Privacy Policy

SPIRIT UP

October 1, 2024.

CONTENT

DEFINITIONS

GENERAL PROVISIONS

CATEGORIES OF PERSONAL DATA PROCESSED

PROCEDURE AND CONDITIONS OF PERSONAL DATA PROCESSING

DATA PROCESSING PURPOSES

LEGAL GROUNDS FOR INFORMATION PROCESSING

TRANSFER AND DISCLOSURE OF PERSONAL DATA

ADVERTISING AND SURVEYS

COOKIE POLICY

THIRD-PARTY WEBSITES AND COOKIES

DURATION OF PROCESSING, MODIFICATION OF PERSONAL DATA AND DELETION OF PERSONAL DATA

REQUESTS FROM PERSONAL DATA SUBJECTS APPLICABLE LAW; JURISDICTION;

CROSS-BORDER DATA TRANSFER

CHANGE OF OWNERSHIP

CONTACT INFORMATION

DEFINITIONS

1.1. For the purposes of this Privacy Policy, the following terms will have the following meanings:

"Spirit Up" means, jointly created and operated by the Company: (i) a website accessible via the Internet at URLs and (ii) an interactive iOS and/or Android mobile application available on the official Apple Inc. App Store and/or the App Store Google's Google Play;

"Automatically Collected Data" means information about the User, his device(s), his use of the Internet and Spirit Up using automatic data collection technologies, including, but not limited to, proprietary and third-party cookies, log files, web beacons, pixels and other similar technologies.;

"Company" means the operator of personal data, the company "Individual Entrepreneur Masalov Vladimir Yurievich", a legal entity duly established and operating in accordance with the legislation of the Russian Federation, address: 5 Gzhatskaya Street, building 8, apartment 92, Moscow, Russian Federation, as well as its subsidiaries and affiliated companies Company name;

"Processing" is any action (operation) or set of actions (operations) with Personal Data performed with or without automation tools, namely: collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (provision, access), depersonalization, blocking, deleting, destroying;

“Personal Data” means any information about a specific or identifiable User;

"User" means both the Practitioner and the Client.;

"Practitioner" means an individual acting in a personal capacity or as a representative or employee of a legal entity registered with Spirit Up for the purpose of providing services to Clients;

"Client" means an individual acting in a personal capacity or as a representative or employee of a legal entity registered with Spirit Up and receiving services from the Practice.;

"Related Documents" means, collectively, the legal documents governing the use of Spirit Up, as defined in the User Agreement, available at the following link: https://spiritup.club

"Account" means a personalized Spirit Up section that is closed to the public. Access to the Account is carried out by entering authentication data in the login interface (for iOS and Android versions of Spirit Up) or on the login web page (for the web version) of Spirit Up: login (username) and password (access code).

BASIC RIGHTS AND OBLIGATIONS OF THE COMPANY AND THE USER

2.1. The Company has the right to:

2.1.1. independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations provided for by applicable law and regulatory legal acts adopted in accordance with it, unless otherwise provided by applicable law;

2.1.2. entrust the processing of personal data to another person with the consent of the personal data subject, unless otherwise provided by applicable law, on the basis of a contract concluded with this person. The person who processes personal data on behalf of the Company is obliged to comply with the principles and rules of personal data processing provided for by applicable law, to respect the confidentiality of personal data, and to take the necessary measures to ensure compliance with the obligations provided for by applicable law. ;

2.1.3. if the personal data subject withdraws consent to the processing of personal data, the Company has the right to continue processing personal data without the consent of the personal data subject, provided that there are grounds specified in the Personal Data Act, in particular.

2.2. The Company is obliged to:

2.2.1. organize the processing of personal data in accordance with the requirements of applicable law;

2.2.2. respond to requests and requests from personal data subjects and their legal representatives in accordance with the requirements of applicable law;

2.2.3. to provide the necessary information to the authorized body for the protection of the rights of personal data subjects at the request of this body within 10 working days from the date of receipt of such request. This period may be extended, but not for more than five years.

working days. To do this, the Company must send a reasoned notification indicating the reasons for extending the deadline for providing the requested information.;

2.2.4. in accordance with the procedure determined by the executive authority authorized in the field of security, ensure interaction with the state system for detecting, preventing and eliminating the consequences of computer attacks on information resources, including informing it about computer incidents that have resulted in the unlawful transfer (provision, dissemination, access) of personal data.

2.3. The User has the right to:

2.3.1. receive information regarding the processing of his Personal Data, except in cases provided for by applicable law. The information is provided to the personal data subject by the Company in an accessible form, and it should not contain personal data related to other personal data subjects, except in cases where there are legitimate grounds for

disclosure of such personal data. The list of information and the procedure for obtaining it are established by applicable law. ;

2.3.2. require the Company to clarify his personal data, block or destroy them if the personal data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated purpose of processing, as well as take legal measures to protect their rights.;

2.3.3. give prior consent to the processing of personal data in order to promote goods, works and services on the market;

2.3.4. revoke consent to the processing of Personal Data at any time if it is based on such consent. Revocation of consent will not affect the legality of processing based on consent prior to revocation, as well as the processing of Personal Data for other reasons.;

2.3.5. to appeal to the supervisory authority or in court against unlawful actions or omissions of the Company in processing his personal data.

2.4. The User is obliged to provide accurate, relevant, up-to-date and complete Personal Data.

2.5. If the Company believes that the Personal Data provided is not accurate, relevant, up-to-date or complete, or is false or misleading, the Company has the right to deny the User access to Spirit Up, or block or terminate access to Spirit Up or to any of its resources, or block or delete the Account.. This provision does not apply to cases where the provision of Personal Data is not mandatory and the User can specify any data (for example, when choosing a username in Spirit Up).

2.6. Control over the fulfillment of the requirements of this Policy is carried out by the authorized body.

the person responsible for organizing the processing of personal data in the Company.

GENERAL PROVISIONS

3.1. This Privacy Policy regulates the Processing of Personal Data, as well as Automatically Collected Data necessary for the use and/or related to the use of Spirit Up by the User, as defined in this document.

3.2. By providing any Personal Data through or through Spirit Up, or otherwise accessing or using Spirit Up, the User confirms that he has read this Privacy Policy and has expressed his agreement to its terms.

3.3. The Company has the right to change this Privacy Policy in any way in order to comply with applicable law and/or comply with government regulations and/or improve Spirit Up, as well as to introduce new or additional rules, policies, terms or conditions regarding Spirit Up, Personal Data Processing, from time to time with or without direction Notifications to the user.

3.4. The Company has the right to notify the User of changes to this Privacy Policy by sending an email message to the email address specified during Account registration and/or posting a notification in Spirit Up.

3.5. All changes to this Privacy Policy will take effect immediately upon publication of the current version of the Privacy Policy in Spirit Up.

3.6. If the User provides any Personal Data through or through Spirit Up, or otherwise accesses or uses Spirit Up after the publication of the current version of the Privacy Policy, it will be considered that the User has accepted the latest version of this Privacy Policy.

3.7. The User is responsible for regularly reviewing this Privacy Policy. Their use of Spirit Up or any part of it after posting a notice of changes to this Privacy Policy in Spirit Up or otherwise making it available for review will constitute the User's consent to such changes, and will be considered an expression of consent to be legally bound by them. If the User objects to any such changes, he has the right to resort to preventing the processing of Personal Data, to deleting Spirit Up from his device and his Account, and to request the deletion of his Personal Data by contacting the email address specified in the "Contact Information" section of this Privacy Policy.

CATEGORIES OF PERSONAL DATA PROCESSED

4.1. In certain cases of using Spirit Up listed below, Spirit Up may request the User to provide information that identifies or allows for direct or indirect identification of the User. Personal Data provided by the User through and with the help of Spirit Up and received from the User through Spirit Up may include (but is not limited to) the following data:

4.2. The Company may process personal data of the following categories of personal data subjects:

4.2.1.Personal Data of Clients processed for the purpose of concluding and executing the Client's User Agreement:

data, if available, contained in a social network profile or an account created in a web resource or application of a third party, used for registration in Spirit Up and authentication in it, such as date of birth and residential address, first name, last name, profile picture, age, as well as other available data;
date (year, month, date) of birth;
valid email address;
residential address;
mobile phone number;

other information that allows the Client to be identified as an individual, which may be required by the Company and requested through Spirit Up for the purpose of providing the Client with access to Spirit Up and its functions and fulfilling the Client's User Agreement.

4.2.2. Personal Data of Practitioners, in addition to those specified in clause 4.2.1 of this Policy, for the purpose of concluding and executing civil law contracts:

passport data or data of another identity document;
registration address;
financial information such as the credit or debit card number, the expiration date of the bank card; • information about the level of education and documents (for example, diplomas, certificates, certificates) confirming experience in the field of the offered practices (if any); and
other information that allows the Practitioner to be identified as an individual, which may be required by the Company and requested through Spirit Up in order to provide the Practitioner with access to Spirit Up and its functions and to comply with the provisions of Related Documents and Contracts between the Practitioner and the Company.

4.3. In addition to Personal Data when downloading, accessing and/or using Spirit Up, the Company and/or service providers authorized by the Company may, to the extent permitted by applicable law, collect, store and process Automatically Collected Data whenever a User interacts with Spirit Up. Such information may include, but is not limited to:

location of the User's device (identification of the country, territorial entity or region);
information about the Internet service provider;
information about the device's operating system (including, but not limited to, the programming language of the operating system and its version) and the device from which the Application is accessed and used, including the type and serial number of the mobile device (where applicable), mobile device ID and information about calls, device events (malfunctions, system activity and settings, date and time of the request, and URL link);
information about the programming language, type and version of the browser used to access and use the Site;
The IP address from which Spirit Up is accessed and used;
information about the mobile network, mobile operator, country codes and mobile operator prefixes;
the time zone;
the domain name and/or URL from which the Site is accessed;
visit/access logs (logs) data;
visited pages and sections of Spirit Up;
the used functionality of Spirit Up;
date and time of access to Spirit Up;
information related to an account in the Apple iTunes or Google Play app stores, or another account used to download and access the App.;
information about the web pages that the User visits from Spirit Up, or those that were visited before or after using Spirit Up;
information (such as contact information such as phone number or email address) from the contact list stored on the device for the purposes of sending invitations to use Spirit Up to contacts and verifying the use of Spirit Up by persons in the contact list (that is, verifying that Spirit Up accounts have already been created with the corresponding phone numbers or email addresses);
information collected by third-party advertising in Spirit Up, from third parties providing the Company's services and from third parties with whom the Company carries out advertising activities, including information from the Company's advertising partners; and
other information about the device(s), the User's Internet surfing habits, and interests that does not allow identification.

4.4. The automatically collected Data processed by the Company and/or third parties authorized by the Company is used solely for the purpose of improving Spirit Up, as well as for advertising and marketing purposes, resolving technical support requests, protecting User Accounts from fraud by detecting unauthorized access, and providing the User with an optimized and personalized experience.

4.5. The User hereby grants the Company, all its affiliated companies, subsidiaries and authorized persons, including, but not limited to, the service provider authorized by the Company, explicit consent to the collection, use and other processing of all Automatically Collected Data listed above.

4.6. The User hereby agrees that the Company and/or third parties authorized by the Company have the right to freely disclose any and all such Automatically Collected Data to third parties of their choice, including, but not limited to, third-party advertisers and other persons.

4.7. The User has the right to regulate the collection of automatically collected data using the permission settings of the operating system of the device or Application used.

4.8. The User may revoke his consent to the processing of Automatically Collected Data in terms of certain information that is not required to fulfill the User Agreement or other Related Documents or to realize the legitimate interests of the Company, as indicated below, as well as by using the permission settings of the operating system of his device.

PROCEDURE AND CONDITIONS OF PERSONAL DATA PROCESSING

5.1. The Company and/or the personal data processor authorized by the Company, who processes Personal Data (when and if applicable), process Personal Data in accordance with the following general principles, in accordance with the procedure and conditions specified in this section:

5.1.1. Personal Data is always received or will be received exclusively from the User, and not from any third party.

5.1.2. The processing of Personal Data is limited to the achievement of specific, predetermined and legitimate purposes. Processing of Personal Data incompatible with the purposes of Personal Data collection is not allowed.

5.1.3. Personal Data is collected, processed, stored and used only in accordance with the purposes of Personal Data Processing established by this Privacy Policy and the User's explicit consents provided in accordance with this Privacy Policy.;

5.1.4. Personal data is processed by the Company in accordance with the requirements of applicable law.;

5.1.5. Personal Data is always collected, processed, stored and used separately from anonymous or depersonalized data that may be received from the User in accordance with this Privacy Policy.;

5.1.6. Personal Data is processed confidentially and employees of the Company whose job responsibilities include processing personal data are allowed to process personal data.;

5.1.7. Personal Data will not be transferred to any third party without the User's express consent to such transfer, except in cases where such transfer is carried out on the basis of the consents provided by the User in accordance with this Privacy Policy, required by government authorities such as courts or law enforcement agencies, or by law, as described further in this Privacy Policy;

5.1.8. the processing of Personal Data by third parties, such as a personal data processor authorized by the Company on behalf (when and if applicable), will always be carried out with the same level of confidentiality, data security and in strict accordance with the principles and objectives set out in this Privacy Policy.;

5.1.9. the amount of Personal Data collected does not exceed and will not exceed the amount necessary for processing purposes in accordance with this Privacy Policy.

5.1.10. The processing of personal data is carried out with the consent of the subjects of personal data to the processing of their personal data, as well as without it in cases provided for by applicable law.

5.2. The Company processes personal data for each purpose of their processing in the following ways:

non-automated processing of personal data;
automated processing of personal data with or without transmission of the received information via information and telecommunication networks;
mixed processing of personal data.

5.3. The processing of personal data for each purpose of processing specified in clause 2.3 of the Policy is carried out by:

receiving personal data in oral and written form directly from personal data subjects;
entering personal data into the Company's journals, registers and information systems;
using other methods of personal data processing.

5.4. Disclosure and dissemination of personal data to third parties is prohibited without the consent of the personal data subject, unless otherwise provided by applicable law.

5.5. The transfer of personal data to the bodies of inquiry and investigation, to the tax service and other authorized executive authorities and organizations is carried out in accordance with the requirements of applicable law.

5.6. The Company takes the necessary legal, organizational and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, distribution and other unauthorized actions, including:

identifies threats to the security of personal data during their processing;
Adopts local regulations and other documents regulating relations in the field of personal data processing and protection;
appoints persons responsible for ensuring the security of personal data in the Company's structural divisions and information systems;
creates the necessary conditions for working with personal data;
organizes accounting of documents containing personal data;
organizes work with information systems in which personal data is processed;
stores personal data in conditions that ensure their safety and prevent unauthorized access to them.;
organizes the training of the Company's employees who process personal data.

5.7. The Company stores personal data in a form that allows determining the subject of Personal Data for no longer than required by each purpose of personal data processing, unless the retention period of personal data is established by applicable law, contract.

5.8. The storage period of personal data processed in personal data information systems corresponds to the storage period of personal data on paper.

5.9. The Company stops processing personal data in the following cases::

the fact of their illegal processing has been revealed. The deadline is within three working days from the date of detection.;
the goal of their processing has been achieved;
the consent of the Personal Data subject to the processing of the specified data has expired or been revoked when, according to the Law on Personal Data, the processing of this data is allowed only with consent.

5.10. Upon achievement of the purposes of processing personal data, as well as in case of withdrawal of the User's consent to their processing, the Company stops processing this data if:

5.10.1. nothing else is provided for by the agreement to which the User is a party, beneficiary or guarantor; 5.10.2. The Company does not have the right to process personal data without the consent of the subject on the grounds provided for by applicable law or other applicable law.;

5.10.3. no other agreement is provided for by the Company and the User.

5.11. If a personal data subject applies to the Company with a request to terminate the processing of personal data within a period not exceeding 10 working days from the date of receipt by the Company of the relevant request, the processing of personal data is terminated, except in cases provided for by applicable law. The specified period may be extended, but not more than five working days. To do this, the Company must send a reasoned notification to the personal data subject, indicating the reasons for the extension.

DATA PROCESSING PURPOSES

6.1. Only Personal Data that meets the purposes of their processing is subject to processing.

6.2. The Company processes Personal Data for the following purposes::

6.2.1. the Company carries out activities in accordance with the activities of the Individual Entrepreneur Aleynichenko E.R., including the conclusion and execution of contracts with the User;

6.2.2. registration of a Spirit Up User by creating an Account in Spirit Up;

6.2.3. providing the User with access to Spirit Up, including paid or additional functionality of Spirit Up and the support service to resolve any issues or disputes, pay royalties by the User or solve problems related to compliance with the User Agreement, the provisions of Related Documents and other agreements between the User and the Company;

6.2.4. ensuring compliance with the User Agreement, the provisions of Related Documents and other agreements between the User and the Company;

6.2.5. conducting marketing activities, including, but not limited to, sending and displaying to the User promotional and advertising or informational materials related to the new functionality or services of Spirit Up, as well as products and services of the Company/or its subsidiaries or affiliates and partners, including advertising partners, and sending other information to the User, which the User requested or agreed to receive;

6.2.6. personalization of content and functionality that the User gets access to while using Spirit Up;

6.2.7. Spirit Up Content Improvements;

6.2.8. tracking demographics, interests, total number and behavior of Users;

6.2.9. providing the User with service messages or notifications containing information related to the Account and to inform the User about his Account, relevant security issues, events or updates, authorization status or changes related to his Account;

6.2.10. conducting sociological, marketing and statistical research based on the Personal Data provided and using information obtained from user surveys conducted by the User in order to take into account his preferences, improve and optimize User interaction with Spirit Up, with its functions and services;

6.2.11. the use of Personal Data for internal commercial purposes of the Company directly related to Spirit Up, including, but not limited to:

measuring the effectiveness of advertising and marketing;
development and improvement of Spirit Up;
consideration of any requests, claims, comments or User reviews;
protection of the Company's activities, its rights, safety or property, or any of its affiliates;
ensuring the observance or restoration of legal rights or preventing damage.

6.2.12. detecting and preventing cases of fraud and malicious use of Spirit Up, ensuring Spirit Up's network and information security, countering spam and other malware and other cybersecurity risks, and complying with applicable laws and security requirements;

6.2.13. responding to requests from government agencies or complying with applicable legal requirements.

6.3. The Company does not process biometric personal data (information that characterizes the physiological and biological characteristics of a person, on the basis of which his identity can be established) or special categories of personal data related to race, nationality, political views, religious or philosophical beliefs, health status, intimate life, except in cases provided for by applicable law. the right one.

LEGAL GROUNDS FOR INFORMATION PROCESSING

6.4.

6.5. When Processing Personal Data, the Company relies on the legal grounds provided by:

The User Agreement and other agreements concluded with Users;
the consent of Users to the processing of their personal data;
the legitimate interest of the Company within the limits provided by the Applicable Law specified in Section 13 of this Policy;
mandatory requirements of applicable law.

6.6. The applicable legal basis will depend on the Personal Data and the specific purpose of their Processing. Below is a list of how the Company uses Personal Data, as described in the section above, with the relevant legal grounds for processing. The Company processes Personal Data if:

the processing is necessary to fulfill the User Agreement, Related Documents and any other agreements between the Company and the User, or to perform actions at the User's request aimed at concluding agreements (Goals 5.2.1-5.2.4, 5.2.9); or
The Company has obtained the User's consent to this (Goals 5.2.5, 5.2.6, 5.2.10); or
the processing meets the legitimate business interests of the Company or its affiliates and does not contradict the fundamental rights and freedoms of the User (Objectives 5.2.7, .5.2.8, 5.2.10-5.2.12); or
there is a corresponding legal obligation; or the processing is necessary to protect the vital interests of the User or the interests of another person (Objectives 5.2.13).

ACCESS AND DATA TRANSFER

7.1. The Company has the right to use Personal Data jointly with other persons affiliated with the Company, such as (but not limited to) subsidiaries and controlling or controlled persons for internal business purposes and 11 operational purposes, for example, to fulfill payments made or received using Spirit Up, including, but not limited to royalties for using Spirit Up.

7.2. As of the effective date of this Privacy Policy, the Company transfers Personal Data to the following authorized service providers:

7.2.1. Spirit Up hosting (including cloud and server hosting) and/or Spirit Up management;

7.2.2. receiving and processing payments made through Spirit Up;

7.2.3. sending e-mail messages;

7.2.4. conducting user behavior research;

7.2.5. creating and sending personalized advertisements to the User and performing any other functions.

7.3. Despite the fact that the Company, its affiliates and authorized persons, as well as the service provider authorized by the Company who processes Personal Data (when and if applicable), treat Personal Data confidentially and do not and will not disclose them to third parties without the User's prior consent or in accordance with this Policy Privacy Policy, the Company and the specified persons reserve the right to disclose Personal Data and, where applicable, Automatically Collected Data., to third parties at their own discretion and without first obtaining the User's consent and without notifying him in the following circumstances and to the following persons:

7.3.1. as may be required by law and in the public interest, in particular, to comply with the requirements of a court order or similar legal process, including if such disclosure of Personal Data is required in accordance with government or legal requests for information, including, but not limited to, requests from any government authorities, including but not limited to local and international police authorities and courts conducting investigations;

7.3.2. to the Company's service providers working in the interests of the Company (e.g. network infrastructure, cloud storage, payment processing, cybersecurity, document storage, customer support, Internet service providers, data analytics, information technology, marketing), to the extent necessary for the Company to fulfill its obligations under the User Agreement, Related Documents and other agreements between the User and the Company;

7.3.3. if the Company enters into a merger, acquisition or sale of all or part of its assets;

7.3.4. if it turns out or the Company has sufficient grounds to believe that the User is violating any legal agreement or law related to the User's use of Spirit Up;

7.3.5. if such disclosure of Personal Data is required for the purposes of fulfilling the Company's obligations in accordance with applicable law;

7.3.6. if such disclosure of Personal Data is required for the purposes of responding to an emergency situation that endangers the life, health or vital interests of another person; or

7.3.7. when the Company has reasonable grounds to believe that such disclosure is necessary to protect the rights of the Company, protect the safety of the User, or the safety of other Users, or investigate cases of fraud or malicious use, or if such disclosure of Personal Data is otherwise required for the purpose of protecting the rights, property or safety of third parties, other users of Spirit Up or an unlimited number of persons in any jurisdiction.

ADVERTISING AND SURVEYS

8.1. The Company, the Company's advertising partners or third-party advertisers may use Personal Data to send notifications and other information and promotional materials about new functionality and new content available through Spirit Up, or other services or products (including new services and products of the Controller or its affiliates), if the User has provided consent to receive them. Spirit Up can also display interactive ads.

8.2. When the User accesses Spirit Up, he/she may provide the Company with express consent to receive such information and advertising materials and use Personal Data for these purposes, as well as to use them for the purpose of sending personalized advertising. Personal Data will not be used to send unsolicited advertising messages ("spam") to the User.

8.3. The Company may from time to time conduct surveys of Spirit Up users with voluntary participation, necessary to improve and optimize interaction with Spirit Up, its functionality and services. The User hereby provides the Company with explicit consent to receive invitations to participate in such surveys. By participating in such surveys, the User provides the Company with explicit consent to the processing of Personal Data, which may be required when completing such surveys.

8.4. The User has the right to refuse to receive information and advertising notifications and materials, to participate in surveys by sending a corresponding notification by e-mail sup@spiritup.club or by changing the appropriate Account settings; or by clicking on a special link with the text "unsubscribe" or similar in any such notification and material; or by performing other actions directly indicated in the text of notifications and materials.

COOKIE POLICY

9.1. The technologies used by Spirit Up may include cookies. A "cookie file" is a small data file that can be sent and placed on a User's hard drive and/or in the memory of a computer or mobile device, depending on what is applicable, when accessing and using Spirit Up.

9.2. The Company may use cookies to collect, store and, in some cases, track information for statistical purposes to improve Spirit Up and the functionality and services it offers, as well as to store user preferences, record information about Spirit Up usage sessions, and record user–specific information about pages that the User accesses. who accesses, or who visits, records of past actions in the Application for the purpose of providing better functionality, The next time the User uses Spirit Up, ensure that the User does not receive the same advertising or informational notifications again, and collect other information that the User sends or that may be required to support, improve, and optimize Spirit Up.

9.3. The Company may also use "web beacons" and other similar technologies to assist in the delivery of a cookie file to the User's computer or mobile device. In addition to cookies used exclusively during a web session and deleted after visiting the Site ("Session Cookies"), the Company may use cookies to store information about user settings and other information for a certain time period not exceeding 2 (two) years ("Permanent Cookies").

9.4. The User hereby grants the Company his express consent to the placement of cookies by the Company in the memory of a computer or mobile device for the purposes set out in this Section, including but not limited to the support and improvement of Spirit Up, as well as access to and use of certain functionality and services of Spirit Up.

9.5. Notwithstanding the above, the User can configure the browser in such a way that it will refuse to accept cookies, save them only for the duration of the session, or delete them prematurely. In case of blocking or refusing to place cookies on the User's computer or other device, access and/or use of certain functionality or services of Spirit Up may be restricted.

9.6. Some Internet browsers, such as Internet Explorer, Firefox and Safari, have the ability to send "Do Not track" signals. Since uniform standards for such signals have not been adopted, Spirit Up currently does not process or respond to them. 9.7. Additional information about the use of cookies and similar technologies, in particular, about the types of cookies used, the purpose of each cookie, the provider and the duration of its storage, is contained in the Cookie Policy.

THIRD-PARTY WEBSITES

10.

10.1. Spirit Up may contain hyperlinks to other websites or other Internet resources that are not controlled by the Controller or its affiliates, or are unrelated to them. The user is solely responsible for reviewing the privacy policies of such websites. This Privacy Policy applies only to Spirit Up.

TERM OF PROCESSING, DELETION OF PERSONAL DATA

11.

11.1. Personal Data is processed and stored by the Company and/or a service provider authorized by the Company that processes Personal Data (when and if applicable) for the entire period necessary to provide the User with access to Spirit Up and the ability to use Spirit Up, namely for the entire duration of the Account, notifications and promotional materials., and the use of Personal Data for other purposes established by this Privacy Policy, but not more than 3 (Three) years from the date of termination of use of Spirit Up for any reason, unless the User requests the deletion of Personal Data before the end of the specified period in accordance with this Section. If the User decides to delete their Account in Spirit Up, the above period will apply to the storage of both Personal Data and Automatically Collected Data. The specified data will be stored in the Company's archives during this period, taking into account the longer periods of mandatory data retention established by applicable law.

11.2. The Company is not obligated to store Personal Data indefinitely, and the Company hereby disclaims any liability arising from or related to the destruction of such Personal Data. The Company will store Personal Data only for as long as it is necessary for the initial purposes of their processing, including for the purposes of fulfilling any legal, accounting or reporting obligations or for dispute resolution.

11.3. Contact information such as the User's name and email address, which are processed based on the User's separate consent for marketing purposes, are stored on an ongoing basis until the User withdraws consent to receive them.

11.4. Information collected through technical means such as cookies, web page counters and other analytics tools is stored for the period specified by the Cookie Policy.

REQUESTS FROM PERSONAL DATA SUBJECTS

12.

12.1. The User has the right to request confirmation of the fact of personal data processing by the Company, the legal grounds and purposes of personal data processing, a copy of Personal Data, as well as other information specified in the Law on Personal Data. The response to the User's request is provided by the Company to the personal data subject or his representative within 10 working days from the moment of contacting or receiving the request from the personal data subject or his representative. This period may be extended, but not for more than five working days, by sending a reasoned notification to the User indicating the reasons for extending the deadline for providing the requested information.

12.2. The information provided does not include personal data related to other subjects of personal data, except in cases where there are legitimate grounds for the disclosure of such personal data.

12.3. The request must contain:

the number of the main identity document of the personal data subject or his representative, information about the date of issue of the specified document and the issuing authority;
information confirming the personal data subject's participation in the relationship with the Company, or information otherwise confirming the fact of personal data processing by the Company;
signature of the personal data subject or his representative.

12.4. The request may be sent in the form of an electronic document and signed with an electronic signature in accordance with applicable law.

12.5. The Company provides the information specified in the Personal Data Act to the personal data subject or his representative in the form in which the relevant request or request is sent, unless otherwise specified in the request or request.

12.6. If the request of the personal data subject does not reflect all the necessary information in accordance with the requirements of applicable law, or the subject does not have access rights to the requested information, a reasoned refusal is sent to him.

12.7. The right of a personal data subject to access his/her personal data may be restricted in accordance with applicable law, including if the personal data subject's access to his/her Personal Data violates the rights and legitimate interests of third parties.

12.8. In case of detection of inaccurate Personal Data when contacting a personal data subject or his representative, or at their request or at the request of a supervisory authority, the Company blocks Personal Data related to this personal data subject from the moment of such request or receipt of the specified request for the verification period, if blocking Personal Data does not violate the rights and legitimate interests the subject of personal data or third parties.

12.9. In case of detection of unlawful processing of Personal Data when contacting (requesting) a personal data subject or his representative or a supervisory authority, the Company shall block unlawfully processed Personal Data related to this personal data subject from the moment of such request or receipt of the request.

12.10.If the Company, the supervisory authority or other interested person identifies the fact of unlawful or accidental transfer (provision, dissemination) of Personal Data (access to personal data), which has resulted in a violation of the rights of personal data subjects, the Company:

12.11. within 24 hours, notify the supervisory authority of the incident, the alleged causes that led to the violation of the rights of personal data subjects, the alleged harm caused to the rights of personal data subjects, and the measures taken to eliminate the consequences of the incident, as well as provide information about the person authorized by the Company to interact with the supervisory authority on issues related to the incident;

12.12. within 72 hours, notify the supervisory authority of the results of the internal investigation of the identified incident and provide information about the persons whose actions caused it (if any).

12.13.Personal Data is destroyed by the Company in the following cases::

12.13.1. achievement of the purpose of Personal Data processing or loss of the need to achieve this goal - within 30 days;

12.13.2. achieving the maximum retention period for documents containing personal data within 30 days;

12.13.3. the provision by the personal data subject (his representative) of confirmation that the personal data was obtained illegally or is not necessary for the stated purpose of processing - within seven working days; 12.13.4. withdrawal by the personal data subject of consent to the processing of his personal data, if their retention for the purpose of their processing is no longer required, - in within 30 days. 12.13.5. Upon achieving the purpose of personal data processing, as well as in the case of revocation by the personal data subject of consent to their processing, personal data is subject to destruction if:

12.13.6. nothing else is provided for in the contract to which the personal data subject is a party, beneficiary or guarantor.;

12.13.7. The Company does not have the right to process personal data without the consent of the subject on the grounds provided for by applicable law.;

12.13.8. no other agreement is provided for by the Company and the personal data subject.

12.14.If a personal data subject applies to the Company with a request to terminate the processing of personal data within a period not exceeding 10 working days from the date of receipt by the Operator of the relevant request, the processing of personal data is terminated, except in cases provided for by applicable law. The specified period may be extended, but not for more than five working days, if a reasoned notification is sent to the personal data subject indicating the reasons for the extension.

12.15.The User has the right to terminate the processing of Spirit Up's Personal Data by sending a request to delete the Account. The User can request the deletion of Personal Data using the interface and functionality of Spirit Up. After the Account is deleted, the Personal Data will not be used by the Company for any further purposes or transferred to third parties, except in cases where this is necessary to prevent fraud and assist law enforcement agencies, as required by law, or to carry out, use or defend legal claims. Despite the deletion request, the User hereby acknowledges that the Company will store Personal Data, including the deletion request, to the extent necessary to comply with the applicable law on mandatory data retention for a period of time established by applicable law.

12.16.The applicable law gives the User the right to restrict or object to the processing or transfer of Personal Data to the Company under certain circumstances. The Company may continue to process Personal Data if necessary to protect against legal action or for any other exceptions permitted by applicable law.

12.17. In case of confirmation of the inaccuracy of personal data, the Company, based on information provided by the personal data subject or his representative or the supervisory authority, or other necessary documents, clarifies the personal data within seven working days from the date of submission of such information and removes the blocking of personal data.

APPLICABLE LAW; JURISDICTION

13.

13.1. Except in cases expressly prohibited by applicable law or specified in this Privacy Policy, this Privacy Policy is governed by the law of the Russian Federation. Accordingly, this Privacy Policy is aimed at complying with the requirements of applicable laws and regulations.

CROSS-BORDER DATA TRANSFER; DATA STORAGE IN CERTAIN JURISDICTIONS

14.

14.1. If the legislation of the jurisdiction of the User's location establishes a requirement for the storage or processing of Personal Data of citizens and residents in that jurisdiction, the Company is obliged to comply with this requirement and will store or process Personal Data on servers hosted in that jurisdiction.

14.2. In accordance with the purposes of Data Processing specified in this Privacy Policy, the Company and/or a Personal Data processing service provider authorized by the Company has the right to transfer Personal Data to persons located outside the jurisdiction of the User's location. These persons may be located on the territory of the European Union and the European Economic Area or in another country of the world recognized by a supervisory authority or other authorized state body in the jurisdiction of the User's location, as ensuring adequate protection of the rights of personal data subjects approved by the order of the supervisory authority. By accepting this Policy, the User agrees to the cross-border transfer of Personal Data to any country in the world where the Company is represented by affiliated companies, has structural divisions or other types of representative offices, as well as to other countries of the European Union, the European Economic Area, the United States, Canada, the countries of the Asia-Pacific region, as well as to any other the country of the world where the Company's affiliated persons or service providers may be located. In cases of cross-border transfer of Personal Data outside the jurisdiction of the User's location, the Company will take all appropriate measures, with all recipients of personal data, to ensure the protection of Personal Data and respect for User rights.

CHANGE OF OWNERSHIP

15.

15.1. Disclosure and use by the subsequent owner or operator of Spirit Up of any User information, including Personal Data provided by the Company in accordance with this Privacy Policy, in the event that the Company cedes its rights with respect to such information in connection with the merger, acquisition or sale of some or all of the Company's assets, or in connection with the merger the acquisition or sale of some or all of the assets related to Spirit Up to a subsequent owner or operator is in the legitimate interests of the Company. In the event of such a merger, acquisition or sale, the continued use of Spirit Up by the User will mean his consent to be legally bound by the privacy policy of the subsequent owner or operator of Spirit Up, which may differ from this Privacy Policy. This provision will be in full force and effect regardless of the termination of the User's use of Spirit Up for any reason.

CONTACT INFORMATION

16.

16.1. To send comments or questions regarding this Privacy Policy or data Protection, or requests for access to Personal Data, their correction, blocking, or destruction, or if at any time the User wishes to revoke the granted permissions to use Personal Data, please contact the Company using the following email address: sup@spiritup.club.