1. Applicability

1.1 This Privacy Policy applies to all Websites, Mobile Applications, and other electronic means of service (“Platform”) owned and operated by RADVARK DEVELOPMENT OÜ (“PROM”).

1.2 RADVARK DEVELOPMENT OÜ is a limited liability company incorporated under the laws of the Republic of Estonia with the registration number 16589265. The legal address (“Registered Office”) of PROM is Maakri tn 30, Tallinn, 10145, Estonia.

2. Scope of Policy

2.1 The provisions herein constitute the regulatory framework of the collection, usage, control, and retention of personal information about users (“You”) of the Platform.

2.2 This Privacy Policy does neither apply to data collected by any other means than accessing and using the Platform nor to data collected by third parties. The use of collected information shall be limited exclusively to the purposes defined under this Privacy Policy.

2.3 This Privacy Policy supplements other notices and regulations issued by PROM, including its Terms of Service, and is not intended to override them.

Data Protection Officer

PROM has appointed a data protection officer (“DPO”) who is responsible for overseeing questions in relation to this Privacy Policy. If You have any questions about this Privacy Policy, including any requests to exercise, please contact the DPO using the following contact details: Attn. Data Protection Officer, RADVARK DEVELOPMENT OÜ, Maakri tn 30, Tallinn, 10145, Estonia, Email: [email protected]

4. User Rights

To review, correct, update, or delete inaccuracies regarding the information about You that PROM stores, please contact PROM directly at [email protected]. PROM will address Your request within seventy-two hours. Data protection law gives you a range of rights in connection with the processing of your personal data:

4.1 You have the right to request that PROM rectifies or deletes the personal data or restricts the processing of your personal data if you think they are inaccurate.

4.2 You have the right to object against the processing based on PROM's legitimate interests as a legal basis. PROM is required to assess and act on your request. Additionally, you also have the right to data portability if applicable.

4.3 You have the right to lodge a complaint with your local supervisory authority or the European Data Protection Supervisor (see section 5).

5. Dispute Resolution

In compliance with Regulation 2018/1725 of the European Parliament and of the Council of 23 October 2018 on the protection of natural persons, PROM commits to resolve complaints about Your privacy and the collection or use of Your personal information. Users with questions or concerns about the use of their personal data should contact PROM at: [email protected]. If Your question or concern cannot be satisfied through this process, PROM has further committed to refer unresolved privacy complaints to the European Data Protection Supervisor (“EDPS”), an independent dispute resolution authority in the European Union. If you do not receive timely acknowledgement of your complaint or if your complaint is not satisfactorily addressed by PROM, users should visit https://edps.europa.eu/data-protection/our-rolesupervisor/complaints_en for more information or to file a complaint.

6. Collected Data

6.1 Non-Personally Identifiable Information

PROM collects Non-personally Identifiable Information (“Non-PII”) about users of the Platform. This information may be used for analyzing trends, administering the Platform, saving user settings, authentication, tracking user behavior around the Platform and gathering general demographic information about the userbase. For more general information or instructions on how to opt-out, please contact the Data Protection Officer at [email protected].

6.2 Personally Identifiable Information

Upon registration on the Platform, PROM may, in addition to the information collected about visitors, also collect Personally Identifiable Information (“PII”) about You:

• Identity Data includes first name, last name, username or similar identifier, date and place of birth, citizenship, and gender.
• Verification Data includes proof of identity (passport or national ID), proof of address (utility bill, government issued document or bank statement) and a self-portrait photograph.
• Contact Data includes billing address, email address and telephone number(s).
• Transaction Data includes details about payments to and from You and other details of products and services You have purchased from PROM.
• Technical Data includes internet protocol (IP) address, Your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices You use to access the Platform.
• Profile Data includes Your username and password, purchases or orders made by You, Your interests, preferences, feedback, and survey responses.
• Usage Data includes information about how You use the Platform including any products and services offered by PROM.
• Marketing and Communications Data includes Your preferences in receiving marketing from PROM and their third parties and Your communication preferences.

6.3 Aggregated Data

PROM also collects, uses and shares Aggregated Data such as statistical or demographic data where deemed necessary. Aggregated Data could be derived from Your personal data but is not considered personal data in law as this data will not directly or indirectly reveal Your identity. For example, PROM may aggregate Your Usage Data to calculate the percentage of users accessing a specific website feature. However, if PROM combines or connects Aggregated Data with Your personal data so that it can directly or indirectly identify You, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

6.4 Special Categories of Personal Data

PROM does not collect any Special Categories of Personal Data about You (this includes details about Your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about Your health, and genetic and biometric data, data on criminal convictions and offenses.

6.5 Children's Privacy

PROM does not knowingly collect or solicit personal information from anyone under the age of 13. In the event that PROM gets to know about the collection of personal information from a child under age 13, PROM will delete that information as quickly as possible. If You believe that PROM might have any information from or about a child under 13, please send an email to [email protected].

6.6 Data Accuracy

It is important that the personal data PROM holds about You is accurate and current. Please keep PROM informed if Your personal data changes or if You become aware that any personal data that PROM holds about You is not accurate.

6.7 Failure to Provide Personal Data

Where PROM needs to collect personal data by law, or under the terms of a contract PROM has with You, and You fail to provide that data when requested, PROM may not be able to perform the contract (for example, to provide You with services). In this case, PROM may have to cancel a product or service provided to You. In that event, PROM will notify You at the time.

7. Data Collection Methods

PROM may use each or any of the following methods to collect each or any of the data specified in section 6 from and about You:

7.1 Direct Interactions

You may provide PROM with Your Identity Data, Verification Data, and Contact Data by filling in forms or by corresponding with PROM by post, phone, email, or other means of communication. This includes personal data You provide when You:

• apply for PROM's products or services;
• create an account on the Platform;
• subscribe to any service or publications by PROM;
• request marketing to be sent to You;
• enter a competition, promotion, or survey; or
• give feedback or contact PROM.

7.2 Automated Technologies or Interactions

As You interact with the Platform, PROM will automatically collect Technical Data about Your equipment, browsing actions and patterns. PROM collects this data by using cookies, server logs and other similar technologies. PROM may also receive Technical Data about You if You visit other websites employing cookies by PROM.

7.2.1 The platform uses cookies to distinguish You from other users of the Platform. This helps PROM to provide You with a good experience when You browse the Platform and allows PROM to improve the Platform.

7.2.2 A cookie is a small file of letters and numbers that is stored on Your browser or the hard drive of Your computer if You agree. Cookies contain information that is transferred to Your computer`s hard drive.

7.2.3 You can block cookies by activating the setting on Your browser that allows You to refuse the setting of all or some cookies. However, if You use Your browser settings to block all cookies (including essential cookies) You may not be able to access all or parts of the Platform.

7.2.4 Most of the cookies we use on our website are 'persistent' cookies. This means that they remain on Your device until You erase them, or they expire. The rest of these cookies are 'session' based which are more temporary in duration. This means they will be erased when You close Your internet browser.

7.2.5 PROM uses the following cookies:

• Strictly necessary cookies. These are cookies that are required for the operation of the Platform. They include, for example, cookies that enable You to log into secure areas of the PROM website.
• Analytical or performance cookies. These allow PROM to recognize and count the number of visitors and to see how visitors move around the Platform when they are using it. This helps PROM to improve the way its website works, for example, by ensuring that users are finding what they are looking for easily.
• Functionality cookies. These are used to recognize You when You return to the Platform. This enables PROM to personalize the Platform content for You, greet You by name and remember Your preferences (for example, Your choice of language or region).
• Targeting cookies. These cookies record Your visit to the Platform, the pages You have visited and the links You have followed. PROM will use this information to make its website and the advertising displayed on it more relevant to Your interests. PROM may also share this information with third parties for this purpose.

7.2.6 Below you can find a list of the individual cookies used and the purposes for which PROM uses them:

7.2.7 Third parties (including, for example, advertising networks and providers of external services like user traffic analysis services) may also use cookies, over which PROM has no control. These cookies are likely to be analytical, performance or targeting cookies.

7.2.8 If You are unclear about the types of functions of cookies used on the Platform, please contact PROM at [email protected]

7.3 Third Parties or Publicly Available Sources

PROM may receive personal data about You from various third parties and public sources as set out below:

• Technical Data rom the following parties: analytics providers such as Google based outside the European Union; advertising networks including but not limited to Google, Twitter, Facebook, Linkedin; search information providers such as Google.com and Bing.com.
• Contact Data and Transaction Data from providers of technical, payment and/or delivery services such as SWIFT, SEPA.
• Identity Data, Verification Data and Contact Data from data brokers or aggregators.
• Identity Data and Contact Data from publicly available sources.

8. Use of Collected Data

PROM uses the collected information to operate and maintain the Platform, to interact with its users and to ensure compliance with Know Your Customer (KYC) regulations. The lawful basis for this use of personal data is art. 6(1)(f) of the EU General Data Protection Regulation (GDPR).

Most commonly, PROM will use Your personal data in the following circumstances:

• Where PROM needs to perform the contract that PROM is about to enter into or have entered into with You.
• Where it is necessary for legitimate interests of PROM (or those of a third party) and where Your interests and fundamental rights do not override those interests.
• Where PROM needs to comply with a legal obligation.

Generally, PROM does not rely on consent as a legal basis for processing Your personal data although PROM will get Your consent before sending third party direct marketing communications to You via email or text message. You have the right to withdraw consent to marketing at any time by contacting PROM at [email protected].

8.1 General Purposes of Data Usage

A description of all the ways PROM may use Your personal data including their legal bases is set out below. PROM may process Your personal data for more than one lawful ground depending on the specific purpose which Your data are used for. In case You require further details about the specific lawful basis on which PROM is relying in order to process Your personal data where more than one lawful basis has been set out in the table below, please contact PROM at [email protected].

8.2 Marketing

If you have given your consent, PROM may use the collected information to send you marketing communications, including but not limited to general newsletters and individual service offers. The lawful basis for this use of personal data is art. 6(1)(a) of GDPR. If you no longer wish to receive these Emails, you may opt out of them at any point.

8.3 Promotional Offers

PROM may use Your Identity, Contact, Technical, Usage and Profile Data to form a view on what You may want or need, or what may be of interest to You. This is how PROM decides which products, services, and offers may be relevant for You.

You will receive marketing communications from PROM if You have requested information from PROM or purchased goods or services from PROM and You have not opted out of receiving promotional offers.

8.4 Third-party marketing

PROM will get Your express opt-in consent before sharing Your personal data with any third party for marketing purposes.

8.5 Opting out

You can ask PROM or third parties to stop sending You marketing messages at any time by following the opt-out links on any marketing message or by contacting PROM at any time. Where You opt out of receiving these marketing messages, this will not apply to personal data provided to PROM as a result of a product/service purchase, or other transactions.

8.6 Cookies

You can set Your browser to refuse all or some browser cookies, or to alert You when websites set or access cookies. If You disable or refuse cookies, some parts of this website may become inaccessible or not function properly. For more information about the cookies used by PROM, please see section 7.2 of this policy.

8.7 Change of Purpose

PROM will only use Your personal data for the purposes for which they were collected, unless PROM reasonably considers that there is a need to use it for another reason and that this reason is compatible with the original purpose. If You wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact PROM at [email protected]. If PROM needs to use Your personal data for an unrelated purpose, PROM will notify You and explain the lawful basis which allows PROM to do so.

8.8 Use without Knowledge or Consent

PROM may disclose your information where required to do so by law, if subject to subpoena or other legal proceeding or if PROM reasonably believes that such action is necessary to comply with the law and the reasonable requests of law enforcement, to enforce the Terms of Service or to protect the security or integrity of the Platform and to exercise or protect the rights, property, or personal safety of PROM, its users or others.

9. Disclosures of Your Personal Data

9.1 General Disclosures

PROM may share Personally Identifiable Information about You with the parties set out in this policy for the purposes set out in section 8.1. PROM may also share “non-PII”, including but not limited to general anonymous usage data, referring/exit pages, visited URLs, used platform types and number of clicks with third parties to provide them with data about usage patterns for certain services. Such non-PII may be stored indefinitely.

9.2 Change of Control

PROM may buy or sell/divest/transfer the company (including any shares in the company), or any combination of its products, services, assets and/or businesses. Your information such as usernames and Email addresses, and other user information related to the Platform may be among the items sold or otherwise transferred in these types of transactions. PROM may also sell, assign, or otherwise transfer such information in the course of corporate divestitures, mergers, acquisitions, bankruptcies, dissolutions, reorganizations, liquidations, similar transactions or proceedings involving all or a portion of the company. You will be notified by Email of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

9.3 Third Party Restrictions

PROM requires all third parties to respect the security of Your personal data and to treat it in accordance with the law. PROM does not allow its third-party service providers to use Your personal data for their own purposes and only permit them to process Your personal data for specified purposes and in accordance with the regulations and guidelines set forth by PROM.

10. International Transfer of Data

Your personal data may be stored and processed in Estonia and any other country in which PROM or its subsidiaries, affiliates or service providers maintain facilities. PROM may transfer collected information, including but not limited to Personally Identifiable Information to affiliated entities or to other third parties across borders and in-between countries or jurisdictions worldwide. If Your personal data get transferred outside of Estonia, PROM will make sure that it is protected to the same extent as it is in Estonia. PROM will use one of these legal safeguards:

• Transfer it to a non-Estonian or non-EU country with privacy laws that give the same protection as those in Estonia or the European Union.
• Put in place a contract with the recipient that means they must protect it to the same standards as Estonia or the European Union.
• For transfers of Your personal data to the USA, the “Trans-Atlantic Data Privacy Framework” applies.

11. Data security

PROM ensures highest standards of data protection technologies and methods to be applied at all stages of collecting, processing, and storing your personal data. The Platform is protected by the Secure Sockets Layer (SSL) protocol which encrypts any personal information you enter into registration/login forms before it is sent from your computer to the Platform while all user data are stored on the PROM servers using the latest encryption technologies.

In addition, PROM limits access to Your personal data to those employees, agents, contractors and other third parties necessary. They will only process Your personal data as instructed by PROM and they are subject to a duty of confidentiality.

Notwithstanding the aforesaid PROM cannot ensure or warrant the security of any information you transmit to PROM or guarantee that your information on the Platform may not be accessed, disclosed, altered, or destroyed by breach of any of PROM's industry standard physical, technical, or managerial safeguards.

In the event that personal information is compromised as a breach of security, PROM will promptly notify You in compliance with the applicable law.

If you have any questions about security on the Platform, please contact PROM at [email protected].

12. Data Retention

For the purpose of maintenance and administration of a business relationship with the User, correspondence with the User, assessment of the User's needs, consultation, Prom will store information for the period of our continuing business relationship and later on for 5 years from the date of termination of our business relationship.

This time limit may be additionally extended if a competent authority conducts an investigation and the further data processing is necessary to execute it or if the Platform feels necessary to maintain data longer, especially, due to the nature of its business or business relationship.

In some circumstances You can ask PROM to delete Your data (see section 13).

In some circumstances PROM will anonymize Your personal data (so that it can no longer be associated with You) for research or statistical purposes, in which case PROM may use this information indefinitely without further notice to You.

13. Your Legal Rights about Your Data

13.1 Your Legal Rights

Under certain circumstances, You have rights under data protection laws in relation to Your personal data:

• Request access to Your personal data.
• Request correction of Your personal data.
• Request erasure of Your personal data.
• Object to processing of Your personal data.
• Request restriction of processing Your personal data.
• Request transfer of Your personal data.
• Right to withdraw consent.

13.2 Exercising Your Rights

To exercise any of these rights or if you have any questions about your rights under data protection law, please contact the PROM Data Protection Officer (DPO): Attn. Data Protection Officer, RADVARK DEVELOPMENT OÜ, Maakri tn 30, Tallinn, 10145, Estonia, Email: [email protected].

13.3 Requirements and Limitations

PROM may need to request specific information from You to help confirming Your identity and ensure Your right to access Your personal data (or to exercise any of Your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. PROM may also contact You to ask You for further information in relation to Your request to speed up our response.

You will not have to pay a fee to access Your personal data (or to exercise any of the other rights). However, PROM may charge a reasonable fee if Your request is clearly unfounded, repetitive, or excessive. Alternatively, PROM may refuse to comply with Your request in these circumstances.

13.4 Response Time

PROM will try to respond to all legitimate requests within one month. Occasionally it could take longer than a month if Your request is particularly complex or if You have made a number of requests. In this case, PROM will notify You and keep You updated.

14. Third-party links

The Platform may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about You. PROM has no control over third-party websites and is not responsible for their privacy statements. When You leave the Platform, PROM encourages You to read the Privacy Policy of every website You visit to ensure the safety of Your personal data.

15. Changes to the Privacy Policy

All changes to this Privacy Policy are effective when they are posted on this page. If PROM changes the policy in a material manner, PROM will notify its users via Email and/or a prominent notice on the Platform, prior to the change becoming effective and update the 'effective date' at the bottom of this page.

16. Definitions

16.1 LAWFUL BASIS

Legitimate Interest means the interest of PROM in conducting and managing its business to provide You with the best and the most secure services/products and customer experience. PROM considers and balances any potential impact on You (both positive and negative) and Your rights before processing Your personal data for the legitimate interests of PROM. Your personal data will not be used for activities where the interests of PROM are overridden by the impact on You (unless PROM has Your written consent or is otherwise required or permitted to by law). You can obtain further information about how PROM is assessing its legitimate interests against any potential impact on You in respect of specific activities by contacting PROM at [email protected].

Performance of Contract means processing Your data where it is necessary for the performance of a contract to which You are a party or to take steps at Your request before entering into such a contract.

Compliance with a legal obligation means processing Your personal data where it is necessary for compliance with a legal obligation that PROM is subject to.

16.2 YOUR LEGAL RIGHTS

You have the right to:

Request access to Your personal data (commonly known as a "data subject access request"). This enables You to receive a copy of the personal data PROM holds about You and to check that PROM is lawfully processing it.

Request correction of the personal data that PROM holds about you. That enables You to have any incomplete or inaccurate data corrected, though PROM may need to verify the accuracy of the new data You provide to PROM.

Request erasure of Your personal data. This enables You to ask PROM to delete or remove personal data where there are no grounds for PROM continuing to process it. You also have the right to ask PROM to delete or remove Your personal data where You have successfully exercised Your right to object to processing (see below), where PROM may have processed Your information unlawfully or where PROM is required to erase Your personal data to comply with local legislation. PROM is not obliged to comply with Your request of erasure in case of opposing legal regulations, which will be notified to You, if applicable, at the time of Your request.

Object to processing of Your personal data where PROM is relying on a legitimate interest (or those of a third party) and there is something about Your particular situation which makes You want to object to processing on this basis as You have reasonable grounds to assume it impacts Your fundamental rights and freedoms. You also have the right to object where PROM is processing Your personal data for direct marketing purposes. In some cases, PROM may demonstrate evidence of compelling legitimate grounds to process Your information which override Your rights and freedoms.

Request restriction of processing of Your personal data. This enables You to ask PROM to suspend the processing of Your personal data in the following cases:

• You want PROM to establish the data's accuracy.
• PROM's use of the data is unlawful, but You do not want PROM to erase it.
• You need PROM to hold the data even if PROM no longer requires it as You need it to establish, exercise or defend legal claims.
• You have objected to PROM's use of Your data, but PROM needs to verify whether there are overriding legal grounds to use it.

Request the transfer of Your personal data to You or to a third party. Upon your request, PROM will provide to You, or a third party You have chosen, Your personal data in a structured, commonly used, machine-readable format. This right applies only to automated information which You initially provided consent for PROM to use or where PROM used the information to perform a contract with You.

Withdraw consent at any time where we are relying on consent to process Your personal data. The use of this right will not affect the lawfulness of any processing carried out before the withdrawal of Your consent. If You withdraw Your consent, PROM may not be able to provide certain products or services to You. PROM will advise You if this is the case at the time of Your withdrawal of consent.

RADVARK DEVELOPMENT OÜ

Privacy Policy V1.0

Effective Date: 11th of November 2022