22 March 2019

For your information

1. What does this Privacy Policy cover

This Privacy Policy (“Policy”) covers any information, about you that may include personal data as defined by applicable laws and regulations (“Personal information”), which NAIVE Software LLC (“NAIVE”), may obtain when you use any of the NAIVE websites, programs, products or services, including its program, product or service (collectively, the “ Services ”), information about which you can find on naïve.pro and other NAIVE websites (collectively, the “Sites”), and as well as during the performance of any contract or agreement NAIVE conclude with you in relation to your using the Services.

Please note that your using any of the Sites and/or Services may be subject to additional terms and conditions, which may amend and/or supplement this Policy.

2. Who processes your personal information

To provide you with access to the Sites and Services, your Personal information is collected and used by NAÏVE Software LLC, a company incorporated under the Russian law, with a head office registered at 74-76k1 Bakuninskaya St., office 1226, Moscow, 105082, Russia (“NAIVE”), or its affiliates for particular Services. You can find information about the entity, which provides particular Service, in the terms of use.

3. What is the purpose of this Policy

Privacy and security of your Personal information are extremely important to us. When you use the Sites and/or Services, NAIVE processes your Personal information and ensures its protection in strict compliance with applicable laws and regulations.

As part of our commitment to protecting your Personal information, we use this Policy to transparently inform you about the following:

4. What type of Personal information is collected by NAIVE

Personal information collected when you use the Sites and/or Services may differ depending on whether you access the Sites or Services while logged in to your NAIVE user account or without logging in. When you are logged in to your NAIVE user account as you are using the Sites or Services, Personal information collected by NAIVE may be collated and combined with other Personal information (such as your identity, contact details, age and gender, if you shared this information with us) collected by NAIVE in your user account. NAIVE does not verify Personal information provided by you and cannot posit if it is true and whether you have the legal capacity required. However, NAIVE assumes that the information you provide is true, sufficiently complete and up-to-date.

Personal information collected by NAIVE when you access, interact with or operate the Sites and/or Services includes: