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Data Protection Policy

The Company is the controller and the processor of the personal data of the users on this


Personal data subjects are visitors of this Website and/or persons who use the functionality

of this Website.

We comply with the principles established by the General Data Protection Regulation(Regulation (EU) 2016/679), namely, personal data:

- are processed legally, honestly and "transparently" by us;

- are collected for certain, explicit and legitimate purposes and are not processed further ina way that is incompatible with these purposes;

- are adequate, appropriate and limited to what is necessary for the purposes for which theyare processed;

- are accurate and, if necessary, updated; every reasonable step should be taken to ensurethat personal data which were inaccurate, taking into account the purposes for which theywere processed, were erased or corrected without delay;

- are stored in a form that allows identification of users no longer than it is necessary for thepurposes for which personal data are processed;

- are processed in a way that provides proper protection of personal data, includingprotection from unauthorized or illegal processing, as well as from accidental loss,destruction or damage using appropriate technical or organizational measures.

Personal data which are collected and processed by the Company in respect to users:name, surname, patronymic, address of residence and contact information, valid e-mailaddress, place of residence, relevant payment information, login (username). The Companyfor the purpose of identifying the user's personality has the right to request a scan-copy ofhis passport. All data which are provided by you should be correct and valid. You are solelyresponsible for the accuracy, completeness and correctness of the data which you provide.

We shall use your personal data to identify the user's identity when registering on ourWebsite, to identify you for the correctness of making payments from the user to the Company and from the Company to the user. We use your payment details (such as thename of the cardholder, the credit card number and the expiration date of the card) for thepurpose of providing you with services on our Website.

We use your personal data for such main purposes: to provide you with our services; tomaintain your account and records; to communicate with you in the frame of the provisionof our services; to provide answers to your questions and comments; to monitor thedynamics and levels of use of our website and the quality of our services; to determine theinterest in our services; to improve the quality of our services and our Website; to notify youabout our special offers and services that may be interesting for you; to determine yourexperience on our Website; to transfer you the winnings (if there are appropriate groundsfor such an action); to receive information from you, including by conducting surveys; forthe resolution of disputes; for charging fees (if there are appropriate grounds); to eliminateproblems and errors on our Website; to prevent potentially prohibited or illegal activities; toensure compliance with our Terms and Conditions and all our policies placed on thisWebsite.

Your personal data may be disclosed (transferred) by the Company to any of our affiliatedcompanies or any business partners (regardless of their territorial location) for the purposesdescribed above in this policy. We guarantee that such companies are aware of thecorrectness of personal data processing according to the General Data ProtectionRegulation (Regulation (EU) 2016/679), and comply with the provisions of this regulatoryenactment.

We and the above-mentioned companies may from time to time involve third parties for theprocessing of your personal data for the purposes indicated above, provided that suchprocessing will be governed by contractual arrangements in the form prescribed by law.Your personal data may also be disclosed to the appropriate governmental, regulatory orexecutive body in case it is prescribed or permitted by law.

The user's Rights:

- to ask the Company for correction or erasure of the user`s personal data or to provide theCompany with an objection for such a processing;

to provide the user`s personal data being incomplete to the Company (subject to theprovision of an additional statement explaining the reasons);

- to set the data processing restriction if one of the following conditions is met:

1) the accuracy of personal data is being disputed by you during a period that allows theCompany to verify the accuracy of your personal data;

2) processing is illegal, and you oppose the erasure of personal data;

3) the Company no longer need your personal data for processing purposes, but they arerequired by you to establish, implement or protect your legal requirements;

4) you objected to the processing of your personal data before checking the legal groundsfor processing such data by the Company;

- to request and receive personal data about you (that were provided by you to theCompany) in a structured, commonly used and machine-readable format (by forming thecorresponding request) and to transfer this data to another controller without anyinterference from the Company;

- to be informed whether the Company store information about you;

- to request from the Company the exact purpose (s) of processing your personal data andinformation about categories of your personal data that are being processed by theCompany;

- to request access to your personal data which the Company stores;

- to request the estimated period during which your personal data will be stored by the

Company, and if it is not possible, the criteria according to which the period of storage ofsuch data is determined;

- to file the objection with the Office of the Commissioner for Personal Data Protection if youbelieve that the Company has violated the applicable data protection legislation against you.The user's Obligations:

- to provide your accurate and true personal data in full volume, in accordance with theTerms and Conditions placed on this website and this policy;

- to provide the Company promptly with your updated personal data, if any of your personaldata were changed;

- to notify the Company promptly about the fact of an unauthorized receipt of your personaldata by a third party if you became aware of such a fact;

- to notify the Company about any disagreements with any of the purposes of dataprocessing or if you wish the Company to terminate the processing of your personal datavia sending a corresponding message.

The user is fully aware that sending a notice of disagreement with any of the purposes ofpersonal data processing and/ or of intention to stop processing of his personal data beingmade by the Company shall be the legal ground for the termination of any relationshipsbetween the Parties within the Terms and Conditions herein.

You are solely responsible for the veracity, accuracy and timeliness of your personal databeing provided to the Company.

The Company's Rights:

- to terminate any and all contractual relationships (stipulated by the Terms and Conditionsherein) with you in case of non-provision of your consent to the Company for processing ofyour personal data for the purposes specified herein;

- to amend this policy unilaterally without receiving any prior approval for such amendmentsfrom you.

The Company's Obligations:

- the Company is obliged to report any correction or erasure of personal data, or restrictionof the processing of the user's personal data to every third party to whom the user's personaldata have been disclosed by the Company for any of data processing purposes establishedby this policy, unless this proves impossible or involves disproportionate effort for theCompany;

- to inform you about the recipients of your personal data (third parties), if a relevant requesthas been received from you;

- to provide you with your personal data (being stored by the Company) in a structured,commonly used and machine-readable format if a relevant request has been filed by you;

- to notify the supervisory authority about a user's personal data breach not later than in 72hours after becoming aware of such a fact. Where the notification to the supervisoryauthority is not made within 72 hours, it shall be accompanied by reasons for the delay.

- to notify immediately the user about the fact of his/her personal data breach if such abreach is likely to result in a high risk to the rights and freedoms of the user.The parties also have all rights and obligations provided by the General Data ProtectionRegulation.

The time period of storing your personal data by the Company extends for the entire periodof the duration of relationships between the parties provided hereunder as well as for thenext three years after the termination of the Parties' relationships (to resolve possibledisputable issues).

If you wish to view any personal data that we store about you or if you want to make anychanges to your personal data or delete them; or if you wish to receive information on howyour personal data are used by the Company, how we ensure the confidentiality of yourpersonal data, you can submit a request. You shall submit such a request to the Companyin writing. The request shall contain your name, address and description of the informationwhich you wish to receive, correct or delete.

In order to maintain confidentiality, when submitting the request, you also need to submit aconfirmation of your identity. For this purpose, you need to attach a copy of your passportto a request.

We reserve the right to charge reasonable fees for duplicate requests, requests foradditional copies of the same data and/or requests which are considered obviously unreasonable or excessive. We can also refuse to provide answers on requests which weconsider to be obviously unreasonable or excessive.

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