PRIVACY POLICY FOR THE WEBSITE BY TRACE STUDIO LTD
(VERSION No04 DATED BY THE JULY 15TH, 2021)
This Privacy Policy of personal data (hereinafter referred to as the "Policy") applies to any information containing personal data provided by individuals to Trace Studio LLC, OGRN 1165476089085, address of the location 198095, St. Petersburg, Chemical Lane, 1, Lit.BE, pom. 1N, No. 68 (hereinafter referred to as the TRACE STUDIO, when using an Internet resource https://trace-studio.com (hereinafter referred to as the "Website").

Management and administration of Website is carried out by Trace Studio LLC in accordance with the requirements of the legislation of the Russian Federation.

This privacy policy for Website follows generally accepted international industry standards to protect of the personal data. Please note that information that you voluntarily make public, or which you disclose by posting will be publicly available and viewable by others. TRACE STUDIO does not hold any liability for any information that you voluntarily choose to be public through such and/or other explicit actions, nevertheless, TRACE STUDIO are committed to protecting and respecting your privacy. This Policy describes how TRACE STUDIO treat information that you provide or that TRACE STUDIO collects about you.

By "Personal Data", refer to data that relates to you as an identified or identifiable natural person. The term "Personal Data" may include your name, your address, your telephone number, your e-mail address, your age, your gender, your preferences, social network ids for instance. Anonymous information, which we are not able to relate to you, does not qualify as Personal Data.

By accepting this Policy, you expressly agree to the provision, processing, and storage of Personal Data about you, subject to the scope and on terms specified in the Policy. By submitting your Personal Data to us, you consent to their storage, processing, transfer (including cross-border transfer, if required by the Website).

1. DATA CONTROLLER (PERSONAL DATA PROCESSING OPERATOR) AND

CONTACT DETAILS OF THE DATA PROTECTION OFFICER

The operator for the processing of Personal Data in the context of the legislation of the Russian Federation, as well as the Controller in the sense of the General Data Protection Regulation (GDPR) and other data protection or data privacy laws in the Member States of the European Union and other guidelines with a data protection nature regarding Website, is:

TRACE STUDIO LLC

Address: 198095, St. Petersburg, Chemical Lane, 1, Lit.BE, pom. 1N, No. 68

dpo@trace-studio.com


2. FUNDAMENTALS OF THIS POLICY

a. Processing of personal data of users of Website is carried out solely for the purpose of fulfilling the TRACE STUDIO obligations to users of Website.
b. Processing of personal data is a prerequisite for the possibility of providing users with access to Website. When processing personal data, TRACE STUDIO adheres to the principles of the legality and interests of users of Website, as well as fully complies with international standards for the protection of personal data.
с. TRACE STUDIO provides each user of the Website with protection of his personal data in the provision of access to the Website.

3. THE RESTRICTION OF THIS POLICY

This Policy applies only to the Website. TRACE STUDIO does not control and is not responsible for third-party resources to which users of the Website can go to through Website.

4. ENSURING INFORMATION SECURITY

TRACE STUDIO understands the importance privacy Personal Data for users of the Website. TRACE STUDIO maintains reasonable and appropriate security procedures to protect privacy information users of the Website from loss, misuse and unauthorized access, disclosure, alteration, and destruction, taking into due account the risks involved in the processing and the nature of the Personal Data.

5. DATA STORAGE

TRACE STUDIO in the process of processing carries out the storage of some of the Personal Data of users of the Website for as long as users of the Website continue to carry out the use of Website. TRACE STUDIO will delete Personal Data users of the Website s within 30 days after receiving the corresponding request of the user of Website via e-mail specified in Section 1 of this Policy.

6. PROCESSING OF PERSONAL DATA OF PERSONS

UNDER THE AGE OF MAJORITY

Processing of Personal Data of persons under the age of majority (under the age 18 years or the minimum legal age to consent to the collection and processing of Personal Data where this is different under applicable law) is impossible without the consent of a guardian or other legal representative. TRACE STUDIO believes that the Website is used by persons who have reached the age of majority or under the age of majority in the presence of the above consent. If in the process of interaction with the user, the TRACE STUDIO will be revealed the fact of using the Website by a person under the age of majority without the consent of a guardian or other legal representative, the Personal Data of such person will be immediately destroyed by TRACE STUDIO from all databases TRACE STUDIO in full.

7. TARGETED AND PERSONALIZED ADVERTISING
To show you personalized advertisements on the Website as well as in other websites and services (including email) we have a legitimate interest to process necessary data to track the content you access in connection with the Website and your online behavior deliver, target, and improve our advertising and the Website.

You can opt-out of interest-based advertising on mobile applications by checking the privacy settings of your Android or iOS device and selecting:

- "limit ad tracking" - (Apple iOS) or

- "opt-out of interest-based ads" - (Android).


8. PROVIDING INFORMATION TO THIRD PARTIES

TRACE STUDIO has the right to provide the Personal Data of users of the Website to its affiliates, subsidiaries, vendors, or agents working on its behalf for the purposes described in this Policy. Vendors or agents of TRACE STUDIO adhere to data privacy and security requirements and are not allowed to use the Personal Data they receive from TRACE STUDIO for any other purpose.

To facilitate the use of the Website, TRACE STUDIO may transfer Personal Data to suppliers or agents working on TRACE STUDIO's behalf. Such companies are located within the European Economic Area, or such companies fully complies with the requirements of the GDPR. Anonymous information that does not allow TRACE STUDIO to identify users of the Website as individuals may be transferred by TRACE STUDIO to partners that may be in countries that are not members of the European Economic Area. Since the list of TRACE STUDIO's partners can change over time, users of the Website can always request an up-to-date list of partners to which data is provided. Users of the Website may request this information via e-mail specified in Section 1 of this Policy. By giving TRACE STUDIO Personal Data, users of the Website agree to such transfer, storage, or processing. TRACE STUDIO will take all reasonable steps necessary to ensure the security of the Personal Data of users of the Website in accordance with this Policy.



9. THE LIST OF PROCESSED PERSONAL DATA

TRACE STUDIO processes only the information that was received directly from the users of the Website including in accordance with the legislation of the Russian Federation and Article 6 (1) (f) of the GDPR Regulation, as well as any information, which is automatically handled by the technical methods when using Website. TRACE STUDIO collects Personal Data and other information that users of Website voluntarily provide, namely:

- Information provided by users of the Website when request information or support from TRACE STUDIO.

- Information that the users of the Website are placed on various forums and websites concerning the Website.

- Access time on the Website.

- Tracking Data and Cookies (specified in Section 10 of this Policy).

- Information sent through data transfer in Website, including participating in competitions, contests, and tournaments, responding to surveys.

- Information relating profiles to users of the Website on social networking sites for the purpose of ensuring integration with such social networking sites.

- Other information, namely, indirectly received information through users of the Website and resources on the Internet using Website. This information may include, but is not limited to, browser and device information, data collected through automated electronic interactions, application usage data, demographic information, geographic, geo-location information, statistical and aggregated information. Statistical or aggregated information does not directly identify a specific person, but it may be derived from Personal Data. When combining such information with Personal Data, TRACE STUDIO will treat the combined information as Personal Data.



10. TRACKING DATA AND COOKIES

TRACE STUDIO and TRACE STUDIO's partners such as marketing and analytics partners may use Cookies, which are text files placed on the computers of users of the Website to help TRACE STUDIO analyze how users use the Website, and similar technologies (e.g. web beacons, pixels, ad tags, and device identifiers) to recognize the use of the Website, marketing and analytics. The use of Cookies is standard on the internet. Although most web browsers automatically accept cookies, the decision to accept them rests with users of the Website s. Users of the Website may adjust their browser settings to prevent the reception of cookies or to provide notification whenever a cookie is sent to users of the Website.

TRACE STUDIO uses this cookie information for the following purposes:

- To improve the Website content and performance.

- To analyze trends and estimate our audience size and usage pattern.

- To administer the Website.

- To recognize you when you return to our Website.

- To deliver a better and more personalized Website.

Information pertaining to the Website such as the number of users of Website daily is typically referred to as "Tracking Data". This type of indirectly collected information is gathered through various means such as an IP address, which is a number that is automatically assigned to the computers of users of the Website whenever you use the Website.


11. LOCAL LEGISLATION

TRACE STUDIO complies with applicable territorial and international legislation. Please note that our Website are provided "as is" and you should get to know with applicable laws. By continuing your use of the Website, you are warrant that your use of the Website is not contrary to the applicable law.

TRACE STUDIO uses technical means to determine the region where you use the Website (without accuracy, which means that we cannot determine the place of the user and identify him) to determine the applicable legislation. TRACE STUDIO process personal Data of Russian citizens in accordance with applicable Russian laws namely, FEDERAL LAW RUSSIAN FEDERATION ABOUT PERSONAL DATA (ed. Federal Laws of 25.11.2009 N 266-FZ, of 27.12.2009 N 363-FZ, of 28.06.2010 N 123-FZ, of 27.07.2010 N 204-FZ, of 27.07.2010 N 227-FZ, of 29.11.2010 N 313-FZ, of 23.12.2010 N 359-FZ, of 04.06.2011 N 123-FZ, of 25.07.2011 N 261-FZ, of 05.04.2013 N 43-FZ, from 23.07.2013 N 205-FZ, from 21.12.2013 N 363-FZ, from 04.06.2014 N 142-FZ, from 21.07.2014 N 216-FZ, from 21.07.2014 N 242-FZ, from 03.07.2016 N 231-FZ, from 22.02.2017 N 16-FZ, from 01.07.2017 N 148-FZ, from 29.07.2017 N 223-FZ, from 31.12.2017 N 498-FZ, from 27.12.2019 N 480-FZ, from 24.04.2020 N 123-FZ, from 08.12.2020 N 429-FZ, from 30.12.2020 N 515-FZ, from 30.12.2020 N 519-FZ).

Please pay your attention to the fact that there are several countries where any use of VPN-services and similar software products to disguise your region of residence, is not allowed. TRACE STUDIO INFORM YOU THAT BEFORE USING THE WEBSITE, IT IS IN YOUR INTERESTS TO READ YOUR LOCAL PERSONAL DATA LAWS.


12. FINAL PROVISIONS

TRACE STUDIO reserves the right to modify this Policy at any time, so please review it on a periodic basis.

This Policy is made in English language. TRACE STUDIO may provide you with a translation in other languages. In case of any inconsistency or discrepancies between a non-English translation of this Policy and the English version, the English version shall prevail.

FAITHFULLY YOURS

TRACE STUDIO LTD