Terms and conditions of using the website and services

1.1. INTRODUCTION

We are responsible for the processing and personal information storage of our consumers (X5 Fintech services), as well as our website’s visitors x5fintech.com. Personal information - any information about a person that allows you to directly or indirectly identify this person, including personal data, in the understanding of the legislation on the protection of personal data.

This Privacy Policy describes the types of personal information that we receive from users of our websites (including the mobile version of the website) and X5 Fintech clients. In addition, in this document, we describe in details the ways and methods of collecting and processing your personal information.

1.2. WHAT INFORMATION DO WE COLLECT AND WHY

1.2.1. INFORMATION, THAT YOU PROVIDE TO US

X5 Fintech collects and processes the following information: customer’s name, email address and phone number. We only collect data that you voluntarily provide to us. For example, we may collect personal information (data from your public social network profile) in order to receive feedback from you about our services, or we can request information about your location to register you on the website, in order to provide services or participate in promotions. You have the right not to provide us with this information, but in this case, our website and services may not work correctly or some of their functionality will be unavailable.

In addition, when you visit our websites, we may receive certain information automatically from you. Such information may include: your IP address, information about the operating system of your computer or mobile device and browser type, type of your device, unique device identifier (UDID) or mobile equipment identifier (MEID) of your mobile device, the address of the website on which there was a link about us and information about the pages you that you have visited on our website.

We may use this information to operate, maintain and customize our website and services. In this Privacy Policy, we also provide additional information on how we use cookies.

1.2.2. MOBILE DEVICES AND LOCATION INFORMATION

Mobile versions of our websites, with your separate agreement, can receive accurate information about the exact location of the mobile device using GPS, Wi-Fi, Bluetooth technology, or taking into account the distance to the nearest mobile base station.

X5 Fintech uses this information to provide services based on your location, for example when searching for live events in your country and your city, or identifying special offers for residents of your region that you may be interested in, or to personalize your interaction with X5 Fintech.

You can always cancel the agreement you provided to X5 Fintech to determine your location by disabling the collection of location data in the settings of your device or your browser. If you want to turn off the location services on your mobile device, we recommend you to contact your mobile service provider or mobile device manufacturer. If you would like us to delete your location information, please send us an email to sales@x5fintech.com. Please note that after deleting the specified data, some services may not work correctly.

1.3. METHOD AND PLACE OF PERSONAL INFORMATION PROCESSING

1.3.1. PROCESSING METHOD

The processing of personal information is carried out using computers and (or) automation tools in accordance with organizational procedures and methods which correspond to data collection purposes.

In some cases, collected personal information may be available to certain X5 Fintech company employees (like Data Operator) related to the operation of the website (such as administration, sales department, marketing department, call center, legal department, system administrators), or third parties (such as third party technical service providers, postal organizations, hosting providers, information technology companies, communication services) that we entrust, if necessary, to act as a Data Processor. You can additionally request a list of these people from us.

The data is processed at the operational offices of X5 Fintech and in any other place where sides involved in processing are located. For more information, please contact us (data controller and database owners).

1.4. USE OF PERSONAL INFORMATION

In order to provide services, your personal information may be used and processed internally by X5 Fintech. Any use of your personal information within X5 Fintech is subjected to this Privacy Policy. From time to time, we may send you messages containing marketing and advertising information about our products and services, promotional offers, etc. If you do not give us written agreement to receive these messages, we will not send them.

X5 Fintech has the right to engage other companies to organize advertising campaigns and other services. These companies can also have access to some of your personal information, only in the part, where it is necessary for making the services. These companies are not allowed to use your personal information for any other purposes.

X5 Fintech does not sell, transfer or disclose personal client’s information and website's users to third parties outside of the X5 Fintech group of companies. However, with your approval, we may occasionally send you marketing information on behalf of one of our partners about products and services offered that may interest you. We may also ask you if you would like to receive marketing materials from our business partners. If you agree to receive the newsletter, we will not share your personal information with these partners, but will send you materials to your email address on behalf of these partners.

X5 Fintech reserves the right to use and disclose any information about you, in cases directly established by law, regulation, in order to protect the integrity of our services and protect rights, or to assist law enforcement agencies in investigating crimes and ensuring public safety.

1.5. PERSONAL INFORMATION PROTECTION

X5 Fintech takes all commercially reasonable measures to prevent unauthorized access to personal information and data obtained, while using the X5 Fintech website or services. We are committed to protect your personal information, but we urge you to take all available precautions to protect your personal information during transmission. To do this, change passwords more often, use a combination of letters and numbers, and use a secure browser.

1.5.1. INFORMATION SECURITY OF CHILDREN

The website x5fintech.com and the X5 Fintech services are not geared towards attracting the attention of children and minors. X5 Fintech does collect personal children or people under the age of 18 and does not send them any requests for personal information.

1.6. ACCES TO THE INFORMATION

You have complete control over all personal information that you provide to us. You have the right at any time to clarify or change the personal information that we have received from you, or change the settings for receiving advertising and marketing information from us and our partners. You have the right at any time to ask us to delete all information collected about you (right to be forgotten). To do this, send us an e-mail to sales@x5fintech.com.

1.7. COOKIES, WEB BEACONS AND OTHER TECHNOLOGIES

The website x5fintech.com collects information about your behavior on our website and visits to the pages of the website. In order to obtain statistics of visits and the effectiveness of using the website, form a personal approach and adapt our services to the interests of each user. We do this by using various technologies, one of which is cookie files. This is data that a website can send to your browser and it will be stored on your computer for later identification by the website.

Most often, cookies are used to evaluate the performance of websites (for example, to measure the number of visitors and the duration of their stay on the website), identify the most interesting and visited topics and pages, as well as to ensure the navigation experience and website usage, without collecting any personal information. Also, cookies can be used to form personal approach based on the existing user’s website and preferences experience. Over time, this information can improve the user experience.

Cookies are usually divided into session and persistent. Session cookies help to efficiently navigate the website, so that information once requested within a session will no longer be requested again. Session cookies are stored in temporary memory and are erased when the browser is closed. Permanent cookies save user settings for current and subsequent visits (for example, they simplify authorization on the website - they allow you to remember the user's info). They are saved on the hard disk of a computer or on the storage of a mobile device and are activated when the browser is launched. We use persistent cookies to store information such as user's language and country.

If you do not wish to receive any more cookies, please adjust your web browser. However, if you disable all cookies, you may not be able to use some of the services and features of the site.

1.8. DIRECT (TARGETED) ADVERTISING

We use cookies, Google Remarketing Tag, Facebook Pixel, and other advertising technologies to direct you advertisements according to your individual interests and preferences. This section of our Privacy Policy provides additional information on this matter.

You may see personalized advertisements of X5 Fintech on the Internet that are based on your interests. This data allows us to customize the appeal to the user and the client, taking into account his demographic interests, as well as contextual and personalize advertising. We use this information to display advertisements that may interest you. This process helps X5 Fintech measure the effectiveness of marketing tools and advertising campaigns.

1.9. OTHER SITES AND X5 Fintech ONLINE SERVICES

All sites and online services of X5 Fintech are subjected to this Privacy Policy. In the process of providing services, X5 Fintech undertakes to strictly comply with the requirements of this Privacy Policy.

1.10. PRIVACY POLICY CHANGES

We have the right to change the Privacy Policy at any time by posting on this page https://x5fintech.com/privacy.

If you disagree with any changes made to the Policy, you must stop using the X5 Fintech website and services and you can request us to delete your personal information.

The security rules of all data apply to the personal information of users of the website x5fintech.com and customers of X5 Fintech, which we have, regardless of the method of collection and method of obtaining it.

1.11. LEGAL INFORMATION

This Privacy Policy meets the requirements of the legislation of the country of registration of the company on the protection of personal data, as well as the requirements of the legislation of most countries of the world and contains detailed information about the collected data, purposes, methods of collecting, processing, using and protecting.

Note for Users of the Russian Federation: this Privacy Policy meets the requirements of Federal Law No. 152-FZ of July 27, 2006 On Personal Data.

Notice for European Users: This Privacy Policy has been prepared in pursuance of the obligations stipulated by the General Data Protection Regulation (EU Regulation 2016/679 of April 27, 2016 or GDPR — General Data Protection Regulation).

1.12. CONTACTS

X5 Fintech LTD