Personal Data Processing Policy of JSC Better Chance

1. Scope of this document

1.1. This Policy (the “Policy”) has been prepared in accordance with Federal Law No. 152-FZ dated 27 July 2006 “On personal data”, and defines the policy of the personal data processor, JSC Better Chance, address: 6 Gasheka Street, 125047, Moscow (“Better Chance”), in relation to the processing of the personal data collected through the use of the website www.betterchance.ru (the “Website”), and sets forth the requirements to the protection of such personal data put in place by Better Chance.

2. Subjects and types of personal data being processed

2.1. Better Chance processes the personal data of the following categories of subjects (and their personal data may be gathered through the use of the Website):

unregistered users;
registered users;
event participants (other than the registered users).

2.2. The processed personal data of the unregistered and registered Website users, as well as the event participants, include all the information provided by users to Better Chance through the Website, including by filling in the relevant data fields on the Website.

3. Purposes of the personal data processing

3.1. Better Chance will process the personal data of unregistered users for purposes of their communications with Better Chance.

3.2. Better Chance will process the personal data of registered users for the following purposes: 1) use of the Website by such users, which shall include:

communications with Better Chance;
provision of reference information to the users;
advising the users on matters of the works and services provision, and user support;
enhancing the Website's usability;

2) promotion of Better Chance's works and services through direct contacts with users; 3) event participation which shall include:

informing users of the upcoming events;
event sign-ups and sign-ins;
providing users with materials for use at the events and with follow-up materials.

3.3. Better Chance will process the personal data of the event participants for purposes of their participation in the events, which shall include:

informing event participants of the upcoming events;
event sign-ups and sign-ins;
providing event participants with materials for use at the events and with follow-up materials.

4. How the personal data are processed

4.1. Better Chance may process personal data with the use of the automation tools or without the use of such tools, by gathering, recording, organising, compiling, storing, refining (updating, modifying), extracting, using, transferring (providing, accessing), blocking, deleting, destroying such data.

4.2. Better Chance shall be entitled to communicate personal data to third parties or to engage third parties for the processing of personal data, to the extent necessary to achieve the purpose of such processing in accordance with this Policy, as well as in the events stipulated by the current personal data laws of the Russian Federation.

4.3. Better Chance will not process personal data during periods longer than required for purposes of such processing unless otherwise envisaged by the current personal data laws of the Russian Federation.

5. How the personal data are protected

5.1. Better Chance takes its responsibility of protecting the collected personal data seriously, acting in compliance with the requirements relating to the protection of such data through a set of measures undertaken in the scope necessary and sufficient for ensuring compliance with the duties envisaged by the current personal data laws of the Russian Federation.

5.2. At the same time, Better Chance shall not be liable for any third-party access to the personal data as a result of the access gained to the personal accounts of the registered users. Registered users of the Website shall have the duty to ensure safeguarding of the data for access to their personal account on their own.

6. Consent to the personal data processing and applicable qualifications

6.1. A user of the Website, acting freely, willingly, and in his/her/their own interest, provides his/her/their

personal data, and in the interests of the event participants – their personal data, to Better Chance.

6.2. By accepting the terms and conditions of this Policy, the Website user hereby acknowledges that the personal data provided by him/her/them are true. Better Chance proceeds on the assumption that the Website user provides true personal data and keeps such data up-to-date.

6.3. By filling in the data fields set out on the Website, the Website user accepts this Policy and gives his/her/their consent to the processing of their personal data in the manner and on the terms set out in this Policy.

6.4. By filling in the data fields in relation to the event participants, the Website user guarantees the event participants have given their consent to the processing of their personal data in the manner and on the terms set out in this Policy. In such case, the Website user shall also notify such event participants of their personal data provision to Better Chance.

6.5. By accepting the terms and conditions of this Policy, the Website user acknowledges his/her/their awareness of their rights and duties stipulated by the current personal data laws of the Russian Federation, in particular, the right of access to their own personal data and the right to revoke their consent.

6.6. If the Website user does not intend to provide the personal data or does not accept this Policy, he/she/they shall discontinue any Website use, and in such case Better Chance will not be able to ensure a possibility of the Website use for the user.

7. Other data that might be processed

7.1. Better Chance may gather information on the Website visits by users without the provision of the relevant information by the users themselves. Such information may be obtained by a variety of methods, means and tools of the Internet statistics gathering and customisation (in particular, cookies, Yandex.Metrika services). Better Chance may use such methods, means and tools for the purposes of promoting works and services of Better Chance, informing on the upcoming events through provision of targeted ads, and enhancing the Website's usability through creation of registered user profiles. On the other hand, such methods, means and tools will not be used for identification of unregistered users.

7.2. If the Website user does not consent to cookie files storing on his/her/their device, they can disable this option in their browser settings on their own. Stored cookies can also be deleted at any time in the browser's system settings. A Website user may change his/her/their browser settings to accept or reject by default all cookies or cookies from certain websites, including the Website.

7.3. Disabling certain cookies might result in precluding the use of certain sections or functions of the Website.

7.4. If the Website user does not consent to the use of methods, means and tools of Internet statistics and customisation, he/she/they shall discontinue any Website use, and in such case Better Chance will not be able to ensure a possibility of the Website use for the user.

8. Final provisions

8.1. This Policy shall be amended or supplemented in the event of relevant amendments or supplements to the current personal data laws of the Russian Federation, and may be amended at any time at the discretion of Better Chance. You can find the current version of the Policy applied by Better Chance, generally available to public, at any time via the following permanent link: www.betterchance.ru.

8.2. All the relations involving Better Chance, to the extent pertaining to the personal data processing and protection, not otherwise covered by this Policy, shall be governed in accordance with the provisions of the current personal data laws of the Russian Federation.

8.3. Latest revision date of the Policy: 25.07.2023.