TERMS AND DEFINITIONS USED IN THIS PRIVACY POLICY

Privacy Policy on processing of personal data provided by personal data subjects (online via the website: junistat.com)

1. GENERAL PROVISIONS

1.1 This Privacy Policy on Processing of Personal Data (hereinafter referred to as the “Privacy Policy”) applies to the collection, recording, systematizing, storage, clarification (updating, modifying), retrieval, use, transmission, depersonalization, blocking, deletion, and destruction of information related to personal data of persons using the Website Services and its Services (hereinafter referred to as “Users”) provided by Personal Data Subjects through the Website: [https://www.junistat.com] (hereinafter referred to as the “Website”) on the Internet.

All issues related to the processing of personal data not regulated by this Privacy Policy shall be resolved in accordance with the current legislation of the United States of America in the field of personal data.

1.2 The current version of the Privacy Policy is a public document and is available to any user of the Internet when using the Site. The Operator may amend this Privacy Policy. When amending the Privacy Policy, the Operator shall notify the users by posting a new version of the Privacy Policy on the website no later than 14 days before the relevant amendments come into force.

1.3. The User agrees to the terms of this provision when using the Website. In case of User’s disagreement with the Terms and Conditions, the use of the Website shall be terminated by the User.

1.4. Personal data processing is based on the following principles:

1.4.1. storing personal data in a form that allows determining the subject of personal data no longer than the purpose of processing personal data requires, if the storage period of personal data is not established by federal law, by a contract to which the beneficiary or guarantor under which the personal data subject is a party;

1.4.2. legality of purposes and methods of personal data processing, integrity and fairness in the Operator’s activities;

14.3. reliability of personal data, their sufficiency for the purposes of processing, inadmissibility of processing of personal data redundant to the purposes declared during collection of personal data;

1.4.4. inadmissibility of combining databases containing personal data processed for purposes incompatible with each other;

1.5. In carrying out its activities, the Operator may transfer personal data of the subjects to the state authorities within the framework of the latter’s powers and functions, as well as to the Operator’s counterparties in strict accordance with the requirements of ensuring the security of these data.

1.6. This Privacy Policy does not apply to any relations arising from:

1.6.1. the organization of storage, acquisition, accounting, and use of documents containing personal data of the Archive Fund of the United States or other archive funds;

1.6.2. the processing of personal data classified in accordance with the established procedure as information constituting state secrets in the United States;

1.7. Conditions of Personal Data Processing by the Operator:

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

1.7.2. personal data processing is necessary for the execution of the contract to which the personal data subject is a party or beneficiary;

1.7.3. personal data processing is necessary to protect the life, health or other vital interests of the personal data subject, in case it is impossible to obtain the consent of the personal data subject;

1.7.4. personal data processing is necessary for the exercise of the rights and legitimate interests of the Operator or third parties or for the achievement of socially significant goals, provided that the rights and freedoms of the personal data subject are not violated;

1.7.5. processing of personal data, access of an unlimited number of persons to which is provided by the personal data subject or at his request;

1.8. The Operator, on the basis of the contract, may entrust the processing of personal data to a third party. The essential condition of such an agreement is the right of this person to process personal data, the obligation to ensure the confidentiality of personal data and the security of personal data during their processing.

1.9. Storage of personal data shall be carried out in a form that allows determining the subject of personal data, no longer than the purposes of their processing require, and they shall be destroyed upon achievement of the processing goals or in case of loss of the need to achieve them in the manner provided for by the Privacy Policy on storage of personal data with the Operator.

2. PURPOSES OF COLLECTING AND PROCESSING PERSONAL DATA

2.1. Personal data processing of personal data subjects is performed by the Operator for the following purposes:

2.1.1. Use of website functionality by the personal data subject;

2.1.2. Processing of information received from users of the Site as part of its activities;

2.1.3. Processing of personal data is carried out for statistical or other research purposes, with the exception of the purposes specified in Article 15 of the Federal Law of 27.07.2006 N 152-FZ “On Personal Data”, provided that personal data is necessarily depersonalized;

2.1.4. Providing information of a notifying nature, including on existing shares and new conditions of existing tariffs and prices for services.

2.1.5. Processing of requests or complaints from Users in connection with the use of the website.

2.1.6. Execution of the Agreement concluded between the Operator and the User by acceptance by the User of the offer posted by the Operator on its website.

2.1.7. promotion of services provided by the Operator in the market.

3. SCOPE OF PERSONAL DATA

3.1. The Operator performs automated processing of the following categories of personal data of Users obtained using the mobile website (including, but not limited to):

3.1.1. Last name, first name, patronymic;

3.1.2. Payment system data (billing and correspondent accounts)

3.1.3. Mobile phone number;

3.1.4. E-mail address;

3.1.5. Passport data

3.1.6. Address of the place of residence;

3.1.7. Name of legal entity;

3.1.8. Registration data of the Legal Entity;

3.2. The operator processes the personal data of the subjects to the extent necessary for interaction

3.3. Cookies can be used in data collection. “Cookies” do not contain information constituting Personal Data, but are aimed solely at personalizing the Site in relation to a particular user device. The settings for using cookies depend on the settings of the browser of the visitor to the website.

4. COLLECTION, PROCESSING, STORAGE, PROTECTION, BLOCKING AND DESTRUCTION OF PERSONAL DATA

4.1. The Operator shall collect personal data of the User in accordance with this Privacy Policy .

4.1.1. Upon entering the website, the Operator shall provide the User with this Privacy Policy for familiarization with the purposes of obtaining personal data specified in Section 2, alleged sources and methods of obtaining personal data, as well as on the nature and nature of personal data to be received in order to obtain the User’s consent for subsequent collection of personal data of the user by the Operator

4.1.2. Collection of personal data of the User is carried out on the website upon login (registration), as well as in the future when the user, on his own initiative, enters additional information about himself using the functionality of the Site.

4.1.3. All personal data of the User are obtained from them personally with their consent (received in electronic form). Personal data processing of Users may be conducted without their consent in instances where personal data are publicly available; personal data processing is performed for statistical purposes and to enhance the service quality of the operator, provided that personal data is depersonalized; and in other cases, stipulated by the legislation of the United States.

4.1.4. The consent of the subject to the processing of personal data is valid for the entire term of the contract (public offer).

4.2. The Operator shall process the personal data of the User in accordance with this Privacy Policy .

4.2.1. Personal data processing is performed by the Operator on the basis of consent of the personal data subject to processing his personal data, expressed by indicating this when entering the site.

4.2.2. Only the Operator, its representatives and counterparties may have access to processing of personal data of Users in the cases specified in this provision.

4.3. The Operator shall store the received and processed data of the User in accordance with this Privacy Policy .

4.3.1. Personal data of users is stored exclusively on electronic media and is processed when necessary, using automated systems.

4.3.2. The Operator undertakes not to transfer the Personal Data of Users to third parties, except in cases of transfer of personal data for the purpose of conclusion and execution of a contract, one of the parties to which is a personal data subject. Subject to user’s consent, personal data may be transferred to the Contractor’s third parties with the condition that such counterparties assume obligations to ensure confidentiality of the received information.

4.3.3. Personal data of Users shall be provided at the request of state or local self-government bodies in accordance with the procedure stipulated by the legislation.

4.4. The Operator shall take technical and organizational legal measures to ensure protection of the User’s personal data against unlawful or accidental access to them, destruction, modification, blocking, copying, distribution, as well as against other illegal actions. Protection of personal data of the User means a set of measures aimed at preventing unlawful or accidental access to them, destruction, modification, blocking, copying, distribution of personal data of subjects, as well as against other unlawful actions.

4.4.1. The protection of the User’s personal data shall be provided at the Operator’s expense in accordance with the procedure established by the legislation of the United States.

4.5. The Operator shall lock the received personal data of the User in accordance with this Privacy Policy . Blocking of personal data of the User means prohibition of editing personal data; prohibition of dissemination of personal data by any means; prohibition of the use of personal data in mass mailings.

4.5.1. The User’s personal data shall be blocked with a written statement of the User sent via the Internet.

4.5.2. Personal data of the User shall be released with the User’s consent or application.

4.5.3. The re-consent of the User to the processing of his personal data entails the unblocking of his personal data.

4.5.4. Temporary release of the User’s blocked personal data may be necessary to comply with the legislation of the United States.

4.6. The Operator shall destroy the User’s personal data in accordance with this Privacy Policy .

4.6.1. The User’s personal data shall be destroyed upon the User’s application sent via the Internet or provided in writing to the address of the Operator indicated in the details.

4.6.2. The collected personal data shall be destroyed within the period established by the relevant federal, state, or local laws in the United States, in cases of the expiration of the established period of personal data processing or the achievement of processing objectives, unless otherwise established by applicable laws in the United States.

4.7. After deleting or deactivating the Account of the User, the Site may store information (including Account profile information) and User Materials for a commercially reasonable period of time, but not more than five years, for the purpose of creating backups and archives, as well as for the purpose of audit.

4.8. Employees of the Operator who are directly involved in personal data processing shall be informed and trained on the provisions of the applicable laws in the United States on personal data, including requirements for personal data protection, documents defining the Operator’s policy regarding personal data processing, local acts on personal data processing, with this Privacy Policy, and any amendments to it.

4.9. When collecting personal data using information and telecommunication networks, the Operator is obliged to publish in the corresponding information and telecommunication network this document defining the policy regarding personal data processing and information on the implemented requirements for personal data protection, as well as to provide access to the specified document using the means of the corresponding information and telecommunication network.

5. RIGHTS AND OBLIGATIONS OF USERS AND OPERATOR

5.1. Users may:

5.1.1. Users have the right to send their requests to the Operator, including requests regarding the use of collection, processing, storage, protection, blocking, and destruction of their personal data in accordance with the relevant laws in the United States, through an electronic document signed by a qualified electronic signature, to email: support@junistat.com

5.1.2. Users have the right to freely access information about yourself through the use of the Site;

5.1.3. Users have the right to require the Operator to clarify, block or destroy its personal data if such data are incomplete, obsolete, inaccurate, illegally obtained or not necessary for the stated processing purpose;

5.1.4. Users have the right to appeal to the authorized body for protection of rights of personal data subjects or in court against unlawful actions or omissions in the collection, processing, storage, protection, blocking and destruction of personal data of the User.

5.2. The Operator may:

5.2.1. The Operator has the right to provide personal data of the User to third parties, if this is provided by the effective legislation or agreement with the User;

5.2.2. The Operator has the right to refuse to provide personal data in cases stipulated by the relevant laws in the United States, such as the Freedom of Information Act, the Privacy Act, and other applicable laws and regulations;

5.2.3. The Operator has the right to use the personal data of the User without his or her consent, in cases stipulated by the relevant laws in the United States, such as for law enforcement purposes, national security, public health or safety, or other legally permissible purposes.

5.3. The Operator shall consider the provisions of paragraph 5.1.1. requests and requests, send a response to received user requests within the time period required by the relevant laws in the United States, including the applicable provisions of the Freedom of Information Act, the Privacy Act, and other applicable laws and regulations. All correspondence received by the Operator from users relates to restricted access information and is not disclosed without the written consent of the User, in accordance with the applicable laws in the United States, such as the Privacy Act and other applicable laws and regulations.

6. LIABILITY

6.1. The responsibility for fulfilling the requirements of Federal Law No.152 “On Personal Data” in the Company is assigned to Shaportov G.I. The responsibility for organizing the processing and ensuring the security of personal data in accordance with the requirements of Federal Law No. 152 “On Personal Data” and this Policy is assigned to Shaportov G.I.

6.2. For violation of the rules for processing personal data, their unlawful disclosure or dissemination, the guilty persons bear disciplinary, administrative, civil or criminal liability in accordance with the current legislation.

7. FINAL PROVISIONS

7.1. The law of the United States shall apply to this Privacy Policy and the relations arising from its application. In case of amendments to legislative and other regulatory acts of the United States, this Privacy Policy, as well as amendments to it, shall apply to the part that does not contradict the newly adopted legislative and other regulatory legal acts of the United States.

7.2. The Operator shall have the right to amend this Privacy Policy. If changes are made to the current revision, the date of the last update is indicated. The new version of the Privacy Policy comes into force from the moment it is posted on the Internet on the Site, in accordance with applicable laws in the United States.

7.3. Data subjects or their representatives have the rights provided by the relevant laws in the United States and other regulatory legal acts regulating the processing of personal data.

7.4. The Operator ensures the rights of data subjects in the manner established by applicable laws in the United States regulating the processing of personal data.

7.5. The right of a data subject to access to their personal data may be limited in accordance with applicable laws in the United States.

7.6. The information specified in relevant laws in the United States regarding personal data is provided to the personal data subject or their representative upon personal request or upon receipt of a request from the personal data subject or their representative. The request shall contain the number of the main document confirming the identity of the personal data subject or their representative, information about the date of issuance of the said document and the authority issuing it, information confirming the participation of the personal data subject in relations with the Operator (contract number, date of contract conclusion, verbal symbol and/or other information) or information otherwise confirming the fact of personal data processing by the Operator, signature of the personal data subject or their representative. If it is technically possible, the request may be sent in the form of an electronic document and be signed by electronic signature in accordance with the relevant laws in the United States.

8.OPERATOR DETAILS

Name: JUNISTAT СORP Address: USA, State of Delaware, 251 Little Falls Drive, Wilmington, New Castle County, 19808 EIN Assigned: 88-1287654