Personal Information Protection Policy for Baack.com and All its Services and Applications

1. General

1.1. This Policy describes the procedure of Personal Data processing and protecting the personal information of individuals who visit Baack.com (hereinafter "Website") and use its services and applications (hereinafter "Users").

1.2. The purpose of this Policy is to ensure due protection of user information, including Personal Data, from unauthorized access and disclosure and to secure the Users' rights to privacy.

1.3. The rules for collection, processing, storage, transfer and destruction of Personal Information of Website Users are formulated in this Policy and other official documents provided by the Website Administration.

1.4. The current version of the Policy is a public document and can be accessed by any Internet user at Baack.com/home/privacy. The Website Administration has the right to modify this Policy and notify the Users by posting an updated version of the Policy on this Website at Baack.com/home/privacy /privacy. Any changes to this Policy shall become effective upon its publication.

1.5. By registering and using the Service, the User agrees with the conditions of this Policy.

1.6. If the User disagrees with this Policy, they are requested to stop using the Website and its Services immediately.

2. Terms of Use

2.1. By making available the Website, its Services and Applications (hereinafter "Website Services"), the Website Administration, acting reasonably and in good faith, believes that the User:

2.1.1. has all necessary rights to register on and use this Website;

2.1.2. provides true information about themselves to the extent necessary for use of the Website Services;

2.1.3. is fully aware that any information posted on the Website may be made available to other Website Users and Internet Users and may be copied and distributed by such users.

2.2. Website Administration is not responsible for the accuracy of Personal Information it receives from Users and does not verify such information, except for when such verification is necessary for the Website Administration to fulfill its obligations to the User.

3. Purposes of Information Processin

The Website Administration processes User Information, including Personal Data, in order to fulfill the Website Administration’s obligations to the Users regarding use of the Website and all its Services and Applications.

4. User Information

4.1. Users’ Personal Data include:

4.1.1. E-mail address provided by the User;

4.1.2. First and last name, date of birth, gender, electronic wallet number and/or bank card number provided by the User;

4.1.3. Any data additionally provided by the User at the request of the Website Administration that enables the Website Administration to fulfill its obligations to the Users arising from the Website Usage Policy. The Website Administration reserves the right to request from the User a copy of the identity document or any other document containing the User's name, surname and photograph. The Website Administration shall also be entitled to request any additional information which, at the discretion of the Website Administration, is necessary and sufficient to identify such user and prevent abuses and infringements of third parties’ rights.

4.2. Other User Information processed by the Website Administration includes:

4.2.1. Additional data obtained when the User accesses the Website, including information regarding devices and technical interaction with the Website (including the User's host IP address, operating system, browser type, geographical location and Internet provider);

4.2.2. The data automatically obtained when the Website is accessed using bookmarks (cookies);

4.2.3. Information received by the Website Administration as a result of the User's actions on the Website.

4.3. Collecting Information about Technical Devices

The Website Administration collects the data necessary for the User to access the Website Services and requires such data in order to:

• maintain and assess the functionality of the Website;
• personalize Website content and display contextual advertising.

The Website Administration informs Users that it automatically receives the following information about the Users' technical devices:

• IP address;
• country code;
• IDFV, Android Advertising ID, IMEI (International Mobile Equipment Identity);
• push notifications token.

Some of these data can uniquely identify the device, however, they do not identify the User. According to some countries' laws, the information identifying the device is regarded as Personal Information.

5. Collection, Processing, Storage, Transfer and Destruction of User Information

5.1. The User’s personal data are collected by the Website:

• at the time of registration;
• when the User subsequently submits additional personal information.

5.1.1. The Personal Information described in clause 4.1.1. of this Policy is provided by the User and is minimally necessary to complete the registration process on the Website.

5.1.2. The Personal Information described in clause 4.1.2. of this Policy is provided by the User additionally on their own initiative using the Edit tab in the My Page section.

When publishing any information on their own personal page, the User is fully aware and agrees that such information may be available to other Internet users taking into account the architecture and functionality of the Website.

5.2. Principles of Personal Data Processing:

• Personal Data is processed lawfully;
• Personal Data is processed in good faith;
• Personal data shall not be processed for a purpose which is incompatible with the original purpose for which it is processed;
• Personal Data serve the purposes of Personal Data processing;
• automated systems are used for Personal Data processing, except in cases when non-automated processing is a required by law.

5.3. Personal Data is stored exclusively on electronic media.

5.4. The Users’ Personal Data may not be transferred to any third parties, except as expressly provided by this Policy:

• If instructed or agreed so by the User, the User’s personal data may be transferred to the Website Administration’s third-party contractors, provided that such contractors assume confidentiality obligations.
• The Users’ Personal Data are provided on the request of government agencies (local self-government bodies) in the manner required by law.

In order to ensure the realization of these goals, the User agrees that:

• subject to applicable laws, their Personal Data shall be collected, processed, stored, systematized, extracted, compared, and used by the Website Administration;
• the Website Administration shall receive and transfer to affiliates and partners the results of automated processing of such data with the use of different models of information evaluation, in the form of integer and/or textual values and identifiers, for the processing of such data by the Website administration and/or the persons specified in this paragraph.

5.5. The User's personal Data shall be destroyed when:

• the User removes such data from their personal page on their own initiative;
• the Website Administration deletes the User's profile or information published by the User in cases determined by the Website usage rules.

6. User's Rights and Obligations

6.1. The User has the right to:

6.1.1.Access their information without restrictions and free of charge by using their login and password.

6.1.2. Make changes to previously provided information on the User's personal page on the Website, provided that the new information is up-to-date and true.

6.1.3. Delete information from their personal page on the Website;

6.1.4. ТRequest the Website Administration to update or delete their Personal Data if such data are:

• incomplete;
• outdated;
• untrue;
• unlawfully obtained;
• are not necessary for the declared purpose of processing or if the actions specified in clauses 6.1.2 and 6.1.3 hereof cannot be implemented;

7. Protection of User Information

7.1. The Website Administration shall take technical, organizational and legal measures to ensure that the User’s Personal Data are protected from accidental or unauthorized access by third parties.

7.2. The User is responsible for keeping their Website login and password confidential. The User may not transfer their rights to use the Service to any third parties, either for free or for a charge, and is also obliged to take measures for keeping their login and password confidential.

8. Limitation of Applicability

This Policy does not apply to the actions of any third parties. The Website Administration bears no liability for the actions of third parties who obtained access to the User's Personal Information.