1. General Terms

This personal data processing policy has been executed pursuant to the requirements of Federal law of July 27, 2006 №152-FL «Personal Data Act». The policy determines personal data processing order and security measures undertaken to protect personal data of the company Viqeo Inc., a Delaware corporation having principal place of business at 2602 Avenue U Suite 2F, Brooklyn, New York, NY 11229, Employer Identification Number 36-4942786, hereinafter referred to as Operator.

1. To ensure proper implementation of own activity, Operator should aim at respecting of civil rights and liberties as well as privacy rights and personal and family secrets when processing personal data of citizens.
2. This Operator's policy regarding personal data processing, hereinafter referred to as Policy, must apply to all the information the Operator can receive about visitors of the following website: https://viqeo.tv.

2. General Definitions Used in Policy

1. Automatic personal data processing refers to personal data processing executed by means of using computer technology;
2. Personal data blocking refers to temporary termination of personal data processing except as otherwise necessary to clarify personal data;
3. Website is a set of graphic and information materials as well as software used for ECM and databases providing an access to such the materials on the Internet at the following address: https://viqeo.tv;
4. Personal data system is a set of personal data contained in personal details database and ensuring their processing by means of the information technologies and technological tools;
5. Personal data depersonalization refers to actions taken to make personal data ownership identification impossible without use of additional information. Here, personal data identification may imply identification of ownership of personal data being owned by certain User or any other personal data subject;
6. Personal data processing implies any action (operation) or set of actions (operations) taken using automation means or using no means to manage personal data including collection, registration, systematization, accumulation, storage and clarification (updating and editing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, removal and complete elimination;
7. Operator is state authority, municipal authority, legal or physical party that coordinates and (or) executes personal data processing in an independent manner or along with other parties as well as sets goals for personal data processing, personal data content subjected to processing, and takes actions or conducts operations related to personal data;
8. Personal data refer to any information expressly or implicitly related to certain or predefined User of the following website: https://viqeo.tv;
9. Any visitor of the website https://viqeo.tv considered User;
10. Personal data submission refers to actions taken to disclose personal data to a certain party or community;
11. Personal data distribution implies any actions taken to disclose personal data to uncertain community (personal data transfer) or to familiarize itself with personal data related to unlimited amount of people including, inter alia, divulgation of personal data in mass media, data allocation in information and telecommunication networks, and provision of access to personal data otherwise;
12. Cross-border transmission of personal data to foreign jurisdiction, regulatory body of foreign state or foreign physical or legal party;
13. Personal data elimination refers to any actions taken to execute irreversible elimination of personal data, which makes further recovery of personal data content in personal data system impossible, and (or) destroy material media bearing personal data.

3. Operator is entitled to collect and process the following personal data of the User:

1. Email account;
2. Anonymized data of website visitors including cookie files from website collected and processed using Internet statistics services such as Yandex.Metrica, Google Analytics etc.
3. The abovementioned data hereinafter provided in this Policy and jointly referred to as Personal Data.

4. Reasons for Personal Data Processing

1. The main reason for processing of personal data of the User is sharing information with the User via emails and providing the User with access to website services, information and/or materials.
2. Operator is also entitled to send notification emails to the User to notify him of new products and services, special offers and different events. User can always opt-out of receipt of notification emails by sending email with the following subject «Waiver of Notice of New Products, Services and Special Offers» to the Operator to the following email address: ssoloviev@viqeo.tv.
3. Anonymized data of Users, which are collected by means of using Internet statistics services, are used to collect information on User Actions on website and improve the quality of the website and its content.

5. Legal Reasons for Personal Data Processing

1. Operator is entitled to process personal data of User only granted their independent provision and/or submission by the User via special forms available on the following website: https://viqeo.tv. Filling corresponding forms and/or submitting own personal data to Operator, User accepts terms of this Policy.
2. Operator processes anonymized User data if User enables such an action in browser settings by activating the option of saving «cookie» files and using JavaScript technology.

6. Personal Data Collection, Storage, Transfer and Other Data Processing Types

Safety of personal data being processed by the Operator is ensured by implementation of legal, organizational and technological measures, which are required to fully address requirements of current legislation related to personal data protection.

1. Operator should ensure safety of personal data and undertake possible measures to restrict unauthorized persons from accessing personal data.
2. User's personal data should under no conditions be transferred to third parties except as otherwise related to execution of current legislation.
3. Should discrepancies in personal data be discovered, User can amend them on his own by sending an email with the subject «Updating Personal Data» to Operator to the following email address: ssoloviev@viqeo.tv.
4. Personal data can be subjected to processing within unlimited period. User can withdraw consent to personal data processing at any given time by sending an email with the subject «Withdrawal of Consent to Personal Data Processing» to Operator to the following email address: ssoloviev@viqeo.tv.

7. Cross-border Transfer of Personal Data

1. Prior to initiation of cross-border transfer of personal data, Operator should make sure that foreign state subjected to personal data transfer can ensure proper protection of rights of the personal data subjects.
2. Cross-border transfer of personal data within jurisdiction of foreign states failing to meet the above indicated requirements can be executed only granted the existence of written consent of personal data subject to cross-border transfer of his personal data and/or execution of agreement involving personal data subject as a party to such an agreement.

8. Final Provisions

1. User can receive any clarifications regarding any issues of interest related to processing of his personal data by contacting the Operator via following e-mail: ssoloviev@viqeo.tv.
2. This document will reflect any changes in policy of personal data processing executed by the Operator. Policy is valid for unlimited period until replaced with new version.
3. Current version of Policy is freely available on the Internet at the following address: https://viqeo.tv/policy/en.