Privacy notice

Thank you for choosing to be part of our community at BALAYAN | GROUP ("Company", "we", "us", "our"). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about this privacy notice, or our practices with regards to your personal information, please contact us at info@balayangroup.com.

When you use any of our services (the "Services"), we appreciate that you are trusting us with your personal information. We take your privacy very seriously. In this privacy notice, we seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this privacy notice that you do not agree with, please discontinue use of our Services immediately.

This privacy notice applies to all information collected through our Services as well as, any related services, sales, marketing, or events.

Please read this privacy notice carefully as it will help you understand what we do with the information that we collect.

To provide you with access to the Services, your personal information is collected and used by Limited Liability Company BALAYAN GROUP, a company incorporated under Russian law, with primary state registration number 1217700098780 and registered at the address: 26 Tverskoy Boulevard, 1st floor, premises N I, room N 3б, 125009 Moscow, the Russian Federation.

1. What information do we collect?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register or express an interest in obtaining information about us or our products and Services, when you participate in activities on the website or when you contact us.

The personal information that we collect depends on the context of your interactions with us and the choices you make and the products and features you use. The personal information we collect may include the following:

• Basic personal details such as your name and job title;
• Contact data such as your telephone number and postal or email address;
• Demographic data such as your address, preferences or interests;
• Website usage and other technical data such as details of your visits to our websites or information collected through cookies and other tracking technologies;
• Personal data provided to us by or on behalf of our clients or generated by us in the course of providing our services, which may, where relevant, include special categories of personal data;
• Identification and other background verification data such as a copy of passports or evidence of beneficial ownership or the source of funds to comply with client due diligence/”know your client”/anti-money laundering laws and collected as part of our client acceptance and ongoing monitoring procedures;
• Recruitment related data such as your curriculum vitae, your education and employment history, details of professional memberships and other information relevant to potential recruitment to BALAYAN | GROUP;
• Data that you may provide to us in course of registering for and attending events or meetings, including access and dietary requirements; and
• Any other personal data relating to you that you may provide.

All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our website.

We automatically collect certain information when you visit, use or navigate the website.

This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our website and other technical information. This information is primarily needed to maintain the security and operation of our website, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies.

2. Will your information be shared with anyone?

In Short: We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations.

We may process or share your data that we hold based on the following legal basis:

• Contract performance: where your information is necessary to enter into or perform our contract with you.
• Legal obligation: where we need to use your information to comply with our legal obligations.
• Legitimate interests: where we use your information to achieve a legitimate interest and our reasons for using it outweigh any prejudice to your data protection rights, if applicable.
• Legal claims: where your information is necessary for us to defend, prosecute or make a claim against you, us or a third party.
• Consent: where you have consented to our use of your information (you will have been presented with a consent form or facility in relation to any such use and may withdraw your consent if you desire).

More specifically, we may need to process your data or share your personal information in the following situations:

Business Transfers.

We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

Affiliates.

We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy notice. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.

Business Partners.

We may share your information with our business partners, including our professional advisors, bankers and auditors, our insurers and insurance brokers, other third party service providers or experts engaged in the course of the services we provide to our clients to offer you certain products, services, or promotions.

Regulators.

We may also process and share your personal data to comply with our regulatory requirements or in the course of dialogue with our regulators as applicable, which may include disclosing your personal data to government, regulatory or law enforcement agencies in connection with enquiries, proceedings or investigations by such parties where compelled to do so. Where permitted, or unless to do so would prejudice the prevention or detection of a crime, we will direct any such request to you or notify you before responding.

Other Users.

When you share personal information or otherwise interact with public areas of our website, such personal information may be viewed by all users and may be publicly made available outside our website in perpetuity.

3. Do we use cookies and other tracking technologies?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Policy.

4. Is your information transferred internationally?

In Short: We may transfer, store, and process your information in countries other than your own.

Our servers are located in the Russian Federation. We record, systematize, accumulate, store, and extract information using databases located on the territory of the Russian Federation. If you are accessing our website from outside the Russian Federation, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information (see "2. WILL YOUR INFORMATION BE SHARED WITH ANYONE? "above).

Russia is a jurisdiction outside the European Economic Area, which has not been recognized by the European Commission as providing an adequate level of personal data protection. We will however take all necessary measures to protect your personal information in accordance with this privacy notice and applicable law.

If you are located in a jurisdiction where transfer of your information to another jurisdiction requires your consent, then by using the Services you provide BALAYAN | GROUP with your express and unambiguous consent to such transfer, storage, and/or processing of the information in other jurisdictions, including the Russian Federation.

5. How long do we keep your information?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements).

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

6. Do we collect information from minors?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly solicit data from or market to children under 18 years of age. By using our website, you represent that you are at least 18 years old. If we learn that personal information from users less than 18 years of age has been collected, we will [deactivate the account and ]take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at info@balayangroup.com.

7. What are your privacy rights?

In Short: You may review, change [or terminate your account] / [or request erasure of your information at any time.

[, request a restriction on processing or erasure of your information or certain parts of it, withdraw your consent of processing the information

If it is provided by applicable law, you also have the right to:

• review the information about you that we store;
• request erasure of your information or certain parts of it, and/or withdraw consent to the processing of your information;
• request the restriction of the processing of your information;
• object to the processing of your information if it is provided by applicable law.

We will honour any such requests or objections as required under applicable law. To the extent provided by applicable law, you may be subject to other rights not specifically mentioned in this privacy policy.

In case where you use the Services, the transfer of information is carried out with your consent expressing your free will and your interest, (in particular, on the ground of an agreement with you) and it is not an obligation by law.

If you are not satisfied with how we process your information, please let us know at info@balayangroup.com and we will investigate your concern. If you are not satisfied with our response, you have the right to make a complaint to the competent data protection authority.

Account Information

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with applicable legal requirements.

Opting out of email marketing:

You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list — however, we may still communicate with you, for example to send you service-related emails that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

8. Controls for do-not-track features

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

9. Do we make updates to this notice?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

10. How can you contact us about this notice?

If you have questions or comments about this notice, you may email us at info@balayangroup.com.