PRIVACY POLICY

Moscow, March 01, 2019

This Personal Data Privacy Policy (hereinafter, the "Privacy Policy") applies to all information, the HRBOX on the hrbox.io domain can receive about the User while using the site, software, and products.

1. TERMS AND DEFINITIONS

1.1 The terms in this Privacy Policy shall have the following meaning:

1.1.1. Oscar Group LLC, INN (Taxpayer Identification Number) 7714457444

1.1.2. "Software, Platform (HRBOX®)" shall mean a software package for electronic computing machine (computers) developed by the Licensor, and is its intellectual property, non-exclusive rights to use which are transferred to the Licensee. Access to the Software is provided by the Internet using the Mobile App or a web browser.

1.1.3. "Mobile App" shall mean the HRBOX mobile application available for installation through Google Play Services, the Apple Store, or other similar services.

1.1.4. "Platform Administration" shall mean employees authorized to manage the platform, and acting on behalf of Oscar Group LLC, who arranges and/or performs the personal data processing, and also determines the purposes of personal data processing, the composition of personal data to be processed, actions (operations) with personal data.

1.1.5. "Personal Data" shall mean any information relating directly or indirectly to the identified or identifiable natural person (personal data subject).

1.1.6. "Personal Data Processing" shall mean any operation or set of operations which is performed on personal data whether or not by automated means, such as collection, recording, organization, structuring, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.

1.1.7. "Personal Data Privacy" shall mean a binding requirement upon the Platform Administration or other person who has access to personal data to prevent their distribution without the consent of the personal data subject or other legal grounds.

1.1.8. "Platform User (hereinafter, the "User")" shall mean a person who has access to the Platform via the Internet and uses the Platform.

1.1.9. "Cookies" shall mean a small piece of data sent by a web server and stored on the user's computer, which the web client or browser sends to the web server in an HTTP request every time it tries to open a page of the corresponding site.

1.1.10. "IP Address" shall mean a unique network address of a node in a computer network built using the IP protocol.

2. GENERAL PROVISIONS

2.1. The use of the Platform by the User means acceptance of this Privacy Policy and the terms of personal data processing.

2.2. In case of disagreement with the terms of the Privacy Policy, the User must stop using the Platform.

2.3. This Privacy Policy applies to the HRBOX Platform only. The Platform does not control or take liability for the websites of third parties, to which the User can follow the links available on the Platform.

2.4. The Platform Administration does not verify the accuracy of personal data provided by the Platform User.

3. SUBJECT OF THE PRIVACY POLICY

3.1. This Privacy Policy sets forth the obligations of the Platform Administration to not disclose and ensure the confidentiality of personal data that the User provides at the request of the Platform Administration at registration or using the Platform.

3.2. Personal Data authorized for processing hereunder is provided by the User in the registration form of the HRBOX Platform and includes the following:

— surname, name, patronymic, including the former ones; gender; date of birth; age; place of birth, nationality, citizenship;

— postal address, contact telephones, e-mail addresses, nicknames, identifiers in social and communication media;

— addresses of registration and actual residence, details of the identity documents, details of personal identifiers in the state recording systems;

— photo and video images provided by the user and uploaded into the software;

— professional activity, skills and qualifications (education background, profession, professional grade assigned, fluency in foreign languages, completed training, internships and practices);

— electronic user data (user identifiers, network addresses, cookies, device identifiers, screen sizes and resolution, information about hardware and software, such as browsers, operating system, installed applications, geolocation, language settings, time zone, time and statistics of applications and information resources use, user actions in services, user-created content) and other information in accordance with the standard forms, applicable procedures and purposes of processing.

— other personal data provided by the personal data subject or the operator of personal data.

— a list of user contacts, including, but not limited to, user accounts included in the interaction within the software.

3.3. The Platform protects Data that is automatically transmitted during viewing of advertising blocks and visits to Site pages with the statistical system ("pixel") installed:

3.3.1. Disabling cookies may result in the inability to access sections of the Platform, requiring authorization.

3.3.2. The Platform collects statistics about the IP Addresses of visitors. This information is used to identify and solve technical issue, to control the legality of financial payments.

3.4. Any other personal data not specified above (history of actions, etc.) shall be subjected to secure storage and nondisclosure, unless otherwise provided in Clauses 5.2. and 5.3. hereof.

4. PURPOSE OF PERSONAL DATA COLLECTION

4.1. The Platform Administration may use the User's personal data for the following purposes:

4.1.1. Performance under services contracts, provision of rights to use the software.

4.1.2. Identification of the User registered on the Platform for the Platform services use.

4.1.3. Providing the User with access to the personalized resources of the Platform.

4.1.4. Communication with the User, including provision of notifications on the Platform use, mailings and information messages, processing requests and applications from the User.

4.1.5. Organization of conferences, seminars, webinars and other public events;

4.1.6. Determining the location of the User to ensure security, preventing fraud.

4.1.7. Confirmation of the accuracy and completeness of personal data provided by the User.

4.1.8. Creating an account to work on the Platform, if the User has agreed thereto.

4.1.9. Notifying the Platform User about various changes related to his/her activities on the Platform.

4.1.10. Providing the User with effective customer and technical support in case of issues related to the use of the Platform.

4.1.11. Subject to the User's consent, providing of functional updates, newsletters and other information on behalf of the Platform or its partners.

4.1.12. Subject to the User's consent, advertising.

4.1.13. Provision of the User with access to the websites or services of the Platform's partners to receive updates and services.

4.1.14. Collection and processing of analytical data on the Company's activities.

4.1.15. Permissions used in the Software:

— Permission to send notifications. Used to obtain up-to-date information by the User online.

— Access to the Camera and Microphone of the device. Used to obtain access to the Platform by QR-code scanning and to facilitate the User's uploading the photo and video on the Platform.

— Access to Gallery and the Device Files. Used to upload photos, videos, documents and other types of files applied by the software. HRBOX does not take liability for the content uploaded by User.

— Access to Device Contacts. Used to store the contact information of users with whom the user interacts within the Program.

5. PERSONAL INFORMATION PROCESSING METHODS AND TERMS

5.1. The User's personal data is processed without for indefinite term, in any legal way, including in personal data information systems whether or not by automated means.

5.2. The User agrees that the Platform Administration has the right to transfer personal data to third parties, in particular, to other registered Users of the Platform.

5.3. The User's personal data may be transferred to the authorized state authorities of the Russian Federation only on the grounds and subject to terms set forth by the laws of the Russian Federation.

5.4. In the event of loss or disclosure of personal data, the Platform Administration informs the User thereon.

5.5. The Platform Administration reasonably undertakes the organizational and technical measures to protect the User's personal data from unauthorized or accidental access, destruction, modification, blocking, copying, distribution, as well as from other illegal actions of third parties.

5.6. The Platform Administration, jointly with the User, reasonably undertakes to prevent losses or other negative consequences caused by the loss or disclosure of the User's personal data.

6. OBLIGATIONS OF THE PARTIES

6.1. User shall:

6.1.1. Provide personal data necessary to use the Platform.

6.1.2. Update, supplement the provided personal data in case of changes.

6.2. The Platform Administration shall:

6.2.1. Use the information received solely for the purposes specified in Clause 4 hereof.

6.2.2. Ensure that confidential information is kept secret, not disclosed without the prior written permission of the User, and also not sell, exchange, publish, or disclose in other possible ways the transferred personal data of the User, unless otherwise provided in Clauses. 5.2. and 5.3. hereof.

6.2.3. Take precautions to protect the confidentiality of the User's personal data in accordance with the customary business practice applied to protect this kind of information.

6.2.4. In case of revealing false personal data or illegal actions, block personal data relating to the relevant User from the moment the User or his/her legal representative or authorized body for the protection of the personal data subjects' rights submitted relevant request for the period of investigation.

7. LIABILITY OF THE PARTIES

7.1. For failure to perform hereunder, the Platform Administration shall be liable for losses incurred by the User in connection with the unlawful use of personal data in accordance with the laws of the Russian Federation, unless otherwise provided in Clauses 5.2., 5.3. and 7.2. hereof.

7.2. The Platform Administration shall not be liable for loss or disclosure of Confidential Information, provided such confidential information:

7.2.1. Became public property before its loss or disclosure.

7.2.2. Was received from a third party until before provision to the Platform Administration by the User.

7.2.3. Was disclosed with the consent of the User.

7.3. The liability of the Company's employees engaged in personal data processing on the grounds of their functional duties for the proper processing and misuse of personal data is established in accordance with the terms of the non-disclosure agreement made by and between the Company and the employee.

8. DISPUTES RESOLUTION

8.1. In the event of dispute arising from the relationship between the Platform User and the Platform Administration, the complaint procedure (a written proposal for voluntary settlement of the dispute) shall be mandatory before filing a claim with the court.

8.2 The compliant recipient shall, within 30 calendar days from the complaint receipt date, notify the claimant in writing of the results of the complaint consideration.

8.3. Should the parties fail to reach an agreement, the dispute shall be referred to the judicial authority in accordance with the applicable laws of the Russian Federation.

8.4. This Privacy Policy and the relationship between the User and the Platform Administration are governed by the applicable laws of the Russian Federation.

9. MISCELLANEOUS PROVISION

9.1. The Policy is a public document of the Company, and its up-to-date version is available for reading at https://hrbox.io/policy.

9.2. The Policy is approved for indefinite term. The Platform Administration has the right to change this Privacy Policy without the consent of the User.

9.3. The reinstated Privacy Policy shall come into force from the publication on the Platform, unless otherwise provided by the reinstated Privacy Policy.

9.4. Please, submit your suggestions or questions regarding this Privacy Policy to lina@hrbox.io

9.5. The Privacy Policy is published at www.hrbox.io.

Additional information about the licensor (right holder):

Licensor (right holder): Oscar Group LLC

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For all questions, please contact 8 (800) 600-36-65, via email: info@hrbox.io