Form for initiative submission

TERMS OF USE (USER AGREEMENT)

GENERAL PROVISIONS

1. 1. 1. This User Agreement (hereinafter referred to as the “Agreement” or the “Rules”) establishes the procedure and conditions for the use of all services and functions of the internet resource of the Platform for Core Competencies Co‑investment (hereinafter referred to as the “Platform” or “PC³”).
      2. This Agreement has been developed in accordance with the applicable laws of the Russian Federation. All relations arising in connection with the use of the Platform shall be governed by the applicable laws of the Russian Federation, as well as by the legislative and regulatory acts of foreign countries, to the extent they do not contradict the provisions of Russian law, unless expressly provided otherwise in this Agreement or its annexes.
      3. This Agreement, in accordance with Article 437 of the Civil Code of the Russian Federation, constitutes a written public offer. Acceptance of this Agreement by the User (acceptance of this offer by the User in accordance with Article 438 of the Civil Code of the Russian Federation) shall be deemed to occur upon the User performing any of the following actions:
         1. Сompleting the registration process;
         2. Using any service or function of the Platform, regardless of whether registration has been completed.
      4. The terms of this Agreement may be accepted by the User only in their entirety. Partial refusal to comply with the terms of this Agreement shall not be permitted. The use of individual services may be governed by additional agreements and rules posted on the relevant pages. Such documents shall form an integral part of this Agreement and shall be binding on all Users when using the relevant services and functions.
      5. A User’s reference to lack of knowledge of the terms of this Agreement and any amendments thereto shall not constitute grounds for non‑compliance with this Agreement. All actions performed by a User on the Platform shall be deemed to be actions of a person who has reviewed and accepted the terms of these rules and any amendments thereto.
      6. This Agreement is addressed to persons who have full legal capacity under applicable civil law.
      7. The services and functions presented on the pages may not be altered in accordance with the wishes of any individual or group of individuals, unless otherwise provided by this Agreement or its amendments.
      8. This Agreement and any amendments thereto may be amended by the Administration without specific individual notice to each User. The procedure for amending and supplementing this Agreement is set forth in Section 9 of this Agreement.

BASIC TERMS AND DEFINITIONS

In this Agreement, the following terms shall have the meanings set forth below:

1. Internet Resource of the Platform for Core Competencies Co‑investment (PC³, Platform) – a set of data (web pages) published on the Internet, united by a common theme, design and a single domain name and its subdomains. The Site’s home page is located at: https://irptec.ru/en/core-competencies-co-investment-platform/. 
2. Administration of the Platform for Core Competencies Co‑investment (Administration) – authorised employees of the Platform Owner who, in accordance with their delegated authority, carry out the administration and technical support of the Platform.
3. Owner of the Platform for Core Competencies Co‑investment (Owner) – IRP Technology LLC (ООО “Ай Эр Пи Текнолоджи”).
4. Identification Number (ID) – a unique number (a sequence of Arabic numerals and/or letters and other characters) assigned to legally significant objects and subjects of the Platform, serving as the basis for the following actions by the Platform (including, but not limited to): identification of Users, tracking of Users’ actions, recognition of actions performed by a User on their own behalf, use in settlement documents for proper accounting of funds in the Nominee Account, use in electronic documents generated by the Platform (agreements, notices, letters and other documents).
5. Qualified Electronic Signature – an enhanced qualified electronic signature, the ownership of which is confirmed by a qualified electronic signature key verification certificate issued by an accredited certification authority. Electronic documents signed on the Platform using a qualified electronic signature shall be deemed equivalent to documents signed by handwritten signature under the laws of the Russian Federation and foreign states, and shall not require additional confirmation or identification of the signatory.
6. Content – any informational and software content. 
7. User’s Personal Page (also Profile, Personal Account) – a part of the Platform in the form of a web page (web pages) automatically created for the User after registration. 
8. Platform for Core Competencies Co‑investment (also PC³, Platform) – an open infrastructure solution for organising and implementing projects through non‑financial co‑investment of core competencies.
9. Platform Users – all individuals and legal entities who in any way use the services and functions of the Platform, regardless of whether they have registered on the Platform.
10. Simple Electronic Signature – an electronic signature used by Users on the Platform. A Simple Electronic Signature may be generated in the following forms: (a) by entering a unique SMS key (a unique sequence of digits and letters) sent to the User’s phone number and known only to the User, into a special field on the Platform page; (b) by entering the User’s registration data when authenticating in the Personal Account; (c) by the User following a unique link sent to the User’s email address.
11. User Registration – the established procedure of actions, upon completion of which the User is assigned an individual login and password. User Registration enables the identification of a specific person.
12. Register of Agreements – an interconnected set of electronic records on the Operator’s server, recording information and events enabling the identification of the parties to agreements concluded through the Platform, their essential terms and dates of conclusion. The Platform ensures the integrity and reliability of the records in the Register of Agreements, as well as the impossibility of modifying such records except when the terms of the agreements are amended by the parties thereto.
13. User Account – a set of data stored on the Platform, containing the information necessary to identify the User when granting access to the Platform, information for authentication and recording of the User’s actions on the Platform. Such account includes, but is not limited to, the email address and password, phone number, identification number (ID), or other similar means of identification.
14. Electronic Signature – information in electronic form attached to or otherwise associated with other information in electronic form (the information being signed), enabling the identification of the person signing the information, as well as verification of the absence of falsification of the information.
15. Platform Electronic Document – an interconnected set of electronic records generated and stored by the Platform, including: applications, agreements, contracts, notices, letters, alerts and other documents/on‑screen forms expressing the User’s intention to perform legally significant actions through the Platform or to obtain its functionality.
16. Electronic Journal – an interconnected set of electronic records recording Users’ actions on the Platform. The Electronic Journal is stored on the Operator’s servers. The data in the Electronic Journal shall not be subject to any modification by the Parties to this Agreement, including by technical means.
17. Terms not defined in this Section may be interpreted in other sections and articles of this Agreement.

REGISTRATION ON THE PLATFORM

1. 1. 1. User registration on the Platform is free of charge and voluntary. The Platform Owner does not charge Users any fees for using the Platform’s services and tools.
      2. When registering on the Platform, the User shall provide accurate and up‑to‑date information required to create the User’s Personal Page, including a unique login and password for access to the Platform, as well as the User’s surname, first name and patronymic (if applicable).
      3. The User shall be responsible for the accuracy, currency and completeness of the information provided during registration and for ensuring that such information is free from claims by third parties.
      4. By accepting the terms of this Agreement through registration on the Platform, the User, in the event of posting information that constitutes personal data under the laws of the Russian Federation, consents to the processing thereof, both with and without the use of automation means, including but not limited to: collection, storage, transfer to third parties and use of information by the Platform Owner for the purposes of fulfilling its obligations to the User under this Agreement.
      5. The login and password chosen by the User shall be the necessary and sufficient information for the User to access the User’s Personal Page. The User shall not have the right to transfer their login and password to third parties and shall bear full responsibility for their security, choosing the method of storage at their own discretion.
      6. Unless proven otherwise by the User, any actions performed using their login and password shall be deemed to have been performed by the respective User. In the event of unauthorised access to the login and password and/or the User’s Personal Page, or disclosure of the login and password, the User shall immediately notify the Administration thereof.
      7. If the User provides incorrect and/or inaccurate information during registration or subsequent use of the Platform’s functions and services, or if the Platform Administration has grounds to believe that the information provided by the User is incomplete and/or inaccurate, the Platform Administration shall have the right, at its sole discretion, to block access to the User’s Personal Page or to the Platform as a whole for the User, with or without prior notice.
      8. Deletion of information about the User at the User’s initiative shall be permitted only with the consent of the Platform Administration. The Platform Administration shall not be bound by any time limits for granting or refusing such consent.

RIGHTS AND OBLIGATIONS OF PLATFORM USERS

1. 1. 1. Any User, regardless of whether they are registered (authorised) on the Platform, shall be obliged to:
         1. comply with this Agreement and other rules posted on the Platform;
         2. refrain from posting on the Platform pages any information or objects (including links and images) that may violate the laws of the Russian Federation or the rights and interests of other persons;
      2. Any person using the Platform’s resources, including any registered and unregistered User, is prohibited from:
         1. using the Platform in any way that violates the terms of this Agreement and/or the provisions of applicable Russian law;
         2. misleading, defaming, insulting, threatening or otherwise infringing the rights and freedoms of other Platform Users or any other persons;
         3. copying, modifying, altering, deleting, supplementing, publishing, transferring intellectual property of the Platform Owner, other Users and/or any third parties, creating derivative works, manufacturing or selling products based thereon, reproducing, displaying or otherwise exploiting or using such rights of third parties without the express permission of their owners;
         4. using the Platform in any harmful manner or in any way that may disrupt the normal and uninterrupted functioning of the Platform;
         5. gaining or attempting to gain unauthorised access to the Platform or any part/function thereof, or to any network connected to the Platform;
         6. without the consent of other Users or third parties, posting any personal information relating to such persons, or unlawfully collecting and/or processing personal data of other Users and/or third parties;
         7. misleading Users and/or third parties as to their identity;
         8. using any devices, software or processes, algorithms or any other automated means to gain access to the Platform, acquire, copy or track any part thereof in a manner that circumvents the Site’s navigation system, or to obtain or attempt to obtain any materials, documents or information by any means not specifically made available through the Site.

RIGHTS AND OBLIGATIONS OF THE PLATFORM ADMINISTRATION AND THE PLATFORM OWNER

1. 1. 1. The Platform Administration shall have the right to delete or restrict (block) access to any information posted on the Platform, as well as to block any User’s access to the Platform, without prior notice to such User and without providing any explanation for such actions.
      2. The Platform Administration shall not be obliged to carry out prior review, moderation or censorship of information provided or published by a User. As a general rule, the Platform Administration shall take action to protect the rights and interests of persons and ensure compliance with the requirements of the legislation of the Russian Federation only upon a request from an interested person submitted to the Platform Administration in accordance with the established procedure.
      3. The Platform Administration reserves the right to change the design of any pages of the Platform, their content, the list of services and functions, as well as to modify or supplement the scripts, software and other objects used, without prior notice to Users.
      4. The Platform Administration shall ensure the operation and availability of the Platform and undertakes to promptly restore its operation in the event of technical failures and interruptions. The Platform Administration shall not be liable for temporary failures and interruptions in the operation of the Platform and for any loss of information caused thereby. The Administration shall not be liable for any damage to the computer or other device of a User or any other person, or to any other equipment or software, caused by or related to the downloading of materials or following links posted on the Platform.
      5. The Platform Administration shall have the right to use statistical information related to the operation of the Platform, information provided by Users, as well as information of other Users, for the purpose of targeted advertising to various audiences of the Platform. For the purposes of organising the operation and technical support of the Platform, and fulfilling this Agreement and other rules posted on the Platform, as well as applicable law, the Platform Administration shall have the technical capability to access Users’ Personal Pages, which it shall exercise in the cases provided for in this Agreement.

INTELLECTUAL PROPERTY RIGHTS

1. 1. 1. All exclusive rights to all software components underlying the Platform’s services and functions, to the page design, as well as to subdomains and corresponding logos derived therefrom, shall belong to the Platform Owner and may not be used without the written consent of the rights holder.
      2. Any Platform User shall be entitled to use the functions and services solely for the purposes for which such services and functions are intended. The User shall not be entitled to copy or modify the software provided by the Platform; create derivative works based on the Platform’s software; reverse engineer the Platform’s software to obtain source code; or alienate or otherwise transfer to third parties in any form any rights granted in respect of the Platform’s software.
      3. All exclusive rights to the Content posted on the Platform shall belong to their respective rights holders. The User shall not be entitled to infringe the intellectual property rights of third parties.
      4. In the event of a User’s infringement of the intellectual property rights of third parties or of the Platform Owner, the Platform Administration shall have the right to delete the User’s Personal Page from the Platform, including all data, including Content provided by the User.
      5. The Platform may contain links to other Internet resources owned by third parties. The Platform Owner and the Platform Administration shall not be liable for any information posted on the websites of third parties to which the User gains access through the Platform or through third‑party content. When navigating from the Platform pages to third‑party Internet resources, the Platform shall not be obliged to warn the User about such navigation or its consequences.

FINANCE AND PAYMENT

1. 1. 1. Most of the Platform’s services and functions are provided to Users free of charge, which does not preclude the introduction of separate paid services or features.

WARRANTIES AND LIABILITY OF THE PARTIES

1. 1. 1. The Platform assumes no responsibility for the suitability of any service or function for the purposes of any specific User and, consequently, does not guarantee that the services and functions will meet the User’s personal requirements, including with respect to continuity, speed, reliability or accuracy.
      2. The User shall be liable for any damage that may be caused to their computer or data as a result of downloading information from the Platform.
      3. The Parties shall not be liable for partial or total failure to perform their obligations under this Agreement if such failure is due to force majeure circumstances arising after the conclusion of this Agreement, which the Parties could not have foreseen or prevented, and as a result of which either Party is unable to perform its obligations.
         1. The Party affected by force majeure circumstances shall, within 2 (two) calendar days, notify the other Party of the occurrence of such circumstances, attaching supporting documents issued by the relevant authority.
         2. During the period of force majeure circumstances, performance of obligations under this Agreement shall be suspended, and no penalties for non‑performance of contractual obligations shall apply. The occurrence of force majeure circumstances, provided that notice thereof has been given, shall extend the term for performance of contractual obligations by a period equal to the duration of such circumstances.
         3. If force majeure circumstances continue for more than 2 (two) consecutive months, either Party shall have the right to unilaterally terminate this Agreement by sending a corresponding notice to the other Party.

AMENDMENT OF THE USER AGREEMENT TERMS

1. 1. 1. This Agreement may be amended by the Platform Administration unilaterally without special notice to Users.
      2. Notice of any amendment or supplement to this Agreement shall be posted on the Platform’s home page.

TERMINATION OF PARTICIPATION ON THE PLATFORM AND AMENDMENT OF REGISTRATION DATA

1. 1. Termination of Participation on the Platform
      1. The Platform shall have the right to block the User’s Account or terminate its operation with respect to any Platform services unilaterally in the following cases:

• the User violates any provision of this Agreement or other terms set out on the Site pages, without explanation of reasons;
• the User discloses (transfers) their contact information to other Site Users prior to the conclusion of an agreement;
• the User reports unauthorised access to their Account.

1. In the absence of any outstanding obligations, the User shall have the right to request the Operator to block their Account on the Platform by sending a corresponding request to the Operator’s email address: pskk@irptec.ru. 
2. The User shall have the right to terminate this Agreement by sending the Operator a notice of termination to the email address: pskk@irptec.ru.  In such case, the Agreement shall be deemed terminated on the 1st (first) business day following the date the User submits the notice of termination. Upon sending such notice to the Operator, the Personal Account functions shall be disabled, except for the function of viewing the Virtual Account balance and the function of submitting payment orders. All obligations of the Parties arising under this Agreement prior to its termination and remaining unfulfilled as of the date of termination shall remain in full force and effect until their full performance by the Parties.
3. Upon termination of this Agreement, all obligations of the Parties arising prior to termination shall be performed in full, regardless of the fact of termination.

1. Amendment of the User’s Registration Data
   1. Amendment of the User’s Account data shall be permitted only on the basis of scanned copies of supporting documents, after they have been verified by the Platform.
   2. The User shall contact the Operator by email to clarify and amend registration data and to receive further instructions.
   3. In the event of a change in the User’s legal address, upon notification of such change (or upon the Operator’s discovery thereof through open data sources), the User shall provide scanned copies of documents confirming the change of the sole executive body.

FINAL PROVISIONS

1. 1. 1. This Agreement shall be governed by and construed in accordance with the laws of the Russian Federation. Any matters not regulated by this Agreement shall be resolved in accordance with the laws of the Russian Federation.
      2. This Agreement is executed in the Russian language. Any version of this Agreement in any other language shall be deemed a supplementary version. In the event of any discrepancy between the Russian-language version of this Agreement and any version in another language, the provisions of the Russian-language version shall prevail.
      3. The invalidity of any individual provision of this Agreement shall not affect the validity of the remaining provisions.
      4. Any disputes or disagreements arising out of or in connection with the performance of this Agreement shall be resolved through negotiations. If the disputes cannot be resolved through negotiations, they shall be settled in accordance with the procedure established by the applicable laws of the Russian Federation..

CONTACT DETAILS OF THE PLATFORM OWNER

IRP Technology LLC (ООО “Ай Эр Пи Текнолоджи”)
Address: 121471, Moscow, Ryabinovaya str., 26, bldg. 1
Taxpayer Identification Number (INN): 7705614186
Tax Registration Reason Code (KPP): 772901001
E-mail: pskk@irptec.ru

PRIVACY AND PERSONAL DATA PROTECTION POLICY 

The purpose of this Privacy and Personal Data Protection Policy (hereinafter referred to as the “Policy”) is to ensure the protection of the rights and legitimate interests of rights holders, data subjects, operators and users of confidential information, including personal data, who have accepted the terms of this Policy (hereinafter referred to as the “Parties to the Policy” or the “Parties”) when interacting on the Platform for Core Competencies Co‑investment.

BASIC TERMS AND DEFINITIONS

In this Policy, the following terms shall have the meanings set forth below:

1. Platform for Core Competencies Co‑investment (hereinafter referred to as the “Platform” or “PC³”) – an open infrastructure solution for organising and implementing projects through non‑financial co‑investment of core competencies.
2. Website of the Platform for Core Competencies Co‑investment (hereinafter referred to as the “PC³ Website”) – a set of data (web pages) published on the Internet, united by a common theme, design and a single domain name and its subdomains. The Site’s home page is located at: https://irptec.ru/en/core-competencies-co-investment-platform/. 
3. Confidential Information – technological, production, financial, economic, organisational, scientific, technical or other information (including information on intellectual property, trade secrets (know‑how), as well as information on methods of carrying out professional activities) which has actual or potential commercial value to the Disclosing Party due to its unknown nature to third parties and to which there is no lawful free access. Confidential Information must be marked as such in accordance with the procedure set forth in Section 4.1 of this Policy.
   1.  The following information shall not be considered Confidential Information:

• information, data or materials that are publicly known and publicly available;
• information that, as of the date of this Policy, was lawfully in the possession of the Receiving Party or was received by the Receiving Party from third parties who, to the Receiving Party’s knowledge, are not bound by any non‑disclosure obligations to the Disclosing Party with respect to such information;
• information which, under applicable Russian law, cannot constitute a trade secret;
• information that is disclosed by the Disclosing Party to third parties without imposing non‑disclosure obligations on such third parties;
• information that, at the time of its transfer to the Receiving Party, was not designated by the Disclosing Party as confidential in accordance with Section 4.1 of this Policy.

1. Owner of the Platform for Core Competencies Co‑investment (hereinafter referred to as the “Owner”) – IRP Technology LLC (ООО “Ай Эр Пи Текнолоджи”).
2. Access to Information – the ability to obtain and use information.
3. Personal Data Controller – a legal entity that, independently or jointly with other persons, organises and/or carries out the processing of personal data, and also determines the purposes of personal data processing, the composition of personal data to be processed, and the actions performed with them.
4. Personal Data – any information relating directly or indirectly to a specific or identifiable individual.
5. Users of the PC³ Website – all individuals and legal entities who in any way use the services and functions of the Platform, regardless of whether they have registered on the Platform.
6. Provision of Information – actions aimed at making information available to a specific group of persons or transferring information to a specific group of persons.
7. Representative – any officer or employee of the Receiving Party authorised by the Receiving Party to access Confidential Information of the Disclosing Party.
8. Receiving Party – the Party that receives information from the other Party.
9. Disclosing Party – the Party that discloses information to the other Party.
10. Dissemination of Information – actions aimed at making information available to an indefinite circle of persons or transferring information to an indefinite circle of persons.
11. Data Subject – an individual to whom the information processed by the Controller directly or indirectly relates.
12. Third Parties – any individual or legal entity, or a foreign organisation that is not a legal entity under applicable law, other than the Disclosing Party, the Receiving Party and the Representatives.
13. Terms not defined in this Section may be interpreted in other sections and articles of this Policy.

GENERAL PROVISIONS

1. 1. 1. This Policy establishes the procedure and conditions for the use of Confidential Information and personal data when interacting on the Platform for Core Competencies Co‑investment.
      2. This Policy has been developed in accordance with the applicable laws of the Russian Federation. All relations arising in connection with the use of the Platform shall be governed by the applicable laws of the Russian Federation, as well as by the legislative and regulatory acts of foreign countries, to the extent they do not contradict the provisions of Russian law.
      3. This Policy, in accordance with Article 437 of the Civil Code of the Russian Federation, constitutes a written public offer. Acceptance of this Policy (acceptance of this offer in accordance with Article 438 of the Civil Code of the Russian Federation) shall be deemed to occur upon the User of the PC³ Website performing any of the following actions:
         1. Сompleting the registration process;
         2. Using any service, function or feature of the Platform, regardless of whether registration has been completed.
      4. The terms of this Policy may be accepted by the Parties only in their entirety. Partial refusal to comply with the terms of this Policy shall not be permitted. The use of individual services may be governed by additional agreements and rules posted on the relevant pages. Such documents shall form an integral part of this Policy and shall be binding on all Parties when interacting on PC³.
      5. A Party’s reference to lack of knowledge of the terms of this Policy and any amendments thereto shall not constitute grounds for non‑compliance with this Policy. All actions performed by a Party when interacting on the Platform shall be deemed to be actions of a person who has reviewed and accepted the terms of these rules and any amendments thereto.
      6. This Policy is addressed to persons who have full legal capacity under applicable civil law.
      7. The Disclosing Party undertakes to transfer, upon the request of the Receiving Party, Confidential Information to the Receiving Party for its use, and the Receiving Party undertakes to accept such information, ensure its security and maintain its confidentiality. 
      8. In order to prevent disclosure or unauthorised use of Confidential Information, the Receiving Party undertakes to take such measures as it takes with respect to its own information of a similar nature. 
      9. All persons having access to Confidential Information and personal data shall comply with this Policy, including taking the necessary legal, organisational and technical measures to prevent unauthorised access, dissemination, distortion or destruction of the relevant information.

DISCLOSURE OF CONFIDENTIAL AND OTHER INFORMATION

1. 1. 1. Confidential Information may be disclosed by the Receiving Party without the consent of the Disclosing Party in the following cases:
         1.  upon a request from state authorities authorised to request such information under applicable law, based on a duly executed request for the provision of such information;
         2.  upon a request from judicial authorities for the purposes of protecting and enforcing rights in accordance with the terms of this Policy and/or other agreements concluded between the Parties.
      2. If the Receiving Party receives a duly executed and substantiated request from an authorised state authority pursuant to which the Receiving Party becomes obliged to disclose Confidential Information without the express written consent of the Disclosing Party, the Receiving Party shall disclose only such part of the Confidential Information as is necessary to comply with the lawful request of the state authority, to the extent permitted under applicable Russian law.
      3. In all other cases, except as provided for in Clause 3.1 of this Policy, the Receiving Party undertakes, for the entire duration of this Policy, not to disclose to any Third Parties any information constituting Confidential Information of the Disclosing Party without the prior written consent of the Disclosing Party, whether in writing, by means of demonstration, or by transferring any relevant documents, drawings, sketches, models or other materials, or in any other manner, unless expressly provided otherwise by this Policy.
      4. The transfer of information shall not constitute or imply the grant of any licences or rights to intellectual property, including copyrights, trademark rights and the like. Such rights may only be transferred under a separate licence agreement, which shall be subject to separate discussion and execution outside the scope of this Policy.

TRANSFER (PROVISION) OF CONFIDENTIAL INFORMATION

1. 1. 1. Any documents and/or other physical media containing Confidential Information transferred by the Disclosing Party to the Receiving Party, as well as their packaging, shall be marked with the words “Confidential Information” or “Confidential”.
      2. Any electronic document shall contain a disclaimer with the following text: “The information contained in this message is intended solely for the specific individuals to whom it is addressed. This message may contain confidential information that may not be disclosed or used by anyone other than the addressees expressly indicated in the message or directly following from the context of the message. If you are not the intended recipient of this message, any use, forwarding, copying or dissemination of the contents of this message or any part thereof is unlawful and prohibited. If you have received this message in error, please immediately notify the sender and delete the message and all its contents, as well as any copies and attachments thereof.”
      3. The Disclosing Party may transfer Confidential Information to the Receiving Party in writing, in electronic form, or by way of transferring (providing) documents, samples, equipment, models, visually, or by other means, including on magnetic media, multimedia means, or in the form of photographs.
      4. Upon the transfer of Confidential Information, the Parties may draw up an Acceptance and Transfer Certificate for Confidential Information.
      5. The risks of improper documentation of information in accordance with the requirements of this Section of the Policy shall be borne by the Disclosing Party. If the Disclosing Party fails to comply with the requirements of this Section of the Policy with respect to the information being transferred, such information shall be deemed publicly available.

MANDATORY DISCLOSURE

1. 1. 1. If either Party receives a duly issued administrative or judicial request to disclose information of the other Party, the recipient of such request shall immediately notify the other Party thereof and offer such other Party the opportunity to protect its interests against such request.
      2. If such request is not cancelled or postponed, the recipient of the request shall have the right to comply with it, limiting such disclosure to the minimum extent required under the circumstances.

USE, RETURN AND DESTRUCTION OF CONFIDENTIAL INFORMATION

1. 1. 1. Upon a written request from the Disclosing Party (which may be made at any time) and without prejudice to any other rights of the Disclosing Party, the Receiving Party shall (unless otherwise provided for in this Policy or any other agreement):
         1. destroy the media containing Confidential Information to the extent that the Confidential Information cannot be restored, or delete such information from such media to the extent that it cannot be restored, if such media is the property of the Receiving Party;
         2. ensure the return to the Disclosing Party of all such media, if such media is the property of the Disclosing Party.
      2. The Receiving Party undertakes to take all necessary measures to prevent leakage, theft, loss, distortion or forgery of Confidential Information, as well as to protect Confidential Information against unauthorised access, destruction, modification, copying, blocking, provision, dissemination, and other unlawful acts with respect to Confidential Information.
      3. At the same time, the Disclosing Party agrees that analytical and other documents prepared by the Receiving Party on the basis of Confidential Information, the creation of which is required by applicable Russian law, shall not be subject to destruction or return.
      4. The Receiving Party shall have the right to retain Confidential Information that is necessary for the purposes of dispute resolution or whose retention is required by applicable Russian law, as well as Confidential Information to which the Receiving Party has lawfully acquired rights from the Disclosing Party.

PRINCIPLES OF PERSONAL DATA PROCESSING

1. 1. All procedures related to the processing of personal data shall be carried out on a lawful and fair basis, and the purposes of processing shall be predetermined, clearly formulated, correspond to the stated purposes of processing and comply with the requirements of applicable law.
   2. Personal data processing by the Controller shall be carried out:

• with the consent of the Data Subject to the processing of their personal data;
• where processing is necessary for the performance of a contract to which the Data Subject is a party;
• where processing is necessary for the performance of obligations imposed on the Controller by federal law or other regulatory legal acts;
• in other cases expressly provided for by law.

1. Personal data shall be stored for no longer than is necessary to achieve the purposes of their processing, unless otherwise provided by law or contract, after which such data shall be destroyed or anonymised in a manner that precludes their recovery.

RIGHTS OF DATA SUBJECTS

1. 1. Data Subjects have all rights granted to them under the legislation of the Russian Federation, in particular Federal Law No. 152-FZ “On Personal Data”, including, but not limited to, the following rights:

• the right to receive information concerning the processing of their personal data, including information on whether the Controller holds their personal data, the source of their acquisition, the purposes and legal grounds for processing, the retention periods, the methods of processing, as well as information on the persons to whom the personal data are transferred;
• the right to access their personal data and to obtain a copy of any records containing such data;
• the right to request the rectification, updating, blocking or destruction of personal data if such data are incomplete, inaccurate, outdated, unlawfully obtained, or are no longer necessary for the stated purposes of processing;
• the right to withdraw previously given consent to the processing of personal data at any time, subject to the restrictions established by law;
• the right to appeal against actions or omissions of the Controller that violate their rights, to the competent authority for the protection of Data Subjects’ rights (Roskomnadzor), as well as in court;
• the right to restrict the processing of personal data and to transfer them to another controller (data portability), to the extent provided for by law.

1. The Controller shall ensure that the rights of Data Subjects are implemented within the timeframes and in accordance with the procedure established by applicable law, including providing the Data Subject with a response to their request within 30 (thirty) calendar days from the date of receipt of the request, unless otherwise provided by law. If a preliminary response is required, such period may be 10 (ten) calendar days, indicating the reasons for extending the overall period and the date of the final response..
2. The Controller’s response to the Data Subject shall be sent in a form corresponding to the form of the request (on paper or in electronic form), using means that ensure confirmation of sending and receipt of the response (including, but not limited to, registered mail with acknowledgement of receipt, electronic mail with delivery confirmation, etc.).

LIABILITY

1. 1. 1. The Receiving Party shall be liable in accordance with applicable Russian law for disclosure of Confidential Information, i.e. for any action or omission as a result of which Confidential Information becomes known to Third Parties in violation of the terms of this Policy. The liability of the Receiving Party shall be limited to the amount of actual, documented damage incurred by the Disclosing Party as a result of the Receiving Party’s culpable actions..
      2. The burden of proving the fact of disclosure and determining the amount of damages shall be on the Disclosing Party.

TERM OF THE OBLIGATIONS UNDER THIS POLICY

1. 1. 1. The obligations under this Policy shall arise from the moment of its acceptance and shall terminate 3 (three) years after the termination of the Parties’ obligations under the concluded agreements, including the User Agreement.
      2. The obligations under this Policy may be terminated early by mutual agreement of the Parties.

FINAL PROVISIONS

1. 1. The Disclosing Party hereby represents and warrants that it has the legal right and authority to transfer (provide) Confidential Information to the Receiving Party.
   2. Neither Party shall use the corporate name, trademarks (service marks), trade names and/or logos of the other Party without the prior written or electronic consent of such Party, executed in accordance with applicable Russian law and sent by courier, postal service or electronic mail.
   3. The rights and obligations of the Parties under this Policy shall, in the event of reorganization of either Party, transfer to the relevant successor(s) of the reorganized Party, and such successor(s) shall assume all rights and obligations under this Policy with respect to the other Party.
   4. In the event of liquidation of the Receiving Party, it shall, prior to the completion of liquidation, return to the Disclosing Party all originals and copies (or ensure the destruction of copies) of all physical media containing Confidential Information transferred under this Policy.
   5. The Parties shall take all necessary measures to resolve disputes through negotiations. If disputes cannot be resolved through negotiations, all disputes, disagreements or claims arising out of or in connection with this Policy shall be settled by the Arbitration Court of Moscow.
   6. Neither Party may assign or otherwise transfer, in whole or in part, its rights and/or obligations under this Policy without the prior written consent of the other Party.
   7. Any amendments, changes or additions to this Policy shall be valid only if made in writing by way of concluding additional agreements signed by an authorised representative of each Party.
   8. Any notices, documentation or other communications (hereinafter “notices”), unless otherwise specified in this Policy, shall be sent by the Parties to each other by registered mail with acknowledgement of receipt or by postal mail with declared value and acknowledgement of receipt to the postal address of the relevant Party specified in Section 10 of this Policy, and shall be made in simple written form on paper and signed by an authorised representative of the relevant Party. If the above conditions are not met, the notices shall not be deemed received by the receiving Party. Notices shall be deemed received by the Party on whichever of the following dates occurs earlier:

• upon delivery to the receiving Party against signature;
• upon expiry of 1 (one) week from the date of sending the notice to the postal address of the Party accepting this Policy.

1. All negotiations and correspondence relating to the subject matter and terms of this Policy that took place prior to its acceptance by the Parties shall become null and void upon acceptance of this Policy..
2. The Disclosing Party hereby warrants and confirms that there are no restrictions on the authority of the person accepting this Policy, as established in accordance with Article 174 of the Civil Code of the Russian Federation, contained in the provisions and/or other internal documents on the governing bodies/branch of the legal entity, and/or that there are no provisions and/or other internal documents on the governing bodies/branch/representative office.

CONTACT DETAILS OF THE PLATFORM OWNER

IRP Technology LLC
Address: 121471, Moscow, Ryabinovaya str., 26, bldg. 1
Taxpayer Identification Number (INN): 7705614186
Tax Registration Reason Code (KPP): 772901001
E-mail: pskk@irptec.ru