Privacy Policy

N.B. We understand your legitimate privacy concerns. We want You to know We are committed to safeguarding Your privacy and Your security whenever You navigate through the Internet.

We believe in privacy and online freedom and that it should be very clear how we manage and protect your personal information. If you have any questions or concerns, please contact us.

Because We treat personal information as confidential information, We kindly ask you to familiarize yourself with our Privacy Policy. Read carefully this document and You will understand what limited information is collected when You access, download or install Our Services. As an example We want to underline that We do not collect, log or store any browsing activity, data or IP addresses.

Since We only collect the minimal usage statistics needed to maintain the quality of our service, and do not store Your personal information, We cannot, willingly or unwillingly, share Your information with third-parties or government authorities - because this data does not exist.

Privacy policy Introduction One of the basic principles of RTSMedia OU is security, including the security of any information gathered by RTSMedia OU, therefore we strive by all means to protect You from an unauthorized and undesirable disclosure of any information gathered while carrying out Our activity.

Realizing the responsibility RTSMedia OU strictly follows the thoroughly elaborated Privacy Policy, uses advanced IT-technologies, constantly investing into the development of data security systems and raising the professional profile of our experts.

The main purposes to elaborate and adopt the present Privacy policy are as follows:

to protect any confidential information from an unauthorized access, illegal use or loss; to protect individual’s rights and freedoms while using the confidential information at the RTSMedia OU resources; to protect individual’s rights for privacy, personal and family secret. The policy is elaborated in compliance with international acts based on the “Convention for the Protection of Individuals with regard to Automatic Processing of Personal Data” of the Council of Europe dated 28th January 1981 and the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (The General Data Protection Regulation – GDPR).

I. General Definitions 1. Under the present Policy we deem confidential any information we obtained, that has not been officially disclosed, published and/or revealed, is not publicly available or commonly known, as well as legally or illegally circulated by any third party, and that may represent economical, financial, commercial, legal or any other value by virtue of its being unknown to a third party.

2. RTSMedia OU acting as data controller also deems confidential individual’s Personal Data, provided to us.

'Personal Data' – any information directly or indirectly is related to a natural person. The following information is regarded as “Personal Data”: the first and last names, date of birth, e-mail address, phone number or any other contact information, your photo or video image, payment card data, transaction data, bank statements, payment account data if any, as well as any other information, directly or indirectly related to a natural person.

The personal information we may collect may include, but is not limited to, the following:

E-mail address, and any other personal or preference information that you elect to provide to us. We only use Your email address to alert You to payment transactions, password changes, updates and announcements. Minimal usage statistics to maintain our quality of Service: date and time on which You start and on which end use our Services, the amount of data transmitted during each session of use of the Services, to which location (eg. UK) (We do not hold servers’ IP addresses), and from which country You connected from (We do not hold IP addresses). We guarantee that We will never log Your browsing activity, data or IP addresses including: Any of the websites you visited in the past or plan on visiting in the future, any data You may have downloaded, shared, or viewed, any of your IP address or DNS queries. Information created by Your when using of the Website (the date and time of visits to the Website, the pages viewed, time spent on the Website, and the Internet sites visited just before and just after the Website). If you email or otherwise contact Us, we may keep your message, email address and contact information to respond to your request. Your provision of such information is entirely optional.

'Processing of Confidential information and Personal Data' – any action (operation) or a chain of action (operation), involving the use Confidential information and Personal data, including use by means of electronic facilities, inter alia gathering, recording, systematization, accumulation, storage, specification (updating, modifying), extraction, usage, sharing (circulation, provision, access), depersonalization, blocking, deletion, elimination of Personal data.

'Consent' – a statement of a natural person or their representative, containing consent for the processing of their Confidential information and Personal data, including by means of electronic facilities.

II. Principles of Confidential information and Personal Data Processing 1. RTSMedia OU performs the processing of Confidential information and Personal Data on a lawful and fair basis in accordance with the following principles:

legitimacy of the purposes and ways of Confidential information and Personal Data processing and bona fides; accordance of the purposes of Confidential information and Personal Data processing with the purposes, previously defined and stated for Confidential information and Personal Data gathering; accordance of the volume and type of the processed Confidential information and Personal Data, methods of processing with the purposes of Confidential information and Personal Data processing; accuracy of Confidential information and Personal Data, its sufficiency for the purposes of processing, inadmissibility of the processing of Confidential information and Personal Data, excessive towards the aims, stated for Personal data gathering; inadmissibility of consolidation of Confidential information and Personal Data databases, created for incompatible purposes; minimization of collecting information. III. Purposes of Gathering, Processing and Use of Confidential information and Personal Data 1. The main purposes of gathering, processing and use of Confidential information and Personal Data are as follows:

to fulfill our obligations; to improve the quality of the provided services; to maintain a high level of security; to inform about our advertising and promotional events. IV. Gathering Confidential Information 1. RTSMedia OU gathers information, obtained in the course of your use of Our electronic resources only for the purposes, specified by the present Privacy Policy.

2. We automatically process the information you provide, when you use Our website, Mobile application or when you contact us or our partners via e-mail, by phone or any other means of communication in order to identify Your needs, raise the quality of Our services, timely execute financial transactions, inform Your, as well as for other purposes, related to the functioning of the Website and Mobile application as it stipulated here before.

3. We store Confidential information and Cookies on the different servers so it is totally impossible to cross-reference Confidential information and Cookies in the case of illegal access to one of Our servers.

4. We obtain Personal data only from You or Our partners and providing that our partners got Your personal consent for the processing of Your Personal Data.

5. By securing consent of a natural person, RTSMedia OU reserves the right to obtain Personal data from a third party. In case of absence of such consent, RTSMedia OU may notify the natural person about the necessity of obtaining this information stating purposes, expected sources and ways of obtaining Personal data, as well as the nature of data and the consequences of a refusal to grant consent for obtaining such data.

6. In the event of changes in a Personal Data he/she may notify RTSMedia OU about these changes and provide appropriate documents.

7. RTSMedia OU has the right to gather, store, circulate and use Personal Data, as well as the information about the private life of the individual, provided that this information has already been released to public or disclosed by the individual himself or at his/her own will.

V. Use of Confidential Information 1. We use your personal information to:

Provide you with personalized Services and a personalized experience on our Website, Mobile application; Provide you with timely and reliable services; Research, develop, manage, protect and improve those Services and the Website; Develop and maintain our relationship with you and communicate with you. 2. While processing any Confidential information RTSMedia OU ensures accuracy of the Personal Data, its sufficiency, and whenever necessary its relevance towards the purposes of Personal data processing. RTSMedia OU undertakes all necessary measures, or secures their taking to delete or specify incomplete or inaccurate data.

3. To achieve the purposes stipulated by the present policy, RTSMedia OU reserves the right to share your Personal data with our trusted partners upon your consent only.

4. As we provide a transit service and some fragments of data (no more than 4 kB per type of packets per user session (ICMP, TCP, UDP)) can settle from time to time. Nevertheless, our service is never engaged in decoding and / or recovery of user data in any form and does not conduct analytical or other evaluation of user connections. All data received from an encrypted VPN connection between the user's device and our service is always sent to the destination server without changes (additions, deletions, modifications). Sources and addressees of connections are not logged and the fact of installing a connection cannot be tracked after its completion / discontinuity even with full access to the system.

5. We may use information derived from the aggregation of user data with other data for research and analytics purposes and improvement and marketing (“Aggregated Data”). Aggregated Data shall be anonymous and in no way reveal the identity of the user.

6. With regards to registration information if any, we use such information to authenticate login to the Services, to communicate with user. Additionally, we may use personal data to inform user of any updates to the Services, including new features and functionalities.

VI. Disclosure of Confidential Information 1. Confidential information may be disclosed in compliance with the requirements of the applicable law, as well as in the following cases:

upon a court’s request or any other similar inquiries; for protection of Your rights and/or property; for Your personal security. VIII. Confidential Information Storage 1. RTSMedia OU stores Confidential information in a form that allows to identify a natural person, as long as it is required for the purposes of Confidential information processing (usually not longer than 30 calendar days). The processed Confidential information are subject to deletion or depersonalization upon accomplishing of the purposes or in case accomplishing of the purposes is no longer required.

2. You acknowledge that by accepting the Terms and Conditions, you authorize RTSMedia OU to use and disclose your Confidential information for the purposes, stipulated by the present Privacy Policy.

IX. Consent You are under no obligation to provide us with Personal Information, but Your refusal to do so may prevent You from using the Website and Mobile application.

1. By a continued use of the Website or Mobile Application, you confirm that you fully understand the content of the Privacy Policy and that you personally, freely, knowingly, willfully and for your own benefit provide us with the consent for gathering, using, storing, processing of your Confidential information, including by means of electronic facilities as it is stipulated by the Privacy Policy.

2. You may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. If you wish to withdraw your consent at any time, please contact us using the contact information provided in the 'Contact Us' section. We will inform you of the implications of withdrawing consent.

3. We will not, as a condition of the supply of services, require you to consent to the collection, use or disclosure of information beyond that required to fulfill the explicitly specified and legitimate purposes for which the information is being provided.

4. Since RTSMedia OU operates in different countries, by using the Website and Mobile application, you guarantee that you have necessary consent of natural person for cross-border sharing, including jurisdictions with underdeveloped Confidential information protection legislation. However, RTSMedia OU endeavors to provide high standards of Confidential information protection by our partners regardless of their location.

X. Confidential information Protection 1.To ensure Confidential information protection we take the following steps:

collection of minimal required data; security equipment; hardware facilities and software packages for data protection; the list of the personnel, whose responsibilities require access to the Confidential information, is strictly restricted and regulated; other step stipulated by law. XI. Third Party Websites 1. RTSMedia OU cannot guarantee the protection of the confidential information you provide at third party websites, to which the website links or on the websites, which refer to our website, because these sites are operated independently from us. The use of information gathered on these websites is regulated by their own Privacy Policies. We bear no responsibility for the actions of such third parties and use of confidential information they gather.

XII. Cookies 1. When you visit the Website, we place a text file called a 'cookie' in the browser directory of your computer's hard drive. A cookie is a small text document, which often includes an anonymous unique identifier. When you visit an Internet site, that site's computer asks your computer for permission to store this file in a part of your hard drive specifically designated for cookies. Each Internet site can send its own cookie to your browser if your browser's preferences allow it, but, to protect your privacy, your browser only permits an Internet site to access the cookies it has already sent to you, not the cookies sent to you by other sites. The cookie cannot be read by any website other than the one that set up the cookies. Some browsers can be set to reject all cookies. If you choose to modify your browser in this manner, some pages of this website may not function properly.

2. As you use our Site, the Site uses its cookies to differentiate you from other Users. Cookies, in conjunction with our Internet server's log files, allow us to calculate the aggregate number of people visiting our Site and which parts of the Site are most popular. This helps us gather feedback in order to constantly improve our Site and better serve our customers. Cookies do not allow us to gather any personal information about you and we do not generally store any personal information that you provided to us in your cookies.

3. We also may use cookies and work with third party service providers who use cookies to collect traffic data and other information about your use of our Website. We and our service providers use this information in aggregated and anonymous form to analyze usage of our Website and to improve the operation of our Website, Services and business generally.

XIII. Restrictions 1. At any time a natural person may restrict the usage of his/her Personal Data for advertising and promotional activities. If a natural person has any concerns regarding our use of Personal Data, such a natural person may contact us in accordance with the procedure specified by the Terms and Conditions.

XIV. Responsibility 1. RTSMedia OU strives to maintain the highest level of the applied technologies, implementing the cutting-edge IT solutions, however, it is obvious that we shall bear no responsibility for the violation of the confidentiality of the information that happened beyond our direct control and/or as a result of a third party’s fault. Therefore, we are not responsible for any losses arising under such circumstances.

XV. Final provisions 1. By a continued use of the Website or Mobile application you confirm that you fully understand the content of the Privacy Policy, and that you personally, freely, knowingly, willfully and for your own benefit accept it in the form it is presented on our website with all amendments that may be introduced to it. The amendments that are introduced to the Privacy Policy will be immediately published on our website, therefore we highly recommend you to visit this web-page on a regular basis.

2. The Privacy Policy and Terms and Conditions form an integral part of the Agreement and shall be considered only in conjunction with each other.

Contact info If you have any questions or comments about this Privacy Policy, please contact us at