By Order of the General Director


No. 5-01/0717 dated July 1, 2017


Confidentiality Policy


Moscow, 2017





1.1. This Confidentiality Policy (hereinafter the confidentiality Policy) is an official document of EMTG LLC (hereinafter the Company) located at the address: 121471, Moscow, Ryabinovaya str., 26, building 1, office В 202, covers all the information published in the Internet at (hereinafter the Site), which the registered and (or) unregistered Site users may receive about the User during the use of the Site, its services, programs and products.

1.2. The aim of the Confidentiality Policy is to ensure protection of information about users, including their personal data, from unauthorized access and disclosure, and also provide information about the procedure of using the data provided by users.

1.3. The relations connected with collection, storage, distribution and protection of information about the Site users, shall be regulated by this Confidentiality Policy, other official documents of the Company and the effective laws of the Russian Federation.

1.4. The current version of the Confidentiality Policy is a public document, and it is accessible to any Internet user by following the link The Company shall have the right to unilaterally make changes in the Confidentiality Policy. When changes are made in the Confidentiality policy or it is adopted in a new version, the Company shall inform the users about it by publishing a relevant document on the Site at permanent address no later than 10 days before relevant changes take effect.

1.5. The use of Site services implies the user’s unconditional agreement with the Confidentiality Policy and the conditions of its personal information processing specified in it. If the user disagrees with these conditions, he/she shall stop using the Site.

1.6. Under the Confidentiality Policy, the User’s personal information shall include:

- The personal information that the User provides about him/her independently at registration (account creation) or in the process of using the Site, including the User’s personal data. The information mandatory for Site services provision is marked in a special way. Other information shall be provided by the User on a voluntary basis, upon his/her discretion;

- The data transferred automatically to Site services in the process of its use with the help of the software installed on the User’s software, including the IP address, cookie data, information about the User’s browser (or other program with the help of which the Site services may be accessed), technical characteristics of equipment and software used by the User, date and time of access to Site services, addresses of requested pages and other similar information;

- Any other information about the User that will be processed in the course of using the Site by the User;

- This Confidentiality Policy is applicable only to the Site. The Company shall not control or be responsible for the resources of third parties that the User may access using the links available on the Site.




2.1. The Company shall collect and store the personal information required to provide the Site services or fulfill agreements and contracts with the User, and also the information which became known in the course of using the Site by the User.

2.2. The Company shall process the User’s personal information for the following purposes:

- Identification of the User registered on the Site.

- Provision of access to customized Site resources to the User.

- Establishing feedback with the User, including sending notifications, requests and other information related to the Site use, services provision, processing and requests and applications from the User.

- Determining the place of the User’s location to ensure safety and prevent fraud.

- Confirm the truth and completeness of the personal data provided by the User.

- Create an account to use the Site services and other aims in the Company’s activity.

- Provision of efficient customer and technical support to the User when the problems arise connected with the Site use.

- Performance of the Customer’s advertising activity and realization of other commercial interests by the Company.




3.1 The Company stores and uses the Users’ personal information in accordance with the regulations of the particular Site services.

3.2 With regard to the User’s personal information, its confidentiality is preserved in the part that the User establishes in Site services settings, except for the cases of voluntary provision of information about himself/herself by the User for public access to an indefinite circle of persons. When separate Site services are used, the user agrees with the fact that a definite part of his/her personal information becomes publicly accessible regardless of privacy settings.

3.3 The company shall have the right to transfer the User’s personal information to third parties in the following cases:

- The User expressed his/her consent to such actions.

- Transfer is necessary to use a certain service by the User or to fulfill a certain contract or agreement with the User.

- Transfer is provided for by Russian or other applicable laws within the procedure established by laws.

- If the Company sells the Site to a third person, the buyer may acquire all obligations related to compliance with the conditions of the Confidentiality Policy with regard to the personal information received by it, without receiving the User’s consent to it.

3.4 The User’s personal data is processed without limitation of term in any lawful way, including in information systems of personal data, using means of automation or without the same. The Users’ personal data shall be processed in accordance with the Federal Law dated 27.07.2006 No. 152-FZ “On personal data".

3.5 In case of loss or undisclosed personal data disclosure by the user, the Company shall inform the User about the incident.

3.6 The Company takes the necessary organizational and technical measures to protect the User’s personal information from illegal or accidental access, destruction, change, blocking, copying, distribution, and also other illegal actions of third parties.

3.7 The Company, jointly with the User, takes all the necessary measures to prevent losses or other negative consequences caused by loss or disclosure of the User’s personal data.




4.1 The User shall:

- Provide true information about the personal data required for the Site use.

- Update and supplement the provided information about the personal data if such information changes.

- Not provide the information about the personal data of third persons to the Company if it has no due powers, and also if the User has insufficient powers.

4.2 The Company shall:

- Use the received information only for the purposes specified in this Confidentiality Policy.

- Ensure that the confidential information is kept secret, not disclose it without the User’s preliminary written consent, and also not sell, exchange, publish or disclose it in the ways not specified in this Confidentiality Policy.

- Take measures to protect confidentiality of the user’s data in accordance with the procedure typically used to protect such kind of information in the existing business practices.

- Block the personal data related to the relevant User from the date of address or request of the User or his/her authorized representative or authorized body that protects the rights of personal data subjects for the period of checking in case of finding wrong personal data or unlawful actions.




5.1 The Company that did not perform its obligations shall be responsible for the losses incurred by the User in connection with unlawful use of personal data, in accordance with the laws of the Russian Federation.

5.2 In case of loss or disclosure of the confidential information, the Company shall not be liable if such confidential information:

- Was made public before its loss or disclosure.

- Had been received from a third party before it was received by the Company.

- Was disclosed upon the User’s consent.




6.1. Before filing a lawsuit to court with regard to the disputes that arise out of relations between the Site User and the Company, it is mandatory to submit a claim (a written proposal of voluntary dispute settlement).

6.2. The term of claim consideration is 10 (ten) calendar days from the date of its receipt. If the claims are not satisfied in full within the specified term, the Party whose right has been violated shall have the right to file a lawsuit.

6.3. If the agreement is not achieved, the dispute is subject to transfer for consideration to Moscow Court of Arbitration.

6.4. The Confidentiality Policy and relations between the User and the Company are subject to the applicable laws of the Russian Federation.




7.1 The Company shall have the right to make changes in this Confidentiality Policy without the User’s consent.

7.2 The new Confidentiality Policy shall take effect from the date of its publication on the Site unless otherwise provided for in the new version of the Confidentiality Policy.

7.3 Any proposals or questions with regard to this Confidentiality policy shall be communicated to