Private dating service for VIP client's

Approved By Order

_ _ _ “___”________2017

Privacy Policyon personal data processing and protection of the International Dating Agency ELITE, established by Alkor LLC (Russia)

GENERAL

1.1. This Policy on personal data processing and protection (the Policy) is developed in accordance with the article 18.1 of the Federal law of 27.07.2006 № 152-FZ “On personal data”, and is the main internal document of Alkor LLC, founder of the International Dating Agency ELITE (the Company), regulating its activity regardingpersonal data processing and protection, operated by the Company.

1.2. The Policy is developed to implement requirements of the legislation of the Russian Federation onpersonal data processing and protection, and is aimed to ensure protection of human civil rights and freedoms while processing personal data in the Company, including protection of rights onpersonal and family privacy.

1.3. This Policy is applied to any user information received by the Company, both before and after the adoption of the Policy.

1.4. This Policy is applied to all user information obtained bythe Company, including data received while using the site www.elitemsk.com(the Website).

1.5. Visiting and using the Website involves unconditional acceptanceof this Policy and conditions of personal dataprocessing.

1.6. In case of disagreement with conditions of personal dataprocessing assumed by the Company, the user must cease using the Website and receiving services of the Agency.

1.7. This Policy applies only to the website www.elitemsk.com.The Company does not control and is not responsible for the collection and processing of personal data by third parties on the websites which the user can navigate through the links available on the website www.elitemsk.com.

1.8. The Company does not verify the accuracy of personal data provided by the user.

CONTENT OF THE OBTAINED AND PROCESSED PERSONAL DATA

2.1. The user’s data received and processed in the framework of this Policy come into the Company in the following ways:

2.1.1. Provided by the user by:

filling out the questionnaire on the website www.elitemsk.com,which includes the following information: name, nick, date of birth, marital status, religious beliefs, education, profession, level of English, knowledge of other foreign languages, country and city of residence, interests, height, weight, eye color, hair color, presence of children, attitude to smoking, drinking habits, mailing address, mobile phone number, home phone number, work phone number, email address, residentialaddress (residence permit), series and number of passport, personal photo, and other information to the user’sdiscretion;
filling the services application on the website www.elitemsk.com, which includes the following information: surname, name, patronymic, date of birth, country and city of residence, email address, phone number;
filling the feedback form on the website www.elitemsk.com,which includes the following information: surname, name, patronymic, country and city of residence, email address, phone number;
communication with the Company by sending written correspondence to the Company address, by phone numbers, e-mail, video communications listed on the website www.elitemsk.com and in any other ways, which may include the following information: name, mailing address, location, phone number, e-mail, passport data and other information to the user’s discretion.

2.1.2. Automatically transferred to the Companywhen accessing and using the website www.elitemsk.com bysoftware installed on the user’s device, including: IP address, information from cookies, information about user’s browser (or other program through which the website isaccessed), access time, address of the requested page.

PURPOSE OF COLLECTION AND PROCESSING OF PERSONAL DATA

3.1. Collection and processing of personal user data bythe Company has the following objectives:

3.1.1. User identification in the framework of legal relations with the Company;

3.1.2. Enter into the services contract with the user on behalf of the Company and (or) partners of the Company.

3.1.3. Communication with the user if necessary, including sending notifications, requests and information related to the use of the Website, provision of services by the Company and (or) its partners, as well as handling inquiries and requests from the user;

3.1.4. Providing effective customer and technical support if the user encounters problems associated with the use of the Website and services of the Company (or) its partners;

3.1.5. Improving the quality of the Website, its usability;

3.1.6. Providing personal services, special offers, pricing information, newsletters and other information on behalf of the Company and (or) its partners upon the user’s consent;

3.1.7. Carrying out promotional activities with the user’s consent;

3.1.8. Grant user access to websites or services of the Company’s partnersin order to receive products, updates and services.

3.1.9. Carrying out statistical and other researches based on depersonalized data.

PROVISION OF ACCESS TO PERSONAL DATA

4.1. The Company ensures the safety of personal data of customers and users.

4.2. In relation to the user’s personal data, their privacy is preserved, except for the cases stipulated in clause 4.3. of this Policy.

4.3. The Company has the right to transfer personal user data to third parties in the following cases:

4.3.1. The user explicitly consented to transfer his/her personal data;

4.3.2. Transfer of personal data is necessary for providing the user a particular service by the Company or its partners. This ensures confidentiality of personal information, and the user is notified of such transfer.

4.3.3. Transfer is provided by the Russian or other applicable legislation within the established procedure (by court order, law enforcement authoritiesrequest, etc.);

4.3.4. Such transfer occurs as part of the sale or other business transfer (in whole or in part), while the purchaser assumes all liability for compliance with this Policy with respect to personal information received;

4.3.5. To ensure protection of the rights and legitimate interests of the Company.

4.4. In case of loss or disclosure of personal data, the Company informs the user about the loss or disclosure (transfer) of personal data.

PROTECTION OF USER’S PERSONAL DATA

5.1. The Company ensures that the level of personal data protection of users and customers meets the requirements set in the Government Decree of the Russian Federation from November 1, 2012 no 1119 “On approval of requirements for personal data protection while processing in personal data information systems”.

5.2. The company takes necessary organizational and technical measures to protect personal data from unauthorized or accidental access, destruction, alteration, blocking, copying, distribution and other unlawful actions of third parties in accordance with the requirements of the Order of the Federal Service for Technical and Export Control of Russia from 18.02.2013 № 21 “On approval of Composition and content of organizational and technical measures for ensuring personal data security while processing in personal data information systems”.

RESPONSIBILITY

6.1. In case of default of its obligations, the Company shall be liable for losses incurred by the user in connection with the misuse of personal data, in accordance with the legislation of the Russian Federation, except the cases stipulated in clause 6.2. of this Policy.

6.2. In the case of loss or disclosure of user’s personal data, the Company is not responsible, if this information became public before its loss or disclosure, or is disclosed by the user or with the user’s consent.

FINAL CLAUSES

7.1. The Company has the right to make changes and additions to this Policy. The revised Policy shall take effect upon its posting on the website www.elitemsk.com, if otherwise provided in the new Policy edition.

7.2. Relations on personal data processing and protection, not addressed in this Policy shall be governed by the applicable laws of the Russian Federation.

7.3. All suggestions or questions related to the personal data processing and protection by the Company should be sent to the email address elitemsk@bk.ru.

7.4. Operator’spersonal data:

International Dating Agency Elite (LLC Alcor)

INN 7719844479;

KPP 772601001;

OGRN 1137746400373;

Legal address: 115191,Russia, Moscow, Dukhovskoypereulok, 17, of. 12A

Mailing address: 115191,Russia, Moscow, Dukhovskoypereulok, 17, of. 12A

Office address: Russia, 109112, Moscow, M. Cherkassky, 2, Business Center «Cabinete Lounge» 2nd floor