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1.1. The policy regarding the processing of personal data (hereinafter referred to as the “Policy”) is aimed at protecting the rights and freedoms of individuals whose personal data is processed by Limited Liability Company Profitclicks (hereinafter referred to as the “Operator”). 1.2. The policy is developed in accordance with paragraph 2 of Part 1 of Art. 18.1 of the Federal Law dated July 27, 2006 No.152-FZ "On Personal Data" (hereinafter - the Federal Law "On Personal Data"). 1.3. The policy contains information to be disclosed in accordance with Art. 14 of the Federal Law "On Personal Data", and is a public document.

2.1. The Operator conducts its activities at the address: 4th floor, b.367 Krasnykh Partizan Str., Krasnodar, Russian Federation, 350049.

3.1. The Operator processes personal data on a legal and fair basis in order to perform the functions, powers and duties assigned by law, exercise the rights and legitimate interests of the Operator, Operator’s employees and third parties. 3.2. The Operator receives personal data directly from the subjects of personal data (hereinafter referred to as “PersData”). 3.3. The Operator processes personal data in automated and non-automated ways, with or without the use of computer technology. 3.4. Processing Personal Data activities include collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion and destruction.

4.1. The Operator processes the personal data of Clients in the framework of legal relations with the Operator, regulated by part two of the Civil Code of the Russian Federation dated January 26, 1996 and Art. 14 FZ "On personal data" (hereinafter - the "Clients"). 4.2. The Operator processes the personal data of Clients in compliance with the laws of the Russian Federation, as well as for the purpose of: — Reception of requests and applications from the subject of PersData; — Informing about new goods, services, special promotions and offers; — Conclusion and execution of the terms of the contract; — Sending of an electronic cash receipt (strict reporting form) in electronic form. 4.3. The Operator processes the personal data of Clients with their consent, provided by clients and/or their legal representatives by means of performing implicative actions on this website, including, but not limited to, placing an order, registering the account, subscribing to a newsletter, in accordance with this policy. 4.4. The Operator processes the personal data of Clients no longer than the purpose of processing personal data requires, unless otherwise provided by the requirements of the legislation of the Russian Federation. 4.5. The Operator can process the following personal data of Clients: — Name and second name; — Address; — Contact phone number; — E-mail address. 4.6. The processing of special categories of personal data is not carried out: — Regarding racial or ethnic origin; — Regarding political views, religious or philosophical beliefs; — Regarding health and personal life.

5.1. When processing personal data, the Operator takes the necessary legal, organizational and technical measures or ensures their adoption to protect personal data from unlawful or accidental access, destruction, alteration, blocking, copying, provision, distribution of personal data, as well as from other illegal actions in regarding personal data. 5.2. Measures to ensure the security of personal data during their processing, applied by the Operator, are planned and implemented in order to ensure compliance with the requirements specified in Article 19 of the Federal Law "On Personal Data". 5.3. In accordance with Article 18.1 of the Federal Law “On Personal Data”, the Operator independently determines the composition and list of measures necessary and sufficient to ensure compliance with legal requirements. The Operator, in particular, has taken the following measures: — Appointed responsible for the organization of PersData processing; — Local acts on the processing of PersData have been developed and implemented, as well as local acts establishing procedures aimed at preventing and identifying violations of established procedures for processing PersData and eliminating the consequences of such violations;    Legal, organizational and technical measures are taken to ensure the safety of PersData in accordance with Article 19 of the Federal Law "On Personal Data";    Internal control is carried out over the conformity of the processing of PersData of the Federal Law “On Personal Data” and the regulatory legal acts adopted in accordance with it, the requirements for the protection of PersData, the Operator’s policy regarding the processing of PersData, local acts of the Operator;    It is acrried out an assessment of the harm that may be caused to the subjects of personal data in case of a violation of the FZ “On Personal Data”, the ratio of the specified harm to the measures taken by the Operator to ensure compliance with the obligations stipulated by the Federal Law “On Personal Data”;    Employees of the Operator who directly process the PersData are familiar with the provisions of the legislation of the Russian Federation on PersData, including the requirements for the protection of PersData, documents that determine the Operator’s policy regarding the processing of PersData, local acts on the processing of PersData. 5.4. In addition to the requirements of the Federal Law “On Personal Data”, the Operator carries out a set of measures aimed at protecting information about Clients, employees and contractors.

6.1. Personal data subject has the right: — To receive personal data relating to this subject and information regarding their processing; — To clarify, block or delete his personal data when they are incomplete, outdated, inaccurate, or unlawfully obtained or not necessary for the stated purpose of the processing; — To withdraw their consent to the processing of personal data; — To protect their rights and legitimate interests, including to recover damages and compensation for non-pecuniary damage by judicial process; — To appeal against the actions or omissions of the Operator to the authorized body for the protection of the rights of personal data subjects or by judicial process. 6.2. In order to exercise their rights or legitimate interests, personal data subjects have the right to contact the Operator in person or with the help of a representative, in order to provide a written request. The request must contain the information specified in part 3 of article 14 of the Federal Law "On Personal Data" and may be sent in electronic form to the address support@ads2.bid

Limited Liability Company “PROFITCLICKS” Legal and actual address: 4th floor, b.367 Krasnykh Partizan Str., Krasnodar, 350049 OGRN: 1182375066136 INN: 2308258253 KPP: 230801001 c/a 40702810310000416681 in JSC "Tinkoff Bank" c/a 30101810145250000974 BIC 044525974 Director Kolchenko Andrey Aleksandrovich