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Confidentiality policy

October 19, 2018

1. What does this confidentiality policy govern?

This confidentiality policy (hereinafter - the Policy) applies to all information, including personal data in the meaning of applicable law (hereinafter - “Personal Information”), which Trood LLC and/or its affiliates, including those in the same group as Trood LLC (hereinafter referred to as Trood) may receive about you in the course of using any Trood websites, programs, products and/or services (hereinafter referred to as “Services”), information about which you can find at trod.ru and other sites belonging to Trood (hereinafter referred to as "Sites"), and in the course of execution by Trood/its affiliates of any agreements and contracts signed with you in connection with your use of the Services. Trood may also receive Personal Information from its partners (hereinafter referred to as “Partners”), websites, programs, products or services of which you use (for example, from Trood advertisers). In such cases, transfer of Personal Information is possible only in cases established by applicable law, and is carried out on the basis of special agreements between Trood and each of the Partners. Please note that the use of any of the Sites and/or Services may be governed by supplementary conditions that may make changes and/or additions to this Policy.

2. Who processes information?

To ensure your use of the Sites and Services, your Personal Information is collected and used by Trood Limited Liability Company, a legal entity established under the laws of the Russian Federation and registered at 119021, Russia, Moscow, Lva Tolstogo str., h. 16 (Trood LLC), or its affiliate, providing the corresponding Service. You can acquaint yourself with the information about the person that provides this or that Service in the Terms of Use of the relevant Service.

For users located in the European Economic Area (EEA) or Switzerland, Trood is represented on the territory of the EEA and Switzerland by Trood Oy, a legal entity established under the laws of Finland, registered at: Moreenikatu 6, 04600 Mäntsälä, Suomi, Finland).

3. What is the purpose of this policy?

Protecting your Personal Information and your privacy is extremely important to Trood. Therefore, when you use the Sites and Services, Trood protects and processes your Personal Information in strict accordance with applicable law.

Following our responsibility to protect your Personal Information, in this Policy we would like to most transparently inform you of the following points:

(a) why and how Trood uses ("processes") your Personal Information when you use the Sites and/or Services;

(b) what is the role and responsibilities of Trood as a legal entity deciding why and how to process your Personal Information?;

(c) what tools you can use to reduce the amount of personal information Trood collects about you;

(d) What are your rights with respect to processing of personal information.

4. What Personal Information Trood collects about you

Personal information collected during operation of the Sites and/or provision of the Services may vary depending on whether you use your account to access the Sites and/or Services or not. In cases where you log in to your account, the Personal Information collected by Trood during your use of the Sites and Services may be compared and linked to other Personal Information collected by Trood as part of your use of your account (for example, information about your identity, contact details, age and gender, if they were provided to Trood). Trood does not verify the Personal Information provided by you and cannot judge its authenticity, or whether you have sufficient legal capacity to provide your Personal Information. Nevertheless, Trood assumes that you provide accurate and sufficient Personal Information, as well as timely update it.

Trood may collect the following categories of Personal Information about you during your use of the Sites and Services:

(i) Personal information you provided when registering (creating an account), such as your name, phone number, address and age;

(ii) electronic data (HTTP headers, IP address, cookies, web beacons/pixel tags, browser ID data, hardware and software information);

(iii) date and time of accessing the Sites and/or Services;

(iv) information about your activity during the use of the Sites and/or Services (for example, the history of search requests; e-mail addresses of those with whom you maintain correspondence; e-mail content and attachments, as well as files stored in Trood systems);

(v) geolocation information;

(vi) other information about you necessary for processing in accordance with the conditions governing the use of Trood specific Sites or Services;

(vii) information about you that we receive from our Partners in accordance with the terms of agreements concluded between you and the relevant Partner, and agreements concluded between Trood and the Partner.

Trood also uses cookies and web beacons (including pixel tags) to collect Personal Information and link such personal information with your device and web browser (see section 11 of this Policy).

Trood does not collect purposefully sensitive Personal Information (such as race, political opinion, health information, or biometric data). However, you can independently provide them to Trood, in which case Trood will process them in the framework of providing you with the Services (for example, if you specify search queries related to your health). In doing so, you should take into account that Trood cannot request your consent for such processing, as it is not aware in advance of the potentially sensitive nature of the Personal Information that you can provide to Trood.

Trood does not collect data for the purpose of creating a “portrait” of the user to the extent that this can significantly affect your rights and freedoms.