PERSONAL DATA PROCESSING POLICY

As amended on December 10, 2021, this Personal Data Processing Policy (hereinafter referred to as the Policy) defines the general principles and procedure for the processing of Users Personal Data of the Scallium Platform (Скейллиум) and the Site and measures to ensure their security at HUBBER LLC.

The parties use the following terms with the meanings given below:

a) Automated processing of personal data - processing of Personal Data using computer facilities;

b) Operator's database - a set of information and data located in the information system of the Operator in order to store Personal Data of Users and other information.

c) Data - other data about the User (not included in the concept of Personal Data).

d) Legislation - the current legislation of the Russian Federation.

e) Operator - HUBBER LLC, independently or jointly with other persons organizing and (or) processing Personal Data, as well as determining the purposes of processing Personal Data, the composition of Personal Data to be processed, actions (operations) performed with Personal Data.

f) Personal data - any information relating directly or indirectly to a specific or identifiable individual (User).

g) User - a person who has access to the Platform and the Operator's Site.

h) Provision of Personal Data - actions of the User aimed at disclosing Personal Data to a certain person or a certain circle of persons.

i) Platform – Scallium (Скейллиум) software belonging to the Operator, through which services are provided, access to the functionality is provided.

j) Subject of Personal Data - the User to whom the Personal Data relates.

k) Site - a site located on the Internet at the address: scallium.pro.

1.1. The Policy regarding the processing of Personal Data has been developed in accordance with the provisions of Federal Law No. 152-ФЗ dated 27.07.2006 «On Personal Data» (as amended and supplemented), other legislative and regulatory legal acts and determines the procedure for processing with Personal Data of Users and (or) transmitted by Users and the requirements for ensuring their security.

1.2. Measures to ensure the security of Personal Data are an integral part of the Operator's activities.

2.1. The Personal Data Processing by the Operator is carried out in accordance with the following principles:

2.1.1. Legality and fair basis for the Personal Data Processing. The Operator takes all necessary measures to comply with the requirements of the Legislation, does not process Personal Data in cases where this is not allowed by the Legislation, does not use Personal Data to the detriment of the User.

2.1.2. Processing only those Personal Data that meet the previously announced purposes of their processing. Compliance of the content and volume of Personal Data Processing with the stated processing purposes. Avoiding the Personal Data Processing that is incompatible with the purposes of collecting Personal Data, as well as excessive in relation to the stated purposes of their processing. The Operator processes Personal Data solely for fulfilling contractual obligations to the User.

2.1.3. Ensuring the accuracy, sufficiency and relevance of Personal Data in relation to the purposes of Personal Data Processing. The Operator takes all reasonable measures to support the current processed Personal Data, including but not limiting the implementation of each Subject of receipt for familiarization with their Personal Data and require the Operator to clarify, block or destroy them if the Personal Data is incomplete, outdated, inaccurate, illegal or optional for the processing purposes stated above.

2.1.4. Storing Personal Data in a form that allows you to identify the User of Personal Data for no longer, than the purpose of Personal Data Processing requires, unless the storage period for Personal Data is established by federal legislation, an agreement to which the User of Personal Data is a party or beneficiary.

2.1.5. Inadmissibility of combining Personal Data Information Systems databases created for incompatible purposes.

3.1. The Personal Data Processing by the Operator is allowed in the following cases:

3.1.1. With the consent of the User to the processing of his Personal Data. Consent is given by filling out an electronic form located on the Operator's website, activating the check box and/or clicking the «Register» button.

3.1.2. Personal Data are subject to publication or mandatory disclosure in accordance with the Legislation.

3.2. The Operator does not disclose to third parties and does not distribute Personal Data without the consent of the User, unless otherwise provided by the Legislation.

3.3. The Operator does not process Personal Data related to special categories and relating to race and nationality, political views, religious or philosophical beliefs, the intimate life of the Personal Data Subject, the membership of the Personal Data Subject in public associations, except as expressly provided for by the Legislation.

3.4. By providing Users with the opportunity to use the Platform, the Operator, acting reasonably and in good faith, believes that:

3.4.1. The User has all the necessary rights to use the Platform;

3.4.2. The User is aware that the User himself cannot delete some types of information transmitted by him to other Users;

3.4.3. Personal Data does not belong to third parties.

3.5. The Operator does not verify the accuracy of the information received (collected) about the Users, except for cases when such verification is necessary in order to comply with the provisions of the Legislation and/or obligations to the User.

4.1. The Operator collects and stores only those Personal Data that are necessary to provide services to the User, to send informational and advertising materials to the User through the Site and Platform, as well as to fulfill the Operator's contractual obligations to third parties. At the same time, the collection of Personal Data can be carried out both through the Platform and the Site, and during the exchange of data via e-mail when concluding an agreement with the Operator in a simple written form.

4.2. The Operator processes Personal Data in order to:

4.2.1. Providing services to the User or to a legal entity (individual entrepreneur), the representative of which is the User;

4.2.2. Processing applications, orders, remarks, suggestions, comments and other communications;

4.2.3. Sending advertising and information mailings to the User via SMS notifications or e-mail;

4.2.4. Providing bonuses and conducting incentive events;

4.2.5. Informing the User about the services of the Operator's partners.

4.2.6. Fulfillment of contractual obligations to the partners of the Operator.

4.2.7. Conducting statistical and other research based on anonymized Personal Data.

4.3. The operator processes the following Personal Data:

4.3.1. Personal Data entered by the User in electronic form during registration:

• First Name Last Name;
• Contact phone number;
• Email address;
• Password;
• Company name and website.

4.3.2. Personal Data entered by the User in the Personal Account on the Site:

• First Name Last Name;
• Public email address;
• Site;
• Position in the company;
• Division;
• Taxpayer identification number;
• The photo;

4.3.3. Personal Data entered by the User when inviting a third party (employee):

• First Name Last Name;
• Email address;
• The role of the employee.

4.4. For the purposes specified in paragraphs. 4.2.1.-4.2.7. The Operator processes the following other information/data:

4.4.1. Standard technical and other data automatically obtained by the Operator when the User accesses the Platform and the Site and subsequent actions of the User on the Platform and on the Site (location at a certain point in time, IP address, type of operating system of the User's device, sections of the Platform and the Site visited by the User).

4.4.2. Information obtained as a result of the User's actions on the Platform and on the Site.

4.4.3. Information obtained as a result of actions of other Users on the Platform and on the Site.

4.5. With regard to the Personal Data and other data of the User, their confidentiality is maintained, except for cases when the specified data is publicly available.

4.6 The Operator has the right to transfer Personal Data and other data of the User without the consent of the User to the following persons:

4.6.1. State bodies, including bodies of inquiry and investigation, and local self-government bodies at their motivated request.

4.6.2. Operator's partners in order to fulfill contractual obligations to the User.

4.6.3. In other cases directly provided by the Legislation.

4.7. The Operator has the right to transfer Personal Data and other data to third parties not specified in clause 4.6 of this Policy in the following cases:

4.7.1. The user has expressed his consent to such actions.

4.7.2. The transfer is necessary as part of the use of the Platform and the Site.

4.7.3. The transfer occurs as part of the sale or other transfer of the business (in whole or in part), while all obligations to comply with the terms of this Policy are transferred to the acquirer.

4.8. The Operator also has the right to transfer anonymized statistical information related to Users to its Clients.

4.9. The Operator carries out automated and non-automated Personal Data Processing and other data.

4.10. Access to information systems containing Personal Data is provided by a password system. Passwords are set by authorized employees of the Operator and are individually communicated to employees of the Operator who have access to Personal Data/Data.

4.11. Upon receipt by the Operator of the Personal Data of a request containing the withdrawal of the Subject of Personal Data of consent to the Personal Data Processing, the Operator is obliged to delete the Personal Data within 30 (thirty) calendar days from the date of its receipt. After removing the User's Personal Data from the Operator's Database, the Operator stores them on its electronic media for the period established by the Legislation.

4.12. The Operator is not responsible for the disclosure of the User's Personal Data by other Users of the Platform, Site and Internet users who have gained access to such data. The Operator recommends that Users take a responsible approach to solving the issue of the amount of information about themselves posted on the Platform and on the Site.

4.13. The Platform and the Site use cookie technology - small text files placed on users' computers in order to analyze their user activity. The information collected using cookies cannot identify the User. The Operator will process this information to assess the User's use of the Platform and Site, compile reports on the activities of the Platform and Site. The user can refuse the use of cookies by selecting the appropriate settings in the browser.

5.1. The Platform and the Site use a third-party service, namely Google (google.com) - Google Sheets, located at https://docs.google.com/spreadsheets - a service provided by Google LLC or Google Ireland Limited, depending on the location from which this service is accessed. Using Google services, the User can transfer his Personal and other data to Google. Place of processing: USA - Privacy Policy; Ireland - Privacy Policy.

5.2. To work with Personal and other data in Google Sheets, the User logs into his personal Google account. Authorization is done using the OAuth tools of the Google API Console https://console.developers.google.com/.

5.3. Personal and other data of the User, to which the Platform and the Site gains access when the Platform and the Site do, not store logging into the Google account.

5.4. The Platform and the Site have access only to the Google Sheets documents created by it, and does not have access to personal documents, Personal and other data of the User.

6.1. The user can at any time change (update, supplement) Personal Data, information about himself, provided that such changes and corrections contain up-to-date and reliable information, by sending a written application to the Operator or by making changes in his Personal Account on the Site.

6.2. The User has the right to delete Personal Data/Data at any time.

7.1. The Operator ensures the confidentiality of the Personal Data/Data processed by him in the manner prescribed by the Law. Confidentiality is not required for:

7.1.1. Personal Data after their anonymization.

7.1.2. Personal Data, access of an unlimited number of persons to which is provided by the User or at his request (hereinafter - Personal Data made publicly available by the User).

7.1.3. Personal Data subject to publication or mandatory disclosure in accordance with the Legislation.

7.1.4. It is not a violation of the confidentiality of Personal Data that the Operator provides information to third parties acting on the basis of an agreement with the Operator to fulfill obligations to the User.

8.1. The User decides to provide his Personal Data to the Operator and agrees to their processing freely, of his own free will and in his interest. Consent to the processing of Personal Data must be specific, informed and conscientious and is provided by the User through the acceptance of an electronic form on the Site.

8.2. The Personal Data of persons who entered into contractual obligations with the Operator, contained in the unified state registers of legal entities and individual entrepreneurs, are open and publicly available, with the exception of information about the number, date of issue and the authority that issued the identity document of the individual. Protection of their confidentiality and the consent of Users for processing is not required.

8.3. In case of receiving requests from organizations that do not have the appropriate authority, the Operator is obliged to obtain the prior consent of the User to provide his Personal Data and warn the persons receiving Personal Data that these data can be used only for the purposes for which they are communicated, and also require these persons to confirm that this rule will (have been) observed.

9.1. The User has the right to receive information regarding the processing of his Personal Data/Data. The User has the right to demand that the Operator clarify his Personal Data, block or destroy them if the Personal Data is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing, as well as take measures provided for by law to protect their rights.

9.2. If the User believes that the Operator is processing his Personal Data in violation of the requirements of the Legislation or otherwise violates his rights and freedoms, the User has the right to appeal against the actions or inaction of the Operator in the authorized body for the protection of the rights of Personal Data Subjects or in court.

9.3. The user has the right to protect his rights and legal interests, including compensation for damages and (or) compensation for moral damage in court.

10.1. Using the Platform, the User has the right to enter the data of third parties to receive mailing of materials of an advertising and informational nature.

10.2. The User undertakes to obtain the prior consent of the Personal Data Subject for their use through the Platform and the Site. The user is solely responsible for the lack of such consent.

10.3. The Operator undertakes to take the necessary measures to ensure the safety of the Personal Data of third parties entered by the User.

11.1. This Policy and the relationship between the User and the Operator arising in connection with the application of the Policy is subject to the law of the Russian Federation.

11.2. All possible disputes are subject to resolution in accordance with the Legislation at the place of registration of the Operator. Before going to court, the User must comply with the mandatory pre-trial procedure and send the Operator a corresponding claim in writing. The deadline for responding to a claim is 30 (thirty) business days.

11.3. If, for one reason or another, one or more provisions of the Policy are found invalid or unenforceable, this does not affect the validity or applicability of the remaining provisions of the Policy.

11.4. The Operator has the right at any time to change this Policy (in whole or in part) unilaterally without prior agreement with the User. All changes take effect the next day after posting on the Operator's Site, available at scallium.pro.

11.5. The user undertakes to independently monitor changes to the Policy and by familiarizing himself with the current version.

The full and abbreviated name, including company name: Limited Liability Company «HUBBER», LLC «HUBBER».

Location address: 115419, Moscow, Shabolovka street, 34, 2nd floor, room 1, room 22b.

Information about the representative of the legal entity: General Director Kishkurno Iraida Lvovna.

Contact phone and fax numbers: 89208111152.

OGRN 1197746051029

TIN/KPP 9725001865/772501001

Current account 40702810900000006566 in the bank of JSC CB «IS Bank» BIK 044525349 cash register 30101810945250000349