Moscow, 2023

I. General Provisions

This Privacy Policy Statement (hereinafter - the Statement) is an official document of IE Bratchikov Alexander Viktorovich, (hereinafter - "Company"/"Operator"), and determines the order of processing and protection of information about individuals (hereinafter - Users) using services, information, services, programs and products located on the website with the domain name www.evernow.be and (hereinafter - the Site) in the mobile application Evernow (hereinafter - the Application).

Privacy is important to the Company because the purpose of this Privacy Policy is to protect the rights and freedoms of individuals and citizens when processing their personal data, including the protection of their rights to privacy, personal and family confidentiality, from unauthorized access and disclosure.

We have developed a Privacy Policy, which describes how we process personal data - any actions (operations) or set of actions (operations) performed with or without the use of automation means with personal data, including collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.

Relations related to the processing of personal data and information about users of the Website and the Application are governed by these Regulations, other official documents of the Operator and the current legislation of the Russian Federation

Processing of personal data is carried out by us on a lawful and fair basis, acting reasonably and in good faith and based on the principles of:

- legality of the purposes and methods of personal data processing;

- integrity;

- compliance of the purposes of personal data processing with the purposes predetermined and declared at the time of personal data collection, as well as with the Company's authorities;

- correspondence of the volume and nature of processed personal data, methods of personal data processing to the purposes of personal data processing.

This Privacy Policy regulates any kind of processing of personal data and personal information (any information allowing to identify an individual and any other information related thereto) about individuals who are consumers of the Company's products or services.

This Policy applies to the processing of personal, personal data collected by any means, whether active or passive, whether through the Internet or not, from individuals located anywhere in the world.

II. Collection of personal data

The purpose of personal data processing is to fulfill the Operator's obligations to the Users regarding the use of the Website, the Application and their services.

Processing of personal data of Users is carried out with the consent of the subject of personal data to the processing of his/her personal data.

Personal data means any information relating to a directly or indirectly defined or identifiable natural person (subject of personal data).

We may request personal data from you any time you contact the Company. The Company may use such data in accordance with this Privacy Policy. It may also combine such information with other information for the purposes of providing and improving its products, services, content and communications.

Below are some examples of the types of personal data that the Company may collect and how we may use such information.

We may collect a variety of data/information including:

- first and last name,

- telephone number

- e-mail address;

- identity document information;

- bank card information (cardholder's name, abbreviated card number).

Personal data may also include additional information provided by Users at the request of the Operator in order to fulfill the Operator's obligations to Users arising from the service contract. The Operator has the right, in particular, to request from the User a copy of an identity document or other document containing the User's name, surname, photo, as well as other additional data which, at the Operator's discretion, will be necessary and sufficient for identification of such User and will allow to exclude abuse and violation of third party rights.

When you involve other persons in our events and activities or invite them to communicate with us, the Company may collect personal data you provide about these persons, such as: first name, last name, e-mail address and telephone number.

When processing personal data, we will ensure that the personal data is accurate, sufficient and, where appropriate, relevant to the purposes for which the personal data is processed.

III. Storage and use of personal data

Users' personal data is stored exclusively on electronic media and processed using automated systems, except in cases where non-automated processing of personal data is necessary due to the fulfillment of legal requirements.


HOW WE USE YOUR PERSONAL INFORMATION

The personal data we collect allows us to send you notifications about new products and services of the Company and partners, special offers and various events. They also help us to improve our services, content and communications. If you do not wish to be included in our mailing list, you can unsubscribe at any time by informing us at the contact details provided for feedback and by making changes to your profile settings on the website and app.

From time to time, we may use your personal information to send important notices containing information about changes to our terms, conditions and policies. Because such information is important to your relationship with the Company, you cannot opt out of receiving such communications.

We may also use personal information for internal purposes such as: conducting audits, analyzing data and various studies to improve the Company's products and services, and interacting with consumers.


COLLECTION AND USE OF NON-PERSONAL INFORMATION

We also collect non-personally identifiable information - data that does not allow us to directly associate it with any particular individual. We may collect, use, share and disclose non-personal information for any purpose. Below are examples of the non-personal information we collect and how we may use it:

We may collect personal information such as: occupation, language, zip code, unique device identifier, location and time zone in which a product is used in order to better understand consumer behavior and improve our products, services and communications.

We may also collect personal data/information about what a user is interested in on our website, app and when using our other products and services. Such personal data/information is collected and used to help us provide more useful information to our customers and to understand what elements of our website, products and services are of most interest. For the purposes of this Privacy Policy, aggregate data is considered non-personal data/information.

If we combine non-personal information with personal information, such aggregate information will be treated as personal information for as long as such information is combined.



IV. Transfer of personal data

Users' personal data shall not be transferred to any third parties, except for cases expressly provided for in these Rules.

Processing of User's personal data is carried out without limitation of time, by any lawful means, including in information systems of personal data with or without the use of means of automation

The User agrees that the Operator has the right to transfer personal data to third parties, in particular, courier services, postal organizations, telecommunication operators, etc., exclusively for the purposes specified in the section "Collection of Personal Data" of this Privacy Policy.

If specified by the User or with the User's consent, it is possible to transfer the User's personal data to third party contractors of the Operator with the condition that such contractors undertake obligations to ensure the confidentiality of the information received, in particular, when using applications.

The applications used by Users on the Website and in the App are placed and maintained by third parties (developers) who act independently of the Operator and do not act on behalf of or on behalf of the Operator. Users are obliged to independently familiarize themselves with the rules of service provision and personal data protection policy of such third parties (developers) before using the respective applications.

User's personal data may be transferred at the request of authorized state authorities of the Russian Federation only on the grounds and in accordance with the procedure established by the legislation of the Russian Federation.

The Operator blocks personal data related to the respective User from the moment of application or request of the User or his/her legal representative or the authorized body for protection of the rights of personal data subjects for the period of verification, in case of detection of unreliable personal data or unlawful actions.


DISCLOSURE OF INFORMATION TO THIRD PARTIES

In some cases, the Company may disclose certain personal information and data to strategic partners who work with the Company to provide products and services, or to those that help the Company market products and services to consumers. We provide third parties with the minimum amount of personal information necessary only to provide the required service or transaction.

Personal information will be provided by the Company only for the purpose of providing products and services to consumers and to improve those products and services and related communications. Such information will not be shared with third parties for their marketing purposes.

To use your personal data for any other purpose, we will request your Consent to process your personal data


SERVICE PROVIDERS

The Company provides personal data/information to Companies that provide services such as: processing information, extending credit, fulfilling consumer orders, delivery, other consumer services, determining your interest in our products and services, conducting surveys to learn about our customers or satisfaction with our service. These companies are committed to protecting your information regardless of the country in which they are located.


OTHER PERSONS.

The Company may be required - by law, legal process, litigation, and/or based on public requests or requests from public authorities within or outside your country of residence - to disclose your personal information. We may also disclose personal data/information about you if we determine that such disclosure is necessary or appropriate for national security, law enforcement or other public interest purposes.

We may also disclose personal data/information about you if we determine that disclosure is necessary to enforce our terms and conditions or to protect our operations and our users. Additionally, in the event of a reorganization, merger or sale, we may transfer any or all of the personal information we collect to an appropriate third party.



V. Destruction of Personal Information

User personal information is destroyed when:

- deletion by the Operator of the information posted by the User, as well as the User's personal page in cases established by the contract (offer) with the User;

- when the subject of personal data revokes his/her consent to the processing of personal data.


IDENTIFICATION FILES (COOKIES) AND OTHER TECHNOLOGIES

The website, online services and applications, e-mail messages and any other communications on behalf of the Company may use identification cookies and other technologies such as: pixel tags, web beacons. These technologies help us better understand user behavior, tell us what areas of our site have been visited by users, and measure the effectiveness of advertising and online searches. We consider information collected by cookies and other technologies to be non-personal information.

Our goal in such cases is to provide a more convenient and personalized interaction with the Company. For example, knowing your name, we may use it in our communications. Knowing that someone using your computer or device has purchased a particular product or utilized a particular service, we can ensure that promotional messages and emails are more closely aligned with your interests. Ultimately, all of this knowledge helps us provide you with the highest quality service.

If you can disable cookies in the settings of the web browser or mobile device you are using. Please note that some website features may become unavailable after cookies are disabled.

As with most websites, we collect some information automatically and store it in statistics files. This information includes Internet Protocol address (IP address), browser type and language, information about your Internet Service Provider, referring and exit pages, operating system information, date and time stamp, and visitation information. We use such information to understand and analyze trends, administer the site, study user behavior on the site, and gather demographic information about our core user population as a whole. The Company may use such information for its marketing purposes.

In some of our e-mail communications, we use interactive links to information on the Company's website and app. When users click on such links, before they reach the destination page on our website, their requests are separately logged. We track such "pass-through" data to help us determine interest in particular topics and to help us measure the effectiveness of our communications with consumers. If you prefer that your enquiries are not tracked in this way, you should not follow text or image links in emails.

Pixel labels allow us to send emails in a format readable by consumers and tell us whether such emails have been read. We may use such information to limit the number of messages sent to consumers or to stop sending them.



VI. Protection of Personal Data

The Company takes precautions - including legal, organizational, administrative, technical and physical - to ensure the protection of your personal data in accordance with Article 19 of the Federal Law dated 27.07.2006 N 152-FZ "On Personal Data" in order to ensure the protection of User's personal data from unlawful or accidental access to them, destruction, modification, blocking, copying, distribution, as well as from other unlawful actions of third parties.

When you use some of the Company's products, services or applications or post on forums, chat rooms or social networks, the personal data you provide is visible to other users and can be read, collected or used by them. You are responsible for the personal data you choose to provide, in such cases, on your own. For example, if you provide your name and e-mail address in a forum entry, such information is public. Please take precautions when using such features.


INTEGRITY AND PRESERVATION OF PERSONAL INFORMATION

When you interact with the Company, you can easily keep your personal data and information up to date. We will retain your personal data and information for as long as necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law.


THIRD PARTY SITES AND SERVICES

The Company's websites, products, applications and services may contain links to third party websites, products and services.

Our products and services may also utilize or offer products or services of third parties.Personal data and information collected by third parties, which may include information such as location data or contact information, is governed by the privacy practices of such third parties. We encourage you to review the privacy practices of such third parties.

Operator is not responsible for the actions of third parties who gain access to User information as a result of using the Internet or the Site Services and for the consequences of using data and information that, due to the nature of the Site, is available to any Internet user.


RESPECTING YOUR PRIVACY AT THE COMPANY LEVEL

To ensure that your personal information is secure, we communicate privacy and security standards to Company employees and strictly enforce privacy measures within the Company.


QUESTIONS ABOUT PRIVACY

If you have any questions regarding the Company's Privacy Policy or the Company's processing of data, you may contact us at the contacts for feedback.



VII.User Communications

The current legislation of the Russian Federation shall apply to this Privacy Policy and relations between the User and the Operator.

Users have the right to send their requests to the Operator, including requests regarding the use of their personal data, sending a withdrawal of consent to the processing of personal data in writing to the address specified in the General Provisions section of these Regulations, or in the form of an electronic document signed with a qualified electronic signature in accordance with the laws of the Russian Federation, and sent via the feedback form.

The request sent by the User shall comply with the requirements set forth in the Rules for submitting requests to the Service and Support Service, namely it shall contain:

- the number of the main identity document of the User or his/her representative;

- information about the date of issue of the document and the issuing authority;

- information confirming the User's participation in the relations with the Operator (in particular, the user's serial number id or a short (subdomain) name replacing the serial number id);

- signature of the User or his/her representative;

- e-mail address;

- contact phone number.

The Operator undertakes to consider and send a response to the received request of the User within 30 days from the date of receipt of the request.


OTHER

In everything else that is not directly reflected in the Privacy Policy, the Company undertakes to be guided by the norms and provisions of the Federal Law of 27.07.2006 N 152-FZ "On Personal Data"

The visitor of the Company's website and Applications, providing his/her personal data and information, thereby agrees to the provisions of this Privacy Policy.

The Company reserves the right to make any changes to the Policy at any time at its discretion in order to further improve the system of protection against unauthorized access to personal data reported by Users without the User's consent.When we make material changes to the Privacy Policy, a notice will be posted on our website and App along with the updated version of the Privacy Policy.

At the same time, we inform you that all materials contained on www.evernow.be and/or book.evernow.be and on the Evernow mobile application that are made freely available on these sites or on the mobile application may be used by you for your personal use only. By continuing to use said sites or mobile application, you agree not to audio-record, video-record, photograph the information, materials, meditations, counseling sessions, videos or webcasts provided on said sites or mobile application for any purpose other than personal use.
You may not reproduce, duplicate or copy, sell or resell, or use for any commercial or other non-personal use, publicly post, or transmit to any third party, in whole or in part, any material made freely available on www.evernow.be and/or book.evernow.be or the Evernow mobile application.

This Policy does not apply to the actions and online resources of third parties.