This Policy is an integral part of the User Agreement (hereinafter referred to as the “Agreement”) posted and/or available on S&C_Pub. Thus, by entering into the Agreement and the said agreements in the manner set forth therein, including the use of the Application, you accept the terms and conditions of this Policy in full.

Methods of Personal Information processing include any actions (operations) or combination of actions (operations), including collection, recording, systematization, storage, clarification (update, change), extraction, use, transfer (provision, access), depersonalization, blocking, deletion, destruction for the purposes set forth in this Policy with or without the use of automation tools at the discretion of S&C_Pub.

Hereinafter, the Policy uses the terms and definitions provided for in the Agreement, as well as other contracts concluded with the User, unless otherwise provided for in this Policy or arising from its substance. In other cases, the interpretation of the term used in the Policy shall be made in accordance with applicable law, business customs, or scientific doctrine.

Personal information

Personal Information in this Policy means:

• Information that the User provides about himself/herself during registration or authorization, as well as in the process of further use of the Application and/or Service, including the User’s personal data;
• Data that is transmitted automatically depending on the User’s software settings in an anonymized form;
• S&C_Pub has the right to set requirements for the composition of the User’s Personal Information, which must necessarily be provided in order to use the Application and the Service based on it. If certain information is not marked by S&C_Pub as mandatory, its provision or disclosure shall be at the discretion of the User;
• When registering, the User is obliged to provide an account name (login), e-mail address and password.

The composition and terms of collection of anonymized data using third party software are determined directly by their right holders and may include:

• browser data (type, version, cookie);
• operating system data (type, version, screen resolution);
• request data (time, source of transition, IP address);
• other anonymized data about the User’s activities in the Application.

S&C_Pub is not responsible for the manner in which the User’s Personal Information is used by third parties with whom the User interacts in the context of using the Application and/or the Service.

Legal grounds for the processing of personal information

The legal grounds on which S&C_Pub uses Personal Information include:

• Processing of Personal Information when the User has provided consent for processing for one or more specific purposes;
• Processing of Personal Information when it is necessary for the performance of a contract to which the User is a party;
• Processing of Personal Information when it is necessary for the conclusion of a contract with the User;
• Processing of Personal Information that is necessary for S&C_Pub to fulfill its obligations under applicable law.

Policy on children

S&C_Pub does not knowingly collect Personal Information from children under the age of 18, does not request it and does not authorize them to use the Application. Individuals under the age of 18 are not permitted to provide personal information, including name, address, phone number and email address. If S&C_Pub becomes aware that information has been obtained from a child under the age of 18, S&C_Pub will promptly delete such information. If you believe that we may have received any information from or about a child under the age of 18, please contact us at s&[email protected].

Purposes of processing personal information

S&C_Pub processes, including the collection and storage of Personal Information that is necessary for the conclusion and execution of contracts with the User, as well as made publicly available by the User by filling in the profile and setting the settings in myAlpari.

S&C_Pub may use Personal Information for the following purposes:

• Conclusion of contracts for the use of the Application and the Service;
• Conclusion of the Agreement is carried out remotely through the exchange of electronic documents, which are signed with a simple electronic signature. In this case, the role of the User’s simple electronic signature key can be played by a pair of login-password or his e-mail address. Therefore, they are requested during registration;
• Fulfillment of obligations under the concluded contracts, including providing the User with access to the Application and the Service;
• Applications for granting access to the Service are accepted using the software tools of the Application and e-mail. As part of the implementation of the functional capabilities of the Service, the Licensor stores, systematizes and displays User profiles containing Personal Information in the Application;
• Identification of the User within the framework of fulfillment of obligations under the contracts concluded with the User;
• The User’s personal profile is linked to the User’s login-password and e-mail address;
• Provision of technical support in connection with the use of the Application and the Service;
• Appeals to the support service are accepted using the Application’s software tools and e-mail;
• Provision of communication with the User for the purpose of information service and improvement of the Service quality under the concluded Agreements, including by notification with the involvement of third parties;
• Communication with the User is carried out via e-mail or via the subscriber phone number specified by the User during registration or while using the Application and/or the Service.

User’s rights with regard to personal information

If provided for by applicable law, the User has the right to:

• To receive information about the collection and use of his/her personal data;
• Access and correct his/her personal data if it is incorrect or incomplete;
• Prohibit the processing of his/her personal data if their accuracy is disputed, if they are processed unlawfully, or if S&C_Pub no longer requires the personal data for the purposes for which they were processed by S&C_Pub;
• Object to the processing of his/her personal data, as well as to the prohibition of their processing in cases where S&C_Pub has processed them in the performance of tasks in the public interest or in its own legitimate interest and there is no compelling need to continue such processing;
• Revoke at any time the consent that the User has given to the processing of their personal data. If the User withdraws his/her consent to the processing of personal data, such withdrawal will not affect the lawfulness of the processing that S&C_Pub carried out on the basis of such consent prior to its withdrawal;
• To request the deletion of his/her personal data when: they are no longer relevant for the purposes for which they were collected or processed; when consent has been withdrawn and S&C_Pub has no grounds to continue processing; when there is an objection to further processing in the public interest or in S&C_Pub’s own legitimate interests and there is no compelling need to continue such processing;
• Not be subject to a decision based solely on automated processing, including profiling, which creates legally significant consequences for the User or affects them in other similar ways, unless there is a legal basis for continuing the processing;
• Receive Personal Data in a structured, commonly used, and machine-readable form to enable data portability, in cases where S&C_Pub processes the Personal Data provided by automated means.

Storage of personal information

All Personal Information collected is retained only for the period necessary to fulfill the purposes for which such information was collected or for the period permitted or required under the provisions of applicable law. Periodically, S&C_Pub reviews its data processing systems to determine whether the purposes for which it collects and processes users’ personal data remain valid. Such determination is based on a number of factors, which include, but are not limited to: whether the User has maintained a relationship with S&C_Pub, whether S&C_Pub has complied with the User’s requests (including any additional tasks), whether a contractual relationship exists between the User and S&C_Pub, and whether there is a contractual or legal basis for continuing to store the User’s personal data. Based on the results of such verification and notifications received from Personal Data Subjects, S&C_Pub updates its systems.

Requirements for protection of personal information

S&C_Pub stores Personal Information and protects it from unauthorized access and dissemination in accordance with internal rules and regulations.

The User’s Personal Information shall be kept confidential, except for information disclosed by the User to an unlimited number of persons, and other cases when the technology of the Application or the Service provided on its basis or the settings of the software used by the User provide for an open exchange of information with other Users of the Application or with any users of the Internet.

Transfer of personal information

S&C_Pub may transfer Personal Information to third parties in the following cases:

• The User has expressed his/her consent to such actions, including cases when the User has applied the settings of the software used by the User that do not limit the provision of certain information;
• The transfer is necessary within the framework of the User’s use of the functionality of the Application and/or the specifics of the Service based on it;
• In connection with the transfer of the Application into the possession, use or ownership of such third party, including assignment of rights under contracts concluded with the User in favor of such third party;
• At the request of a court or other authorized state body within the procedure established by law;
• To protect the rights and legitimate interests of S&C_Pub in connection with the breach of contracts concluded with the User.

Changing the privacy policy

This Policy may be changed or terminated by S&C_Pub unilaterally without prior notice to the User. The new version of the Policy comes into force from the moment it is posted on the S&C_Pub Website, unless otherwise provided by the new version of the Policy.