Personal Data Processing Policy

1. General Provisions

This personal data processing policy has been drawn up in accordance with the requirements of the Federal Law of 27.07.2006. No. 152-FZ "On Personal Data" (hereinafter referred to as the Personal Data Law) and defines the procedure for processing personal data and measures to ensure the security of personal data taken by youtikins.com (hereinafter referred to as the Operator).

1.1. The Operator sets as its most important goal and condition for carrying out its activities the observance of the rights and freedoms of a person and citizen when processing his personal data, including the protection of the rights to privacy, personal and family secrets.

1.2. This Operator policy on the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator can receive about visitors to the website https://youtikins.com

2. Basic concepts used in the Policy

2.1. Automated processing of personal data is the processing of personal data using computing technology.

2.2. Blocking of personal data — temporary cessation of processing of personal data (except for cases when processing is necessary to clarify personal data).

2.3. Website — a set of graphic and information materials, as well as computer programs and databases that ensure their availability on the Internet at the network address https://youtikins.com.

2.4. Personal data information system — a set of personal data contained in databases and information technologies and technical means that ensure their processing.

2.5. Depersonalization of personal data — actions as a result of which it is impossible to determine without the use of additional information the ownership of personal data by a specific User or another subject of personal data.

2.6. Personal data processing — any action (operation) or set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.

2.7. Operator — a government agency, municipal agency, legal entity or individual that independently or jointly with other persons organizes and/or carries out the processing of personal data, as well as determines the purposes of processing personal data, the composition of personal data subject to processing, actions (operations) performed with personal data.

2.8. Personal data — any information relating directly or indirectly to a specific or determinable User of the website https://youtikins.com.

2.9. Personal data permitted for distribution by the personal data subject — personal data, access to which by an unlimited number of persons is granted by the personal data subject by giving consent to the processing of personal data permitted by the personal data subject for distribution in the manner prescribed by the Law on Personal Data (hereinafter — personal data permitted for distribution).

2.10. User — any visitor to the website https://youtikins.com.

2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific group of persons.

2.12. Distribution of personal data — any actions aimed at disclosing personal data to an unlimited number of persons (transfer of personal data) or familiarizing an unlimited number of persons with personal data, including disclosure of personal data in the media, posting in information and telecommunication networks or providing access to personal data in any other way.

2.13. Cross-border transfer of personal data — transfer of personal data to the territory of a foreign state to a foreign government body, foreign individual or foreign legal entity.

2.14. Destruction of personal data — any actions as a result of which personal data are destroyed irrevocably with the impossibility of further restoration of the content of personal data in the personal data information system and/or the tangible media of personal data are destroyed.

3. Basic rights and obligations of the Operator

3.1. The Operator has the right:

— to receive reliable information and/or documents containing personal data from the personal data subject;

— in the event of the personal data subject’s withdrawal of consent to the processing of personal data, as well as the sending of an appeal with a request to terminate the processing of personal data, the Operator has the right to continue processing personal data without the consent of the personal data subject if there are grounds specified in the Law on Personal data;

- independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of the obligations stipulated by the Law on Personal Data and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Law on Personal Data or other federal laws.

3.2. The Operator is obliged to:

- provide the personal data subject, at his request, with information regarding the processing of his personal data;

- organize the processing of personal data in the manner established by the current legislation of the Russian Federation;

- respond to requests and inquiries of personal data subjects and their legal representatives in accordance with the requirements of the Law on Personal Data;

- notify the authorized body for the protection of the rights of personal data subjects, at the request of this body, of the necessary information within 10 days from the date of receipt of such request;

- publish or otherwise provide unlimited access to this Policy regarding the processing of personal data;

— take legal, organizational and technical measures to protect personal data from unauthorized or accidental access to them, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other illegal actions in relation to personal data;

— stop the transfer (distribution, provision, access) of personal data, stop processing and destroy personal data in the manner and cases stipulated by the Law on Personal Data;

— fulfill other obligations stipulated by the Law on Personal Data.

4. Basic rights and obligations of personal data subjects

4.1. Personal data subjects have the right:

— to receive information concerning the processing of their personal data, except for cases stipulated by federal laws. Information is provided to the personal data subject by the Operator in an accessible form, and it must not contain personal data related to other personal data subjects, except for cases when there are legal grounds for disclosure of such personal data. The list of information and the procedure for obtaining it are established by the Law on Personal Data;

— to demand that the operator clarify his personal data, block or destroy it if the personal data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated purpose of processing, and to take measures provided by law to protect his rights;

— to put forward a condition of prior consent when processing personal data for the purpose of promoting goods, works and services on the market;

— to revoke consent to the processing of personal data, as well as to send a request to stop the processing of personal data;

— to appeal to the authorized body for the protection of the rights of personal data subjects or in court against the illegal actions or inaction of the Operator when processing his personal data;

— to exercise other rights provided for by the legislation of the Russian Federation.

4.2. Personal data subjects are obliged to:

— provide the Operator with reliable information about themselves;

— notify the Operator about clarification (update, change) of their personal data.

4.3. Persons who have provided the Operator with false information about themselves or information about another personal data subject without the latter's consent shall be liable in accordance with the Russian Federation legislation.

5. Principles of personal data processing

5.1. Personal data shall be processed on a lawful and fair basis.

5.2. Personal data shall be processed limited to achieving specific, predetermined and legitimate purposes. Processing of personal data that is incompatible with the purposes of collecting personal data shall not be permitted.

5.3. Combining databases containing personal data that are processed for purposes incompatible with each other shall not be permitted.

5.4. Only personal data that meet the purposes of their processing shall be processed.

5.5. The content and volume of personal data processed correspond to the stated purposes of processing. Excessive processing of personal data in relation to the stated purposes of their processing shall not be permitted.

5.6. When processing personal data, the accuracy of personal data, their sufficiency, and, where necessary, relevance in relation to the purposes of processing personal data shall be ensured. The operator takes the necessary measures and/or ensures that they are taken to remove or clarify incomplete or inaccurate data.

5.7. Personal data shall be stored in a form that allows the personal data subject to be identified, for no longer than is required for the purposes of personal data processing, unless the storage period for personal data is established by federal law, an agreement to which the personal data subject is a party, beneficiary or guarantor. The personal data being processed shall be destroyed or depersonalized upon achieving the processing purposes or in the event of loss of the need to achieve these purposes, unless otherwise provided by federal law.

6. Purposes of personal data processing

Purpose of processing

Informing the User by sending emails

Personal data

E-mail address

Link to a page on a social network

Legal grounds

Agreements concluded between the operator and the personal data subject

Types of personal data processing

Collection, recording, systematization, accumulation, storage, destruction and depersonalization of personal data

Sending informational letters to an email address

7. Conditions for processing personal data

7.1. Personal data shall be processed with the consent of the personal data subject to the processing of his personal data.

7.2. The processing of personal data is necessary to achieve the goals stipulated by an international treaty of the Russian Federation or by law, to exercise the functions, powers and duties imposed on the operator by the legislation of the Russian Federation.

7.3. The processing of personal data is necessary for the administration of justice, the execution of a judicial act, an act of another body or official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.

7.4. The processing of personal data is necessary for the performance of an agreement to which the personal data subject is a party, beneficiary or guarantor, as well as for concluding an agreement on the initiative of the personal data subject or an agreement under which the personal data subject will be a beneficiary or guarantor.

7.5. The processing of personal data is necessary to exercise the rights and legitimate interests of the operator or third parties or to achieve socially significant goals, provided that the rights and freedoms of the personal data subject are not violated.

7.6. The processing of personal data is carried out, access to which is granted to an unlimited number of persons by the subject of personal data or at his request (hereinafter referred to as publicly available personal data).

7.7. The processing of personal data is subject to publication or mandatory disclosure in accordance with federal law.

8. The procedure for collecting, storing, transferring and other types of processing of personal data

The security of personal data processed by the Operator is ensured by implementing legal, organizational and technical measures necessary to fully comply with the requirements of the current legislation in the field of personal data protection.

8.1. The Operator ensures the safety of personal data and takes all possible measures to prevent unauthorized persons from accessing personal data.

8.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to the implementation of current legislation or if the subject of personal data has given consent to the Operator to transfer data to a third party for the fulfillment of obligations under a civil law contract.

8.3. In case of detection of inaccuracies in personal data, the User can update them independently by sending the Operator a notification to the Operator's e-mail address support@youtikins.com with the subject line "Update of personal data".

8.4. The period for processing personal data is determined by the achievement of the purposes for which the personal data were collected, unless another period is provided for by the agreement or applicable law.

The User can at any time revoke their consent to the processing of personal data by sending the Operator a notification via e-mail to the Operator's e-mail address support@youtikins.com with the subject line "Revocation of consent to the processing of personal data".

8.5. All information collected by third-party services, including payment systems, communication tools and other service providers, is stored and processed by the specified persons (Operators) in accordance with their User Agreement and Privacy Policy. Subject of personal data and/or with the specified documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.

8.6. The prohibitions established by the subject of personal data on the transfer (except for providing access), as well as on the processing or conditions of processing (except for obtaining access) of personal data permitted for distribution, do not apply in cases of processing of personal data

8.7. When processing personal data, the Operator ensures the confidentiality of personal data.

8.8. The Operator stores personal data in a form that allows identifying the subject of personal data for no longer than required for the purposes of processing personal data, unless the storage period of personal data is established by federal law, an agreement to which the subject of personal data is a party, beneficiary or guarantor.

8.9. The condition for termination of personal data processing may be the achievement of the purposes of personal data processing, expiration of the consent of the subject of personal data, withdrawal of consent by the subject of personal data or a requirement to terminate the processing of personal data, as well as the detection of unlawful processing of personal data.

9. List of actions performed by the Operator with the received personal data

9.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), extracts, uses, transfers (distributes, provides, accesses), depersonalizes, blocks, deletes and destroys personal data.

9.2. The operator carries out automated processing of personal data with or without the receipt and/or transmission of the received information via information and telecommunications networks.

10. Cross-border transfer of personal data

10.1. Before starting activities on the cross-border transfer of personal data, the operator is obliged to notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out the cross-border transfer of personal data (such notification is sent separately from the notification of the intention to process personal data).

10.2. Before submitting the above notification, the operator is obliged to obtain relevant information from the authorities of a foreign state, foreign individuals, foreign legal entities to whom the cross-border transfer of personal data is planned.

11. Confidentiality of personal data

The operator and other persons who have received access to personal data are obliged not to disclose to third parties or distribute personal data without the consent of the personal data subject, unless otherwise provided by federal law.

12. Final provisions

12.1. The User can receive any clarifications on issues of interest regarding the processing of his/her personal data by contacting the Operator via e-mail support@youtikins.com.

12.2. This document will reflect any changes to the Operator's personal data processing policy. The Policy is valid indefinitely until it is replaced by a new version.

12.3. The current version of the Policy is freely available on the Internet at https://youtikins.com/en/terms/personal-data.

Privacy Policy This is the Privacy Policy of YOUTIKINS (hereinafter referred to as “Administration”, “we,” “us” or “our”). Our Privacy Policy explains how we collect, use, share and protect information in relation to our Website https://youtikins.com/ (the “Service”). We collect this information when you visit our website with your computer, tablet or mobile phone, as well as during the use of any of our Websites, services, products or services and during the execution by YOUTIKINS of any agreements and agreements with the User. By using the Service, you understand, agree and give your unconditional consent to the collection and use of information in accordance with this Privacy Policy. Our Privacy Policy applies to all visitors, users, and others who access the Service (“Users”). In case of disagreement with our Privacy Policy, the User should refrain from using the Website.

1. Definitions

1.1. Data Controller — the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed. For the purpose of this Privacy Policy, we are a Data Controller of your Personal Data.

1.2. Administration — the entire administrative and technical team of the Service «YOUTIKINS», responsible for its development and maintenance of efficiency. The Administration is in direct contact with the User and undertakes to provide consulting information on issues directly related to the use of the Service.

1.3. Personal Data — Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).

1.4. Usage Data — data collected automatically either generated by the use of the Service or fromthe Service infrastructure itself (for example, the duration of a page visit).

1.5. Processing of Personal Data — any operation (action) or a set of those that the Operator produces with personal data. They can collect, record, systematize, accumulate, store, clarify (if necessary, to update or change), extract, use, transfer (distribution, granting, access access), depersonalize, block, remove, and even destroy. These operations (actions) can be performed both automatically and/or manually.

1.6. Confidentiality of Personal Data — is a mandatory requirement for the Data Controller or any other official working with the User's data to keep the information confidential, without disclosing it to outsiders, if the user who provided the personal data has not expressed his consent, and there is no legal basis for disclosure.

1.7. Website — service "YOUTIKINS" that provides services for online promotion in social networks, as well as SMM, SEO and PR services on the Internet, located on the Internet at https://youtikins.com/.

1.8. User — is any living individual who is using our Website and/or its services and is the subject of Personal Data. The User corresponds to the Data Subject, who is the subject of PersonalData.

1.9. Service — a set of all the Services provided by the Website at https://youtikins.com to the User.

1.10. Services — a set of functions of a technical nature, provided to the User as part of the paid purchase of promotion services and advertising. In particular, the Service solves the problem of attracting subscribers, likes, reposts, comments, etc., to the User accounts in social networks.

1.11. Cookies — a short piece of data sent by a web browser or web client to a web server in an HTTP request, whenever the User tries to open a page of the site. The fragment is stored on the User's computer. "IP address" is a unique network address of a node in a computer network built on TCP/IP Protocol.

2. General Provisions

2.1. This Policy is an integral part of the Public Offer (hereinafter – "the Offer"), posted on the Internet at: https://youtikins.com/en/terms/user-agreement, as well as other contracts concluded with the User, when it is expressly provided for by their terms.

2.2. This Policy is drawn up in accordance with the Federal law "on personal data" № 152-FZ of July 27, 2006, as well as other legal acts of the Russian Federation in the field of protection and processing of personal data and applies to all personal data that the Data Controller canreceive from the User who is a party to a civil contract.

2.3. Administration has the right to make changes to this Policy. When changes are made, the Policy header indicates the date when the revision was last updated. The new version of the Policyshall enter into force upon its posting on the Website at https://youtikins.com/en/terms/privacy, unless otherwise provided by the new version of the Policy.

2.4. This Policy, including the interpretation of its provisions and the procedure for acceptance, execution, modification and termination, shall be subject to the legislation of the Russian Federation.

3. User’s Personal Information that is processed by Data Controller

3.1. The Website does not verify the accuracy of the personal information provided by the User andis not able to assess their legal capacity.

3.2. This Policy applies only to information processed in the course of using the Website. Administration does not control and is not responsible for the processing of information by thirdparty websites to which the User can click on the links available on the Website.

3.3. "Personal information" in this Policy refers to:

• information provided by the User independently during registration (account creation) or during the use of the Website, including personal data of the User. The information required for the Website is marked in a special way. Other information is provided by the User at their discretion;
• data that is automatically transmitted to the Website in the course of the User's use ofthe Website using the software installed on the User's device, including IP address, Cookie data, information about the user's browser (or other program by which the website is accessed), technical specifications of the equipment and software used by the User, date and time of access to the website, addresses of the requested pages and other similar information;
• other User information (including Usage Data), the processing of which is provided by the terms of use of the Website.

4. Means and Purposes for Processing User’s Personal Data

4.1. Data Controller collects and stores only the personal information that is necessary for the provision of services or the execution of agreements and contracts with the User, except incases where the legislation provides for the mandatory storage of personal information for a period specified by law.

4.2. Data Controller processes the User's personal information for the following purposes:

• identification of the parties to the services agreements and contracts with the Website;
• provision of personalized services to the User, as well as execution of agreements and contracts;
• sending notifications, requests and information regarding the use of the Website, execution of agreements and contracts, as well as processing requests andapplications from the User;
• improving the quality of Website usability for the User, development of new services;
• targeting of advertising materials;
• conducting statistical and other research based on depersonalized data.

5. Terms of processing User's Personal information and its transfer to third parties

5.1. With respect to the User's personal information, its confidentiality is maintained, except in cases of voluntary provision by the User of information about himself for general access to anunlimited number of persons.

5.2. Administration has the right to transfer the User's personal information to third parties in the following cases:

• The User agreed to such actions;
• The transfer is necessary for the User to use a certain service or for the execution of a certain agreement or contract with the User;
• The transfer is necessary for the functioning and efficiency of the Website;
• The transfer is provided for by Russian or other applicable law within theprocedure established by the legislation;
• Such transfer takes place within the framework of sale or other transfer of business (in whole or in part), while the purchaser assumes all obligations to comply with the terms of this Policy in relation to the personal information received by them;
• In order to protect the rights and legitimate interests of the Website or third parties in cases where the User violates the Website’s User Agreement, this Privacy Policy, or documents containing the terms of use of specific services.
• As a result of the processing of the User's personal information by depersonalizing it, depersonalized statistical data are obtained, which are transmitted to a third party for research, work or services on behalf of the Website.

6. Change and Deletion of Personal Information. Mandatory Data Storage

6.1. User may at any time change (update, supplement) the personal information provided by them by contacting the Administration at the address support@youtikins.com.

6.2. Rights under paragraph 6.1. of the Privacy Policy may be restricted as required by law. For example, such restrictions may require the Administration to retain the information changed or deleted by the User for a period established by law and to transmit such information in accordance with the procedure established by law to the public authority.

7. Processing of Personal Information using Cookies and Counters

7.1. Cookies transmitted by the Website to User’s equipment and Cookies transmitted by User's equipment to the Website may be used by the Website to provide User with personalized services, to target advertisements that are shown to User for statistical and researchpurposes, as well as to improve the website.

7.2. User is aware that the equipment and software used to visit websites on the Internet may have the function of prohibiting operations with Cookies (for any websites or for certain websites), as well as deleting previously received Cookies.

7.3. The structure of the Cookie, its content and technical parameters are determined by theWebsite and are subject to change without prior notice to the User.

7.4. Counters hosted by the website can be used to analyze the user's Cookies, to collect and process statistical information about the use of the Website, as well as to ensure the health ofthe Website in general or their individual functions in particular. The technical parameters of the counters are determined by the Website and are subject to change without prior notice to the User.

8. Protection of User's Personal Information

8.1. Administration shall take the necessary and sufficient organizational and technical measures to protect User's personal information from unauthorized or accidental access, destruction, modification, blocking, copying, distribution, as well as other illegal actions with it by thirdparties.

9. Changes to the Privacy Policy

9.1. Administration has the right to make changes to this privacy Policy. When making changes in the current version, the date of the last update is indicated. The new version of the Policy shall enter into force upon its posting, unless otherwise provided by the new version of the Policy. The current version is always available on the website under privacy policy.