Date of renewal: 14 August 2017

The Company “Suncom FZE” and its affiliated companies (hereinafter — “Suncom FZE” , “we”, “our” or “us”) pays particular attention to protection of confidentiality of our users (hereinafter — “users” or “you”). In your Policy of confidentiality (hereinafter — «Policy») methods of collection of information we use are described, including personal information you give or which is collected by us on our web-sites including (all together — “Service”) as well as methods of storage and use of such information and handling with it. Please, be informed, that the area of application of this Policy is limited by information collected and received by the Company “Suncom FZE” with your help of the use of this Service. The Company “Suncom FZE” is not responsible for actions of the third parties or companies, for the content of their sites, for the use of information you give and for any products and services they can offer. Any links of such sites do not mean our sponsorship of these persons and companies or the fact, that we have any relationship with them.

Using the Service you express your consent with this Policy of Confidentiality and give your consent on collection, transmission, manipulation, storage, disclosure and other types of use of your information as described in the current Policy of Confidentiality. Notwithstanding the fact where you live or from which country you give information you transfer to us the right to use information in any country where “Suncom FZE” works, including your personal data according to the rules stated in this Policy. If you do not agree with these conditions, please, do not use this Service.

1. Collection and use of information

1.1. The company “Suncom FZE” does not have intention to collect information which relates according to the current legislation to your personal data as well as to personal data of your employees and contractors, for example, surname, name, patronymic, year, month, date and place of birth, address, name of the company, place of job, telephone number, e-mail address and other information («Personal data»), via sites which below to the company, except the cases when Personal data was given by you voluntarily.
1.2. The company “Suncom FZE” executes collection of information according to description given below. The company “Suncom FZE” executes collection of information first of all in order to create your profile, to provide you with services, to improve our Service and to communicate with you, to execute investigations and to make reports for the internal use. We keep information in full correspondence with international and national legislation in the places of presence of the Service and provision of services. Data of the Russian users is stored on servers which are located on the territory of the Russian Federation.
1.3. The company “Suncom FZE” has the full right to execute trans-border transmission of data, creation of replicates of users` data bases, processing and storage of information on the servers and equipment which are located in the countries with high level of protection of personal data according to Convention of protection of physical persons in the course of computerized processing of personal data (ETS N 108) dated 28 January 1981 (with amendments dated 15 June 1999).
1.4.   The company “Suncom FZE” uses information collected with the help of the Service for the following goals:

communication with you and the third persons;
processing of your requests and transactions;
improvement of the Service;
customization of the Service according to your needs;
development of our Service;
marketing analysis;
goals related with our business.

2. Web-sites of “Suncom FZE”

When you visit web-sites of “Suncom FZE”, automatic collection and maintenance in files of logs of the following data can be executed: data about computer`s operation system, IP-address, data about time of the visit, browser type, language and links of the web-sites from which you logged on our web-site. We can apply this information for the purposes of monitoring, development and analysis of your use of this Service. Furthermore, we can ask you to provide us with the following data of personal character which we can process. This data includes besides all other data: your name, profile photo, your gender, age or date of birth, links on your profiles on social networks or other sites of the third persons, user`s name, as well post address and e-mail. We can use this information to create user`s profile and provide you with services. We can use your e-mail for communication with you in order to know your opinion about Services of “Suncom FZE”, as well as in order to inform you about the news of the company and special offers. Data of your gender and date of birth can be used for analysis of user`s tendencies and advertising materials which are oriented at the targeted audience. Your e-mail can be used for sending you any goods or souvenirs used as advertising materials. If you don`t want to receive advertising materials of such type, you can any time refuse from its reception having sent them e-mail on the following address: [email protected].

3. Social networks (elements) and mini-applications

On our web-site there are elements of social networks such as buttons VK and Facebook “I like” and widgets such as the button “Share” or interactive mini-programs working on our site. Such Elements can register your IP-address and information of pages you visited on our site. They can also maintain files cookies which is necessary for the correct functioning of such Elements. Elements and widgets of social networks are placed at the third persons or directly on our Site. Your interaction with such Elements is regulated by the policy of confidentiality of company which provides them.

4. Customer service

4.1. When you apply to our service of clients` support, we can maintain your e-mail and use it
in order to use it for the contact with you, to ask you about your impressions from the Services of “Suncom FZE” and to inform you about the news of the company and special offers. If you don`t want to receive e-mails, you can anytime refuse from them having pressed the link of refusal from subscription which is in the bottom of each e-mail or having written to the following address: [email protected].
4.2. The Company “Suncom FZE” executes users` support of the Service as by e-mail [email protected], as well as by applications for instant change of messages including Telegram, Viber, WhatsApp. Answers on the questions of users and their requests concerning problems with the Service are provided by any free representatives of the Company “Suncom FZE” within one working day.

5. Push-notifications of browser

With assistance of your browser client we can from time to time send you push-notifications in order to provide you with updates for the Service, data of new products and other messages related with services which can be important for you. You can any time refuse from communications of such type and switch them off having changed appropriate settings in browser.

6. Other methods of collection of information

6.1. We can also receive information from you with the help of: (1) your participation in inquiries concerning the Service; or (2) your participation in actions and pranks which are held in the framework of the Service.
6.2. We can give you opportunity to participate in actions and pranks which are announced in the framework of our Service. If you decide to participate, we will ask you to give us definite personal information. Participation in these actions and pranks is absolutely voluntary, that is why it is up to you to decide if you give us such information or not. Requested information, as a rule, includes contact data (for example, name and address for delivery) and demographic information (for example, post index).
We will use this information in order to inform winners and to give them prizes, to follow the traffic and personalize the Service we provide you. Such actions and pranks can be held by external suppliers of services; it will be prohibited to such company to use personal information of users for any other purposes.

7. Technologies of tracking

7.1. We and our partners in marketing and outsourcing, affiliated companies and suppliers of analytical services use such technologies as files cookies, web-beacons, scripts and tags. It is necessary to identify computer or user`s device and “remember” information connected with your visit on the site, for example, your settings or user`s name and password. Information which contains file cookies can be connected with your personal data (for example, with your user`s identifier) for the purpose of improvement of the quality of our Service, adaptation of recommendations taking into account your interests and simplifying the use of the Service. You can switch off files cookies any time, but after that you won`t be able to get access to some functions of the Service or to use them.
7.2. We can automatically collect definite information using "Cookies". Cookies are small files of data which are stored on the hard disc with assistance of the web-site. Besides all other, the use of cookies helps us to improve the site and your experience on our Service. We use cookies in order to see which areas and peculiarities of the Site are more popular in order to calculate the number of computers which have access to the site, to improve your experience of using the Service and to remember your preferences. If your browser does not accept cookies or if you do not allow access, your access to functional or services can be limited.
7.3. Web-beacons also known as gifs are electronic images which can be used on the site or in our e-mails. Web-beacon can be used on our web-pages in order to collect information of the use of the Platform and efficiency of our sending of e-mails.
7.4. We can reflect advertising given to the third parties using of which on your computer or any other device files cookies will be stored which will let you control the content and advertising looked through by you. As external advertising campaigns associate your computer or device with the number, they will be able to identify your computer or device every time when they send you advertising. Such advertisers can use information about your visits of our Service, sites of the third parties and applications in order to analyze efficiency of advertising and to reflect advertising of goods and services which will correspond to your interests. This Policy does not apply to the methods of data collection used by such external advertisers and we are not responsible for them. We recommend you to learn appropriate policy of confidentiality in order to know more thoroughly about the rules of use of files cookies and other technologies.

8. Services of mobile analytics

We use software of mobile analytics which allows us to understand functionality of our mobile software on your device better. This software can register such information as frequency of use of application, event which take place in application, summarized data of use, data of productivity as well as resource from which application was loaded. We do not connect information maintained in analytical software, with any personal data you transmit via mobile application.

9. Services of the third parties

In our services there can be used technologies of tracking given by external providers of business-services (for example, Google Analytics and Yandex Metrics). Such technologies of the third parties can use in our services files cookies, API and development kits (SDK), which will allow them in the name of our company to execute collection and analysis of users` information. These external companies can have access to the following data: your device`s identifier, MAC-address, IMEI, region (region where one speaks indicated language), information of geolocation and IP-address. This will allow them to provide their services according to their appropriate policies of confidentiality. Our policy of confidentiality is not expanded on the instruments of tracking of the third parties. We do not have access to such measures of tracking of the third parties and their control.

10. Advertising networks

10.1. In the Service we provide we can reflect advertising. Advertisers can collect and use information about you, particularly, data about your activity during the session in the Service, data of device`s identifier, MAC-address, IMEI, information of geolocation and IP-address. They can use this information for the purpose of advertising announcements which can be interesting for you.
10.2. Besides, in other services you can see advertising of our Services. If you click on one of such advertisings and start using the web-site, you will become the user of our Service. In order to confirm the fact of installation, the advertiser can be given device`s identifier.

11. How we use data

We use information collected via our Service for the purposes which are described in this Policy and brought to your notice in connection with our Service. For example, we can use your information for the following purposes:
to create profile on one of the web-sites and to allow users to access the Service;
to provide functioning of our Service and to take measures on its improvement;
to understand your needы and preferences better in order to provide you with extended opportunities and to give you pleasure from the use of our Service;
to answer your comments or questions and to provide client`s support;
on your request to provide you and to deliver products and services to you;
to send you confirmations about the order, accounts for the payment, technical notifications, updates, preventions of security violation, messages from the technical support service and administrative messages;
to inform you about special offers, bonuses, coming events and other news about products and services offered by the company “Suncom FZE” and our partners optionally;
to give you opportunity to communicate with other users;
to connect or unify it with other information we receive from the third persons in order to understand your needs and preferences better and to provide you with services optimally.

12. Disclosure of your information

“Suncom FZE” transmits your personal data only if there is your allowance or according to description given below:
With your consent; for example, when you express consent about the fact, that we can transmit your information to the third parties for marketing purposes of these third parties which will be regulated by appropriate policy of confidentiality of such third parties. If you do not want us to transmit your information to the third parties, please, connect us by
e-mail: [email protected]. If you do not want to receive such e-mails from the third parties, please, connect them directly.
“Suncom FZE” can invite for cooperation other persons and companies which will provide you with services in the name of our company. As an example of such services there can be services of data analysis and clients` service. For provision of such services for “Suncom FZE” these agents and suppliers can have access to your personal data.
We can disclose your information within the limits allowed by the current legislation, for example, in order to execute decree of the court or in case we are not sure that such disclosure is necessary for execution of law`s requirements; for the purposes of investigation of fraud or giving an answer to authority`s request, for obligatory execution or realization of our rights; for the purpose of protection of rights, property or security as of our own as well as of our users our other persons. It includes change of information with other companies and organizations for the purpose of protection from the fraud.
The company “Suncom FZE” can transmit your information in the course of merger, selling of our assets or financing or acquisition of all or the part of our assets by another company. You will be informed by e-mail and/or having posted announcement on our web-site of any modifications concerning possession and the use of your personal data.
We can disclose joint or anonymized data about you to advertisers, editors, business partners, sponsors and other third parties.

13. Modification implementation to this Policy

We can review this Policy of confidentiality for the purposes of reflection of modifications in our principles of work with information. In case of introduction of any considerable changes we will inform you about it by e-mail (e-mail indicated in your profile) or by posting of this announcement on this Site before these modifications come into effect. We recommend you to visit occasionally this page in order to learn the latest information about our principles of confidentiality preservation.

14. Security

14.1. The company “Suncom FZE” will take all commercially reasonable measures for protection of your information from unsanctioned access, losses, use for the purposes other than intended as well as unsanctioned modifications by the third parties.
Notwithstanding the fact that we do everything depending on us in order to store information received from the users of the Service in the safe area, access to which is limited, we cannot guarantee absolute security of information in the course of its transmission via Internet or its storage in our systems. Furthermore, though we try to provide integrity and security of our networks and systems we cannot guarantee that measures of security we use will prevent from penetration of hackers of the third parties for the purpose of receipt of unlawful access to this information. We do not guarantee and do not confirm that your information will be protected from the loss, from the use not as intended or from unsanctioned modification by the third parties. There is no method of data transmission via Internet or electronic storage of data which provides its 100% protection. For this reason we cannot guarantee absolute security.
14.2. If you use password in the Service, you are responsible for its safety in confidence. Do not transmit data with your password to the third parties. If you consider that your password was compromised or stolen, please, inform us immediately. You are responsible for maintenance of the password you use for access to the Service and for any actions or actions executed under your password. We recommend you to use “strong” passwords (passwords which use combination of higher and lower case of letters, numbers and symbols) for your profile. The company “Suncom FZE” can`t and won`t be responsible for any damages or harm resulted from non-conformity of conditions described above.

15. Access to personal information

If your personal information was changed or if you do not want to use our Service, you can correct, update or delete inexact data having made necessary modification in the settings of your profile or having addressed to e-mail: [email protected]. We will answer to your request of provision of access to information within 30 days.

16. Data storage

We will store your information until your profile remains active or as required for provision of services. If you want to cancel your profile or if you want us not to use your information to provide you with services, connect us by e-mail: [email protected]. We will store and use your information according to necessity of execution of legal obligations, dispute regulation and realization of agreements.

17. Our Policy with respect to the children

We do not execute voluntary collection of personal information at children aged under 18, do not ask for it and do not allow them to use our Service. If you are under 18, you should not give information about yourself, particularly, your name, address, telephone number and e-mail. For the persons under 18 it is forbidden to give personal information. If we get to know that we collected information from the child aged under 18, we will immediately delete such information. If you consider that we could receive any information from the child or about the child aged under 18, please, contact us by e-mail: [email protected]

18. Refusal from receipt of marketing messages

18.1. You can refuse from receipt of our advertising or marketing electronic messages. You can do it having executed instructions which are given in such e-mails or having written to the
e-mail: [email protected]. If you refuse from receipt of such marketing e-mails, we can continue sending you e-mails with non-advertising content concerning your profile or our continuing business relations.
18.2 You can also refuse from receipt of our messages-notifications having done it by message or by e-mail: [email protected].

19. Cross-border data transmission

We can transfer information collected by you to affiliated companies or to the third parties beyond the country of your residence or your jurisdiction to other countries or jurisdictions globally. Please, be informed, that in these countries and jurisdictions there can be no law of data protection similar to current laws which can exist in your jurisdiction and we take measures in order to provide adequate protection of data in the course of its transfer to other countries and to provide the use and disclosure of information about you including your personal data according to the principles stated in this Policy.

20. Contact information

United Arab Emirates, Ras-el-Haima,
Al Jazirah Al Hamra, RAKIA Amenity Center — Tower 1, 12 floor
If you have questions concerning this Policy, please, address by e-mail: [email protected]