Terms of Use

ORGANIZATION OF MONEY TRANSFERS VIA KIBERPAY PAYMENT SERVICE

Terms and Definitions

Account	A set of data about the Organization stored in the KIBERPAY Payment Gateway, necessary for its authentication and providing access to the KIBERPAY Payment Gateway
Bank card / Card	Bank card as part of the Payment system; as well as a bank card of the Bank, not related to any payment systems, issued by the Bank and accepted only in the Bank’s devices
Treaty	Agreement for the provision of payment services, services for technical support and information technology interaction, concluded between the Organizations, by joining these Terms
Client	An individual who is a holder of a Bank card issued by banks, who is a client of the Organization
Organization	Legal entity / Individual Entrepreneur who has acceded to these Terms in order to make Transfers
Check	Account of the Organization opened under the Agreement with the Payment Service. Account movements are reflected in the merchant’s personal account https://lk.kiberpay.com/
Translation	Actions of the Payment Service to execute the order of the Organization / Client within the applicable forms of non-cash payments: to transfer funds using the details of the Client’s Bank Card from the Organization’s account to the Client / to transfer funds using the details of the Bank Card from the Client to the Organization’s account / to transfer funds from the Organization’s account within the Payment System of the Bank of Russia (including the Fast Payment Service
Payment Gateway	A software package that allows you to carry out operations of payment for goods/works/services, as well as to make money transfers on the Internet. Connection occurs through API integration.
Rules	The order of technical interaction, posted at: https://kiberpay.com
The API documentation describes	Software and hardware complex used by the Parties for the purpose of information and technological interaction under this Agreement
Bank card details	Card number or phone number linked to the card
Tariffs	Tariffs consist of the cost of services: -for the transfer of funds when making a deposit or withdrawal on the payment pages; – on payment of remuneration and accepted means of payment
Payment service rules	A set of documents regulating the activities of the payment service
Card issuer	Credit organization issuing cards, as well as settlements on Transactions performed using cards

1. SUBJECT OF THE CONTRACT

1.1. The subject of the Agreement is the provision by the Payment Service of services for the execution of orders for the transfer of funds in order to replenish or withdraw funds from the brokerage accounts of the Partner Organizations of the Payment Service.
1.2. The Payment Service assumes the obligation to provide services for technical support and information technology interaction for the collection, processing and transmission of information on Transfers made under this Agreement, and also fulfills other obligations stipulated by this Agreement and its annexes.
1.3. The Organization provides complete and reliable information and documents for the collection, processing and transmission of information on Transfers made under this Agreement.
1.4. For the services provided to the Organization, the Payment Service charges the Organization a fee in accordance with the Tariffs. The Organization pays for the services of the Payment Service in the manner and on the terms provided for in this Agreement and its annexes.
1.5. In order to make settlements under this Agreement, the Parties, using technical and software tools, exchange information on Transfers in the form of electronic documents that are generated and sent in accordance with the Rules in force at the time of the exchange.
1.6. Under the Agreement, the Parties act on their own behalf, in their own interests and do not carry out instructions from other persons.
1.7. The Payment Service is not a tax agent in relation to the Organization and Clients and is not liable for the calculation, withholding and transfer of taxes to the budget system of the Russian Federation arising in connection with the financial activities of the Organization and/or the Client.
1.8. In order to comply with the requirements of Part 3, Article 6 of the Federal Law 152-FZ “On Personal Data”, the Organization instructs the Payment System for the purposes of this Agreement to process the personal data of the Clients as subjects of personal data, namely: collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, depersonalization, blocking, deletion, destruction.

2. CONCLUSION OF THE AGREEMENT

1.1 These Conditions for the provision of services for the transfer of funds using bank card details (hereinafter referred to as the Conditions) are standard for all Organizations and determine the provisions of the Accession Agreement concluded between the Payment Service and the Organization.
1.2 The conclusion of the Agreement means the acceptance by the Organization of these Terms in its entirety, agreement with them and the obligation to strictly comply with them.

3. RIGHTS AND OBLIGATIONSPARTIES

3.1. The organization is committed to:
3.1.1. Transfer orders for Transfers to the Payment Service in the agreed formats using the agreed means and data transmission channels in accordance with the Rules.
3.1.2. Maintain the balance of funds on the Collateral Account in the amount necessary to make Transfers to Clients and pay the Payment Service remuneration under the Agreement. Execution of Transfer Orders is accepted for execution by the Payment Service, provided that there are sufficient funds on the Account.
3.1.3. Pay the Bank and the Processing Center a commission in accordance with section 4 of the Terms.
3.1.4. Independently and at its own expense ensure the availability of communication channels and software necessary for the implementation of information interaction with the Payment Service in accordance with the Rules.
3.1.5. Ensure the protection of information from unauthorized access during information interaction with the Payment Service.
3.1.6. Within 2 days from the date of receipt of the request from the Payment Service, submit documents confirming the identification by the Organization of the Clients from whom and to whom the Organization makes Transfers, in accordance with Federal Law No. 115-FZ of 07.08. legalization (laundering) of proceeds from crime and financing of terrorism”, incl. at the request of the Bank, provide information about the Clients to whom the Organization makes Transfers (full name, details of an identity document, residential address, etc.).
3.1.7. Reimburse in triple the amount of fines paid by the Bank imposed by the Payment Systems as a result of the Organization’s activities, under the Agreement, as well as reimburse other expenses incurred by the Payment Service due to the fault of the Organization, while the Payment Service is obliged to provide the Organization with documents confirming the amount of expenses incurred, referred to in this paragraph, in the manner provided for in Section 4 of these Terms.
3.1.8. Independently and on its own behalf, take measures to establish in relation to an individual the last name, first name, patronymic, series and number of the document proving his identity, in order to further send a request to the Organization for Verification of the data of individuals.

3.2. The organization has the right:
3.2.1. The Organization has the right to receive back funds in an amount exceeding the Organization’s debt to the Payment Service under the Agreement (including in case of early termination of the Agreement). In this case, the Organization sends a request to transfer the payment to the Account. After checking the compliance of the amount, the Payment Service transfers funds to the account specified by the Organization within two (two) working days from the receipt of the Organization’s request.

3.3. The payment service undertakes:
3.3.1. Receive messages from the Organization with instructions for Transfers in the manner agreed by the Parties in accordance with the Rules.
3.3.2. Carry out information exchange on Transfers.
3.3.3. Make Transfers in accordance with the instructions of the Organization / Client within 1 (one) business day.
3.3.4. Provide the Organization with information about the execution of Transfers.
3.3.5. Store information about completed Transfers in electronic databases during the term of the Agreement.
3.4. The payment service has the right:
3.4.1. Unilaterally make changes to the Tariffs no later than 15 (Fifteen) calendar days prior to the entry into force of these changes. When tariffs are changed, in order to continue cooperation with the Organization, it is necessary to agree on new working conditions from both sides.
3.4.2. If there are no transactions on the Accounts of the Organization during the calendar month, the Payment Service has the right to unilaterally block the Account of the Organization and terminate the Agreement.
3.5. The payment service undertakes:
3.5.1. Provide services for the collection, processing and distribution of information on Transfers to settlement participants in accordance with the Rules.
3.5.2. Provide the Organization without errors and distortions with processed information about the Transfers and transactions made within the framework of this Agreement in accordance with the Rules.
3.5.3. Immediately notify the Organization of all known failures that may result in a delay in the transmission of information on activities carried out under this Treaty.
3.5.4. Independently and at its own expense, ensure the availability of communication channels and software necessary for information interaction with the Organization.

4. PAYMENT PROCEDURE

4.1. The remuneration to the Payment Service for the provision of technical support services and services for information technology interaction in accordance with this Agreement is paid by the Organization based on the calculation for each executed Transfer in accordance with the Tariffs. The remuneration to the Processing Center is deducted from the Account without additional order of the Organization on the terms of the Organization’s prior acceptance.
4.2. The amounts of transfers made by the Clients to the Organization under the Agreement are credited by the Payment Service to the Account.
4.3. The amounts of transfers made by the Organization to the Clients under the Agreement are debited by the Payment Service from the Account of the Organization in accordance with the terms of the Agreement. Funds are debited from the Account either on the date of submission of the application for the Transfer, or upon confirmation of successful crediting of the transfer of funds to the bank card of the recipient of funds.
4.4. If the amounts on the Account of the Organization were not enough to fulfill the Client’s order to withdraw funds, the Organization can replenish its balance in cryptocurrency to perform conversion transactions valid on the date of the operation, with the proceeds from the sale of foreign currency credited to the Account of the Organization in the currency of the Russian Federation.
4.5. The Payment Service has the right to suspend the provision of services and not to reimburse the Organization for the Operations performed in cases of complaints from Clients about the failure to provide the requested services or dishonest behavior on the part of the Organization.
4.6. If the Transfer funds have already been credited to the Account, the Payment Service has the right to withhold these amounts in the following cases:
if the Transfer is made in violation of the terms of this Agreement;
in case the Payment System receives information from the Client or the Card Issuer, incl. in electronic form, that the performed Transfer belongs to the “FRAUD” category.
4.7 The Payment Service has the right to postpone crediting the Organization of the Transfer Amount for up to 180 (One hundred and eighty) calendar days (during which the Card Issuer or the Client has the right to file a claim for the Transfer) if the Payment System receives a notification that the Transfer made is classified as “FRAUD” and/or violation by the Organization of the Terms. After the expiration of the specified period, the Bank makes a decision on crediting or refusing to credit the Transfer amount to the Account based on the information received from the Payment system (issuer). The Organization bears all expenses of the Payment system for the return of the amount of the Transfer to the Client.
4.8 The Organization has the right to submit motivated claims to the Payment Service for the amounts of funds transferred to the Account / debited from the Account of the Organization within 30 (thirty) calendar days from the date of transfer / debiting. Otherwise, settlements between the Parties are considered confirmed.

5. CONFIDENTIALITY

5.1. Information received by the Parties in the course of the execution of the Agreement and not intended by the Party that submitted it for advertising purposes is considered confidential.
5.2. The Parties undertake to take all necessary and sufficient measures to ensure that confidential information does not become known to third parties.
5.3. The Parties guarantee the secrecy of information and messages received by them in the course of the implementation of the Agreement.
5.4. Coordinate in advance with each other the disclosure of any information on cooperation between the Parties, regardless of the form and method of information disclosure.
5.5. Place in advertising and information materials, mention in the media, including in informational and journalistic publications, place on any resources on the Internet the trademarks of the Parties only after prior agreement on the location, content and form of information of the respective Party.

6. RESPONSIBILITIES OF THE PARTIES

6.1. The Parties shall be liable for non-fulfillment or improper fulfillment of their obligations under the Agreement in accordance with the current legislation of the Russian Federation. Each Party is obliged to compensate the other Party in full for documented real losses incurred as a result of non-fulfillment or improper fulfillment by the Party of its obligations under the Agreement.
6.2. The Parties are released from liability for partial or complete failure to fulfill obligations under the Agreement if this failure was the result of force majeure circumstances that arose after the conclusion of the Agreement as a result of extraordinary events that the Party could neither foresee nor prevent by reasonable measures.
6.3. Upon the occurrence of the circumstances specified in this section, the Party for which it has become impossible to fulfill its obligations under the contract must notify the other Party within 5 (Five) working days, attaching documentary evidence.

7. VALIDITY CONTRACT

7.1 The Agreement comes into force from the moment of its conclusion in the manner prescribed by paragraph 2 of these Terms and is valid for an indefinite period. Each of the Parties has the right to terminate unilaterally out of court.
7.2 Agreement by notifying the other Parties no later than 15 (fifteen) calendar days before the proposed date of termination.Notice must be sent by mail (with acknowledgment of receipt) or by courier.
7.3 Any amendments and additions to the Agreement shall come into force if they are made in writing, signed by authorized persons of the Parties and affixed with the seals of the Parties (if any), except for the cases established by the Agreement.
7.4 Termination of the Agreement does not release the Parties from the fulfillment of obligations that arose before the date of termination of the Agreement.

8. DISPUTES RESOLUTION

8.1. Any dispute arising from the Agreement or related to its execution is subject to resolution, first of all, in the complaint procedure.
8.2. The Party that received a claim from the other Party is obliged within 10 (Ten) working days to satisfy the claims stated in the claim or send a reasoned refusal to the other Party. All required documents must be attached to the response.
8.3. If the dispute that has arisen is not resolved in the claim procedure, it is subject to consideration in the Moscow Arbitration Court.

9. OTHER CONDITIONS

9.1. The Parties undertake to immediately inform each other in writing about changes in their names, bank and other details, as well as about other circumstances that are essential for the fulfillment by the Parties of their obligations under the Agreement.
9.2. The Parties acknowledge that the means and technologies used under the Agreement and the Rules for processing, storing, transmitting and protecting information provide encryption, integrity control, creation of Transfer instructions and are sufficient to protect information from unauthorized access, confirm the authenticity, integrity and authorship of Transfer instructions , as well as reliable and efficient work, conflict resolution.
9.3. The Parties recognize all orders for Transfers executed in accordance with the Rules, equivalent to documents made in writing on paper, signed with a handwritten signature and stamped (if necessary), having legal force, confirming the existence of legal relations between the Parties and give rise to similar rights and obligations of the Parties.
9.4. The Parties acknowledge that the use of the worldwide public telecommunications network – the Internet may cause interruptions in the acceptance and processing of orders for Transfers due to failures of the telecommunications equipment of telecommunications service providers, as well as other reasons. The parties are obliged to take all available means of protection against these threats.
9.5. The Parties recognize Moscow standard time as a single time scale when working under the Agreement. The control time is the time of the system clock of the Bank’s hardware.

10. ADDRESSES AND DETAILS OF THE PAYMENT SERVICE

https://kiberpay.com/
Company name: VIPOLE LTD
Activity: Software development
VAT (required) BG 205169650

KiberPAY Policy regarding the processing of personal data

Last updated 27.02.2023

General provisions
Principles of personal data processing
Scope and categories of data processed, purposes of collection
The procedure and conditions for processing, storing personal data
Special categories of personal data
Consent of the subject of personal data to the processing of his personal data
Rights of the subject of personal data
Deleting data
Transfer of information
Cookies
Legal grounds for the processing of personal data
Limitation of this Policy

1. General provisions

1.1. This document (hereinafter referred to as the “Policy”) is an official document defining the policy of KiberPAY (hereinafter also referred to as the “Company”) regarding the collection and processing of personal information of individuals, users of the Company’s Services.

1.2. This Policy defines the procedure for processing personal data and measures to ensure the security of personal data in the Company in order to protect the rights and freedoms of a person and citizen in the processing of his personal data, including the protection of the rights to privacy, personal and family secrets.

By accepting this Policy, the Subject (User) agrees toprocessing their personal data in order to use the Company’s Services. ATotherwise, the person must refrain from any use of the ServicesCompanies.

1.3. The following basic concepts and terms are used in the Policy:

− user -individuals (including representatives of legal entities) who have the opportunity to visually familiarize themselves with the information posted on the websitehttps://cyberpay.com/information, persons using the services of the company, as well as customers of the Company;

− subject (of personal data) –a natural person who is directly or indirectly identified or determined using personal data, sending their own personal data to the Company in order to gain access to the functionality of the Company’s Service;

– processing of personal data – any action (operation) or a set of actions (operations) performed using automation tools or without using such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data;

– automated processing of personal data – processing of personal data using computer technology;

– dissemination of personal data – actions aimed at disclosing personal data to an indefinite circle of persons;

– provision of personal data – actions aimed at disclosing personal data to a certain person or a certain circle of persons;

– blocking of personal data – temporary suspension of the processing of personal data (except when processing is necessary to clarify personal data);

– destruction of personal data – actions, as a result of which it becomes impossible to restore the content of personal data in the information system of personal data and (or) as a result of which material carriers of personal data are destroyed;

– depersonalization of personal data – actions, as a result of which it becomes impossible to determine the ownership of personal data by a specific subject of personal data without the use of additional information;

– personal data information system – a set of personal data contained in databases and information technologies and technical means that ensure their processing;

− cross-border transfer of personal data – the transfer of personal data to the territory of a foreign state to an authority of a foreign state, a foreign individual or a foreign legal entity.

− user agreement – the Agreement posted on the Company’s website, concluded between the Company and the subject, regulating the relationship between the Company and the subject on the use of the Internet resource https://kiberpay.com/;

− services of the Company – a software package owned by the Company, which includes a WEB – interface located on the Internet;

client–– a legal entity, an individual entrepreneur, as well as an individual engaged in private practice in accordance with the procedure established by the legislation of the Russian Federation, who has concluded or intends to conclude a service agreement with the Company;

client representative– an individual whose personal data is transferred to the Company, who is a member of the Client’s management bodies; being the owner/founder/shareholder/participant of the Client; acting on behalf of the Client on the basis of a power of attorney / specified in the card with samples of signatures and seals of the Client;

dissemination of personal data– actions aimed at disclosing personal data to an indefinite circle of persons;

TSP– A trade and service company that sells goods and provides services to an indefinite circle of people.

1.4. This Policy is an open and public document. Its current version is available on the Internet at: https://kiberpay.com/.The Company has the right to make changes to this Policy. When changes are made, the heading of the Policy indicates the date of the last revision of the revision. The Company does not collect any information about the individual who reads this Policy.

2. Principles of personal data processing.

2.1. The Company processes personal data on the basis of the following principles:

− legitimacy and fairness;

– limiting the processing of personal data to the achievement of specific, predetermined and legitimate purposes;

− preventing the processing of personal data that is incompatible with the purposes of collecting personal data;

− preventing the merging of databases containing personal data, the processing of which is carried out for purposes that are incompatible with each other;

− processing only those personal data that meet the purposes of their processing;

− compliance of the content and scope of the processed personal data with the stated purposes of processing;

− preventing the processing of personal data that is excessive in relation to the stated purposes of their processing;

− ensuring the accuracy, sufficiency and relevance of personal data in relation to the purposes of processing personal data;

– destruction or depersonalization of personal data upon reaching the goals of their processing or in case of loss of the need to achieve these goals, if it is impossible for the Operator to eliminate the committed violations of personal data, unless otherwise provided by federal law.

3. Scope and categories of data processed, purposes of collection

3.1. Personal data permitted for processing under this Policy is provided by the subject of personal data (obtained by the Company in an automated mode), as well as by his legal representative, by filling out registration and other forms on the Company’s website, sending by the subject to the Company information and documents containing personal data of the subject, the latter making payments for the services provided to the Company, the performance by the subject of financial transactions (transactions) on the Merchant’s website by filling out the Company’s payment form on the Internet, as well as within the framework of an agreement between the Company and a legal entity (Merchant, Client).

3.2. In accordance with this Policy, the Company guarantees the protection of the personal data of the subject collected in an automated mode, as well as sent by the subject to the email addresssupport@kiberpay.com, info@kiberpay.com, payments@kiberpay.com, owned by the Company.

3.3. Personal data provided by the subject and / or received by the Company in an automated mode include:

− name;

− address Email;

− room phone;

− IP address.

In order to perform the function of a payment subagent, the company receives from individuals the data of a bank card, with the help of which payment for goods/works/services of the merchant is carried out, namely:

− Number bank card.

− Address Email.

− Name bank card holder.

3.4. The Company has the right to process information about an individual obtained as a result of the exchange of information with third parties who are the Company’s clients and involve the Company in the provision of processing services. By accepting this information, the Company does not assume that this information was obtained legally, and its transfer to the Company was carried out with the permission of an individual.

3.5. The Company does not have the ability to verify the legal capacity of an individual, and also does not verify the information provided by an individual. The Company assumes that an individual has provided sufficient, true and up-to-date information about himself.

4. The procedure and conditions for processing, storing personal data

4.1. The company processes personal data in the presence of at least one of the following conditions:

− processing of personal data is carried out with the consent of the subject of personal data to the processing of his personal data;

− processing of personal data is carried out with the consent of the legal representative of the subject of personal data for the processing of personal data;

− the processing of personal data is necessary for the performance of an agreement to which the personal data subject is a party or beneficiary or guarantor, as well as to conclude an agreement on the initiative of the personal data subject or an agreement under which the personal data subject will be the beneficiary or guarantor;

− the processing of personal data is necessary to exercise the rights and ensure the legitimate interests of the Company or third parties, or to achieve socially significant goals, provided that the rights and freedoms of the subject of personal data are not violated;

– processing of personal data is carried out, access to which is granted to an unlimited number of persons by the subject of personal data or at his request (hereinafter referred to as publicly available personal data);

4.2 The obligations of the Company to ensure the confidentiality of personal data are paramount in the processing of the latter. The Company undertakes not to disclose to third parties and not to distribute personal data without the consent of the subject of personal data, unless otherwise provided by federal law.

5. Special categories of personal data

5.1. The Company does not process personal data relating to race, nationality, political views, religious philosophical beliefs, health status, intimate life of the subject of personal data.

6. Consent of the subject of personal data to the processing of his personal data

6.1. The subject of personal data decides to provide his personal data and agrees to their processing freely, by his own will and in his own interest. Consent to the processing of personal data is provided by the subject of personal data or his legal representative in writing by performing actions in the registration form of the Company (putting the appropriate “check-box”, “tick”) associated with the registration of the subject in the system for using the Company’s Service, as well as by entering the bank card details in the payment form.

6.2. The Company proceeds from the fact that the subject provides reliable personal data and independently ensures the relevance of the information provided.

6.3. The Company has the right to verify the provided personal data. If there are irremovable doubts about the reliability and / or relevance of the personal data provided, the Company has the right to refuse the subject access to the Service, including the personalized functionality of the Company’s Service.

7. Rights of the subject of personal data

7.1. The subject of personal data has the right to receive information from the Company regarding the processing of his personal data or the personal data of his minor children, unless such right is restricted in accordance with federal laws.

7.2. The subject of personal data has the right to demand from the Company the clarification of his personal data or the personal data of his minor children, their blocking or destruction in cases provided for by contractual relations with the Company, as well as in cases where personal data is incomplete, outdated, inaccurate, illegally obtained or not are necessary for the stated purpose of processing, as well as to take legal measures to protect their rights. To exercise the above rights, the subject sends to the Company’s email address support@kiberpay.com.

7.3. The subject of personal data has the right to protect his rights and legitimate interests, including compensation for losses and (or) compensation for moral damage in court.

7.4. The security of personal data processed by the Company is ensured by the implementation of legal, organizational and technical measures necessary to meet the requirements of federal legislation in the field of personal data protection. To prevent unauthorized access to personal data, the Company applies the following organizational and technical measures:

− appointment of officials responsible for organizing the processing and protection of personal data;

− restriction of the composition of persons having access to personal data;

− familiarization of the subjects with the requirements of federal legislation and regulatory documents of the Company on the processing and protection of personal data;

− organization of accounting, storage and circulation of information carriers;

− determination of threats to the security of personal data during their processing, the formation of threat models based on them, including during automated data processing

− development of a personal data protection system based on the threat model, including in automated data processing;

− checking the readiness and effectiveness of the use of information security tools, including in automated data processing;

− delimitation of user access to information resources, personalization and accounting of access of the Company’s employees to software and hardware for information processing;

− registration and accounting of actions of users of personal data information systems;

− use of anti-virus tools and means of restoring the personal data protection system;

− application, where necessary, of firewalls, intrusion detection, security analysis and cryptographic information protection;

− organization of access control to the territory of the Company, protection of premises with technical means for processing personal data.

7.5. The Company is not responsible for the websites and software of third parties, to which the subject can go through the links available when using the Company’s Service.

7.6. The Company takes all necessary and sufficient organizational and technical measures to protect information about an individual from unauthorized or accidental access, destruction, modification, blocking, copying, distribution, as well as from illegal actions of third parties. All information collected by the company is stored in an encrypted, depersonalized form in full compliance with the International Payment Card Industry Data Security Standard (PCI DSS).

8. Deleting data

8.1. If you wish to revoke your consent to us using your data to provide you with access to the Company’s services, you can send a request to delete personal data by e-mail support@kiberpay.com. After fulfilling your request to delete personal data, we will completely and irrevocably anonymize your personal data. Please note that in the event of a request to delete personal data, the following rules apply:

– we have the right to partially retain your personal data within the legitimate interests of our business, including to combat fraud and improve security;

– we have the right to store and use your personal data to the extent necessary to comply with legal requirements;

– information that you have shared with others (for example, reviews, forum posts) may remain publicly available even after your data is deleted, and your attribution will be removed. Some copies of your information may remain in our database without any possibility of personal identification;

– due to the implementation of a system of protection against accidental or intentional damage or loss of data, backup copies of your personal data will be deleted with a certain delay.

9. Transfer of information

9.1. The Company has the right to transfer information about an individual to third parties in the following cases:

− physical the person has given their consent to such actions;

− transfer of information to third parties is necessary for the proper performance by the Company of the functions of a payment subagent;

− transfer of information to the Company’s partners, including affiliates, within the framework of joint projects;

− the transfer of information to third parties is necessary for the proper performance by the Company of an agreement or contract with this individual;

− transfer of information to third parties that support the services of the Company to the extent necessary for the implementation of such technical support;

− the transfer is provided for by Russian or other applicable legislation within the framework of the procedure established by law;

– the transfer takes place as part of the sale or other transfer of business, and all obligations to comply with the terms of this Policy are transferred to the acquirer;

− in order to ensure the possibility of protecting the rights and legitimate interests of the Company or third parties in cases where the Company has reasonable grounds to believe that an individual violates the requirements of applicable law.

9.2. The Company has the right to distribute and / or provide third parties with access to information about an individual without any restrictions after processing the relevant information, which resulted in the deletion of information that allows identifying the identity of an individual (depersonalization of information), as well as after statistical processing of this information.

9.3. The Company has the right to use information about an individual for the purposes of analyzing the interests and preferences of its audience, adapting the Company’s services according to the results obtained from the above analysis, as well as for the purposes of advertising on the Internet to the extent necessary to display it to the target audience.

10. Cookies

10.1. The Company strives to ensure that interaction with its Services is as informative as possible and meets the interests of users. To do this, the Company uses cookies. The Company believes that it is important for the user to know which cookies the Company uses and for what purposes. This will help protect the personal information of users and ensure the maximum convenience of the Company Service for the user. Cookies contain small amounts of information and are downloaded to the user’s computer or other device from the Company’s website server. Each time the user visits this website, the user’s browser sends cookies back to the server in order to be able to identify the user and remember user preferences.

10.2. Cookies may be used for various purposes. They may be required for the normal operation of the website. For example, without cookies, a website will not be able to remember that you are logged in or that you have completed a contact form. Such cookies are called strictly necessary.

10.3. Cookies neededto analyze the use and improvement of the Company Services, as well as to count the number of visitors. The Company associates website usage statistics and other reports with specific individuals. These cookies are called analytical cookies.

10.4. Social media cookies are used to integrate social media with the website so that the user can use the “Like” and “Share” features on their favorite social network.

An important area of use for cookies is online advertising. With their help, websites display only the most useful and interesting ads for the user. These cookies are called advertising cookies.

10.5. Deleting or blocking cookies may affect the user experience and some parts of this website may become unavailable. The user can find information on how to disable cookies or change browser cookie settings by clicking on the following links:

− Google Chrome:hhttps://support.google.com/chrome/answer/95647?hl=en&hlrm=en

− Internet explorer: https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies

− safari: https://support.apple.com/en-us/HT201265

− Firefox: https://support.mozilla.org/ru/kb/vklyuchenie-i-otklyuchenie-kukov-ispolzuemyh-web-s

− opera:https://help.opera.com/en/Windows/10.20/en/cookies.html

Most browsers allow you to see the cookies stored on the user’s device and individually delete or block cookies from certain or all websites. If all cookies are deleted, all data about the user’s preferences will be lost, including the preference to refuse the use of cookies, since it involves the installation of an opt-out cookie.

More information about changing your browser settings to block or filter cookies is available on the resource.http://www.aboutcookies.org/orhttp://www.cookiecentral.com/faq/.

10.6. The Company may also use technologies to track whether a user has read, opened or forwarded certain messages sent by the Company to the user’s email. The purpose of using these technologies is to make communication tools more useful and attractive to the user.

10.7. In the event that the user does not wish the Company to know whether the user has read certain e-mails, the user should unsubscribe. In this case, the Company will not be able to send emails to the user without an activated tracking service. The user can also cancel the subscription by following the instructions that the Company will send him in an electronic message.

By using the Company’s Service, the user agrees toThe Company may place cookies on the user’s computer or otherwisedevice. However, the user has the ability to manage cookies.

11. Legal grounds for the processing of personal data

11.1. The relations discussed in this Policy related to the collection, storage, protection, processing, dissemination and protection of information about individuals are regulated in accordance with the current legislation of the Russian Federation. The legal basis for the processing of personal data is:

statutory documents of the Company;

contracts concluded between the Company and the subject of personal data;

consent to the processing of personal data. The application to them of the norms of foreign law is possible only in cases provided for by the legislation of the Russian Federation and international agreements valid for the Russian Federation.

payment system rules.

other norms of the legislation of the Russian Federation.

11.2. If the user uses the Company Services in the European Economic Area, in accordance with local law, he has certain rights in relation to personal information. In accordance with these rights, the user can: access his personal information, correct the information stored by the Company, erase personal information, restrict the Company’s use of the user’s personal information, receive personal information in the established electronic format and forward it to third parties (right to data portability) file a complaint with your local data protection authority.

12. Limitation of this Policy

12.1. The Company is not responsible for the actions of third parties using the Company’s services in their activities, and strongly recommends that an individual not provide their own personal data to third parties without sufficient grounds. In the case of joint partnership projects of the Company with third parties, the official documents of these projects must indicate how information about an individual is protected, including information about who processes and stores this information. The Company is not responsible for non-compliance by third parties with the requirements of the current legislation.

https://kiberpay.com/

Company name: VIPOLE LTD

Activity: Software development

VAT (required) BG 205169650