Personal Data Processing Policy

Introduction

The company LLC "TEGRO" OGRN 1217700576345 TIN 7730271359 considers compliance and protection of interests to be the main principle of its work their clients. This principle is also reflected in the collection, storage, processing and transfer of any information related to directly or indirectly defined, or determined to an individual (subject of personal data) (hereinafter referred to as "Personal Data").

Our task is to respect the interests of our Customers and ensure safety when working with Personal data. It is for these purposes that we have prepared our Privacy Policy (hereinafter referred to as the "Policy") in strict accordance with the principle of confidentiality protection Personal data.

The purpose of this Policy is to provide you with a complete and transparent understanding of: the legal basis for the collection and processing of your Personal Data; categories of Personal Data, which we may collect about you; what happens to the Personal Data we collect; where we process your Personal Data; how much we store your Personal Data; to whom we may share your Personal Data; and explain your rights as a subject Personal data.

"You, the Customer" in this Policy means a person who gets access to the Tegro.Money Service on the Tegro.money website (hereinafter referred to as the "Site"), contacts us with a request for use The Tegro.Money service or on the issues of the Client's Personal Account.

This Policy applies only to the information we process. This is not refers to companies that we do not own or control, or employees that we not controlled. Information about our Tegro.Money Service may contain links to third-party websites, and any information you provide to these sites will be covered by any policies the privacy they may have. Be sure to read the policy privacy of any third-party sites that you visit. These sites are required to protect any information that you provide to them, therefore we cannot be held responsible for the misuse of your personal information.

Please read this document carefully to understand our Policies and Practices regarding Your information and how we will treat it. By accessing the Tegro.Money Service and using its, you agree to the collection, use and transfer of your information in accordance with this Policy.

This Policy is an integral part of the Public Offer to conclude an Agreement on using the Tegro.Money Service, hereinafter referred to as the "Agreement".

2. Who are we

Tegro.Money - Registration address of the company, 121087, Moscow, Bolshaya Filevskaya str., 3, bldg. 1, pom. 66

The Personal Data processing rules set out in this Policy explain our approach to processing and protection of Personal Data when interacting with our Website or the Tegro.Money Service. In our approach, we comply with the norms "On the protection of personal Data" (hereinafter the Act "On the Protection of Personal Data"), as well as Regulation No. 2016/679 The European Parliament and the Council, General Data Protection Rules (hereinafter "GDPR").

3. What personal data do we collect and why

In the context of the Act "On the Protection of Personal Data and GDPR, we have the right to process the following categories of Personal data of Clients:

• First name, last name - to identify you as a specific Client for the conclusion Agreements with By you;

• Password - to protect your Personal account of the Client;

• Date of birth is our legal obligation, we do not provide our Service Tegro.Money persons who have not reached the age of full legal capacity;

• Permanent residence or other residence is our legal obligation, to make sure that you can use our Tegro.Money Service;

• Phone number - to inform you, including about Service updates Tegro.Money;

• Email address - for communication with you. For example, we can send notifications about suspicious attempts to log into your Personal Account from new devices and changes in Tegro.Money;

• Tothe receipt of personal identity documents is our legal obligation in accordance with the Anti-Money Laundering Act;

• Copies of documents confirming residence are our legal obligation in accordance with the Anti-Money Laundering Act;

• Information coming from questionnaires Tegro.Money or similar forms - to to provide you with the most convenient use of the Tegro.Money Service.

If the Client is an entrepreneur or a person engaged in professional activity:

• Name of the entrepreneur;

• Place of business;

• Tax identification/Registration number;

• Bank Account Details;

• Information coming from Tegro.Money questionnaires or similar forms.

Tegro.Money receives and stores certain information, for example, using cookies every time a Customer or Visitor visits the Tegro.Money Service. We also receive certain information, when your web browser gets access to Tegro.Money services or advertising materials and others materials provided either on behalf of Tegro.Money on other websites, or by clicking on email messages, including:

• Technical information, including the Internet Protocol (IP) address used for connections computer or device connected to the Internet, login information, type and version browser, time zone settings, browser plug-ins types and versions , operating system plat format systems, desktop resolution, browser language;

• Information about your visit or opening of the email, including the full list clicks on the website, through our Website (including date and time) for the purpose of fulfilling legal obligations, binding on the data operator in accordance with Section 9 of the Act on Counteraction laundering;

• Page response time, loading errors, duration of visits to certain pages, information about the relationship of pages (for example, scrolling, mouse clicks and hovers) and methods, used to navigate from the Site page.

We collect the above Personal Data in order to fulfill the Agreement with You in in accordance with Article 6 (1) (b) of the GDPR and in order to fulfill our legal obligations according to Article 6 (1) (c) of the GDPR, in particular to fulfill our legal obligations in accordance with with the Act "On Countering Money Laundering".

Our legitimate interest is to offer you our products and services and notify you of any benefits and news related to the Service provided Tegro.Money. We will inform you about this using the Client's Personal Account and/or contact you by by e-mail, in the text of the letter, you can unsubscribe from the mailing list at any time.

You hereby confirm that any Personal Data you provide is true, accurate and relate exclusively to you or that you have provided only such data, the use of which does not violate the rights of third parties or parties. You should always notify us about any changes to your Personal Data in order to process only complete and up-to-date data regardless of whether such an update is requested or not required.

4. Legal grounds for processing your information

We process your Personal Data legally. Therefore, we process your Personal data only if:

• You have given consent to the processing of your Personal Data in one way or another, provided for in the Policy and/or Agreement; or

• the processing of your Personal Data is necessary for the execution of the Agreement; or

• the processing of your data must be carried out by us in accordance with the requirements applicable legislation, court decision or other competent state or municipal the authority.

5. Transfer of data to third parties

Tegro.Money protects your Personal Data and provides it to third parties only in the following cases, defined by this Policy:

• with your consent or instructions;

• when it is required to follow your instructions;

• in accordance with the requirements of the legislation;

• to enforce the conditions Agreements either to protect the rights, property and safety of Tegro.Money, Customers or the public.

6. Disclosure of information

We do not disclose information that can personally identify you to any person other than cases described in this Policy, including:

• fraud prevention institutions (including fraud in relation to actions, financial fraud and the Financial fraud Bureau);

• third-party financial institutions (if permitted by any terms and conditions or other agreements): including the credit institution where you or your company has your bank account, and card schemes regulating the issuance and use of credit, debit, payment, bank or other payment cards, alternative payment schemes and any other financial institutions that can process payments and that are not under under the control of Tegro.Money or for whose actions or omissions Tegro.Money is not responsible;

• in cases where it is required or permitted by law: in accordance with by law, we may transfer information about you to regulatory authorities and law enforcement agencies for to the whole world, or we may otherwise determine that it is appropriate or necessary to do so. Such disclosures may include requests from government agencies for judicial purposes. process, national security, or in cases where we consider it in the national interests or otherwise legally;

• with your consent: Your information may also be used for other purposes, for to which you provide your specific consent or, when required by law, any the relevant jurisdiction. Except in cases where it is allowed, Tegro.Money does not sells, does not rent, does not provide third parties with information about its Customers, and also does not discloses it otherwise for commercial purposes.

7. Transfer of personal data internationally

All categories of Personal Data received from our Customers are stored on servers in the European Economic Area (EEA). Personal data may also be processed employees working within and/or outside the EEA who work for Tegro.Money or one of our Payment Partners. Such employees may, among other things, be engaged in the provision of support services in the field of providing services within the framework of the Tegro.Money Service. We will do everything reasonable measures to ensure the safe handling of your Personal Data in in accordance with this Privacy Policy.

We always comply with the GDPR, as well as the provisions of the Personal Data Protection Act in relation to any such transfer of Personal Data. Please note that in non-EEA countries, the level of data protection may differ from the level of data protection in EEA countries: However, in all cases, our requirements for the storage and use of your personal data will continue to be governed by this Privacy Policy.

Tegro.Money, as part of the provision of the Service, Tegro.Money can also process payments through others Payment Partners. Payment Partners may process and store your Personal Data for Outside the EEA, both we and they must disclose your information to foreign authorities to help them fight crime and terrorism. Please note if these organizations are based outside outside of the EEA, your Personal Data may not be protected in accordance with the same standards.

By using the Tegro.Money Service, you give Tegro.Money informed consent to the use of your Personal Data in the manner described in this Privacy Policy.

8. Security of personal data of clients

We pay great attention to the personal data processing policy of Tegro.Money, which we must support our colleagues, compliance with internal instructions and selection of contract partners, who must always meet the highest standards of protection and will always apply with your data in accordance with these policies. When processing your Personal Data, we we use the most modern technical resources for maximum protection.

We process your Personal Data in such a way as to prevent any unauthorized and/or accidental access to Personal Data, their modification, destruction or loss, unauthorized transfer and unauthorized processing, as well as any other misuse of your Personal Data.

Your Personal Data is processed automatically. All data storage systems are protected in accordance with current standards and are not available in the Tegro.Money Service by themselves. Ordinary the tools are used to protect data from known types of external attacks. We don't use profiling or automated decision-making.

For example, we provide:

• restriction and indication of the composition of Tegro.Money employees who have access to Personal Data data;

• familiarization of Tegro.Money employees with the requirements of applicable legislation and regulatory documents on the processing and protection of Personal data;

• accounting and storage of material media and their use, which excludes theft, substitution, unauthorized copying and destruction of information;

• identification of security threats to the confidentiality of Personal Data during their processing and formation of threat variants;

• development of personal data protection systems based on threat variants;

• checking the readiness and effectiveness of the use of information security tools;

• implementation of a permissive system of access to information resources, software and hardware for information processing and protection;

• registration and accounting of actions of users of Personal data information systems;

• password protection of Clients' access to the Personal data information system;

• implementation of anti-virus control, prevention of introduction into the corporate network;

• detection of intrusions into the Tegro.Money corporate network that violate or create prerequisites violation of the established requirements for ensuring the security of Personal data;

• centralized management of the personal data protection system;

• training of employees using information security tools used in Personal data information systems, rules for working with them;

• monitoring of user actions, conducting proceedings on facts violations of personal data security requirements.

Third parties to whom Personal Data may be transferred to ensure the functioning of Tegro.Money, may be located in other countries where laws on the processing of Personal Data they may be less stringent than in your country. From time to time, Personal Data may also stored in other places, and in such cases we guarantee that the Personal Data will be stored and handled with the proper level of protection and security.

9. Refusal to participate

You can contact us to stop sending marketing messages at any time, for To do this, follow the unsubscribe links of any marketing message sent to you or by contacting us at any time.

If you refuse to participate in receiving these marketing messages, it is not will affect the processing of your Personal Data for other non-marketing purposes, such as granting you the right to use the Tegro.Money Service, etc.

10. Use of cookies

We may use cookies for various purposes and thereby improve your work in On the Internet, for example, by remembering your login details or preferences during previous views of Tegro.Money to use them when you return to Tegro.Money in the future.

When you visit the Site, we invite you to familiarize yourself and accept our use of files cookie. By accepting the banner and continuing to use the Site, you agree to be placed in your the browser of cookies in accordance with this Policy.

We use session tracking technologies and continuous tracking technologies.

We use the following cookies:

1. Strictly necessary cookies. They are used to make the site work correctly, they allow you to move around our site and use its features. These cookies cannot be disabled. These cookies do not identify you as an individual, these are data that are not transmitted to third-party analytics systems.

1. “PHPSESSID”	Session (stored only while the site is open), designed to identify site users by our system.
2.“Tegro.Money_payer”	It is set for a period of 365.25 days (1 year), contains the payer's identifier for identification by our system.
3.”cookie_mode”	The mode for working with cookies selected by the user is saved, it is set for 365 days.

2. Cookies that enhance the functionality of the system. They are used to increase the personalization of the site. These cookies allow us to individually select the content of the site for you, as well as remember your preferences.

1.“Tegro.Money_last_btype”	Session (stored only while the site is open), designed to identify site users by our system.
2.“AWSALB”	Installed by the service “chat.chatra.io ” (tech support chat), set for 7 days. Chat.chatra.io – Data Usage Policy located at https://chatra.io/privacy-policy/
3.“locale”	It is set for a period of 30 days when visiting the site. Stores information about the user's chosen interface language of the site.

3. Marketing cookies. Used to record information about your actions on the Internet in order to reflect the most suitable content for you, and also to provide us and our partners with advertising information according to your interests.

Google Analytics

Cookie	Expiration date
1. “lead”	It is installed only if the client came from advertising platforms to identify him and is stored for 6 weeks;
2. without a name	Installed by the service "facebook pixel code", session (stored only while the site is open).
3. “_fbp”	It is installed by the facebook pixel code service, the validity period is 3 months.
4. “fr”	Installed by the “facebook pixel code" service, the validity period is 3 months.
5. “1P_JAR”	It is set by the “Google Analytics - Global site tag" service, the term actions 1 month.
6. “ANID”	It is set by the “Google Analytics - Global site tag" service, the term actions are 2 years old.
7. “IDE”	It is set by the “Google Analytics - Global site tag" service, the term actions are 2 years old.
8. “NID”	It is set by the “Google Analytics - Global site tag" service, the term the action is 6 months.
9. “_ga”	It is set by the “Google Analytics - Global site tag" service, the term actions are 2 years old.
10. “_gid”	It is set by the “Google Analytics - Global site tag" service, the term actions 1 day.
11.“_gat_gtag_UA_140894402_1”	It is set by the “Google Analytics - Global site tag" service, the term actions 1 hour.
12. “remixlang”	It is installed by the VK.Retargeting service, the validity period is 355 days.
13. “call_s”	Installed by the service “Сalltouch.ru ”, valid for 365 days.
14. “_ct”	Installed by the service “Сalltouch.ru ”, valid for 365 days.
15. “cted”	Installed by the service “Сalltouch.ru ", session (stored only while the site is open).
16. “_ct_ids”	Installed by the service “Сalltouch.ru ", session (stored only while the site is open).
17. “_ct_site_id”	Installed by the service “Сalltouch.ru ", session (stored only while the site is open).
18. “_ct_session_id”	Installed by the service “Сalltouch.ru ", session (stored only while the site is open).

Visitors and Customers can always opt out of cookies if their browser allows it, although this may interfere with their use of the Site.

11. Changes to our Privacy policy

Tegro.Money may periodically make changes to the Policy: in case of significant changes Tegro.Money will publish relevant notifications on the Website, in the Client's Personal Account and others the services or otherwise notify you so that you can familiarize yourself with the changes before, how to continue working with the Tegro.Money Service. If you do not agree with any changes, you you can delete your Personal Account of the Tegro.Money Client. Continuing to work with Tegro.Money after publishing or distributing a notice of changes to the Policy means that you we agree with the changes made.

12. Rights of the personal data subject

As a personal data subject, you have the following rights with respect to your Personal Data data collected by Tegro.Money:

• Access rights: You have the right to know exactly what Personal Data about you you have us there are, namely:

  a) the purpose for which we process your Personal Data;
  b) the amount of your Personal Data;
  c) the period during which we will continue processing your Personal data;
  d) the sources of your Personal Data, if we have not received them from you directly.

In this Policy, we have tried to describe in sufficient detail all the points related to processing Your Personal Data, however, if you have doubts about which ones the data we process in relation to you, please do not hesitate to contact us.

If you would like to receive a copy of your Personal Data, please contact us via Client's personal account.

• Right to correction: If you find that we are processing inaccurate Personal data about you, you have the right to receive from us, without undue delay, the correction of such inaccurate Personal data concerning you. We can also help you fix the data directly in the settings of the Client's Personal Account.

• Right to delete: This means your right in certain circumstances to delete Your Personal Data if available, including, but not limited to, the following reasons:
  
  a) Personal data is no longer required in connection with the purposes for which they were collected or otherwise processed;
  b) You withdraw your consent on the basis of which the processing is performed, and we do not we have no other legal grounds for processing;
  c) You object to processing due to legitimate interests;
  d) Personal data has been illegally processed;
  e) the existence of legal obligations established by law The European Union or its member State.

• The right to restrict processing: You have the right to receive a processing restriction from us, if you believe that your Personal Data has been illegally processed or processed in violation of Your privacy.At your request, we will assess the situation without undue delay, and in any case, within one month, we will either limit processing or refuse to do so, or we will extend the deadline if the exercise of the right turns out to be difficult. In any case, within one one month from the date of receipt of your request, we will inform you about the results of our assessment and the accepted us measures.

• The right to transfer data: If we process your data in accordance with by agreement or with with your consent and by automated means, you have the right to receive Personal data concerning you, in a structured, widely used and machine-readable format, or you have the right to transfer your personal data to another controller of your choice. This the right should not adversely affect the rights and freedoms of other parties.

• Rights related to automated decision-making and profiling: How data subject, you have the right not to be subjected to a decision based solely on automated processing.

• Right to object to data processing: You have the right to object to processing of your personal data, if this data is processed on the basis of our legitimate interests.Unless there are any legal grounds for consideration that prevail over yours interests or rights and freedoms, and there is no need to process data in connection with legal Accordingly, we will stop processing such data without undue delay.

• The right to be notified of any data breach if such a breach may lead to a high risk for your rights and freedoms. If such a situation occurs, we will notify you no later than 72 hours after the incident.

13. Data storage

If we find that there is a risk to the security of your Personal Data, we will we will immediately notify you of this fact.

Tegro.Money stores your data as long as your Personal Account of the Tegro.Money Client is active or as long as it's necessary. Tegro.Money can store certain information even after deleting your Personal the Client's cabinet, if it is necessary to comply with the requirements of the legislation, permits disputes, prevention of fraud or abuse, as well as to ensure the provisions of this Privacy Policy. Tegro.Money may store Personal Data in for a limited period of time in accordance with legal requirements.

We process your Personal Data for the duration of our Agreement and no more 10 years after its termination, to settle any disputes that may arise in relation to the relationship between the Client and Tegro.Money.

14. Contacts

All financial and technical issues are handled by means of circulation via personal account

If something in the text of this Policy remains unclear to you, we will be happy to clarify it provisions.

For questions related to the processing of your data, you can also contact by mail [email protected].