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Privacy Policy Date of publication: 16 Jan 2019 Current version is available at here: 1. What does this Privacy Policy cover This Privacy Policy (“Policy”) covers any information, about you that may include personal data as defined by applicable laws and regulations (“Personal information”), which Sole trader Roman Zolotarev (“ST”) may obtain when you use any of the ST websites, programs, products or services, (collectively, the “Services”), information about which you can find on,,,, (collectively, the “Sites”), and as well as during the performance of any contract or agreement the ST conclude with you in relation to your using the Services. Also, Personal information can be obtained by the ST through its partners (“Partners”), such as advertising partners, who provide you with access to or let you use websites, programs, products or services owned or operated by them. Partners can provide Personal information to the ST only as stipulated by applicable laws and regulations and in accordance with special agreements between the ST and each of the Partners. Payment transactions are processed by Paddle. Paddle Buyer Privacy Notice available at 2. Who processes your personal information To provide you with access to the Sites and Services, your Personal information is collected and used by Sole trader Roman Zolotarev registration number 317169000003180. 3. What is the purpose of this Policy When you use the Sites and/or Services, the ST processes your Personal information and ensures its protection in strict compliance with applicable laws and regulations. 4. What type of Personal information is collected Personal information collected when you use the Sites and/or Services may differ depending on whether you access the Sites or Services while logged in to your user account or without logging in. When you are logged in to your user account as you are using the Sites or Services, Personal information collected by the ST may be collated and combined with other Personal information collected by the ST in your user account. The ST does not verify Personal information provided by you and cannot posit if it is true and whether you have the legal capacity required. However, the ST assumes that the information you provide is true, sufficiently complete and up-to-date. Personal information collected by the ST when you access, interact with or operate the Sites and/or Services includes: (i) Information provided by you when you register (create) a user account, such as your name and email address; (ii) electronic data (HTTP headers, IP address, cookies, web beacons/pixel tags, browser information, information about your hardware and software); (iii) date and time of accessing the Sites or Services; (iv) information related to your activity when using the Sites or Services; and (v) information about you that we may receive from a Partner of the ST in accordance with an agreement you made with this Partner and an agreement between the ST and this Partner. In addition, the ST uses cookies and web beacons (including pixel tags) to collect your Personal information and associate this Personal information with your device and web browser (see Section 10 below). The ST does not actively collect any sensitive personal data (such as racial origins, political opinions, health, or biometric data). The ST does not perform any form of profiling which has the potential to significantly impact your rights and freedoms. 5. What are the legal basis and the purposes for processing your Personal information The ST is not allowed to process your Personal information if it does not have a valid legal ground. The ST will therefore only process your Personal information if: (i) The processing is necessary to perform our contractual obligations towards you including providing you with Sites and/or Services; (ii) the processing is necessary to comply with our legal or regulatory obligations; or (iii) in case it is provided by applicable law, the processing is necessary for the legitimate interests of the ST and does not unduly affect your interests or fundamental rights and freedoms. Please note that when the ST processes your Personal information on this basis, the ST will always seek to maintain a balance between legitimate interest of the ST and the protection of your privacy. Examples of such legitimate interests are: to better understand how you interact with our Sites and/or Services; to enhance, maintaining accessibility, modify, personalize or otherwise improve the Sites and Services for the benefit of all users; and to offer you other products and services from the ST or other companies which we think can be of interest to you (i.e. personally-targeted advertising). (iv) for specific purposes we may ask your consent for processing of your Personal information. The ST always processes your Personal information for a specific purpose and only processes Personal information which is relevant to achieve that purpose. In particular, we process your Personal information for the following purposes: (i) To provide you with the Sites and/or Services; (ii) to provide you with access to your user account; (iii) to contact you to notify and/or inform you or request information from you in relation to the Sites and Services, or to execute our agreements with you or process your request or application; (iv) to provide advertisements and/or commercial offers based on your preferences and other Personal information available to the ST; (v) to improve user experience; (vi) to develop new products, applications, and services; (vii) to protect your rights and the rights of the ST; and (viii) to collect, process and present statistical data, or perform other research and/or analysis of Personal information. 6. How your Personal information is protected In most cases, Personal information is processed automatically. To protect your Personal information and ensure its confidentiality, the ST follows technical and organisational measures to protect Personal information against unauthorised, accidental or unlawful destruction, loss, alteration, misuse, disclosure or access and against all other unlawful forms of processing. These security measures have been implemented taking into account the state of the art of the technology, their cost of implementation, the risks presented by the processing and the nature of Personal information. 7. Who else has access to your Personal information The ST may transfer Personal information to third parties to complete the purposes listed in Section 5 above. Such third parties may include: (i) Partners, such as media publishers, advertising networks and other partners providing ST with services related to the placement and display of advertisement on the websites, programs, products and/or services owned or operated by such Partners; (ii) advertisers or other Partners serving targeted advertisement on the ST Sites or Services; and third parties who process Personal information, such as IT systems providers and/or consultants. (iii) any third party to whom we assign or novate any of our rights or obligations under a relevant agreement; (iv) any national or international regulatory, enforcement, exchange body, central or local government department and other statutory or public bodies or court where we are required to do so by applicable law or regulation at their request; (vi) third parties if you expressed your consent to such transfer or transfer of your Personal information is required for your use of a certain Service or performance of a particular agreement or contract with you; (iv) any third party to ensure legal protection for the ST and/or the third parties if you violate the User Agreement of any of the ST Services (, this Policy, or if there is a threat of such violation. 8. For how long do we store your Personal information The ST will only keep your Personal information for as long as it is necessary to fulfil the purpose for which it was collected or to comply with legal and regulatory requirements. If you wish to have any Personal information removed from databases of the ST, you can have it removed via your account or using interface of the Sites or Services (where applicable). 9. Your rights 9.1 What are your rights If it is provided by applicable law, you have a right of access to your Personal information as processed by the ST under this Policy. If you believe that any information we hold about you is incorrect or incomplete, you can log in to your user account and correct your Personal information yourself. If it is provided by applicable law, you also have the right to: request erasure of your Personal information; request the restriction of the processing of your Personal information; object to the processing of your Personal information if it is provided by applicable law. The ST will honour any such requests or objections as required under applicable law. To the extent provided by applicable law, you may be subject to other rights not specifically mentioned herein. 9.2 How can you exercise your rights To exercise the above rights, please log in to your user account, which will provide you with the option to do so, or in case of absence of special function in user account interface please contact the ST (see Section 12 hereof). If you are not satisfied with how the ST processes your Personal information, please let the ST know and the ST will investigate your concern. If you are not satisfied with response from the ST, you have the right to make a complaint to the competent data protection authority. 10. How do we use cookies 10.1 What are cookies Cookies are small text files placed on the device you use to access our Sites. They contain information that is collected from your device and sent back to the Sites on each subsequent visit so as to remember your actions and preferences over time. The following types of cookies are used on the Sites: strictly necessary cookies: these cookies are required to run the Sites and provide you with the Services and may, among other, allow the ST to identify your hardware and software, including your browser type; statistical cookies: these cookies enable the ST to recognise users, count the number of users and collect information such as your actions on the Sites and the Services, including the web pages you visit and the content you retrieve; performance cookies: these cookies collect information about how users interact with the Sites and Services, enabling the ST to identify errors and test new functionalities to improve the performance of the Sites and the Services; functionality cookies: these cookies enable the ST to provide specific functionalities in order to improve your experience on the Sites, for example by storing your preferences; advertising cookies: these cookies collect information about users, sources of traffic, page visits and advertising displayed to you and followed by you. They enable the ST to display advertising which may be of interest to you based on collected Personal information. These cookies are also used for statistical and research purposes. 10.2 How long are those cookies stored on your device ST only uses the information contained in the cookies for the above purposes, after which the data collected will remain stored on your device for a period that may depend on cookies type, but no longer than necessary to achieve their purpose and will be automatically removed from your system thereafter. 10.3 Who else has access to the information contained in the cookies Personal information collected through cookies placed on your device may be transmitted to and accessed by the ST or the third parties referred to in Section 7 hereof. The use of Personal information outside of the Sites for advertising purposes, if any, may be subject to separate policies available on the above third parties' websites. The ST or those third parties might also provide you with a possibility to opt out of receiving targeted advertising, which shall be subject to laws and regulations applicable to such products, utilities and offerings. You can delete the cookies stored by your browser (usually via the options in your browser’s Privacy menu — please refer to your browser’s manual or developer’s website). If you do not consent to the use of cookies, certain features of the Sites might become unavailable, which may affect your browsing experience. You may also set up your browser preferences to accept or decline by default all cookies or cookies from specific websites, including the Sites. The ST may also use web beacons (pixel tags) in order to access the cookies previously placed on your computer for the following purposes: (i) to track your actions on the Sites and when using the Services, by accessing and interacting with the cookies stored on your computer; (ii) to collect statistical information related to operating the Sites, the Services or products, utilities, advertisements or other ST offerings. 11. Updates to this Policy This Policy may be subject to amendments. The ST shall be entitled to make such amendments at discretion of the ST, including, without limitation, to reflect changes in applicable legislation or amendments to the Sites and/or Services. The ST undertakes not to introduce significant changes, imposing additional obligations or reducing your rights under this Policy without proper notice to you. You will be notified about such changes. If applicable, changes will be announced on the Site (e.g. via a pop-up or web banner) prior to such changes taking effect, and you may also be notified via other channels (e.g. by email) if you have provided us with your contact details. 12. Questions and Suggestions The ST welcomes your questions or suggestions concerning implementation of or amendments to this Policy. To contact the ST please use this feedback form: You can also use this form to exercise your rights or report any inaccuracies in your Personal information or protest its processing.

Date of publication: 16 Jan 2019 1. General Provisions 1.1. Sole trader Roman Zolotarev (TIN 16570847237; registration number 317169000003180; address Kazan, Tatarstan Republic, Russian Federation) (hereinafter — ST) offers Internet users (hereinafter — the User) the opportunity to use its Services on the terms and conditions of this User Agreement (hereinafter — the Agreement, User Agreement). This Agreement shall take effect upon the User’s express agreement with its terms according to Clause 1.4 hereof. 1.2. The ST offers to the User access to Services. All currently available Services as well as their development and/or addition of new Services shall be the subject of this Agreement. 1.3. The use of Services shall be regulated by this Agreement and Privacy Policy ( This Agreement may be amended by the ST without notice, and a new revision of this Agreement shall take effect when posted online at the web address given in this paragraph, unless otherwise stated in the new revision of this Agreement. The current revision of this User Agreement is always available at 1.4. By starting the use of any Services/certain functions or going through the registration procedure, the User shall be deemed to have accepted the terms of this Agreement in full without any limitations or exceptions. If the User does not agree to any provisions of this Agreement, the User must not use Services of the ST. If the ST makes any amendments to this Agreement as prescribed by Clause 1.3 hereof to which the User does not agree, the User shall cease to use any Services of the ST. 2. User Account 2.1. To use certain Services or certain specific functions of Services, the User shall complete registration to create a unique account. 2.2. Upon registration the User shall provide valid and complete information requested in the registration form and shall regularly update such information. If the User provides invalid information or the ST has reasons to believe that any information provided by the User is incomplete or invalid, the ST may at sole discretion of the ST block or delete the User’s account or deny the User the use of any Services (or certain functions). When signing up, the User may upload an image for the User’s profile (avatar). The profile image can be attached to the User’s posts in Services. The profile image shall meet the requirements of Section 4 of this Agreement. When the User uses the User’s image as a profile image, the User is aware and agrees that the ST may publish and further use the User’s image in Services, promotional items, corporate blogs, and the ST accounts in third-party resources. 2.3. The ST shall reserve the right to require at any time that the User verify the information provided upon registration and to request supporting documents (personal identification documents in particular); failure to provide these documents may, at the ST’s discretion, be regarded as provision of invalid information and entail consequences according to Clause 2.2 hereof. In case the User’s information specified in the documents fails to conform to the information provided upon registration or if the information provided upon registration does not make it possible to identify the User, the ST shall reserve the right to deny the User’s access to the User account and to usage of Services. 2.4. Any personal information of the User contained in the User account shall be stored and processed by the ST according to Privacy Policy ( 2.5. Means of access to the User’s account. 2.5.1. Upon registration the User uses the User’s own email address to access the account. 2.5.2. After registration, the User will be able to access the User’s own account using alternative means of authentication replacing the previously chosen email address. 2.5.3. When the User logs in, the data entered by the User on the User’s own device can be automatially saved on the User’s device until the end of User session under the User’s account. The credentials automatically saved on the User’s device can be used to access Service of the ST. 2.6. The User shall be responsible for security of the chosen means of access to the User’s account and for confidentiality of such means. The User shall be responsible for any actions (and their consequences) in and with Services through the User’s account. Any actions in or with Services of the ST performed through the User’s account shall be considered done by the User, except for the cases when the User as prescribed by Clause 2.6 hereof notifies the ST of unauthorized access to Services through the User’s account and/or any other breach (alleged breach) of confidentiality of the chosen means of access to the User’s account. 2.7. The User shall promptly inform the ST of any instances of unauthorized (not allowed by the User) access to Services through the User’s account and/or any breach (alleged breach) of confidentiality of the chosen means of access to the User’s account. For security reasons, the User shall securely log out after completing each session (Log Out button) of operating Services. The ST shall not be responsible for any potential loss or damage of information as well as any other consequences appearing as a result of failure by the User to comply with this part of this Agreement. 2.8. The User may not reproduce, duplicate or copy, sell, resell or use for any commercial purposes any parts of Services (including content available to the User through Services) or access to Services, except when authorized by the ST. 2.9. The ST may block or delete the User’s account as well as prohibit access through any account to certain Services and delete any content without giving reasons including in case the User violates the terms of this Agreement and terms of any documents listed in Clause 1.3 hereof and in case of failure to use a service. 2.10. User account deletion. 2.10.1. The User may at any time delete its account at all Services or, if such option is available, terminate the account in respect of certain Services. 2.10.2. An account shall be deleted by the ST as follows: an account is blocked for 30 days during which the User cannot access the User’s own account, while the content posted through such account may be deleted; if within such period the User’s account is restored, the User’s access to the account will be renewed, but the content posted through such account might not be restored; if within such period, the User’s account is not restored, all content posted through the account shall be deleted, and the login shall be available to other users. From such moment, restoration of account or any related information as well as access to Services through the account is not available. 2.11. The User shall not share User’s account with any other people (or robots). 3. General Usage and Storing Provisions 3.1. The ST may impose restrictions on the use of Services for all Users including: availability/unavailability of certain service functions, content, maximum number of service uses in a certain period, etc. The ST may prohibit automatic requests to servers of the ST as well as terminate acceptance of any automatically generated information (for instance, spam). 3.2. The ST has the right to send information messages to the users. Using the Services, the User agrees to receive advertising messages in accordance with Part 1, Article 18 of the Law “On Advertising”. The User has the right to decline receiving advertising messages by using the corresponding functionality of the service, as part of which or in connection with which the User has received advertising messages. 3.3. To improve the quality of Services, the ST may collect opinions and feedback of Users on various matters sending an info message, when the User visits the service once again. Collected opinions and feedback can be used to form statistics, which can be used in Services. The ST can also publish feedback submitted by the User through its account in Services with and without the user name indicated. When writing feedback, the User undertakes to be guided by the requirements of this Agreement, including the requirements stipulated by cl. 5 of this Agreement. 4. User Content 4.1. The User shall be responsible for compliance of any content posted by the User with applicable legal requirements including responsibility to third parties in case posting by the User of any content or its subject matter infringes on rights and legitimate interests of third parties including personal non-property rights of authors, any other intellectual property rights of third parties and/or encroaches on other intangible assets. 4.2. The User acknowledges and agrees that the ST is not under obligation to review any content posted and/or distributed by the User through Services and that the ST has the right (but shall not be obliged to) at its discretion to prohibit the User from posting and/or distributing content or may remove any content available through Services. The User acknowledges and agrees that the User shall independently assess any risks related to using content including its reliability, validity or usefulness. 4.3. The User acknowledges and agrees that technologies of service operation may require reproduction (replication) of User content by the ST as well as its processing by the ST for compliance with technical requirements of a particular service. 5. Terms of Service Use 5.1. The User may use standard features of the Service free of charge. Advanced features of the Service are available subject to subscription (hereinafter — Subscription). 5.2. With the Subscription, the User signs a contract with the ST (hereinafter — Contract) as specified in this document and provisions of Art. 429.4 of the Civil Code of the Russian Federation (subscription contract). Under the Contract, the ST undertakes to provide advanced features of the Service to the User for the Subscription Period, and the User undertakes to pay the Subscription cost. For the purposes of these Terms, the Subscription Period means a period of time (e.g., 30 or 365 days) for which the User subscribes and a respective fee is charged. 5.3. Information on the subscription fee, payment methods and the Subscription Period as well as information on other privileges available with the Subscription can be found at This information forms part of this Agreement and is covered by the rules of cl. 1.3 of this Agreement. The User understands and agrees that the list of privileges available at may be changed, inter alia, may be extended/shortened. Payment transactions are processed by Paddle. Paddle Buyer Terms and Conditions available at 5.4. The User may be provided with the discount at sole discretion of the ST. 5.5. The User will pay upfront. The Subscription will be provided to the User with all the functions and in full from when the User is granted access to the Service. No other moment can be construed as the time the ST discharged the obligations it assumed. The ST reserves the right to make advanced features of the Service accessible to the User before the subscription fee is paid. In this case, the ST will be deemed to have discharged all its obligations when the User is granted access to the Service. 5.6. With the Subscription, the User authorizes the ST to charge, as a prepayment, in each Subscription Period the User specified when subscribing, the subscription fee the ST will set on the day of payment, until the User refuses to renew the Subscription for the next Subscription Period. The User may ask for a refund for the last Subscription Period within 14 days since the most recent charge for User’s account. 5.7. The User understands and agrees that the Subscription, by default, is indefinite from when the first Subscription Period is paid for. The User may refuse to renew the Subscription for the next Subscription Period. Besides, the ST may terminate the Subscription in other cases or on other grounds as specified in the Argeement. 5.8. The User’s refusal to pay the subscription fee for the relevant Subscription Period constitutes the User’s refusal to renew the Subscription. In this case, user access to advanced features of the Service will terminate from the day following the last day of the paid Subscription Period. 5.9. The Service can only be used with access to the Internet. The User will independently gain and pay for such access under the terms and rules of the User’s telecoms operator or Internet provider. 5.10. As a general rule, the User is identified according to details of the User’s account. The ST may use other data to identify the User, including payer data, if such identification does not violate the rights of the parties, the rights of third parties, or the current laws. 5.11. Where the current laws permit, when the Subscription is paid online, when the said payment is refunded, a cash voucher will be e-mailed to the address specified at invoicing or created at registration of the User’s account authorized with to make the payment. 5.12. Upon using the Service, the User shall not: download, send, transmit or in any other way post and/or distribute any content that is illegal, harmful, slanderous, unethical or violates intellectual property rights, promotes hatred and/or racial, ethnic, sexual, religious or social discrimination or is insulting to any persons and/or organizations; violate third-party rights including underage people and/or cause harm in any way; impersonate any other person or representative of an organization and/or community without being authorized to do so, including employees of the ST, forum moderators, website owners and apply any other forms and methods of unlawful representation of other persons online as well as mislead other users and the ST regarding features and characteristics of any subjects or objects; download, send, transmit or otherwise post and/or distribute content if not authorized to do so by law or contract; download, send, transmit or otherwise post and/or distribute unauthorized advertising information, spam (including spamdexing), lists of e-mail addresses of other people, pyramid schemes, multilevel marketing (MLM), Internet earning systems and e-mail businesses, chain letters as well as use the ST service for participation in any of the above; download, send, transmit or otherwise post and/or distribute any materials containing viruses or other computer codes, files or programs designed to breach, destroy or limit the operation of any computer or telecommunication equipment or software; collect and store personal information of other persons without proper authorization; interfere with regular operation of websites and Services of the ST; assist any actions to violate any restrictions and prohibitions imposed by this Agreement; otherwise violate legal standards including international law. 6. Exclusive Rights to Services and Content 6.1. Any objects available through Services including design elements, text, graphics, illustrations, video, software, databases, music, soundtracks and other objects (hereinafter — service content) as well as any content posted at Services are exclusive property of the ST, Users and other right holders. 6.2. Any content and service elements may be used only within functions offered by a particular service. No elements of the Service content as well as any content posted at Services may be used in any other way without the right holder’s prior consent. The term “use” shall include reproduction, duplication, processing and distribution on any basis, representation on frame, etc. The exception shall be any cases prescribed by Russian laws or terms of use of a certain the ST service. The personal non-commercial use by the User of service content elements and any content is authorized upon preservation of all marks of copyright, associated rights, trademarks, other notices of copyright, preservation of the name (pseudonym) of the author/right holder’s name unchanged and preservation of corresponding object unchanged. The exception shall be cases directly stated by Russian laws or user agreements of certain Services. 7. Third Party Websites and Content 7.1. Services may content links to other websites (third-party websites). Such third parties and their content are not verified by the ST for compliance with any requirements (validity, completeness, accuracy, etc.). The ST shall not be responsible for any information or materials posted at third-party websites that the User may access through the Services including any opinions or statements at third-party websites, advertising, etc. as well as availability of such websites or content and consequences of their use by the User. 7.2. A link (in any format) to any website, product, service, any commercial or non-commercial information published on the Website shall not be considered as approval or recommendation of such products (Services, activities) by the ST, unless directly stated at the ST resources. 8. Advertising at Services 8.1. The ST shall be responsible for its advertising at Services to the extent prescribed by Russian laws. 9. No Guarantees, Limitation of Liability 9.1. The User uses Services at the User’s own risk. Services are provided as is. The ST accepts not responsibility including for compliance of Services with the User’s goals; 9.2. The ST does not guarantee that Services comply/will comply with User’s requirements; that Services will be provided without interruptions, promptly, sustainably and without errors; that results received with the use of Services are accurate and reliable and may be used for any purposes or in any capacity; that the quality of any product, service, information, etc. received through the Services will meet the User’s expectations; 9.3. Any information and/or materials (including downloadable software, messages, any instructions and guidelines, etc.) which the User accesses through Services may be used by the User at the User’s own risk and the User shall be responsible for any potential consequences of the use of such information and/or materials including any damage to the User’s computer or third parties, loss of information or any other damage; 9.4. The ST shall not be liable for any losses resulting from the User using Services or separate parts/ functions of Services; 10. Other Provisions 10.1. This Agreement is an agreement between the User and the ST regarding the procedure of using Services and shall replace all previous agreements between the User and the ST. 10.2. This Agreement shall be regulated and interpreted according to laws of the Russian Federation. Any issues not regulated hereby shall be settled according to Russian law. Any disputes arising out of relations regulated by this Agreement shall be settled as prescribed by applicable Russian laws according to Russian legal standards. In any part of this Agreement, unless otherwise stated, the term “law” shall mean laws of the Russian Federation as well as laws of the country of the User’s location. 10.3. Nothing in this Agreement shall be interpreted as agency, partnership, mutual activities, employment or any other relations not directly stated in this Agreement. 10.4. If for any reasons one or several provisions of this Agreement are declared invalid or unenforceable, it shall not affect the validity or enforceability of the remaining provisions hereof. 10.5. This Agreement is made in the Russian language and in certain cases may be provided to the User for review in a different language. In case of any differences between the Russian text of this Agreement and the text of this Agreement in any other language, the Russian text shall prevail.

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