosed to these authorities and / or persons, the Party that disclosed the Confidential Information shall notify in writing the owner of the Confidential Information about the fact of providing such information, its content and the authority to which the Confidential Information was provided, no later than 1 (one) business day from the date of disclosure of the Confidential information.
9.9. As follows from other sections of these Rules, Customers 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 the Clients.
10.1. The Administrator has the right to save the Client’s Personal and other data for as long as necessary to achieve the goal specified in this Appendix, or within the time period established by applicable law, or until the Client removes this data.
10.2. The client is responsible for providing reliable information, as well as for updating the previously provided data in case of any changes.
10.3. The Client allows the Administrator to allow other persons with whom the Administrator has entered into relevant agreements to receive, save and process data about the Client (except for Personal Data and Information Materials), such as the IP address of the Client, cookies, as well as statistical information about the Client’s activity, for improving the quality of services provided by these persons and providing information of an advertising nature.
10.4. The Client agrees that the confidentiality of data transmitted via the Internet is not guaranteed if access to this data is obtained by third parties outside the area of technical communications controlled by the Administrator, and the latter is not responsible for damage caused by such access.
10.5. If, when using the Site and (or) the System, the Client has somehow become aware of information regarding the Administrator and (or) third parties, which, according to applicable law, is confidential and (or) a trade secret, the Client is prohibited from storing, using and distributing such information.
10.6. When you click on the links on our Site, you may end up on third-party sites. We do not bear any responsibility for the content of these third-party sites, as well as for the personal data that these sites may collect, including policies for the storage and use of such data. Third-party sites may have their own rules for working with personal information. We strongly recommend that you familiarize yourself with the information on this subject on third-party sites in order to understand what rules determine the work with your personal data. After you leave our Site, the provisions of our Privacy Policy cease to apply.