Confidentiality Policy

Moscow, 9 June 2020

This Personal Data Confidentiality Policy (hereinafter referred to as the Confidentiality Policy) applies to all information relating to the Customer which TransLink-24 LLC may receive while the Customer is using the web site of TransLink-24 LLC, http://translink-group.com (hereinafter referred to as the Site).

1. TERMS AND DEFINITIONS

1.1 The following terms are used in this Confidentiality Policy:

1.1.1. The “Site Administrators” means the employees authorized to manage the Site, who, acting in the name of TransLink-24 LLC, organize and /or carry out the processing of personal data and define the purposes for which personal data is processed, the content of the personal data to be processed, and the actions (operations) carried out using the personal data.

1.1.2. “Personal Data” means any information relating to an individual who is identified or identifiable, whether directly or indirectly ( a personal data subject).

1.1.3. “Processing of Personal Data” means any actions (operations) or series of actions (operations) performed in respect of Personal Data, whether or not by means of automated technologies, including the collection, recording, systematization, accrual, storage, clarification (renewal, amendment), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion and destruction of Personal Data.

1.1.4. “Confidentiality of Personal Data” means the obligation not to allow the distribution of Personal Data without the consent of the Personal Data subject or other lawful ground, which obligation is binding on the Operator and any other persons who obtain access to the Personal Data.

1.1.5. “Site User” means any person who has access to the Site http://translink-group.com via the Internet, and who uses the Site.

1.1.6. “Cookies” means small fragments of data which are sent by the web server to the user’s computer, and which the web client or web browser sends to the web server as part of the HTTP-request when it tries to open a page of the site in question.

1.1.7. “IP Address” means the unique network address of a link in a computer network, which is formed in accordance with the IP protocol.

2. GENERAL PROVISIONS

2.1. This Confidentiality Policy applies to the web site http://translink-group.com and to all computer devices. By using the Site http://translink-group.com a Site User accepts this Confidentiality Policy and the conditions governing the processing of the User’s Personal Data. The User has been informed and agrees that his/ her acceptance, communicated in electronic form through the Site, constitutes an acceptance which complies with the requirements of the law on Personal Data and which allows the confirmation of its receipt by TransLink-24 LLC.

2.2. If the User does not accept the terms of this Confidentiality Policy, he/ she must stop using the Site.

2.3. This Confidentiality Policy applies only to TransLink’s Site. TransLink has no control over and bears no liability in respect of any sites of third parties to which the User may be directed by clicking on links displayed on TransLink’s Site.

2.4. The Site Administrators do not verify the accuracy of personal data provided by Users of TransLink’s Site.

3. SUBJECT OF THE CONFIDENTIALITY POLICY

3.1. This Confidentiality Policy sets out TransLink’s obligations in relation to the non-disclosure of, and establishment of a regime for the protection of the confidentiality of, any Personal Data which a User may provide at TransLink’s request when placing an order for a specific service.

3.2. The Personal Data which may be processed under this Confidentiality Policy is provided by the User by means of completing the Express Order application form on the Site http://translink-group.com and includes the following information:

3.2.1. the User’s full name;

3.2.2. the User’s contact telephone number (contact person);

3.2.3. e-mail address;

3.2.4. telephone;

3.3. Any other personal information, not mentioned above, must be stored and not distributed, except in the cases specified in Clauses 5.2. and 5.3. of this Confidentiality Policy.

4. REASONS FOR THE COLLECTION OF PERSONAL INFORMATION

4.1. TransLink may make use of a User’s Personal Data for the following purposes:

4.1.1. To identify the User, for the purpose of placement of an order and/ or entering into an Agreement on the provision of translation services.

4.1.2. To communicate with the User, including in order to send the User notifications and ask questions concerning the services being provided, and to process questions and requests received from the User.

4.1.3. To determine the User’s location in order to ensure security and prevent fraud.

4.1.4. To inform a User of TransLink’s Site concerning the status of the Order.

4.1.5. To process and receive payments, confirm taxes or tax discounts and challenge payments.

4.1.6. To provide the User with efficient client and technical support in the event of any problems arising in connection with the use of the Site.

4.1.7. With the User’s consent, to provide the User with information about services, special offers, information about prices, news updates and other information from TransLink.

4.1.8. With the User’s consent, to carry out advertising-activities.

5. MANNER OF PROCESSING PERSONAL DATA AND APPLICABLE TIME PERIODS

5.1. The User’s Personal Data may be processed at any time and by any means permitted by law, including in personal data information systems, whether or not by means of automated technologies.

5.2. The User agrees that TransLink has the right to transfer Personal Data to third parties including courier services, organizations providing mail services, electrical communications operators, but exclusively for the purposes of carrying out the User’s order, placed through the Site, or the subsequent delivery of the results of the order.

5.3. The User’s Personal data may be transferred to authorized state authorities of the Russian Federation, but only on the grounds and in accordance with the procedures established by the law of the Russian Federation.

5.4. In the event of any loss or disclosure of personal data, the Site Administrators shall inform the User of such loss or disclosure.

5.5 TransLink shall take the necessary organizational and technical measures in order to protect the User’s Personal Data from unlawful or accidental access, destruction, change, blocking, copying or distribution, and also from unlawful actions by third parties.

5.6 TransLink and the User shall take all necessary measures to prevent loss or other negative consequences resulting from any loss or disclosure of the User’s Personal Data.

6. OBLIGATIONS OF THE PARTIES

6.1. The User shall:

6.1.1. Provide such information on its Personal Data as is necessary in order to place the order.

6.1.2. Update the information on its Personal Data or provide additional information if the Personal Data changes (if necessary).

6.2. The Site Administrators shall:

6.2.1. Use the information provided exclusively for the purposes indicated in Clause 4 of this Confidentiality Policy.

6.2.2. Ensure that confidential information is stored and that its secrecy is maintained, not disclose it without the prior written permission of the User, and not sell, exchange publish or disclose the User’s Personal data which it has received in any other possible manner, except in the cases specified in Clauses 5.2. and 5.3. of this Confidentiality Policy.

6.2.3. Take such precautionary measures to protect the confidentiality of the User’s Confidential Data as are commonly adopted for the protection of such information in accordance with current business practice.

6.2.4. Block the Personal Data of a given User as soon as they receive a communication or request from such User, his/ her legal representative or the body authorized to ensure the protection of the rights of personal data subjects for the period of the assessment, if it becomes evident that the Personal Data is unreliable or unlawful actions have been performed.

7. RESPONSIBILITY OF THE PARTIES

7.1. TransLink, if it fails to perform its obligations, shall bear responsibility for losses incurred by the User as a result of the unlawful use of the Personal Data in accordance with the laws of the Russian Federation, except in the cases specified in Clauses 5.2., 5.3. and 7.2. of this Confidentiality Policy.

7.2. TransLink shall not bear any responsibility for the loss or disclosure of confidential information if such confidential information:

7.2.1. Entered the public domain before it was lost or disclosed;

7.2.2. Was received from a third party before it was received from TransLink.

7.2.3. Was disclosed with the User’s permission.

7.3. TransLink shall not bear responsibility for any harm or losses incurred by Users as a result of mistakes or inaccuracies in the information specified by the Site Administrators or by Users on the Site. TransLink, in turn, shall make every effort to resolve any disagreements that may arise between the User and the Site.

7.4. If access to the Site is unavailable or restricted, due to maintenance work or other work of a technical nature which is being performed in order to ensure the normal functioning of the Site, then TransLink shall not bear responsibility to Users for their inability to obtain any particular information.

7.5. The User shall be responsible for any damage that may be incurred as a result of its use of materials received when using the services provided by the Site.

7.6. The User is solely responsible for any problems that may arise in the course of the User’s registration for and use of the Site. TransLink bears no responsibility for any harm or losses incurred by a User as a result of problems caused by the User’s mistakes or negligence when using the Site.

8. DISPUTE RESOLUTION

8.1. Before a court claim is brought in connection with a dispute arising out of relations between the User and TransLink, a complaint (a written proposal for the amicable resolution of the dispute) must first be presented.

8.2. The party receiving a complaint must, within 30 days of such receipt, inform the party that issued the complaint about the results of its consideration of the complaint.

8.3. If no agreement is reached in relation to the dispute, it shall be referred for consideration by a court in accordance with the current laws of the Russian Federation.

8.4. The current laws of the Russian Federation apply to this Confidentiality Policy and to the relations between the User and TransLink.

9. ADDITIONAL PROVISIONS

9.1. TransLink reserves the right to make amendments to this Confidentiality Policy without the agreement of the User.

9.2. The new version of the Confidentiality Policy shall enter into effect as soon as it is published on TransLink’s Site, unless it states otherwise.

9.3. All proposals or questions concerning this Confidentiality Policy should be addressed to: [email protected]

9.4. This Confidentiality Policy is published on the Internet at: https://www.translink-group.com/.