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Privacy Policy

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Privacy Policy

VTB Mobility

This Privacy Policy (“Policy”) relates to our website at
(the “Site”), and all related downloadable software, [mobile application] and other
services provided by us and in or on which a link to this Privacy Policy is displayed,
and all other communications with individuals by written or oral means, such as
email or phone (collectively, together with the Site, (our “Service”).
This Policy describes the information that VTB Mobility (“we” or “us”) gathers on or
through the Service, how we use and disclose such information, and the steps we
take to protect such information. By visiting the Site, or by purchasing or using any
Services, you consent to the privacy practices described in this Policy.
This Policy is incorporated into, and is subject to, our [Acceptable Terms of Use
Policy] and our [Terms of Business]. Capitalized terms used but not defined in this
Policy have the meaning given to them in [our Terms of Business and our
[Acceptable Terms of Use Policy]
“Client” means a customer of ours.
“Client Data“ means personal data, reports, addresses, and other files, folders or
documents in electronic form that a User of any of our Services stores within the
Service which would include but not be limited to [[] uploaded by a Client to our
“Personal Data” means information that specifically identifies an individual or that is
linked to information that identifies a specific individual.
“Public Area” means the area of the Site that can be accessed both by Users and
Visitors, without needing to use a login ID and a password.
“Restricted Area” means the area of the Site that can be accessed only by Users, and
where access requires the use of a login ID and a password.
“User” means a Client or an employee, agent, or representative of a Client, who
primarily uses the restricted areas of the Site for the purpose of accessing the
Service in such capacity.
“Visitor” means an individual other than a User, who uses the public area, but has
no access to the restricted areas of the Site or Service.

The Information We Collect on the Service:
We collect different types of information from or through the Service:

User-provided Information. When you use the Service, as a User or as a
Visitor, you may provide, and we may collect Personal Data. Examples of
Personal Data include name, email address, mailing address, mobile phone
number, and credit card or other billing information. Personal Data also
includes other information, such as geographic area or preferences, when
any such information is linked to information that identifies a specific
individual. You may provide us with Personal Data in various ways on the
Service. For example, when you register for an Account, use the Service, post
Client Data, interact with other users of the Service through communication
or messaging capabilities, or send us customer service -related requests.
[Information Collected by Clients. A Client or User may store or upload into
the Service Client Data. Each Client is responsible for providing notice to third
persons concerning the purpose for which the Client collects their Personal
Data and how this Personal Data is processed in or through the Service as
part of Client Data].

“Automatically Collected" Information. When a User or Visitor uses the
Service, we may automatically record certain information from the User’s or
Visitor’s device by using various types of technology, including cookies, “clear
gifs" or “web beacons.” This “automatically collected" information may
include IP address or other device address or ID, web browser and/or device
type, the web pages or sites visited just before or just after using the Service,
the pages or other content the User or Visitor views or interacts with on the
Service, and the dates and times of the visit, access, or use of the Service. We
also may use these technologies to collect information regarding a Visitor or
User’s interaction with email messages, such as whether the Visitor or User
opens, clicks on, or forwards a message. This information is gathered from all
Users and Visitors.

[Integrated Services. You may be given the option to access or register for
the Service through the use of your user name and passwords for certain
services provided by third parties (each, an “Integrated Service”), such as
through the use of your Google account, or otherwise have the option to
authorize an Integrated Service to provide Personal Data or other
information to us. By authorizing us to connect with an Integrated Service,
you authorize us to access and store your name, email address(es), date of
birth, gender, current city, profile picture URL, and other information that the
Integrated Service makes available to us, and to use and disclose it in
accordance with this Policy. You should check your privacy settings on each
Integrated Service to understand what information that Integrated Service
makes available to us, and make changes as appropriate. Please review each
Integrated Service’s terms of use and privacy policies carefully before using
their services and connecting to our Service.]
Information from Other Sources.

We may obtain information, including Personal Data, from third parties and sources
other than the Service, such as [our partners, advertisers, credit rating agencies, and
Integrated Services]. If we combine or associate information from other sources with
Personal Data that we collect through the Service, we will treat the combined
information as Personal Data in accordance with this Policy.
How We Use the Information We Collect
We use the information that we collect in a variety of ways in providing the Service
and operating our business, including the following:

We use the information – other than Client Data - to operate, maintain, enhance and
provide all features of the Service, to provide the services and information that you
request, to respond to comments and questions and to provide support to users of
the Service. We process Client Data solely in accordance with the directions provided
by the applicable Client or User.
We use the information – other than Client Data - to understand and analyze the
usage trends and preferences of our Visitors and Users, to improve the Service, and
to develop new products, services, features, and functionality.
We may use a Visitor’s or User’s email address or other information – other than
Client Data – to contact that Visitor or User (i) for administrative purposes such as
customer service, to address intellectual property infringement, right of privacy
violations or other issues related to the Client Data or Personal Data posted on the
Service or (ii) with updates on promotions and events, relating to services offered by
us and by third parties we work with. You have the ability to opt-out of receiving any
promotional communications as described below under “Your Choices.”
Cookies and Tracking Technologies
“Cookies” are text-only pieces of information that a website transfers to an
individual’s hard drive or other website-browsing equipment for record-keeping
purposes. Cookies allow the Site to remember important information that will make
your use of the Site more convenient. Please see our Cookie Policy for more
information [insert link]

To Whom We Disclose Information
Except as described in this Policy, we will not intentionally disclose the Personal Data
or Client Data that we collect or store on the Service to third parties without the

consent of the applicable Visitor, User or Client. We may disclose information to
third parties if you consent to us doing so, as well as in the following circumstances:
Unrestricted Information
Any information that you voluntarily choose to include in a Public Area of the
Service, such as [on a chat forum] [or a banner advertisement], [insert other as
appropriate] will be available to any Visitor or User who has access to that content.
Service Providers
[We work with third party service providers who provide website, application
development, hosting, maintenance, and other services for us. These third parties
may have access to, or process Personal Data or Client Data as part of providing
those services for us. We limit the information provided to these service providers to
that which is reasonably necessary for them to perform their functions, and our
contracts with them require them to maintain the confidentiality of such

Non Personally Identifiable Information
We may make certain automatically-collected, aggregated, or otherwise non-
personally-identifiable information available to third parties for various purposes,
including (i) compliance with various reporting obligations; (ii) for business or
marketing purposes; or (iii) to assist such parties in understanding our Clients’,
Users’ and Visitors’ interests, habits, and usage patterns for certain programs,
content, services, and/or functionality available through the Service.
Law Enforcement, Legal Process and Compliance
We may disclose Personal Data or other information if required to do so by law or in
the good-faith belief that such action is necessary to comply with applicable laws, in
response to a court order, judicial or other government subpoena or warrant, or to
otherwise cooperate with law enforcement or other governmental agencies.
We also reserve the right to disclose Personal Data or other information that we
believe, in good faith, is appropriate or necessary to (i) take precautions against
liability, (ii) protect ourselves or others from fraudulent, abusive, or unlawful uses or
activity, (iii) investigate and defend ourselves against any third-party claims or
allegations, (iv) protect the security or integrity of the Service and any facilities or
equipment used to make the Service available, or (v) protect our property or other
legal rights, enforce our contracts, or protect the rights, property, or safety of

Transfer of Ownership
Information about Users and Visitors, including Personal Data, may be disclosed and
otherwise transferred to an acquirer, successor or assignee as part of any merger,
acquisition, debt financing, sale of assets, or similar transaction, as well as in the
event of an insolvency, bankruptcy, or receivership in which information is
transferred to one or more third parties as one of our business assets and only if the
recipient of the User or Visitor Data commits to a Privacy Policy that has terms

substantially consistent with this Privacy Policy.
Client Data may be physically or electronically transferred to an acquirer, or
successor or assignee as part of any merger, acquisition, debt financing, sale of
assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or
receivership in which information is transferred to one or more third parties as one
of our business assets, for the sole purpose of continuing the operation of the
Service, and only if the recipient of the Client Data commits to a Privacy Policy that
has terms substantially consistent with this Privacy Policy.

Your Options
Access, Correction, Deletion

We respect your privacy rights and provide you with reasonable access to the
Personal Data that you may have provided through your use of the Services. If you
wish to access or amend any other Personal Data we hold about you, or to request
that we delete any information about you that we have obtained from an Integrated
Service, you may contact us as set forth in the “How to Contact Us” section. At your
request, we will have any reference to you deleted or blocked in our database.
You may update, correct, or delete your Account and or Account information and
preferences at any time by contacting us at This email address is being protected from spambots. You need JavaScript enabled to view it.. Please note
that while any changes you make will be reflected in active user databases instantly
or within a reasonable period of time, we may retain all information you submit for
backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal
obligations, or where we otherwise reasonably believe that we have a legitimate
reason to do so.
You may decline to share certain Personal Data with us, in which case we may not be
able to provide to you some of the features and functionality of the Service.
At any time, you may object to the processing of your Personal Data, on legitimate
grounds, except if otherwise permitted by applicable law.
This provision does not apply to Personal Data that is part of Client Data. In this case,
the management of the Client Data is subject to the Client’s own Privacy Policy, and
any request for access, correction or deletion should be made to the Client
responsible for the uploading and storage of such data into the Service.

Navigation Information
You may opt out from the collection of navigation information about your visit to the
Site by Google Analytics by using the Google Analytics Opt-out feature.
Opting out from Commercial Communications
If you receive commercial emails from us, you may unsubscribe at any time by
following the instructions contained within the email or by sending an email to the
address provided in the [“How to Contact Us” section].
Users are able to view and modify settings relating to the nature and frequency of

promotional communications that they receive from us by contacting us via email on
This email address is being protected from spambots. You need JavaScript enabled to view it..
Please be aware that if you opt-out of receiving commercial emails from us or
otherwise modify the nature or frequency of promotional communications you
receive from us, it may take up to [ten (10)] business days for us to process your
request. Additionally, even after you opt-out from receiving commercial messages
from us, you will continue to receive administrative messages from us regarding the
If a Client requests us to remove any data, we will respond to its request within
[fifteen (15) days. We will delete, amend or block access to any Personal Data that
we are storing only if we receive a written request to do so from the Client who is
responsible for such Personal Data, unless we have a legal right to retain such
Personal Data. We reserve the right to retain a copy of such data for archiving
purposes, or to defend our rights in litigation. Any such request regarding Client Data
should be addressed as indicated in the [“How to Contact Us”] section and include
sufficient information for us to identify the Client and the information to delete or

Third-Party Services
The Services we provide may contain features or links to websites and services
provided by third parties. Any information you provide on third-party sites or
services is provided directly to the operators of such services and is subject to those
operators’ policies, if any, governing privacy and security, even if accessed through
the Service. We are not responsible for the content or privacy and security practices
and policies of third-party sites or services to which links or access are provided
through the Service. We encourage you to learn about third parties’ privacy and
security policies before providing them with information].

Your Privacy Rights
We will not share any Personal Data with third-parties for their direct marketing
purposes to the extent prohibited by law. If our practices change, we will do so in
accordance with applicable laws and will notify you in advance.

Interest Based Advertising
Interest based advertising is the collection of data from different sources and across
different platforms in order to predict an individual’s preferences or interest and to
deliver to that individual, or his/her computer, smart phone or tablet, advertising
based on his/her assumed preference or interest inferred from the collection of data
pertaining to that individual or others who may have a similar profile or similar

[We work with a variety of third parties to attempt to understand the profiles of the

individuals who are most likely to be interested in our Services so that we can send
them promotional emails or serve our advertisements to them on the websites and
mobile apps of other entities.

These third parties include: (a) advertising networks, which collect information about
a person’s interests when that person views or interacts with one of their
advertisements; (b) attribution partners, which measure the effectiveness of certain
advertisements; and (c) business partners [or insert as appropriate], which collect
information when a person views or interacts with one of their advertisements.
In collaboration with these third parties, we may collect information about our
customers, prospects and other individuals over time and across different platforms
when they use these platforms or interact with them. [Individuals may submit
information directly on our Sites or on platforms run by third parties, or by
interacting with us, our advertisements, or emails they receive from us or from third
parties. We may use special tools that are commonly used for this purpose, such as
cookies, beacons, pixels, tags, mobile advertising IDs, flash cookies, and similar
technologies. We may have access to databases of information collected by our
business partners].

The information we or third party collect enables us to learn what purchases the
person made, what ads or content the person sees, on which ads or links the person
clicks, and other actions that the person takes on our Sites, or in response to our
emails, or when visiting or using third parties’ platforms.
We, or the third parties with which we work, use the information collected as
described above to understand the various activities and behaviors of our
customers, Site visitors and others. We, or these third parties, do this for many
reasons, including: to recognize new or past visitors to our Sites; to present more
personalized content; to provide more useful and relevant ads - for example, if we
know what ads you are shown we can try not to show you the same ones
repeatedly; to identify visitors across devices, third party websites and sites, or to
display or send personalized or targeted ads and other custom content that is more
focused on a person’s perceived interest in products or services similar to those that
we offer.

Our interest-based ads may be served to you in emails or on third-party platforms.
We may serve these ads about our products or services or send commercial
communications directly ourselves or through these third parties.
Visitors may opt out of receiving interest based advertising by advertising networks
that may be delivered to them on our platform and other websites by visiting the
following websites: []
These features will opt a Visitor out of many – but not all - of the interest-based
advertising activities in which we or third parties engage.]

Third Party Cookies
We are legally required to disclose whether other third parties may collect

personally identifiable information about an individual's online activities from our
Site or Service. Please see our Cookie Policy for more information [insert link].
The information gathered by these third parties is used to make predictions about
your interests or preferences so that they can display advertisements or promotional
material on this Site and on other sites across the Internet tailored to your apparent

The business partners and advertising networks that serve interest-based
advertisements on the Services have limited access to a small amount of information
about your profile and your device, which is necessary to serve you advertisements
that are tailored to your apparent interests. It is possible that they may reuse this
small amount of information on other sites or services.

We do not share with these third parties any information that would readily identify
you (such as email address); however, these third parties may have access to
information about your device (such as IP or MAC address). We do not have access
to, or control over, the technologies that these third parties may use to collect
information about your interests, and the information practices of these third
parties are not covered by this Privacy Policy. Other than as discussed in this
document, we have no control over these third parties.

Minors’ Privacy
Protecting the privacy of minors is especially important. Our Service is not directed to minors under
the age of 16, and we do not knowingly collect Personal Data from persons under the age of 16
without obtaining parental consent. If you are under 18 years of age, then please do not use or
access the Service at any time or in any manner. If we learn that Personal Data has been collected on
the Service from persons under 16 years of age and without verifiable parental consent, then we will
take the appropriate steps to delete this information. If you are a parent or guardian and discover
that your child under 18 years of age has obtained an Account on the Service, then you may alert us
at [] and request that we delete that child’s Personal Data from our systems.
The Service is not intended to be used by minors, and is not intended to be used to post content to
share publicly or with friends. To the extent that a minor has posted such content on the Service, the
minor has the right to have this content deleted or removed using the deletion or removal options
detailed in this Privacy Policy. If you have any question regarding this topic, please contact us as
indicated in the [“How to Contact Us”] section. Please be aware that, although we offer this deletion
capability, the removal of content may not ensure complete or comprehensive removal of
that content or information.

Data Security
We follow generally accepted industry standards to protect the information
submitted to us, both during transmission and once we receive it. We use ISO
certified cloud services and applications. We maintain appropriate administrative,
technical and physical safeguards to protect Personal Data against accidental or
unlawful destruction, accidental loss, unauthorized alteration, unauthorized

disclosure or access, misuse, and any other unlawful form of processing of the
Personal Data in our possession. This includes, for example, firewalls, password
protection and other access and authentication controls. We use TLS technology to
encrypt data during transmission through public internet and ISO certified cloud
services and applications, [and we also employ application-layer security features to
further anonymize Personal Data.]

However, no method of transmission over the Internet, or method of electronic
storage, is 100% secure. We cannot ensure or warrant the security of any
information you transmit to us or store on the Service, and you do so at your own
risk. We also cannot guarantee that such information may not be accessed,
disclosed, altered, or destroyed by breach of any of our physical, technical, or
managerial safeguards. If you believe your Personal Data has been compromised,
please contact us as set forth in the [“How to Contact Us”] section.
If we learn of a security systems breach, we will inform you of the occurrence of the
breach in accordance with applicable law.

Data Retention
We only retain the Personal Data collected from a User for as long as the User’s
account is active or otherwise for a limited period of time as long as we need it to
fulfill the purposes for which we have initially collected it, unless otherwise required
by law. We will only retain and use information as necessary to comply with our legal
obligations, resolve disputes, and enforce our agreements.

Privacy Settings
Although we may allow you to adjust your privacy settings to limit access to certain
Personal Data, please be aware that no security measures are perfect or
impenetrable. We are not responsible for circumvention of any privacy settings or
security measures on the Service. Additionally, we cannot control the actions of
other users with whom you may choose to share your information. Further, even
after information posted on the Service is removed, caching and archiving services
may have saved that information, and other users or third parties may have copied
or stored the information available on the Service. We cannot and do not guarantee
that information you post on or transmit to the Service will not be viewed by
unauthorized persons.

Data Transfer
International transfers

[The Company will not transfer personal information outside the European Economic
Area (EEA), which comprises the countries in the European Union and Iceland,
Liechtenstein and Norway.

The Company may transfer personal information outside the European Economic
Area (EEA) (which comprises the countries in the European Union and Iceland,
Liechtenstein and Norway) to [insert name of country] on the basis [that that
country, territory or organization is designated as having an adequate level of
protection OR that the organization receiving the information has provided
adequate safeguards by way of [binding corporate rules OR standard data protection
clauses OR of compliance with an approved code of conduct]].]

The Company will ensure that staff are adequately trained regarding their data
protection responsibilities. Individuals whose roles require regular access to personal
information, or who are responsible for implementing this policy or responding to
subject access requests under this policy, will receive additional training to help
them understand their duties and how to comply with them.
Foreign Visitors
The Service is hosted in the UK. If you choose to use the Service from regions of the
world with laws governing data collection and use that may differ from EU and UK
law, then please note that you are transferring your Client Data and Personal Data
outside of those regions to the UK for storage and processing. Also, we may transfer
your data to other countries or regions in connection with storage and processing of
data, fulfilling your requests, and operating the Service. By providing any
information, including Client Data and Personal Data, on or to the Service, you
consent to such transfer, storage, and processing.

Data Controller and Data Processor
We do not own, control or direct the use of any of the Client Data stored or
processed by a Client or User via the Service. Only the Client or Users are entitled to
access, retrieve and direct the use of such Client Data. We are largely unaware of
what Client Data is actually being stored or made available by a Client or User to the
Service and do not directly access such Client Data except as authorized by the
Client, or as necessary to provide Services to the Client and its Users.
Because we do not collect or determine the use of any Personal Data contained in
the Client Data and because it does not determine the purposes for which such
Personal Data is collected, the means of collecting such Personal Data, or the uses of
such Personal Data, we are not acting in the capacity of data controller in terms of
the European Union’s Directive 95/46/EC on data privacy or the European Data
Protection Regulation (“GDPR”) and do not have the associated responsibilities
under GDPR.

We should be considered only as a processor on behalf of our Clients and Users as to
any Client Data containing Personal Data that is subject to the requirements of
GDPR. Except as provided in this Privacy Policy, We do not independently cause

Client Data containing Personal Data stored in connection with the Services to be
transferred or otherwise made available to third parties, except to third party
subcontractors who may process such data on our behalf in connection with our
provision of Services to Clients. Such actions are performed or authorized only by the
applicable Client or User.

The Client or the User is the data controller under the Directive for any Client Data
containing Personal Data, meaning that such party controls the manner such
Personal Data is collected and used as well as the determination of the purposes and
means of the processing of such Personal Data.
We are not responsible for the content of the Personal Data contained in the Client
Data or other information stored on our servers (or our subcontractors’ servers) at
the discretion of the Client or User nor are we responsible for the manner in which
the Client or User collects, handles disclosure, distributes or otherwise processes
such information.

Changes and Updates to this Policy
Please revisit this page periodically to stay aware of any changes to this Policy, which
we may update from time to time. If we modify the Policy, we will make it available
through the Service, and indicate the date of the latest revision, and will comply with
applicable law. Your continued use of the Service after the revised Policy has become
effective indicates that you have read, understood and agreed to the current version
of the Policy.

How to Contact Us
Please contact us with any questions or comments about this Policy, your Personal
Data, our use and disclosure practices, or your consent choices by email at
This email address is being protected from spambots. You need JavaScript enabled to view it..

Changes to this privacy policy
This privacy policy was published on 21/05/2018 and last updated on 21/05/2018

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