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VipVip Confidentiality Policy

Standard Confidentiality Policy

1. Basic Terms

1.1. Aggregator shall be the Internet website at

1.2. Developer shall be an individual or legal entity placing its information in VipVip app and using it in accordance with the Terms of Application Placement and Rules for Application Placement in VipVip app.

1.3. Aggregator Administration shall be Business Process Technologies domiciled at Great Britain Suite 2 5 St Vincent Street Edinburgh, Scotland UK, EH3 6SW.

1.4. Application shall be a software unit containing developer's information created by the Developer in the Aggregator, moderated by the Site Administration and embedded in VipVip mobile app.

1.5. User shall be a duly registered VipVip app user.

1.6. Project shall be a system consisting of the Aggregator and VipVip mobile app.

1.7. Policy shall be this Standard Confidentiality Policy.

2. General Provisions

2.1. This Policy shall be an official standard document of the Developers regulating a procedure of processing and protection of information on individuals who use the Applications. This Policy shall not cover the Developers who have published and use their own instrument setting a policy of user personal data processing.

2.2. The purpose of this Policy shall be ensuring proper protection of information on users, including their personal data, against any unauthorized access or disclosure.

2.3. Activities related to collection, storage, distribution or protection of information on users shall be regulated by this Policy, other official documents of the Developers and applicable law.

2.4. The current version of the Policy which is a public document has been developed by the Site Administration and shall be available to any users on the Internet when following the "Confidentiality Policy" hyperlink.

The Site Administration can amend this Policy. When amending the Policy, the Site Administration shall notify users thereon by posting a revised version of the Policy on at the permanent link not later than 10 days prior to entry into effect of such amendments.

2.5. When using the Applications, the user shall agree with the terms of this Policy.

2.6. If the user does not agree with the terms of this Policy, he/she shall immediately cease to use the Applications.

3. Terms of the use of the Applications

3.1. By rendering services associated with the use of the Applications, the Developer, acting in a reasonable manner and in good faith, shall consider that the user:

- has all relevant authorizations to start and use the Applications. - specifies reliable personal information in the scope required for the use of the Applications; - understands that some types of data specified by him/her when registering shall become available to the Developer and Aggregator Administration and cannot be deleted by the user on his/her own; - has read this Policy, accepts it and assumes the rights and obligations as set forth herein.

3.2. The Developer and the Site Administration shall not verify reliability of any received (collected) information on users.

4. Purposes of the Information Processing

The Developer shall process information on users including their personal data in order to fulfill its obligations to users related to the use of the Application.

5. Contents of the Information on Users

The Developer shall process information on users including:

5.1. Users' personal data to be provided by the Site Administration with users' consent and required for the use of the Applications: a name, last name, date of birth, phone number, email and actual address (if specified);

5.2. Additional information on the number of user's purchases from the Developer, number of points, number of referred or new users, number of users in the referral structure, amount of user's purchases;

5.3. Other information associated with the loyalty rewards program in the app of this Developer.

5.4. Information obtained by the Developer as a result of users' actions when using the Applications.

6. Users' Personal Data Processing

6.1. Personal data is processed based on the following principles:

a) legality of purposes and means of personal data processing and due care; b) compliance of purposes of personal data processing with purposes previously defined and claimed during collection of personal data collection and with Developers' authority; c) compliance of the scope and nature of processable personal data and methods of personal data processing with purposes of personal data processing; d) no combination of personal data databases generated for incompatible purposes.

6.1.1. Terms and purposes of private information processing

The Developer shall processes user's personal data with his/her consent in order to provide the user with services for the use of the Applications.

6.1.2. Personal data collection

User's personal data provided for by paragraph 5.1 hereof shall be communicated to the Developer by the Site Administration with the user consent. The user consent to communicate his/her personal data to the Developer shall be given as implicative action during the first download and user registration in VipVip app for the first time.

In case of change and/or removal of information specified in paragraph 5.1 and 5.2 of this Policy, the Site Administration shall notify the Developer thereof by making a relevant note in the 'Client Database' table in the Aggregator.

6.1.3. Personal data storage and use

Users' personal data shall be stored solely on electronic media and processed using automated systems and by the Developer for actions associated with the proper performance of the rewards loyalty program and VipVip system in whole.

6.1.4. Private information transfer

Users' personal data shall not be transferred to any third party, except if directly stipulated hereby.

Users' personal data shall be provided upon request of governmental authorities (local authorities) in a manner required by law.

6.1.5. Personal data destruction

User's personal data shall be destructed: - if the Developer deletes the user from the Client Database; - upon user's written request to the Aggregator Administration; - when the Aggregator Administration deletes the user due to revelation of any of his/her actions causing physical/financial/image damage to VipVip project..

6.2. Since the Applications shall be one of the means of communication and liaison with the Developer and other users, the following information can be available to other users of this Application:

6.2.1. user name and last name,

6.2.2. user phone number,

6.2.3. information on how the user uses the Application and on user's actions when he/she uses the Application.

7. Users' Rights and Obligations

7.1. Users shall have the right to:

7.1.1. freely access the Application, free of charge;

7.1.2. amend or correct information about themselves using functionality of the Application on their own or with the help of the Developer or its responsible person, should such amendments or corrections contain up-to-date reliable information;

7.1.3. delete the Application;

7.1.4. obtain information on their personal data processing from the Developer upon request.

7.1.5. obtain information on their personal data processing from the Aggregator Administration upon request.

8. Means of User Information Security

The Developer shall take organizational and legal measures to secure user's personal data against unauthorized or accidental access thereto, as well as destruction, change, blocking, copying, distribution or other illegal actions.

9. Policy Constraints

This Policy shall not cover action and Internet resources of any third party.

The Aggregator Administration shall not be personally liable for actions of any third party that, due to the Developer's negligence of security, have gained access to information on the user available in the Aggregator once authorization is completed. The Aggregator Administration recommends the Developer to be scrupulous about the access to the Aggregator, not to disclose a password to any third party, not to use the option of password remembering in the browser or any other program, use the Sign out button once work in the Aggregator is finished etc.

10. Users' Requests

10.1. Users can request the Developer concerning use of their personal data according as provided for 7.1.4 hereof in written form through the contact form or to email address specified in the Application.

10.2. User's request shall contain the following information: - number of the primary ID document of the user or his/her representative; - date issued and issuing authority of such document; - information proving user's relations with the Developer (particularly, a phone number used for authorization and other details specified when registering in VipVip mobile app, as well as the app name for which the request was sent);

10.3. The Developer undertakes to consider and reply to user's request within 30 days from the date of the request.

10.4. All correspondence received by the Developer from users (written or electronic inquiries) shall be considered as limited access information and shall not be disclosed without written consent of the user. Personal data and other information on the user who sent a request shall not be used otherwise than for reply to the received request or in cases directly stipulated by the law.