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I. General Provisions

  1. This personal data processing policy has been drawn up and defines the procedure for processing personal data and measures to ensure the security of personal data taken by the CLS GLOBAL FZC LLC (hereinafter referred to as the «Operator», «we», «us», «our»).
  2. The Operator sets as its most important goal and condition for the implementation of its activities the observance of the rights and freedoms of a person and in the processing of his personal data, including the protection of the rights to privacy, personal and family secrets.
  3. This Operator's policy regarding the processing of personal data (hereinafter referred to as the «Policy») applies to all information that the Operator can receive about visitors to the (hereinafter referred to as the «Website»), mobile applications or any other features,   technologies or products offered by the Operator (collectively the «Services»)
  4. It is understood and presumed that by the fact of the Services use or by providing the Operator the personal data, the User has fully read, understood and accepted this Policy. If any User does not agree with this Policy in general or any part of it, such User should withhold from using the Services. User’s continued use of the Services following the posting of changes to this Policy will be deemed as User’s acceptance of those changes.

II. Collection of Personal Data

The primary purpose of personal data collection, storage and processing shall only be the identification of the Users:

  1. The Operator may collect personal and non-personal data from Users in a variety of ways, including, but not limited to, when Users visit the Website, register on the Website or fill out different forms as may be required from time to time.
  2. The Operator may place small data files called cookies (Google Analytics, Twitter, Slack, Telegram and LinkedIn buttons, Track URL) on the User’s computer or other device to collect and store information about User visit to, or use of the Website. User may control the use of cookies within internet browsers’ settings. If you reject or delete certain cookies, be aware that the performance of the related features and functions of the Website and services may be impaired

III. Principles of personal data processing

  1. The processing of personal data is carried out on a legal and fair basis.
  2. The processing of personal data is limited to the achievement of specific, predetermined and legitimate purposes. It is not allowed to process personal data that is incompatible with the purposes of collecting personal data.
  3. It is not allowed to combine databases containing personal data, the processing of which is carried out for purposes that are incompatible with each other.
  4. Only personal data that meet the purposes of their processing are subject to processing.
  5. The content and scope of the processed personal data correspond to the stated purposes of processing. The redundancy of the processed personal data in relation to the stated purposes of their processing is not allowed.
  6. When processing personal data, the accuracy of personal data, their sufficiency, and, if necessary, relevance in relation to the purposes of processing personal data, is ensured. The operator takes the necessary measures and/ or ensures their adoption to remove or clarify incomplete or inaccurate data.
  7. The storage of personal data is carried out in a form that allows you to determine the subject of personal data, no longer than required by the purposes of processing personal data, if the period for storing personal data is not established by law, an agreement to which the subject of personal data is a party, beneficiary or guarantor. The processed personal data is destroyed or depersonalized upon reaching the goals of processing or in case of loss of the need to achieve these goals, unless otherwise provided by law.
  8. The purpose of processing the User's personal data is to provide the User with access to the services, information and / or materials contained on the Website.
  9. Impersonal data of Users collected using Internet statistics services are used to collect information about the actions of Users on the site, improve the quality of the site and its content.
  10. The Operator undertakes to provide any and all efforts and actions prescribed by applicable law to store any of User’s personal data in secrecy.
  11. The Operator shall use relevant electronic and procedural safeguards to protect the privacy of the personal data provided to the Operator from loss, misuse,   disclosure, alteration and destruction. As soon as the Operator receives User’s private information, the Operator shall implement reasonable security measures and procedures to avoid unauthorised access from any third party.
  12. Transmission of personal data over the Internet using personal computers or mobile devices is not completely safe and, therefore, the Operator shall not liable for the security of any personal data Users are transmitting over the Internet.

IV. Disclosing of Personal Data

  1. The Operator may share information about User as follows:

    with current and future (e.g. companies that the Operator plans tomerge with or be acquired by) Operator’s partners, affiliates,subsidiaries and other companies under common control and ownership;

    with affiliates, consultants, and other service providers, e.g. bankingand brokerage partners, identification service providers for fraudprevention purposes, lawyers;

    to comply with the law, enforce the Website policies, or protect theOperator’s rights, property or safety.
  2. User acknowledges and agrees that in the event of the Operator were acquired, or the Company goes out of business or enters bankruptcy, User information would be one of the assets that is transferred or acquired by a third party and transfer of User’s personal data to such third parties may occur.
  3. By submitting the personal data to the Operator, the Users confirm that such personal data may became subject of the transnational transfer to enable processing of personal data by our staff operating in other countries.

V. List of Actions performed by the Operator with the received Personal Data

  1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), extracts, uses, transfers (distributes, provides, accesses), depersonalizes, blocks, deletes and destroys personal data.

  2. The Operator carries out automated processing of personal data with the receipt and / or transmission of the received information via information and telecommunication networks or without it.

VI. Final Provisions

  1. The User can receive any clarifications on issues of interest regarding the processing of his personal data by contacting the Operator via e-mail
  2. This document will reflect any changes in the policy of processing personal data by the Operator. The policy is valid indefinitely until it is replaced by a new version.

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