LEGAL INFORMATION

We have created this Privacy Policy to demonstrate our commitment to privacy and security principles. The Privacy Policy describes how our company collects information from all end users of its Internet services (hereinafter referred to as the Services), including people who have access to some of our services without a registration (hereinafter referred to as Guests), as well as customers who have purchased Products and/or make a monthly payment to subscribe to the Service (hereinafter referred to as Members). The Policy also includes an explanation of what we do with the information we collect, as well as what options for the collection and use of such information the Guests and Members have. We ask you to read the Privacy Policy carefully.

Personal information that our company collects and how it is used

Introduction

Members may be asked to provide certain personal information when they sign up for our Products or Services, such as last name, first name, patronymic, address, telephone number, billing information (such as credit card number) and the type of personal computer that will be used for the Services access. Members’ personal information collected during registration (or at any other time), is primarily used to prepare Products or Services in accordance with your needs. Member’s information will not be transferred or sold to third parties. However, we may partially disclose personal information in special cases described below in the “Disclosure” section.

Disclosure

We reserve the right to disclose Member and Guest information to the following third parties in the situations described below:

• Companies working on our behalf. We work with other companies that perform business support functions on our behalf, and therefore your personal information may be partially disclosed. We require such companies to use the information only for the purpose of providing contractual Services; they are prohibited from transferring this information to other parties unless it is necessary to provide the agreed Services. Examples of business support functions include fulfilling orders and requests, prizes and bonuses distribution, customer surveys and information systems management. We also disclose summarized and non-personalized information when selecting service providers.
• Subsidiaries and joint ventures. A subsidiary or joint venture is an organization with at least 50% of the Company’s equity interest. When transferring your information to a partner in a subsidiary or joint venture, our Company requires not to disclose this information to other parties for marketing purposes and not to use your information in any way contrary to your choice. If you have specified that you do not want to receive any marketing materials from our Company, then we will not share your information with our partners in subsidiaries and joint ventures for marketing purposes.
• On co-positioned or partner pages. Our Company can share information with partner companies, together with which it implements special offers and promotional activities on co-positioned pages of our website. When requesting personal data on such pages, you will receive a warning about the transfer of information. The partner uses any information you provide in accordance with their own privacy notice, which you can read before providing information about yourself.
• When transferring control over the enterprise. Our Company reserves the right to transfer your personal data in case of total or partial sale or transfer of our business or its assets. When selling or transferring the business, our Company will provide you with the opportunity to refuse to transfer information about yourself. In some cases, this may mean that the new organization will not be able to continue to provide you with the Services or Products previously provided by our Company.
• Law enforcement agencies. Our Company may, without your consent, disclose personal information to third parties for any of the following reasons: to avoid violations of the law, regulatory legal acts or court orders; to participate in government investigations; to assist in preventing fraud; to strengthen or protect the rights of the Company or its subsidiaries.
• With your consent. In all other cases, before transferring your personal information to third parties, our Company commits to obtain your explicit consent. For example, our Company may implement a joint proposal or competition with a third party; we will then ask your permission to share your personal information with a third party.

Online shopping

When you order Services or Products directly from our Company, the personal information you provide is used to process this order. We do not share this information with third parties unless it is necessary to fulfill such an order. When ordering through other companies that may link to our website, for example by offering a gift that is sent directly to the recipient, you may be asked to provide information about the recipient, such as name, address and phone number. We have no control over how third parties use the personal information you provide in such cases. Please be careful. We recommend that you read the Privacy Policy and Terms of Use of any other companies whose websites can be accessed from our site.

Advertising online

Our company can place advertisements on the Internet. In such cases, we provide our advertisers with structured and non-personalized information about our Guests and Members, collected during registration, as well as through online surveys and promotional activities. In addition, in some cases, we use this structured and non-personalized information for targeted advertising and joint ventures. For example, an advertiser or a joint venture company says which audience to reach and delivers appropriate advertising. Later, based on the collected and structured non-personalized information, we publish or send advertising to the target audience. Our company does not disclose personal information about Guests and Members to such advertisers or joint ventures. Information about how to opt out of our Company’s online advertising is included directly in the advertising materials.

Responding to email requests

When Guests or Members send email requests to our company, the response is sent to the email address from which the request came. Our company does not use return addresses for any other purpose and does not share them with any third parties.

Voluntary customer surveys

We occasionally conduct both commercial and private customer surveys. We encourage our Guests and Members to participate in these surveys as they provide us with important information that can help us improve our Products and Services, as well as improve the way we provide them. Your personal information and responses will remain strictly confidential even when a survey is conducted by a third party. Participation in our customer surveys is optional. Information about how to opt out of a survey is included in survey messages. We may take information from individuals participating in our customer surveys and combine (structure) with other customers’ responses to create broader and more generalized responses to survey questions (in particular, gender, age, place of residence, hobbies, education, place of work, industry sector and other demographic information). After that, this structured information is used to improve the quality of our Services and to develop new Services and Products. Such structured and non-personalized information may be transferred to third parties.

Automatic collection of information Cookies

To collect information, our Company may use Cookies. These are small information files that are stored by your browser on your computer’s hard drive when requested by a website. Our Company’s Cookies do not contain any personal information and are primarily used in the following ways:

• to track temporary information (for example, Cookies allow us to track which pictures you upload and download);
• to register you in special programs (Cookies allow us to remember you when you enter our website’s areas for which you must be a Member);
• to remember your country and language preferences;
• to help us understand our audience size and traffic distribution;
• to collect and record information about what you viewed on our website and in our email;
• to manage and present information on the website, as well as to understand what images can be displayed on your computer, and to present information in accordance with your interests.

Web beacons

We may also place small “tracking pixels” or “beacons” on our website, in third-party Internet advertisements and in our emails. Such beacons are used with Cookies to collect non-personal information about website use, such as: date and time of visit, pages viewed, landing page, browser type (e. g., Internet Explorer, NetScape), operating system type (e. g., Windows, Linux or Mac), visitor’s ISP domain name (e. g., AOL). We collect such information about thousands of website visits and analyze it in general. This information is important, in particular, to determine our online advertising effectiveness, for example, banners and the choice of location for future advertising on other web resources.

Disable Cookies and Beacons

If you do not like the collection of such information through Cookies and beacons, we recommend you to disable these functions in your browser settings, but please remember that this will limit the effectiveness and functionality of our Company’s website. How to have Cookies and beacons disabled is usually described in your browser instructions.

Children’s information protection

Protecting children from Internet information is especially important. Сhildren under the age of 13 are protected by federal law. For this reason, our Company deliberately does not allow children under the age of 13 to become registered members or purchase Products and Services on our websites without confirmed permission from their parents. Our Company deliberately does not collect or request personal information from children under the age of 13 without the explicit consent of their parents. If we ever include children under the age of 13 in the target audience of our website, these special pages will be highlighted and will contain a detailed privacy notice in accordance with the provisions of the Children’s Online Privacy Protection Act (COPPA). We will also provide mechanisms for obtaining parental permission, their access to information, and enable parents to request the deletion of their children’s personal information. Our Company welcomes parents and caregivers who spend time online with their children and participate in their interactive activities and hobbies.

Public Forums

Certain parts of our website may provide access to public Services, such as discussion boards, chats and live events. When using such Services, please be careful when posting information about yourself. Please note that personal information disclosed on such websites, such as your name, username, email address, etc., may be collected and used for unauthorized mailing. These Services are open to the public, and what you post there can be viewed by anyone because the information is not protected. You may find other people’s comments to be offensive, dangerous, or inappropriate. We have no control over the comments you may receive by participating in such services.

Our Company’s Commitment to Confidentiality

We use a variety of administrative, managerial and technical security measures to protect your personal information. Our Company adheres to international control standards for dealing with personal information, which include certain control measures to protect the information collected on the Internet. Our employees are trained to understand and implement these control measures and are familiar with our Privacy Notice, policies and guidelines. However, while we strive to protect your personal information, you should also take steps to protect it. We strongly recommend that you take all possible precautions while surfing the Internet. The services and websites we run provide measures to protect against leakage, unauthorized use and alteration of information that we control. Although we do our best to ensure the integrity and security of our network and systems, we cannot guarantee that our security measures will prevent any illegal access to this information by third party hackers.

Alteration and Deletion of Users’ Personal Information

All personal information that you provide for registration on our website can be changed at any time or completely removed from our database at your request. To do this, you need to contact us in any way convenient for you, using the contact information posted in a special section of our website. If you want to opt out of our regular mailing, you can do this at any time using a special link that is placed at the end of each letter.

Where to Send Questions About Our Privacy Policy?

If you have any questions about this Privacy Policy or the practices described above, you can contact us using the contact information on our website.

Changes to this Policy

Our Company reserves the right at any time and in any way to edit, supplement or change this policy, the Terms of Use and the Service Agreement, as well as other policies and agreements of our Company, by updating this page.