EnMoscúWe take your business to the markets of the CIS and Russia

PRIVACY POLICY

Moscow, November 11, 2015

This Personal Data Privacy Policy (hereinafter, the “Privacy Policy”) applies to all information that the “Intérpretes EnMoscú” website, hosted at the domain www.enmoscu.es, may obtain about the User while the User is using the site and its services.

1. DEFINITIONS 1.1. The following terms are used in this Privacy Policy: 1.1.1. “Site Administration” — the employees authorised to manage the site, acting on behalf of “Intérpretes EnMoscú” (sole proprietor Osipov K. A.), who organise and/or carry out the processing of personal data and determine the purposes of processing, the scope of personal data to be processed, and the actions (operations) performed with them. 1.1.2. “Personal data” — any information relating to a directly or indirectly identified or identifiable natural person (the data subject). 1.1.3. “Processing of personal data” — any action (operation) or set of actions (operations) performed on personal data, with or without automated means, including collection, recording, systematisation, accumulation, storage, updating (modification), retrieval, use, transfer (distribution, provision, access), anonymisation, blocking, deletion and destruction of personal data. 1.1.4. “Confidentiality of personal data” — the obligation of the Operator or any other person with access to personal data not to disseminate them without the consent of the data subject or another legal basis. 1.1.5. “Site User” (hereinafter, the “User”) — a person who accesses the Site via the Internet and uses the Site. 1.1.6. “Cookies” — a small piece of data sent by a web server and stored on the user’s computer, which the web client or web browser sends back to the web server in an HTTP request each time it attempts to open a page of the corresponding site. 1.1.7. “IP address” — a unique network address of a node in a computer network built on the IP protocol.

2. GENERAL PROVISIONS 2.1. The User’s use of the site constitutes acceptance of this Privacy Policy and of the terms of processing of the User’s personal data. 2.2. If the User disagrees with the terms of the Privacy Policy, the User must stop using the site. 2.3. This Privacy Policy applies only to the “Intérpretes EnMoscú” site. “Intérpretes EnMoscú” does not control and is not responsible for third-party sites that the User may visit via links available on the site. 2.4. The Site Administration does not verify the accuracy of the personal data provided by the User of the “Intérpretes EnMoscú” site.

3. SUBJECT OF THE PRIVACY POLICY 3.1. This Privacy Policy establishes the obligations of the Administration of the “Intérpretes EnMoscú” site not to disclose, and to protect the confidentiality of, the personal data that the User provides at the request of the Site Administration when arranging payment for the services provided. 3.2. The personal data authorised for processing under this Privacy Policy are provided by the User by filling in the registration form in the “Payment” section and include the following information: 3.2.1. the User’s surname and first name; 3.2.2. the User’s contact telephone number; 3.2.3. e-mail address. 3.3. “Intérpretes EnMoscú” protects the data that are automatically transmitted while viewing advertising blocks and visiting pages on which a statistical system script (“pixel”) is installed: IP address; cookie information; browser information (or of any other program accessing the advertising); access time; the address of the page hosting the advertising block; the referrer (address of the previous page). 3.3.1. Disabling cookies may make it impossible to access parts of the site that require authorisation. 3.3.2. “Intérpretes EnMoscú” collects statistics on the IP addresses of its visitors. This information is used to detect and solve technical problems and to monitor the lawfulness of financial payments. 3.4. Any other personal information not mentioned above (payment history, browsers and operating systems used, etc.) is stored securely and is not disseminated, except in the cases provided for in clauses 5.2 and 5.3 of this Privacy Policy.

4. PURPOSES OF COLLECTING THE USER’S PERSONAL INFORMATION 4.1. The Site Administration may use the User’s personal data for the following purposes: 4.1.1. Identifying the User registered on the site in order to arrange remote payment for services with “Intérpretes EnMoscú”. 4.1.2. Determining the User’s location to ensure security and prevent fraud. 4.1.3. Processing and receiving payments, confirming tax or tax benefits, disputing a payment, and determining the User’s eligibility for a credit line. 4.1.4. Providing the User with effective customer and technical support in case of problems related to the use of the Site.

5. METHODS AND TERMS OF PROCESSING PERSONAL INFORMATION 5.1. The processing of the User’s personal data is carried out without time limitation, by any lawful means, including in personal data information systems with or without automated means. 5.2. The User’s personal data may be transferred to the authorised state authorities of the Russian Federation only on the grounds and in the manner established by the legislation of the Russian Federation. 5.4. In the event of loss or disclosure of personal data, the Site Administration shall inform the User of the loss or disclosure. 5.5. The Site Administration takes the necessary organisational and technical measures to protect the User’s personal information from unlawful or accidental access, destruction, modification, blocking, copying and dissemination, as well as from other unlawful actions of third parties. 5.6. The Site Administration, together with the User, shall take all necessary measures to prevent losses or other negative consequences caused by the loss or disclosure of the User’s personal data.

6. OBLIGATIONS OF THE PARTIES 6.1. The User must: 6.1.1. Provide the personal data required for payment for services on the “Intérpretes EnMoscú” site. 6.1.2. Update and supplement the personal data provided if this information changes. 6.2. The Site Administration must: 6.2.1. Use the information received exclusively for the purposes specified in section 4 of this Privacy Policy. 6.2.2. Keep confidential information secret, not disclose it without the User’s prior written permission, and not sell, exchange, publish or disclose by any other possible means the personal data transferred by the User, except as provided in clauses 5.2 and 5.3 of this Privacy Policy. 6.2.3. Take precautions to protect the confidentiality of the User’s personal data in accordance with the practices normally used to protect this kind of information in existing business practice. 6.2.4. Block the personal data relating to the respective User from the moment of a request by the User, their legal representative, or the authorised body for the protection of the rights of personal data subjects, for the period of verification, if inaccurate personal data or unlawful actions are detected.

7. LIABILITY OF THE PARTIES 7.1. If the Site Administration fails to fulfil its obligations, it shall be liable for losses incurred by the User in connection with the unlawful use of personal data, in accordance with the legislation of the Russian Federation, except in the cases provided for in clauses 5.2, 5.3 and 7.2 of this Privacy Policy. 7.2. In the event of loss or disclosure of Confidential Information, the Site Administration shall not be liable if this confidential information: 7.2.1. Became public before its loss or disclosure. 7.2.2. Was received from a third party before it was received by the Site Administration. 7.2.3. Was disclosed with the User’s consent.

8. DISPUTE RESOLUTION 8.1. Before filing a lawsuit regarding disputes arising from the relationship between the Site User and the Site Administration, it is mandatory to submit a claim (a written proposal for voluntary settlement of the dispute). 8.2. The recipient of the claim shall notify the claimant in writing of the results of the examination of the claim within 30 calendar days of receiving it. 8.3. If no agreement is reached, the dispute shall be referred to a judicial authority in accordance with the current legislation of the Russian Federation. 8.4. This Privacy Policy and the relationship between the User and the Site Administration are governed by the current legislation of the Russian Federation.

9. ADDITIONAL TERMS 9.1. The Site Administration may amend this Privacy Policy without the User’s consent. 9.2. The new Privacy Policy takes effect from the moment it is posted on the Site, unless otherwise provided by the new version of the Privacy Policy. 9.3. Any suggestions or questions regarding this Privacy Policy should be submitted via the site’s contact section. 9.4. The current Privacy Policy is available at www.enmoscu.es/en/privacy\_policy/

Updated November 11, 2015.

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