VERTERA WEBSITE PRIVACY POLICY

INTRODUCTION

Welcome to the Privacy Policy for Vertera! Here we explain what data we collect when you come to our Websites and use it. We also explain why we collect this data and who your data is shared with. Please read over this and contact us with any questions regarding this document. Before you can sign up for a personal account with Vertera, please review this Privacy Policy and signify your acceptance of the various sections.

VERTERA STOLITSA LIMITED LIABILITY COMPANY (OGRN: 1217700475937, address: 9 floor 6, room V, office 613 2nd Brestskaya Str., Moscow 123056) (hereinafter referred to as the "Company") undertakes to protect personal data collected or received from visitors (hereinafter referred to as the "Visitors") of the https://vertera.org/de Website, as well as other websites and applications operated by the Company (hereinafter referred to as the "Websites"), and other interactive media used that have a link to this Policy. It also describes how we use the Personal Information we collect when registering as a Customer (“Customer”) or as an Independent Partner of Company

In this Privacy Policy (“Policy”) we explain how your personal data, meaning any information relating to you as an identified or identifiable natural person (“Personal Data”), that we may hold about you, is collected, used, stored, disclosed, and removed (each and all referred to as "processing").

The personal data processing policy has been drawn up in accordance with clause 2 of Art. 18.1 of the Federal Law of the Russian Federation "On Personal Data" No. 152-FZ of July 27, 2006 and applies to all Personal Data processed by the Company, which can be obtained from both an individual or a legal entity (counterparty) that has a contractual relationship with the Company

Clients, Independent Partners of the Company expressly agree to the processing of their Personal Data as described in this Policy. We do not collect any personally identifiable information from a person under the age of 18. If you believe that a person under the age 18 has provided us with personally identifiable information, please contact our customer support.

This Policy only applies to information we process. It does not apply to the practices of companies that we don't own or control, or employees that we don't manage. Information on our products’ may contain links to third party websites, and any information you provide to those sites will be covered by any privacy policies they may have. Please be sure to read the privacy policies of any third-party sites you visit. It is those sites' responsibility to protect any information you give them, so we can't be held liable for their wrongful use of your personally identifying information.

The legal basis of this Policy is the Federal Law of the Russian Federation "On Personal Data" No. 152-FZ dated July 27, 2006 (FZ "On Personal Data"). When registering on the Site, Clients, Independent Partners of the Company confirm their agreement with the terms of this Policy and their consent to the processing of their Personal Data in accordance with the terms of this Policy.

We may update this Policy from time to time and will notify you of changes to this Policy affecting your rights by email and/or by posting on our Websites.

WHAT PERSONAL DATA IS COLLECTED AND IT’S PURPOSES?

With regard to each of your visits to the Websites, the Company will automatically collect the following Personal Data:

• Technical information, including the Internet Protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time-zone setting, browser plug-in types and versions, operating system and platform;
• Information about your visit to the Websites, including the full Uniform Resource Locators (URL) clickstream to, through and from the Websites (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.

We collect this information to improve our Websites, products, fulfil our administrative purposes and protect our business interests.

In addition, through the communications channels made available on the Website’s “Contacts” webpage, we collect your contact details, such as your name, email address. We collect this information to provide you with the answers, an appropriate response to your inquiries or comments.

If you are registering as a Customer we may collect the following Personal Data from you:

• Your First name, Last name. It is the contractual requirement. If you don’t provide this data, you won’t be able to register as a Customer;
• Password. It is the contractual requirement. Without the password you cannot create your account in our online system as the data must be secured;
• E-mail address. It is required for confirmations and communications. Without email you will not receive confirmations. Also we use it to communicate with you;
• Phone number. We collect this information to manage your registration as a Customer, create and manage your online account, communicate with you; Also it is required for confirmations and for delivering your orders;
• Information on your purchases from Vertera, and information about your preferences for particular types of products, purchasing habits, purchasing history and spending behavior. We collect this information to improve our Websites, products, fulfil our administrative purposes and protect our business interests;
• Postal address. It is the contractual requirements, if you do not provide it we will not be able to deliver your order.

In addition, when you communicate with us through various communications channels, we collect your contact details, such as your name, email address. We collect this information to provide you with the answers, an appropriate response to your inquiries or comments.

We may collect other types of personal data in exceptional circumstances only. If we do need to process additional types of Personal Data about you, we will make sure that you are informed about the processing of your Personal Data and that there is a valid legal basis for doing so (for example, your consent).

If you are registering as a Partner of Company we may collect the following Personal Data from you::

• Your First name, Last name and Middle name. If you don’t provide this data, you won’t be able to register as a Partner;
• Your date of birth. Registration only accepted for over 18s, because of the statutory requirement;
• Your personal code. We will use this data to verify you as an exact Partner and to pay the rewards according to the Marketing plan of the Company;
• Copy of the passport / ID card. We will use this data to verify you as an exact Partner and to pay the rewards according to the Marketing plan of the Company, because of statutory requirements;
• Postal address. It is the contractual requirements, if you do not provide it we will not be able to deliver your order;
• Registration address. It is our statutory requirements. We cannot offer bonuses without your current address;
• E-mail address. It is required for confirmations and communications. Without email you will not receive confirmations. Also we use it to communicate with you;
• Phone number. It is required for confirmations and for delivering your orders;
• Account number (banking/payment system). It is our statutory obligations, required for paying the bonuses to you;
• Password. It is the contractual requirement. Without the password you cannot create your account in our online system as the data must be secured;
• Information on your purchases from Vertera, and information about your preferences for particular types of products. We collect this information to improve our Websites, products, fulfil our administrative purposes and protect our business interests.

If you object to the use of your Personal Data to fulfil any of the purposes set out above, please contact us. Whilst your decision to provide your Personal Data to Vertera is generally voluntary, if you do not provide certain information Vertera may not be able to accomplish some of the purposes outlined in this Privacy Policy. For example, we may not be able to post products to you without knowing your postal address.

WHAT IS THE LEGAL BASIS OF THE USE OF THE PERSONAL DATA?

Contractual Necessity: As required to establish and fulfil a contract with you (Terms and Conditions), for example, if you make a purchase from it. This will include taking payments, communicating with you, providing customer services and arranging the delivery or other provision of products or services. Also to establish a partnership contact we will need to verify you identity, taking payments, communicating with you, providing partnership services, and providing you with the bonuses and rewards.

Legitimate Interests: As required by it to pursue its own legitimate interests, in particular:

• to communicate with you (including providing you with information to help you improve your business (such as providing you with training materials and sessions);
• to invite you to take part in market research or studies, and attend (business update) conferences;
• to help it monitor, improve, administer and protect its products, content, services and Websites, both online and offline;
• to monitor and ensure compliance by you with its policies and rules;
• to monitor any Customer or Partner account to prevent, investigate and/or report fraud, terrorism, misrepresentation, security incidents or crime, in accordance with applicable law; and
• to measure or understand the effectiveness of advertising it serves to you and others, and to deliver relevant advertising to you (including, performance of customer satisfaction and similar studies).

Legal Compliance: To ensure compliance with applicable laws and the protection of the Company's legitimate business interests and legal rights, including, but not limited to, use in connection with legal claims, compliance, regulatory, tax, investigative purposes (including disclosure of such information in connection with legal process or litigation).

Consent: Subject to the following, the Company will send you direct marketing in relation to the Company's products and services similar to those which you have already purchased, or other products and services provided by the Company. This will only be sent where you have given your consent to the Company during the Customer’s or Partner’s sign-up process. You can manage your preferences or unsubscribe at any time by following the links in emails we send you.

WHO WILL YOUR PERSONAL DATA BE SHARED WITH?

To render you quality services, we transfer your Personal Data to the following partners:

• Companies providing courier services that deliver goods at the postal addresses indicated by you;
• Postal services;
• The products' suppliers that deliver goods directly to you;
• Other Vertera group companies, including WR International AG for group level analytics;
• Government authorities and/or law enforcement officials if required for the purposes above, if mandated by law or if required for the legal protection of its own legitimate interests in compliance with applicable laws.

This sharing will be for the purposes set out above or to comply with specific legal obligations to which we are subject.

The Company transfers your Personal Data, as a rule, to countries that provide adequate protection for personal data subjects on the basis of your consent provided when registering on the Site. In the event that your Personal Data will be transferred to countries that do not provide adequate protection of the rights of subjects of Personal Data, then the Company is obliged to obtain your prior written consent to such a transfer that meets the requirements of the legislation of the Russian Federation or to transfer your Personal Data on other legal grounds provided for the legislation of the Russian Federation.
When transferring your Personal Data to any third parties mentioned in the Policy, the Company ensures strict observance of the confidentiality of the transferred Personal Data, as well as other requirements of the legislation of the Russian Federation in the field of personal data protection. For this, the Company enters into appropriate agreements with third parties that meet the requirements of the legislation of the Russian Federation and, in particular, the Federal Law "On Personal Data".

Vertera uses appropriate safeguards to protect personal information which is transferred to countries outside of the European Economic Area which are considered to provide a lower level of protection for personal information. European Commission-approved Standard Contractual Clauses and other legally acceptable transfer mechanisms are in place with our email system provider and IT support and IT system maintenance suppliers. Contact us using the details set out below to see a copy of the relevant safeguards.

INTERNATIONAL DATA TRANSFERS

We store your information primarily within the European Economic Area. However, some features and requirements of the service, involve transferring your information to third-party service providers outside the European Economic Area. We have described all those service providers above in the Section “WHO WILL YOUR PERSONAL DATA BE SHARED WITH?”. Where such service providers are not established in a country ensuring an adequate level of protection within the meaning of Regulation (EU) 2016/679, such as the United States, the transfers will be covered by the standard data protection clauses adopted by the European Commission or by another appropriate safeguard mechanism such as the Privacy Shield Framework.

WHERE DO WE STORE YOUR PERSONAL DATA?

When collecting your Personal Data, the Company ensures the recording, systematization, accumulation, storage, clarification (update, change), extraction of your Personal Data using databases located on the territory of the Russian Federation.

WHAT COOKIES WILL BE USED ON THE WEBSITES ?

The Websites uses cookies (small files placed on website users’ hard drive) to distinguish you from other Customers and Partners of the Websites. This helps us to provide you with a high quality experience when you browse the Websites and also allows us to improve the Websites. We use cookies to analyze the flow of information; customize the services, content and advertising; measure promotional effectiveness; and promote trust and safety.

We offer certain services that are available only through the use of cookies. Generally, we use the following categories of cookies:

1. Strictly Necessary Cookies
Some cookies are essential for the operation of the Websites. For example, some cookies allow us to identify registered Customers or Partners and ensure they can access the Websites. If a registered Customer or a Partner opts to disable these cookies, the Customer, Partner may not be able to access all of the content of the Websites.

2. Performance Cookies
Other cookies may be used to analyze how Visitors, Customers, Partners use the Websites and to monitor Websites performance. This allows us to provide a high quality experience by customizing the offering and quickly identifying and fixing any issues that arise. For example, performance cookies may be used to keep track of which pages are most popular and to determine why some pages are receiving error messages.

3. Functionality Cookies
Functionality cookies are used to allow us to remember Visitors’, Customers’, Partners’preferences and tailor the Websites to provide enhanced features.

4. Google Analytics
We use Google Analytics to understand how Visitors engage with our Websites. This means that when you visit our Website your browser automatically sends certain information to Google. This includes, for example, the web address of the page that you're visiting and your IP address. You will find the details of how the Google technology collects and processes data following this link https://www.google.com/policies/privacy/partners/. If you don’t want the Google Analytics to be used in your browser, you can install the Google Analytics browser add-on. You can find more about the Google Analytics and Google privacy policy https://policies.google.com/privacy. Visitors, Customers,Partners are always free to decline cookies if their browser permits, although doing so may interfere with their use of the Websites. Please find detailed information on how to disable cookies here ( http://www.allaboutcookies.org/manage-cookies/). More detail on how businesses use cookies is available here (http://www.allaboutcookies.org/).

• Strictly Necessary Cookies
• Performance Cookies
• Functionality Cookies
• Google Analytics

Some cookies are essential for the operation of the Websites. For example, some cookies allow us to identify registered Customers or Partners and ensure they can access the Websites. If a registered Customer or a Partner opts to disable these cookies, the Customer, Partner may not be able to access all of the content of the Websites.

Other cookies may be used to analyze how Visitors, Customers, Partners use the Websites and to monitor Websites performance. This allows us to provide a high quality experience by customizing the offering and quickly identifying and fixing any issues that arise. For example, performance cookies may be used to keep track of which pages are most popular and to determine why some pages are receiving error messages.

Functionality cookies are used to allow us to remember Visitors’, Customers’, Partners’preferences and tailor the Websites to provide enhanced features.

We use Google Analytics to understand how Visitors engage with our Websites. This means that when you visit our Website your browser automatically sends certain information to Google. This includes, for example, the web address of the page that you're visiting and your IP address. You will find the details of how the Google technology collects and processes data following this link https://www.google.com/policies/privacy/partners/.

If you don’t want the Google Analytics to be used in your browser, you can install the Google Analytics browser add-on. You can find more about the Google Analytics and Google privacy policy https://policies.google.com/privacy.

Visitors, Customers,Partners are always free to decline cookies if their browser permits, although doing so may interfere with their use of the Websites. Please find detailed information on how to disable cookies here ( http://www.allaboutcookies.org/manage-cookies/).

More detail on how businesses use cookies is available here (http://www.allaboutcookies.org/).

HOW LONG WE KEEP YOUR PERSONAL INFORMATION ?

Personal Data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes. The Company will keep your Personal Data for the length of the contractual relationship you have with the Company and, to the extent permitted, after the end of that relationship for as long as necessary to perform the purposes set out in this policy.

The storage of personal data is carried out in a form that makes it possible to determine the subject of personal data no longer than the purpose of processing personal data requires, unless the storage period for personal data is established by federal law, an agreement to which the subject of personal data is a party, beneficiary or guarantor. The processed personal data are subject to destruction or depersonalization upon achievement of the processing goals or in case of loss of the need to achieve these goals, unless otherwise provided by federal law.

For example, Vertera may keep special information even after deletion of the account, if it is necessary to fulfill the requirements of law, to settle the dispute, to prevent fraud or abuse, and to ensure compliance with provisions of this Privacy Policy. Personal Data of the Visitors having not signed in to the account shall be stored within 12 months in order to analyze behavioral activity. For Customers who have not order products from the Company, we will delete all personal data 12 months after the approval of your account deletion request to analyze Customer activity and improve the Websites, our products.

For Customers who have ordered any products from Vertera our data deletion policy is the following:

Order processing information will be kept by Vertera for 5 years or until tax audit close, whichever is later. Other Personal Data will be deleted in 12 months after the approval of your account deletion.

For Partners:

Order processing information will be kept by Vertera for 5 years or until tax audit close, whichever is later. Vertera may use your Personal Data while you are active with Vertera. In deciding how long to keep personal information after you cease to be active with Vertera, we take into account any ongoing obligations we may have (e.g. to store the information for accounting purposes) or the length of time given to commence or defend any legal claims.

We will stop processing your data for direct marketing, including profiling activities, if you object to such processing of your data or if you withdraw your consent to processing, where your consent has previously been obtained.

YOUR RIGHTS

Here we have summarised the principal rights that you have under data protection law. Some of the rights are complex, might contain restrictions depending on the legal basis for processing the data and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

Clients, Independent Partners of the Company (Personal Data Subjects) have the right to:

• make a decision on the provision of their Personal Data to the operator of Personal Data;
• withdraw consent to the processing of your Personal Data;
  add, supplement or change the processed Personal data;
• demand to exclude your Personal Data from publicly available sources of Personal Data;
• to receive information regarding the processing of their Personal Data, including containing:
  1. 1) confirmation of the fact of processing of Personal Data by the operator;
  2. 2) the legal grounds and purposes for the processing of Personal Data;
  3. 3) the purposes and methods of processing Personal Data used by the operator;
  4. 4) the name and location of the operator, information about persons (except for the operator's employees) who have access to Personal Data or to whom Personal Data can be disclosed on the basis of an agreement with the operator or on the basis of the Federal Law "On Personal Data";
  5. 5) processed Personal data related to the relevant subject of Personal data, the source of their receipt, unless another procedure for submitting such data is provided for by the Federal Law "On Personal Data";
  6. 6) the terms of processing Personal data, including the terms of their storage;
  7. 7) the procedure for the exercise by the subject of Personal data of the rights provided for by the Federal Law "On Personal Data";
  8. 8) information on the performed or expected cross-border data transfer;
  9. 9) the name or surname, first name, patronymic and address of the person who processes Personal Data on behalf of the operator, if the processing is entrusted or will be entrusted to such a person;
  10. 10) other information provided for by the Federal Law "On Personal Data" or other federal laws

The right of the subject of Personal Data to access his Personal Data may be limited in accordance with the federal laws of the Russian Federation.
You can exercise any of your rights in relation to your Personal Data by contacting our support team.

LINKS TO OTHER WEBSITES

The Websites may contain links to websites maintained by third parties, whose information and privacy practices are different than ours. We are not responsible or liable for the information or privacy practices employed by such third parties. We encourage you to read the privacy statements of all third party websites before using such websites or submitting any personal data or any other information on or through such websites.

UPDATES OF THE PRIVACY POLICY

This Privacy Policy may be revised, modified, updated and/or supplemented at any time, without prior notice, at the sole discretion of Vertera. When we do, we will post a notification on the main page of our Websites, revise the updated date at the top of this page. We encourage Customers, Partners to check this page with a regular frequency for any changes to stay informed on how we help to protect the Personal Data we collect. Each Customer, Partner must acknowledge and agree that it is his personal responsibility to review this Privacy Policy periodically and become aware of modifications.

By using our Websites, the Customer, Partner automatically signify his acceptance of this Privacy Policy. If the Customer, Partner does not agree to this Privacy Policy, we would require him not to use our Websites. In case the Customer, Partner continue the use of the Websites following the posting of amendments to this Privacy Policy, it will be deemed his acceptance of those amendments.

REPORTING TIMELINE

In the event of Personal Data breach Vertera is obliged to notify the appropriate supervisory authority without undue delay and, where, feasible, not later than 72 hours after having become aware of it. In such situation you also shall be notified immediately.

HOWTO CONTACT US

If you have any comments or inquiries about our Privacy Policy, if you would like to update information we have about you, or to exercise your rights, you may contact us via support@vertera.org