PRIVACY POLICY AND USER AGREEMENT

This Privacy Policy and User Agreement sets out relations between «Inconnections» Ltd. (Limited Liability Company), PSRN 1197746047070/TIN 9729279893, hereinafter the «Company» on one side and a Person, hereinafter referred to as the «User» on the other side on using the program for an electronic computer (hereinafter – «Inconnections Service», «Service», «Mobile Application»), as follows:

1. Terms and definitions, used in the Agreement:

Administration – company staff, as well as the individuals responsible for the properly management of the «Inconnections Service» and Company Service delivery to the Users, in the use of mobile Application of the latter.

Service – a combination of programs intended for the Computer and other objects of intellectual property of the Company (including graphical design of the interface and etc.), the information (Content), placed by the Company and/or the Users. Access to the Service is possible through the mobile application.

User – an individual person, registered and having necessary legal capacity for getting access to the Service and realization all opportunities, provided by the Service functional.

Login – a symbolic combination independently chosen by a user or an e-mail address/mobile phone of the user. Registration or using several logins by the same users is forbidden.

Password - a symbolic combination independently chosen by a User and providing along with a login his identification, while Service usage.

Announcement – information report about an Item (including photos, prices and other additional information of the Item), placed through the Service into the Mobile Application by the User and addressed to an unspecified group of persons.

Private office (User Account) – communication interface between a User and the Service, where it is possible to place, change personal information (surname, name, photo, phone number, contacts), make query (search) of necessary profiles and their viewing, accessed by the User after his registration on the Service.

User Contacts – unlimited group of people, whom a User is directly relevant to and can contact if necessary (the user is entitled to publish contact data of third parties to any other users to his discretion and solely responsible for this actions).

Promo code - a symbolic combination independently chosen by a User which is assigned to him and pointed by new (involved) Users, while their registration in the Service.

Search – an action performed through the message by a User to a different one, if one user or another is suitable for him in the area which is sought.

Contacts – the group of persons, whose areas of activity a User provided, as that ones with whom he can connect others, in accordance with the choice of the field, which is given to him.

2. Service terms of use. Application of the Agreement.

2.1. This User Agreement (hereinafter referred to as the - «Agreement») has been prepared by the Company and defines Service terms of use, along with the rights and obligations its Users and the Company. The Agreement also regulates the relations concerning for protection of the rights and interests of third parties, who are not Users, but whose rights and interests may be affected as a result of Users' actions.

2.2. Any User is required to gain a full understanding with this Agreement in advance of the Service usage. User's actions within the Service such as search, viewing, registration on the Service and other activities related to the functional possibilities of the Service, mean that User fully and unconditionally accepts this Agreement and its Regulations, and at the same time agrees to receive information and advertising e-mails.

The Agreement of the Service usage concluded in the form of a public offer and provided by the Civil Code of the Russian Federation does not demand a bilateral signing and is valid in electronic form.

2.3. The Company reserves the right from time to time to change, modify, or supplement this Agreement, Privacy Policy. In case any significant changes, the relevant notification will be published by the Company in the Application, in order to the User will become aware with the modifications prior to their entering into force. The Company accepts the fact that changes may not have retroactive effect. If you disagree with any developments, you may close down your personal account. If you carry on using the Service after publication or sending notification about any changes in the agreement, it means you automatically agree with all updated terms and conditions.

3. User Registration

3.1. A person wishing to become a User is obliged to register at the appropriate page of the Service. Registration is voluntary and free. The User guarantees to the Company that he has reached the age permissible under the law oh his Country for acceptance this Agreement and Regulations and possesses the relevant powers to use this Service.

3.2. Upon registration a User will be received the Login and Password chosen by himself, which will be used furthermore dealing with the Service. The User must complete Registration only once.

In case a User has been invited to the Service by another User, he may indicate personal promo code of that User who has invited him.

3.3. At registration User is obliged to provide accurate and up-to-date information to the Service Administration for creating his personal page including unique for every User Login (e-mail/phone/chosen by user login) and Password as well as his name, last name and telephone number.

Registration form of the Service may request any additional information from the User.

3.3.1. If the User is a Legal Entity, when registering on the Service, the User provides the Service Administration with the necessary reliable and relevant information to form the User's personal page, including the unique for each User Login (email address / phone number / user name chosen by the User), as well as the full name of the Legal Entity, legal form, and Tax Identification Number (TIN), surname and name of the authorized representative, and phone number, also, such Users must be provided with supporting documents (charter, TIN / KPP assignment certificate; order on the appointment of the General Director; Decision to create a company) to the mail of the Service administration (info@inconnections.pro).

3.4. User individually selects password, however the Company strongly recommends choosing Password minimum of 6 characters in length, including simultaneously lowercase, capital letters and numbers.

3.5. At registration User is responsible for giving accurate, timely, complete, relevant legislative information and its freedom from third parties claims. You shall be solely responsible for the safekeeping of Your Password and shall not disclose it to any third party.

3.6. Company assumes no responsibility for User rights violations by third parties having obtained unauthorized access to the Login and Password of the User.

3.7. At registration User expresses his consent with this Agreement and takes all specified rights and obligations connected with use of the Service.

3.8. In accordance with the Russian Federation Law, users' personal information shall be gathered and processed legally. The Company processes personal data for the purposes of providing access to the Service and its functional to the Users along with checking, research and analysis of such data which allow to maintain and improve current functional of the Service and develop a new one as well. The Company takes appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. We restrict access to personal information to Company employees, contractors and agents who need to know that information in order to operate, develop or improve our service and provide users access to it. The Company is entitled to use the information and personal data published by Users with the aim of implementation of existing legislation (including preventing and/or punishing illicit and/or unlawful activities from the Users). Disclosing user information can be imposed in accordance with the present legislation as required by the court, law enforcement officials, in other circumstances provided for in the law as well. Taking into account personal data processing for the implementation of the present Agremeent, the consent of the Users is not required in accordance with the Law "On Personal Data".

3.9. User accepts that for the aims provided for in this Agreement, the Company may gather and manage additional information concerning any User, which is got through the access to the Service or from third parties and including data on technical means (devices) along with the ways of technological interaction with the Service (IP address of the host, kind of operating system of the User, type of browser, geographical position, data on providers and etc), user activity on the Service and other data received by specified ways. Company has the right to dispose of statistical information related to the functioning of the Service together with the users' information to organize functioning and technical support of the Service and performance the terms of this Agreement.

4. Agreement subject and Service description.

4.1. Under this Agreement the Company provides its Users the right to utilize the Service as described in this Agreement.

4.2. The Service offers the Users a platform for:

-publishing information about his personal and contacts' line of work in his profile;

-posting information about the organization of the event in the User profile with the possibility of inviting other Service Users;

-search (request) and viewing necessary profiles;

- access to messages service which allows information exchange with users.

4.3. By default, the service provides the User with monthly (every 31 days from the moment of user registration) five free requests, while unused requests are burned out.

4.4. While the exhaustion of basic request limits, User is entitled to acquire packages of additional request limits on a paying basis, according to the rules, order and tariffs described in the Offer of the engagement agreement in the «Inconnections» mobile application. Such offer is an integral part of this Agreement and is available in the section «Confidentiality» in the Application.

5. User rights and obligations.

5.1. With regard to rules of the present Agreement, User is entitled to manage the Service for free as a computer program for posting information, profile searching and viewing.

5.1.1. If the User is a Legal Entity, then for registration on the Service for such User a monthly fee is provided for each calendar month.

5.2. When using the Service, User shall be obliged:

- comply with the provisions of this Agreement;

- fill in his profile with all necessary information in any language;

- before placing any information on the Service, assess the legality of its posting in advance;

-publish information only about the contacts in respect of those User can actually become the link.

- bring to the attention of the Users complete and solely reliable information about themselves and their contacts attached on the personal Profile/Account.

- personal data along with the information about private life of other users and third parties without prior approval of the latter must be kept secret and not to be provided other users and third parties who have become familiar in the result of communication with another users.

5.3. When using the Service, User shall be prohibited:

- register as a user on behalf of or for another person («false account»);

- to mislead the Users regarding your identity using Login and Password of another registered User;

- to distort information about yourself, your age or your relationship with other individuals or organizations;

- to upload, store, publish, distribute and provide access to or otherwise use any information that:

- contains threats, discredits, offends, denigrates the honour and dignity or business reputation or violates the privacy of other Users or third parties;

- violates the rights of minors;

- is vulgar or obscene, contains pornographic images and texts or scenes of a sexual nature involving minors;

- contains scenes of inhuman treatment of animals;

- contains a description of the means and methods of suicide, any incitement to commit it;

- promotes and / or arouses racial, religious, ethnic hatred or enmity, promotes fascism or the ideology of racial superiority;

- contains extremist materials;

- promotes criminal activity or contains advice, instructions or guidelines for the commission of criminal acts;

- contains information of limited access, including, but not limited to, state and commercial secrets, information on the privacy of third parties;

- contains advertising or describes the attractiveness of the use of narcotic substances, including "digital drugs" (sound files that affect the human brain due to binaural beats), information about the distribution of drugs, recipes for their manufacture and tips for use;

- is fraudulent;

- and also violates other rights and interests of citizens and legal entities or the requirements of the legislation;

- illegally to upload, store, publish, distribute and provide access to or otherwise use the intellectual property of the Users and third parties;

- use the software and carry out actions aimed at disrupting the normal operation of the Services or the users' personal pages;

- by any means, including but not limited to, by deception, abuse of trust, hacking, attempting to access to Login and Password of another User;

- carry out illegal collection and processing of personal data of other persons;

- place any other information that, according to the personal opinion of the Administration, is undesirable, does not correspond to the purposes of creating the Service, infringes the interests of the Users or, for other reasons, is undesirable for posting on the Service.



6. Rights and obligations of the Company

6.1. The Company carries out the current management of the Service, determines independently its structure, appearance and other elements. The Company keeps the right at any time to revise or change the design of the Service, its functionality, modify or supplement the scripts used, the software used or stored within the Service, and the terms of access to them for the Users.

6.2. The Company also has the right, at its own discretion, to terminate (temporarily or permanently) the provision of access to the Service, completely or in any part of it, to all the Users altogether or to an individual User.

6.3. The Company has the right, without reimbursement of any costs or losses at any time without notification to the User, to block the Personal Account of the User. Deleting the User's Personal Account means automatic deletion of all information contained in it. After deleting the Personal Account, the User loses access to the use of the Service. The Company has the right, but is not obliged, to restore the User's access to the Service.

6.4. The Company has the right to make comments to the Users, to warn, notify, inform them about non-compliance with the terms of this Agreement. The instructions of the Company addressed to the User regarding the use of the Service are binding for such a User.

6.5. The Company has the right at any time, at its own discretion, to conduct a random inspection of the Personal Accounts / Profiles for the purpose of compliance with this Agreement by the Users and their compliance (Accounts / Profiles) in accordance with current legislation.

6.6. The Company also has the right to request from the User at any time, and the User is obliged, upon the Company's request, to provide it with information, documents and / or materials confirming accuracy of the information provided by the User about himself (herself), in the Personal Account / Profile, and also its compliance with this Agreement and current legislation.

6.7. The Company has the right to send information (for example, development of the Service and its functionality) to the User on its own behalf or with the assistance of technical partners, including service and advertising messages, to the User's e-mail, mobile phone (SMS, phone calls), and push notifications. The User has the right at any time to refuse receiving of advertising and other information without explaining the reasons for refusal. Service messages informing the User about the status / changes in the status of purchase and sale transaction are sent automatically and cannot be rejected by the User, since such messages are a necessary condition for the provision of services.

6.8. The user has the right to refuse receiving of advertising messages after creating the Personal Account of the User in the mobile application of the Service by editing the Personal Account of the User (in the application in the section "Alerts" in the "Profile Settings").



7. Warranties, Liability, Risk-taking by the Users

7.1. The use of the Service is carried out by the Users:

– places independently information about himself (herself) regarding a kind of activity and information about its contacts.

– considers the Profiles / Personal Accounts of other Users at his (her) own discretion and under his (her) own responsibility and makes a decision regarding the sending of a request to one or another User.

7.2. If the User has doubts about the legality of the implementation of certain actions, including those related to the placement of Information in the Personal Account / Profile, the Company recommends to refrain from doing the latter.

7.3. The User is personally responsible for any information that he / she places in the Application, informs other Users, as well as for any interactions with other Users carried out at his / her own discretion.

7.4. The User undertakes to observe discretion when choosing a contact, at his / her own responsibility makes decision about request, independently verifying that the information specified in the Profile / Personal Account is valid and legal.

7.5. The Users are responsible for their own actions in connection with the use of the Service, including in connection with making requests for contacts, information about which is posted in the Profile / Personal Account,
creating and placing information in their own Personal Account and the other sections of the Service, in accordance with current legislation. Violation of this Agreement and current legislation entails civil, administrative and criminal liability.

7.6. The User confirms that he / she acts legally, has all the necessary rights (in particular for placing information about his / her contacts) and does not violate by his / her actions the legitimate rights and interests of third parties and current legislation.

8. Limitation of Liability of the Company

8.1. The Company does not provide any guarantee that the Service or its elements may be suitable for specific purposes of use. The company cannot guarantee and does not promise any specific results from the use of the Service or its elements. Service, including all scripts, individual elements and design of the Service are provided "as is".

8.2. The Company does not provide any guarantees of absence of service interruptions related to technical malfunctions, preventive maintenance, etc., however, it makes commercially reasonable efforts to ensure the operation of the Service around the clock. The Company does not provide any guarantee that the Service or any of its elements will function at any particular time in the future or that they will not stop working.

8.3. The Company is not responsible and does not provide redress for any damage, direct or indirect, caused to the User or third parties as a result of the use or inability to use the Service, unless otherwise provided by applicable legislation.

8.4. The Company is not responsible for any damage of device or software of the User or another person caused or associated with the use of the Service through no fault of the Company, or when clicking on the links provided by third parties to the Service.

8.5. Under no circumstances the Company and its representatives are responsible to the Users and / or third parties for any indirect, incidental, unintentional damage, including loss of benefit or lost data, damage to honour, dignity or business reputation caused in connection with the use of the Service, the content of the Service or other materials to which the Users or other third parties accessed through the Service, even if the Company warned or indicated the possibility of such harm, unless otherwise provided by applicable legislation.

8.6. The Company does not participate in formation of the content of the Personal Accounts and other sections of the Service. At the same time, the Company is not obligated to verify the Personal Accounts and their content, reliability of the Users. The Company is not responsible for the content of the information provided by the Users, including the content of his / her contacts and of his / her and their type of activity, the use by the Users of trademarks, third-party logos and other sections of the Service formed by the Users.

8.7. The Company is not a party to transactions between the Users, and is not an organizer, intermediary, agent or representative of any User and / or other interested party regarding the transaction proposed between the Users. All transactions made by the Users in connection with the placing on the Service of information about themselves and their contacts are concluded and executed without direct or indirect participation of the Company.

9. Service of Private Messages

9.1. After registration, the User is granted access to the messaging service, which allows exchanging correspondence with the Administration and other Users. Correspondence carried out through this service is not personal. The User, using this Service, accepts the fact that the Administration at any time has the right to read the messages sent.

9.2. The User agrees to receive personal messages from the Administration at any time and of any nature, including advertising. The Administration reserves the right to supplement the text of messages sent by the Users with advertising materials. The Administration does not carry out moderation (preview, evaluation and filtering) of messages sent by the Users to each other. The Users are not allowed to use the Service of Personal Messages for:

– Committing actions that violate the laws of the Russian Federation, the norms of international law;

– Uploading, sending, distribution, or any other way of publishing unauthorized advertising information, spam, "pyramids", "letters of happiness";

– Uploading, sending, distribution or any other way of publishing materials that are illegal, harmful, threatening, offending morality, slanderous, infringing copyrights, promoting hate and / or discrimination of people based on race, ethnicity, gender, social class;

– Uploading, sending, distribution or any other way of publishing materials that violate the rights of third parties.

9.3. The Administration reserves the right to provide in cases, stipulated by the legislation of the Russian Federation, access to personal messages of the User to third parties.

10. Terms and Conditions of Intellectual Property (Rights)

10.1. Exclusive rights to the Service, including but not limited to computer programs, databases, interface, technical developments, logo, trademark, other means of individualization used and allowing to implement the functionality of the Application, belong to the Company.

10.2. Except as established by this Agreement and the current law of the Russian Federation, neither the Service nor its components, including those listed in the paragraph above, may be copied (reproduced), processed, distributed, displayed in a frame, published, downloaded, transferred, sold or otherwise used in whole or in part without the prior written permission of the Company.

10.3. If the information (content) posted by the User is protected by copyright, the rights to such information are reserved by the User who posted such information.

At the same time, the User grants other Users of the Service a free, non-exclusive right to use such content by viewing, reproducing (including copying), processing (including printing copies) and other rights solely for the purpose of personal non-commercial use, except for cases where the use harms or may harm the legally protected interests of the copyright holder.
In addition, the User grants the Company a free, non-exclusive right to use the content posted on the Service and legally owned by him/her for the Company to ensure the functioning of the Service to the extent
determined by its functionality and architecture, and also to display the content in the Company's promotional materials, including for the purpose of displaying the Service interface, including by making such promotional materials available to the public, including for the purpose of advertising the Service on various information resources. The specified non-exclusive right is granted for the entire duration of the exclusive right and comprises, among other things, the right to reproduce the content and process the content, inter alia by incorporating the content into a complex object or composite work, to display the content, make it available to the public, post it by cable, etc. and is valid throughout the world. The Company is entitled to transfer the rights specified in this clause to third parties. The expiration of the content posting on the Service and/or of the validity period of the non-exclusive right does not entail the need to withdraw from circulation the Company's promotional materials with the display of content (including their removal from the Internet).

10.4. Nothing in this Agreement grants the User the right to use the logo, brand name, trademarks, domain names and other distinctive signs of the Company.

11. Applicable Law and Dispute Resolution.

11.2. If the User resides in the Russian Federation and abroad, he/she agrees that any disputes related to this Agreement and to other terms of use of the "Inconnections" Application shall be governed exclusively by laws of the Russian Federation without regard to the choice of law principles. The User agrees that all claims and disputes should be considered only in the courts of the city of Moscow (Russian Federation).

12. Territory of the Agreement.

12.2.The User has the right to use the Application throughout the territory of the Russian Federation and in other territories where it is accessible using mobile devices.

12.3.This Agreement shall enter into force for the User from the moment of his/her accession to the terms of the Agreement and shall be valid for an indefinite period.

Appendix No. 1 to the Agreement

Rules for Protecting Information about Users of the "Inconnections" Application

These Rules are an official document of the Company and determine the procedure for processing and protecting information about individuals (hereinafter referred to as "Users") using the services of the "Inconnections" Application (hereinafter referred to as the "Application") and its Services.

The purpose of these Rules is to ensure the proper protection of information about Users, including their personal data, from unauthorized access and disclosure.

Relations associated with collection, storage, distribution and protection of information about Users of the Application are governed by these Rules, other official documents of the Company and the current law of the Russian Federation.

The current version of the Rules, which is a public document, is available to any user of the Application in the "Service Rules" section. The Company is entitled to make changes to these Rules. When making changes to the Rules, the Administration of the Application notifies the Users about this by posting a new version of the Rules in the Appendix.

By registering and using the Application, the User agrees to the terms of these Rules.

If the User disagrees with the terms of these Rules, he/she should immediately stop using the Application and its services.

Terms of Use of the Application

Providing services for the use of the Application and its Services (hereinafter referred to as the "Application Services"), the Company, acting reasonably and in good faith, believes that the User:

- has all the necessary rights that allow him/her to register and use this Application;

- gives reliable information about himself/herself in the amount necessary for using the Application Services;

- is aware that information in the Application posted by the User about himself/herself may become available to other Users of the Application, may be copied and distributed by such Users;

- is aware that certain types of information transmitted by him/her to other Users cannot be deleted by the User;

- has read these Rules, accepts the Rules and assumes the rights and obligations specified in them.

- the Company does not verify the accuracy of the received (collected) information about its Users, except in cases where such verification is necessary in order for the Company to fulfil its obligations to the User.

Information Processing Purposes

The Company processes information about its Users, including their personal data, in order to fulfil the Company's obligations to the Users regarding the use of the Application and its Services.

Information about Users

User personal information includes the following:

- information provided by the Users and minimum required for registration in the Application: name, surname, date of birth, mobile number, e-mail address.

- information additionally provided by the Users at the request of the Company in order to fulfil the Company's obligations to the Users, namely: name, surname, e-mail address, date of birth, accounts in social networks, contact telephone number. Among other things, the Company is entitled to request from the User a copy of an identity document or another document containing the name, surname, photo of the User and other additional information which, at the discretion of the Administration of the Application, will be necessary and sufficient to identify such a User and will allow to exclude abuses and violations of the rights of third parties.

Other Information about Users Processed by the Company

The Company also processes other information about its Users, which includes the following:

- standard data automatically obtained when accessing the Application and by subsequent actions of the User (IP address of the host, type of the operating system of the User);

- information automatically obtained when accessing the Application using bookmarks (cookies);

- information created by the Users in the Application;

Users' Information Protection Measures

The Company takes technical and organizational-legal measures in order to ensure the protection of the User's personal data against unlawful or accidental access to them, their destruction, modification, blocking, copying, distribution, and against other illegal actions.

Login/e-mail address/phone number and the User Password are used to authorize access to the Application. The User is liable for the safety of this information. The User is not entitled to transfer his/her Login and Password to third parties, and is also obliged to take measures to ensure their confidentiality.

Processing User Information

The Company processes the personal data on the basis of the following principles:

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

- good faith;

- compliance of the purposes of personal data processing with the purposes predetermined and stated during the collection of personal data and with the powers of the Administration of the Application;

- compliance of the volume and nature of the processed personal data, methods of personal data processing with the purposes of personal data processing;

- inadmissibility of combining personal data databases created for incompatible purposes.

Conditions and Purposes of Personal Data Processing

The Company processes the User's personal data in order to fulfil the contract between the Company and the User for the provision of the Application Services (Agreement). As provided by Article 6 of the Federal Law No. 152-FZ of 27.07.2006 "On Personal Data", it is not required to have a separate consent of the user to processing of his/her personal data. As provided by subclause 2 of clause 2 of Article 22 of the said Law, the Administration of the Application is entitled to process the personal data without notifying the public authority for protection of the rights of subjects of personal data.

Collection of Personal Data

Personal data of the User are collected in the Application during Registration, as well as later when the User enters additional information about himself/herself on his/her own initiative using the Application Services. Personal data are provided by the User and are required during Registration.

Disclosure of Personal Data

The Users' personal data are not disclosed by the Company to any third parties, except for providing the Users' personal data for the purpose of performance of this Agreement and at the request of the competent state authorities (Prosecutor's Office, Police, Court and others) in order to comply with applicable laws of the Russian Federation and other countries.

Final Provisions

This Agreement implies the conclusion of an agreement between the User and the Company regarding the procedure for using the Application and its Services and supersedes all previous agreements between the User and the Company.

In case of any disputes or disagreements related to the execution of this Agreement, the User and the Company will use their best efforts to resolve them through negotiations. If disputes are not resolved through negotiations, they shall be settled in accordance with the procedure established by the current law of the Russian Federation.

This Agreement shall enter into force for the User from the moment of his/her accession to it and shall be valid for an indefinite period.