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CONSENT TO THE PROCESSING OF PERSONAL DATA GABUMAS

(hereinafter referred to as the "DRAFT") (Version dated *10/03/2022*)

This Applicant's Waste Management Consent (hereinafter referred to as the "Consent") regulates the processing of data provided by the Applicant for the use of its services or for participation in the Project, including the information reflected in the Application.


TERMS AND DEFINITIONS


Applicant - a legal entity (its Representative), an individual entrepreneur or an individual who has sent an Application on the Resource, thereby expressing his desire to use the services or participate in the Project

Application/question - information provided by the Applicant on the Resource in order to notify the Company of the Applicant's desire to receive services or take part in the Project. The information necessary for sending the Application is provided through the Resource by activating the “Submit” button with the preliminary filling in of the given and required fields for filling out (“Name”, “E-mail”, phone number, “Comment”). By clicking the "Send" button, the Applicant confirms his agreement with the Privacy Policy, as well as with the text of this Consent, thus by sending the above information, the Applicant expresses a direct and informed consent to the processing of his personal data.

Resource - the website of GABUMAS LTD, located on the Internet at: https://gabumas.com/

The project is a line of the Company's activity focused on identifying possible options for interaction with the Applicants, implemented through analytics, support and mentoring.

Representative (Representatives) - an individual (persons) whose personal data is sent to the Company through the Resource (including information reflected in the Application).


PROCESSING OF PERSONAL DATA


I (the Applicant), acting freely, by my own will and in my own interest, give my direct, informed and informed consent to the Company to the processing of my personal data, the list of which is given in the Privacy Policy, the fact that I have read it.

By providing the personal data of his Representative, the Applicant confirms that he has duly received from the Representative a consent similar in content to the processing of personal data. The Applicant undertakes to provide the original of such consent at the request of the Company within 3 (three) calendar days from the moment the Applicant receives such a request.

This Consent is given, inter alia, to the processing of the following categories of personal data: last name, first name, patronymic, citizenship, registration address, passport series and number, date of issue, name of the issuing authority and subdivision code, TIN, city of work, contact phone number, email address . The processing of personal data can be carried out using automation tools or without them, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), retrieval, use, transfer (granting access; including transfer to legal entities named in the Policy confidentiality), depersonalization, blocking, deletion, destruction of personal data, except for the dissemination of personal data.


Personal data is processed for the following purposes:
1. analysis of the information contained in the Application;
2. confirmation of your identity and your will, desire to participate in the Project;
3. communication between the Applicant and the Company in the framework of the use of services or the implementation of the Project, as well as informing the Applicant about the progress of the Project;
4. fulfillment of the obligations of the Company during the implementation of the Project;
5. verification of the Applicant and analysis of the information submitted by the Applicant during the implementation of the Project;
6. communicating with the Applicant to send notifications, requests and information related to the Project, processing requests and Applications;
7. compliance by the Company with legal obligations established by applicable law.

The Applicant expresses his consent to the transfer (provision, access) and assignment by the Company to third parties of the processing of personal data transferred by the Applicant to the Company under the Project, to the extent necessary to achieve the purposes of processing personal data specified in this Consent. The list of persons processing the personal data of the Applicant and/or his Representatives on behalf of the Company, as well as the addresses of such persons, are specified in the Privacy Policy.

The Company uses encryption to protect sensitive information transmitted over the Internet, and the Company also protects your information offline. Access to information is provided only to those employees who need this information to perform a specific job. The computers/servers on which we store personal information are in a secure environment. However, no method of transmitting information over the Internet or storing information is completely secure. Thus, the Company cannot guarantee the absolute security of any information. Subject to the foregoing in this paragraph, the Applicant agrees with the receipt/provision of Personal Data via open communication channels and understands that when exchanging messages via open communication channels, the Company does not guarantee confidentiality in relation to the information transmitted in this way.

The Company does not verify the personal data provided by the Applicant and cannot judge their authenticity. The Company proceeds from the fact that the Applicant provides reliable and sufficient personal data, and also updates them in a timely manner, thus the risk of providing false personal data is borne by the Applicant who provided them.

This Consent is provided from the date of its issuance, and is valid until its withdrawal. The Applicant, the Representative of the Applicant, whose personal data is specified in the Application, has the right to withdraw consent to the processing of their personal data at any time by sending a corresponding notice in writing to the Operator. The procedure for withdrawing consent is described in the Privacy Policy.

Please note that the text of this Consent may change from time to time. All updates to the text of this Consent will be posted on this page.

This Consent is drawn up in Russian. We can provide you with a translation in English and other languages, upon your request. In the event of any inconsistencies or inconsistencies between the translation of this Consent and the Russian version, the Russian version shall prevail.

Sincerely, GABUMAS LTD

PRIVACY POLICY OF THE GABUMAS PROJECT (hereinafter referred to as the "PROJECT") (VERSION DATED *11/22/2021*)


Thank you for choosing GABUMAS LTD services!


Please read our Privacy Policy (hereinafter referred to as the "Policy") to understand what data, for what purposes and in what ways we may process. This Privacy Policy is designed to make its content as easy to understand as possible. If you have any questions or suggestions regarding the Policy, please contact us via the email address provided in this Policy, so that we can respond to you as quickly as possible.


The controller under the General Data Protection Regulation (GDPR) and other data protection or data privacy laws in the Member States of the European Union, as well as other data protection requirements in relation to the Project, as following:


GABUMAS LTD, RIGA FERAIOU 7-9, LIZANTIA COURT OFFICE 310, 1087, AGIOI OMOLOGITES, NICOSIA, CYPRUS

Email: info@gabumas.com


Data processing is carried out by us solely for the purposes defined by this Policy. Please note that you have the right to withdraw consent at any time in the manner specified in this Policy.

By accepting this Policy, you also accept the Rules for participation in the GABUMAS project. You acknowledge and represent that you are of the age required to enter into a binding agreement in the country in which you reside or a resident, or that you have the permission of one of your parents or legal guardian, if required by the applicable local law of the country in which reside or of which you are a resident. For the purposes of this Policy, “child” means any natural person who is under the minimum age required to provide consent to the collection and processing of Data, in accordance with the applicable local law of the country in which he resides or is a resident of which he is. From time to time, we may update this Privacy Policy by posting a notice in the Project prior to such changes becoming effective.


This Policy defines:

– What data do we process;

– To whom we may share your data;

– Purpose of data processing;

– How long do we store the data;

– How do we protect your data;

– How you can manage the data.



TERMS AND DEFINITIONS


Applicant - a legal entity (its Representative), an individual entrepreneur or an individual who has submitted an Application on the Resource.

Application/question - information provided by the Applicant on the Resource in order to notify the Company of the Applicant's desire to take part in interaction with the Company within the Projects. The information necessary for sending the Application is provided through the Resource by activating the "Submit" button with the preliminary filling in of the given and required fields for filling out:

Name

E-mail

Phone number


By clicking the "Send" button, the Applicant confirms his agreement with these Rules for participation in the Project, the Privacy Policy, as well as with the provisions of the Consent to the processing of personal data, thus, by sending the above information, as well as other additional materials and documents, the Applicant expresses a direct and informed consent to the processing of their personal data.

Resource - the website of GABUMAS LTD, located on the Internet at: https://gabumas.com/ Project – a type of Company activity aimed at identifying possible options for interaction with Applicants, implemented through expertise, analytics, support and mentoring.


1. DATA PROCESSED


By your data we mean any information related to you and your use of the services. All data about your activity processed by us and necessary to provide access to the Project is referred to hereinafter as “Data”.

Although the data we process may not include data in the category “personal data”, we treat all information related to the Data as the personal data.

We collect the following personal data relating to users of our Services:

– any information that concerns you (the Applicant) and the use of services;

- Full Name; e-mail address; phone number; mailing address; other personal data posted on the Resource and / or received by us in the process of interaction between the Applicant and the Resource.

- data that is automatically transmitted during the use of the Resource through the software installed on the computer of an individual (the subject of personal data), such as information about the browser used (or other program that accesses the website); IP address; cookie data.

– Other data that you (the Applicant) choose to provide us.


We process your personal data on the following legal grounds:

– data necessary to provide you with access to the Project or to provide an access to our services;

– data required for marketing or analytical purposes based on your consent. Ways of collecting information (categories of sources used in the collection).


1.1 Data provided by yourself.

This type of data includes the following information provided by you:

– when forming and providing the data of the Applicant;

– for your use of social functions and channels for communication with other people in the Project;

– when receiving technical support services.


ATTENTION! We cannot be held responsible for the topicality, correctness, completeness or quality of the information provided by you. When you place the data you provide yourself, we proceed from the presumption of your good faith, we accept the information provided as up-to-date, correct, complete and reliable. If you provide inaccurate and (or) outdated information, access to a number of services may be limited for you, and the provision of technical support services and support on the processing of personal data is suspended until you confirm that the specified information belongs to you. These measures are necessary to ensure the protection of your data.


1.2 Information that we receive or generate as a result of your use of the Project. We may collect data related to your use of the Project, your use of our services and the nature of that use, and your devices. The collection of such information is necessary for the analysis of possible technical errors in the operation of the Project and their timely elimination.


1.3 Information collected from external sources.

We may receive information about you and your activities from third parties when you connect external accounts; from advertisers or service providers about your contacts and interactions with them.


1.4 COOKIES

Cookies are text files with small pieces of data, such as a username and password, that are used to identify your device when you use the Internet. Specific cookies, known as HTTP cookies, are used to identify specific users and improve your browsing experience.

The data stored in a cookie is generated by the server when you connect. This data is marked with an identifier that is unique to you and your device. For more information see Cookie Policy.


2. PROVISION OF DATA TO THIRD PARTIES


In order to provide services, we may share Data with vendors or agents working on our behalf. We do not sell your personal data to third parties. We may disclose Data to third parties who provide services to us, ensuring that they are contractually required to maintain the confidentiality of your personal data and will comply with the GDPR and other applicable data protection laws.


We may share your information with the following types of third parties:

a) technical and infotainment user support providers who assist us in providing the services,

b) third party software providers, including software as a service solution providers, where the provider processes personal data on behalf of GABUMAS;

c) analytical services that help us develop and improve the Project;

d) providers who help analyze our offers and services;

e) marketing and advertising agencies, including organizations or online platforms chosen by us to conduct promotional campaigns on our behalf and to advertise the Project and services that may be of interest to you; and/or

f) professional advisors such as lawyers, accountants, tax advisors, auditors and insurance brokers;

g) service providers who assist us in providing our services.


We may transfer data to our affiliates and/or counterparties in the EU/EEA and outside the EU/EEA. If the transfer of data outside the EU/EEA is not regulated by a decision of the EU Commission, we rely on the legal safeguards referred to in Article 46 of the General Data Protection Regulation (GDPR). The implementation of these safeguards includes standard contractual clauses approved by the EU Commission, which we have enhanced with additional security measures, such as: additional individual risk assessment, additional contractual guarantees and technical guarantees, including additional encryption or pseudonymization, to ensure secure communication with GABUMAS affiliates. and partners outside the EU/EEA.

Find out more about the standard contractual clauses approved by the EU Commission.

We may share personal data with external vendors, service providers or contractors that we engage to perform services or functions on our behalf and in accordance with our instructions. Where such suppliers are located in the EU, we ensure that they are contractually bound to comply with the applicable data protection regulations. We also stipulate in our agreements with such organizations that they process personal data only in accordance with our instructions and for the purposes of providing the service, protect the integrity and confidentiality of your personal data provided to them. We may also disclose personal information to our advisors, consultants, law enforcement and other government agencies (such as tax and social security agencies), police, prosecutors, and courts. All these recipients are themselves responsible for complying with EU data protection regulations. Some of the suppliers we work with are located outside the European Economic Area. If the EU Commission has not recognized the countries in which such counterparties are located as providing adequate protection of personal data, we rely on the legal guarantees described above. The listed third parties may access and process your data in accordance with their own privacy policies, being their own Data Controller. We encourage you to read their privacy policy to learn more about how they process data.

We may disclose your personal data based on our legitimate interest to investigate, prevent or take action regarding illegal activities, suspected fraud, violation of our intellectual property rights, situations involving potential threats to the physical safety of any person, violation of our Policies and (or ) Terms of Use, or other binding agreements, and as required by law. Please feel free to contact us for more information about data transfers to third countries, as well as our guarantees and additional security measures.

3. PURPOSE OF PROCESSING


We process data about you only if such processing is necessary to provide you with access to the Project and (or) services, while taking reasonable security measures to protect your data from loss, misuse and unauthorized access, disclosure, alteration and destruction. For users who are subject to the GDPR Regulation (hereinafter referred to as the Regulation), we use the Data collected as part of the Project and / or services for our legitimate interests in accordance with Article 6(1)(f) of the Regulation and for the purposes specified in the Rules for participation in the GABUMAS project and this Policy. For example, we may use Data collected for the purpose of:

• to provide our services or information requested by you, and to process and complete any transaction;

• respond to your inquiries, questions, comments, wishes and complaints, and to provide customer service;

• monitoring and analyzing Project usage and trends, and personalizing and improving the Project and user experience associated with our site, such as providing ads, content and providing key features that match their profiles or interests, and increasing functionality and usability project;

• sending you confirmations, updates, security alerts, advisory and administrative messages;

• to otherwise facilitate your use, management and operation of our site;

• and for any other purpose for which the data was collected.

Information is collected when you provide Data as part of the use of the Project and (or) services only with your consent, and you can manage your Data at any time. Only anonymous/depersonalized information can be collected by indirect means.


4. DATA RETENTION TERMS


We process and store the Data for the duration of the Project and for thirty (30) days from the confirmation of the request for deletion, with the exception of the information necessary to comply with the requirements of applicable law (for example, in the field of taxation and accounting), as well as anonymous information . We do not control the Data published by you, copied by other users, as well as the Data published in the Project chat (if applicable) or in thematic groups and forums. After deleting your data, your depersonalized account can be saved in the Project if it is used in interaction with other users. Information, including personal data of users (if applicable), collected or created in the process of providing technical support to users, is retained for the duration of the Data that applied for support, in order to ensure optimal resolution of emerging questions and problems. Information that does not contain personal data can be stored for the entire duration of the Project.


5. SECURITY AND DATA PROTECTION


GABUMAS respects the privacy of your data and is committed to provide the highest level of protection possible. Despite the measures we take to protect your information organizationally and technically, any measures taken by us will not be valid if you neglect the security of your data.

The Project implements reliable protection tools that ensure the security of your Data. We do our best to secure the Project and constantly improve our ways of protecting information. As some of the ways to protect information from unauthorized access, modification, disclosure or destruction, We use the following methods:

– data encryption during storage and transmission;

– we improve the techniques and methods of collecting, storing and processing data;

– access to the Data in encrypted and anonymized form is available only to authorized employees, consultants or interested groups of persons who need access to this information to perform their duties;

– all persons having access to the Data are instructed in working with the data, their knowledge and skills are systematically tested.

Despite all the measures taken by us, your careful attitude to the Data and information on access to it plays an important role in the safety of the Data. In order to avoid unauthorized access to the Data, we strongly recommend that you do not transfer access to the Data to third parties and comply with the Rules for participation in the GABUMAS project. If you violate the Rules for participation in the GABUMAS project and this Policy, we cannot guarantee the security of your Data.

6. DATA MANAGEMENT


You have all the technical possibilities to determine how the Data will be used. We are constantly improving the ways in which we manage the Data available to you. You have the right to receive information from us about how we process your personal data, to view copies of all personal data we hold, and to request that we correct, correct or delete your personal data from our systems. You can also restrict or object to the processing of your data.


You can exercise your rights in the following ways:

– withdraw your consent to the processing of Data at any time;

– to access Data about you. You have the right to access the Data we have collected about you, which means you have the right to request information about the storage of the Data, access to the Data, as well as a copy of the stored Data.

– demand restriction of Data processing for the time necessary to verify the accuracy of the information;

- To change the data. You independently determine the volume and the Data itself, which will be associated with You;

– to exercise their right to object to the processing of Data. If you believe that we have no legitimate basis for processing the Data, please contact us at info@gabumas.com. If we fail to satisfy your claim, you have the right to file a complaint with the supervisory authority;

– delete the Data associated with you.


The procedure for withdrawing consent to the processing and deletion of Data:

PLEASE NOTE, the Data is used by us solely for the purpose of providing you with access to the Project and improving the quality of services. As a result of deleting the Data, you will lose access to the Project, the Data will be permanently deleted.


Request execution order:

1. An initial request that complies with this Policy may be submitted via email to info@gabumas.com .

2. Confirmation of the request is carried out by you through the specified and verified e-mail address.

3. Completion of the request is usually carried out within 30 days from the date of confirmation of the request. This period is necessary for the adoption of organizational and technical measures to fulfill your request and, if necessary, may require more time.

PLEASE NOTE, we reserve the right to refuse to fulfill a request if the ownership of the Data is not confirmed by You and (or) the request affects the rights and freedoms of others. If you do not have the technical ability to perform the steps to confirm the ownership of the Data, you can send a letter to:


RIGA FERAIOU 7-9, LIZANTIA COURT OFFICE 310, 1087, AGIOI OMOLOGITES, NICOSIA, CYPRUS

Recipient: GABUMAS LTD

In the letter you must provide information by which we can uniquely identify you and the Data belongs to you.

7. LOCAL LAWS


We provide you with the access to the international Project and strive to comply with applicable local laws. Please note that our services are provided "as is" and you are responsible for your own applicable local laws. By continuing to interact with us within the framework of the Project, you guarantee that the activities carried out by you within the framework of the Project do not contradict the applicable local legislation and the Rules for participation in the GABUMAS project. Please note we do not sell PD to consumers in the state of California. The transfer of data is carried out in order to provide services on legal grounds.


8. FINAL PROVISIONS


We reserve the right to change this privacy policy at any time, so please review it as often as possible.


This Policy is drawn up in Russian. We can provide you with a translation in English and other languages upon your request. In the event of any inconsistencies or inconsistencies between the translation of this Policy and the Russian version, the Russian version shall prevail.

Sincerely, GABUMAS LTD




INFORMATION PLACED ON YOUR DEVICE

When you access our services, we may store information on your device with your permission. This information is called COOKIES, which are small text files containing letters and numbers, and which are stored on your device and remember your preferences while you are using our services when visiting our website.


ESSENTIAL AND NECESSARY COOKIES


We use essential and necessary cookies to enable any user on our website to navigate the site and use its features, such as accessing secure areas of the website. Without particular cookies you will not be able to use our website effectively.


REGISTRATION PROCESS


These cookies contain information accumulated during your registration process and allow us to identify you as a customer or affiliate and provide all the essential services you need.


OUR WEBSITE


For visitors to our website we use cookies in order to collect information.

Our servers use three different types of cookies:

“Temporary” cookies for the duration of visiting our website - this type of cookie is intended only for your computer during your visit to our website. Session-based cookies help you to navigate our site faster and, if you are a registered customer or affiliate, this allows us to provide you with information that is more applicable to you. These cookies are automatically deleted when you close your browser.

“Persistent” cookie files - this type of cookie will remain on your computer for a certain amount of time set for each installed cookie.

“Analytical” cookie - this type of cookie allows us to identify and count the number of visitors on our website and see how visitors use our services. This helps us to improve the website itself, for instance, by allowing you to easily log in and find what you are looking for.

It is you who decides and it is you who always has a choice - agree and accept or disagree and reject the recipient of cookies.


The majority of web browsers automatically accept cookies, but if you wish you can change settings of your browser in order to control your cookies.


You can use your web browser to:


  • delete all cookies;
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  • allow all cookies;
  • block third party cookies;
  • clear all cookies when closing the browser
  • open “private browsing”/”incognito” session, which allows you to browse the Internet without saving local data;
  • install add-ons and plugins for browser functionality extension.

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