Privacy Policy

This Policy is an integral part of the User Agreement (“Agreement”). Thus, by entering into the Agreement and the said agreements in the manner set forth therein, including the use of the Application, you accept the terms of this Policy in full.
The methods of processing Personal Information include any action (operation) or combination of actions (operations), including collection, recording, systematization, storage, clarification (updating, modification), extraction, use, transfer (provision, access), anonymization, blocking, deletion, destruction for the purposes set forth in this Policy with or without the use of automated means at the discretion of Habra.
Hereinafter in this Policy, the terms and definitions provided by the Agreement and other agreements concluded with the User are used, unless otherwise provided by this Policy or arising from its essence. Otherwise, the term used in this Policy shall be interpreted in accordance with applicable law, customary business practice, or scientific doctrine.

Personal Information

Personal Information in this Policy means:

  • Information that the User provides about himself/herself upon registration or authorization, as well as in the process of further use of the Application and/or the Service, including the User’s personal data.
  • Data that is transmitted automatically depending on the settings of the User’s software in an impersonal form.
  • Art&Ca has the right to establish requirements for the composition of the User’s Personal Information that must be provided in order to use the Application and the Service based on it. If certain information is not marked by Art&Ca as mandatory, it is provided or disclosed by the User at his or her own discretion.
  • When registering, the User must specify an account name (login), email address and password. When registering, Art&Ca creates a unique identifier for each User (user_id). The User_id is linked to the User’s profile information.
  • In order to conclude the Contracts the User can also provide the following personal data about themselves: name, title, phone number.
  • If a natural person is acting on behalf of an organization, he can provide in addition the name, TIN, KPP, OGRN, registration address and postal address of such organization, corporate phone number, settlement account, name of the servicing bank, its BIK and correspondent account. The specified information about the organization does not relate to personal data.
  • If a natural person acts as an individual entrepreneur or in his interests, at the request or with the direct written consent of such individual entrepreneur, respectively, the following may be additionally provided: the name and initials of the individual entrepreneur, TIN, OGRNIP, and address for correspondence, telephone number, settlement account, the name of the servicing bank, its BIK and correspondent account.
  • Data disclosed by the User to an unspecified circle of people. Using the functionality of the Application, the User may independently, by their own actions, at their own discretion, disclose to an unspecified circle of people (publish in the Application) information of their profile in the Application, which may include personal data, including: full name, first name, middle name, gender, date of birth, city of location, place of work, position, information about themselves in a free form. The information you add to your profile becomes available to an unlimited number of people, subject to the profile information display settings in the Service.
  • Art&Ca does not verify the accuracy of the Personal Information provided and the availability of the User’s necessary consent to its processing in accordance with this Policy, assuming that the User acts in good faith, with discretion and makes all necessary efforts to keep such information up to date and to obtain all necessary consents from the subjects of personal data.
  • Art&Ca collects and stores data about the User’s actions on the Service, using log files. In the case of actions performed by an authorized User, such information is linked to the User ID.
  • Within the framework of providing certain types of services, Art&Ca may provide Users with the ability to independently place on certain pages of the Site the software for the collection and processing of anonymized data, similar to the one specified in paragraph 2.7 of this Policy, as a result of which such Users can receive the data specified in paragraph 2.1.2 in anonymized form. The composition and conditions for the collection of anonymized data in this case shall be determined by the User who has placed the software for the collection and processing of anonymized data, but may not be in conflict with this Policy.
  • Art&Ca is not responsible for how the User’s Personal Information is used by third parties with whom the User interacts as part of the use of the Application and/or the Service.

Legal basis for processing Personal Information

The legal bases on which Art&Ca uses Personal Information include:

  • Processing of Personal Information when the User has provided consent to the processing for one or more specific purposes;
  • Processing of Personal Information when it is necessary for the performance of a contract to which the User is a party;
  • Processing of Personal Information when it is necessary for the conclusion of a contract with the User;
  • Processing of Personal Information that is necessary for Habr to perform its obligations under applicable law.

Policy Regarding Children.

Art&Ca does not knowingly collect Personal Information from, solicit or allow children under the age of 18 to use the Application. Individuals under the age of 18 are not permitted to provide personal information, including name, address, phone number, and email address. If Art&Ca becomes aware that information has been obtained from a child under the age of 18, Art&Ca will promptly delete such information. If you believe that we may have received any information from or about a child under the age of 18, please contact us at art&[email protected].

Purposes of Processing Personal Information.

Art&Ca will process, including the collection and storage of the Personal Information that is necessary to enter into and perform contracts with the User, and that is made publicly available by the User by filling out a profile and setting settings in myAlpari.

Art&Ca may use Personal Information for the following purposes:

  • Conclusion of contracts for the use of the Application and the Service;
  • Conclusion of the Contract is carried out remotely through the exchange of electronic documents, which are signed by a simple electronic signature. In this case, the role of the User’s simple electronic signature key can be a pair of login – password or their email address. That’s why they are requested when registering.
  • Performance of obligations under the concluded contracts, including providing the User access to the Application and the Service; Applications for the provision of access to the Service are accepted using the software tools of the Application and email. As part of the functionality of the Service, the Rights Holder shall store, systematize and display the User profiles containing Personal Information in the Application.
  • Identification of the User within the framework of performance of obligations under the agreements concluded with the User; the User’s Personal profile is linked to the User’s login-password and email address.
  • Providing technical support in connection with the use of the Application and the Service;
  • Requests to the support service are accepted using the software tools of the Application and e-mail.
  • Providing communication with the User for the purpose of information service and improving the quality of the Service under the signed Agreements, including in the order of notification with the involvement of third parties;
  • Communication with the User is carried out through e-mail or by subscriber phone number specified by the User during registration or during the use of the Application and/or the Service.
  • Using impersonal data for targeting advertising and/or informational materials by age, gender, other characteristics.
  • Conducting marketing, statistical and other research on the basis of anonymized data. The data from the data collection systems specified in clause 2.7. in impersonal form shall be collected and analyzed in order to find out how much time Users spend in different sections of the Application, their interests and preferences.
  • Compliance with legal requirements.
  • As the organizer of distribution of information on the Internet, Art&Ca stores information on the facts of reception, transmission, delivery and (or) processing of written text, images, sounds, video or other electronic communications of Internet users and information about these users for one year from the end of such actions.

User rights with respect to Personal information

If provided by applicable law, the User has the right:

  • To receive information about the collection and use of their personal data.
  • To gain access to his personal data and to correct it if it is incorrect or incomplete.
  • To prohibit the processing of their personal data if their accuracy is disputed, the processing is unlawful, as well as in cases where Art&Ca no longer needs the personal data for the purposes for which they were processed by Art&Ca.
  • To object to the processing of his/her personal data and to prohibit its processing in cases where Art&Ca has processed it in the performance of tasks in the public interest or in its own legitimate interests, and where there is no compelling need to continue such processing.
  • To withdraw at any time the consent that the User has given to the processing of their personal data. In the event that the User withdraws its consent to the processing of personal data, such withdrawal will not affect the lawfulness of the processing that Art&Ca carried out on the basis of such consent prior to its withdrawal.
  • To request the deletion of their personal data when: they are no longer relevant to the purposes for which they were collected or processed; when consent has been withdrawn and Art&Ca has no grounds to continue processing; when there are objections to further processing for the public benefit or Art&Ca’s own legitimate interests and there is no compelling need to continue such processing; when personal data have been processed unlawfully.
  • Not to be subject to a decision based solely on automated processing, including profiling, which creates legally significant consequences for the User or affects in other similar ways, unless there is a legal basis for continuing the processing.
  • To receive personal data in a structured, commonly used, and machine-readable form, in order to be able to transfer the data, in cases where Art&Sa processes the personal data provided by automated means.
  • These rights may be exercised by using the tools that Art&Ca offers in the Appendix or by making a specific request to Art&Ca in the ways described below. Art&Ca will respond in a timely manner to any such requests in accordance with applicable law. In some cases, Art&Ca may ask the User to go through an identification process before processing the request. User may contact the appropriate supervisory authority in its jurisdiction if Art&Ca’s response is not satisfactory.

Retention of Personal Information

All Personal Information collected shall be retained only for the period necessary to fulfill the purposes for which such information was collected or for the period permitted or required by the provisions of applicable law. Art&Ca periodically reviews its data processing systems to determine whether the purposes for which users’ personal information is collected and processed remain valid. Such determination is based on a number of factors, which include, but are not limited to: whether the User maintains a relationship with Art&Ca, whether Art&Ca has fulfilled the User’s requests (including any additional tasks), whether a contractual relationship exists between the User and Art&Ca, and whether contractual or legal grounds exist for continuing to store the User’s personal data. Based on the results of such verification and notifications received from personal data subjects, Art&Ca will update its systems. In order to improve the quality of the Service and enable legal protection, Art&Ca may store log files of actions performed by the User within the use of the Application and/or the Service, as well as in connection with the conclusion and performance by the User of the Agreement and other contracts on its part, for a period of 1 (One) year from the date of their execution.

Requirements for the protection of Personal Information

Art&Ca stores Personal Information and protects it from unauthorized access and dissemination in accordance with its internal rules and regulations.

With respect to the Personal information of the User its confidentiality is preserved, except for information disclosed by the User to the public (clause 2.4. of this Policy), and other cases where the technology of the Application or the Service provided on its basis, or the settings of the software used by the User provides for the open exchange of information with other users of the Application or with any users of the Internet.

Transfer of Personal Information

Art&Ca may share Personal Information with third parties in the following cases:
The User has expressed his or her consent to such actions, including when the User applies settings to the software used that do not restrict the provision of certain information;
The transfer is necessary as part of the User’s use of the functionality of the Application and/or the specifics of the Service based on it;
In connection with the transfer of the Application to the possession, use or ownership of such third party, including the assignment of rights under contracts concluded with the User in favor of such third party;
At the request of a court or other authorized governmental body within the procedure established by law;
To protect the rights and legitimate interests of Art&Ca in connection with the violation of contracts concluded with the User.

Modification and deletion of Personal information

The User has the right to edit at any time the Personal information he/she provided during registration or authorization in his/her myAlpari.
You may delete your account or exercise your right to withdraw your consent to the processing of your Personal Information by sending Art&Ca a request to delete your account to art&[email protected].

Changing this Privacy Policy

This Policy may be changed or terminated unilaterally by Art&Ca without prior notice to the User.

A new version of this Policy becomes effective upon its posting on Art&Ca’s website, unless otherwise provided for in the new version of this Policy.