DEFINITION

“Website” means an information unit on the Internet, a resource of web pages (documents) that are united by a common theme and linked to each other by means of links. It is registered to the Copyright Holder and is necessarily linked to a specific domain, which is its address. This Policy has been developed for the following website: keeyak.com

“Personal Information” means a set of personal data and / or non-personalized information about the User, provided by him to the Copyright Holder and / or automatically collected by the Copyright Holder and / or third parties.

” Policy” means this Website Privacy Policy (with all existing additions and amendments).

” User” means a legal or natural person who uses the Site and / or has accessed it from any device.

”Terms of use“means an agreement concluded between the Copyright Holder and the User regarding the procedure, rules and features of using the Site. The user joins such an agreement and does not have the right to make and / or demand any changes or additions to it.

”Copyright holder” means the following person in whose name the Site is registered:

Zhejiang Jingyan Technology Co.,LTD. PRC, Zhejiang Province, Hangzhou, Yuhang district, Weilai Park, building 2, office 605

” Cookies” means small files sent by any site and placed on the User’s computers, smartphones, tablets, watches and other mobile devices to improve the operation of the sites, as well as the quality of the content posted on them.

RELATIONSHIPS TO WHICH THE POLICY APPLYS

General provisions This Policy is used and applicable solely to Personal Data received from the User in connection with his use of the Site. The provisions of this Policy are aimed at:

(1) determination of the types and types of Personal Data received, directions and purposes of use (processing) of Personal Data, as well as sources of obtaining such Personal Data; And

(2) determination of the User’s rights regarding the protection of the confidentiality of the Personal Data transmitted by him; And

(3) determination of persons responsible for the processing and storage of Personal Data, as well as third parties to whom such data is disclosed (in whole or in part).

The rules of this Policy do not apply in the case of processing by third parties of Personal Data that is voluntarily provided by the User.

By using the Site, the User agrees to the terms of this Policy and gives his consent to the Copyright Holder for the collection, processing, retention and storage of Personal Data in the manner and under the conditions provided for in this Policy. If the User does not agree with the terms of the Policy and / or certain terms of the Policy are not clear to him, in this case the User is obliged to immediately stop using the Site.

User rights to protect personal data In connection with the provision of Personal Data, the User automatically receives the following rights:

(1) receive data relating to their processing (grounds and purposes of such processing, methods of processing used, information about persons who have access to them or to whom they may be disclosed on the basis of an agreement or the Law).

(2) to receive data on the location and identification data of persons performing the processing of Personal Data.

(3) to receive data on the period of storage of Personal Data.

(4) to receive information about the completed or proposed cross-border transfer of Personal Data.

(5)appeal against the actions or omissions of the Copyright Holder to the authorized body for the protection of the rights of personal data subjects or in court.

(6) to receive damages and/or compensation for moral damages in court as a result of violations of the User’s rights to the protection and protection of his Personal Data committed by the Copyright Holder and/or third parties.

(7) exercise other rights in the field of personal data protection provided for by the Law or the provisions of this Policy.

LIST OF PERSONAL DATA COLLECTED

Non-personally identifiable user information In connection with the use of the Site, the Copyright Holder may automatically collect and process the following non-personalized information about the User:

(1) information about traffic, the possible number of clicks made, logs and other data.

(2)information about the location of the User (geolocation).The user can disable geolocation at any time by changing the appropriate browser settings.Geolocation is used by the Site only when the User actively uses it. When you exit the browser, geolocation stops working.

(3)device information (identification number of the device from which you are logging in, operating system, platform, browser type and other information about the browser,IP address). Personal data about users The User provides the Copyright Holder with the following personal data:

(1) email address.

(2) mobile phone number.

(3) data and information obtained as a result of combining certain Personal data of a particular User, as well as data and information received data about the User received from third parties (partners, marketers, researchers).

The user is the only person responsible for the completeness of the personal (personal) data provided and is obliged to change them in a timely manner (update, check, correct) on a regular basis.

The Copyright Holder assumes that all personal (personal) data provided by the User are reliable, and that the User keeps such information up to date.

Using Captcha Captcha is integrated into the Site, which is a type of Cookies, the purpose of which in this case is (1) to protect the User from possible spam coming from third parties on the Internet, as well as from other irrelevant and / or prohibited content, and (2) identification of the User in order to distinguish him from bots/robots, and (3) improvement of the User’s ability to use the content of the Site.

Logging into the site allows Captcha to automatically access and collect the following information:

(1) Cookies set in the browser within the last 6 (six) months; and/or

(2) number of clicks made by the User; and/or

(3) web page styling information; and/or

(4) browser language settings; and/or

(5) plug-ins installed in the User’s browser; and/or

(6) all Javascript objects.

Use of cookies

The Site uses certain Cookies to save the IP address, User preferences or the type of device used in order to (1) keep statistics of visits and site traffic, and (2) to personalize the displayed screen of the User’s data, and (3) saving the data necessary to identify the User, including when accessed from different devices, and (4) displaying advertisements in accordance with interests and User’s preferences. The Site may use both its own Cookies belonging to the Copyright Holder and Cookies of third parties.

The site uses the following Cookies:

(1)Technical (functional) cookies that are needed to control traffic and data transfer, to identify Users and provide access to the content for the User, and without which the use of the Site is functionally limited , as well as to prevent the provision of recommendations that do not correspond to the interests of the User.

(2) Statistical Cookies that are needed to track the frequency of visits to the Site by Users, to identify ways in which the Site is used, and to identify the type and type of content that is popular or interesting for the user.

(3) Location Cookies, which are needed to determine the location of the User in order to personalize the content displayed on the screen of his device.

(4) Third party cookies, which are set by third parties with the permission of the User and are intended to conduct statistical research regarding the User’s behavior on the Internet and/or send personalized advertising or marketing materials to the User and/or provision of goods or services.

The user has the right to disable cookies at any time by changing certain settings in his browser. Such disabling does not entail limiting or changing the User’s access to the functionality of the Site and / or its content. To disable Cookies, follow these steps:

________

PURPOSE OF COLLECTION AND PROCESSING OF PERSONAL DATA

Determining the purposes of processing The collection and processing of Personal Data is carried out for the following purposes:

(1) to analyze the User’s behavior, as well as to identify the User’s preferences for a particular type of content.

(2) for the efficient and correct operation of the Site, improving its functionality and content.

(3) to identify the User.

(4) to send personalized advertising and marketing materials to the specified email address and/or mobile phone of the User.

(5) to comply with the requirements of the Act.

(6) to determine the location of the User.

(7) for technical support of the Site, identification of problems in its operation and their elimination.

(8) to maintain contact with the User (communication).

(9) to fulfill other obligations of the Copyright Holder that arose before the User.

(10) for statistical research.

(11) for any other purpose, subject to obtaining separate consent from the User.

The processing of Personal Data is carried out on the basis of the principles:

(1) lawfulness of the purposes and methods of processing; and

(2) good faith; and

(3) conformity of the purposes of processing Personal Data with the purposes predetermined and declared at the time of collection of such Personal Data; and

(4) compliance of the volume and nature of the processed Personal Data with the stated purposes of their processing.

Conditions for the processing of personal data The processing of Personal Data is carried out in the following cases:

(1) obtaining consent from the User; or

(2) achievement by the Copyright Holder of the goals provided for by an international treaty or the Law; or

(3) provision by the User of their Personal Data to an unlimited number of persons; or

(4) to fulfill other obligations of the Copyright Holder to the User, including, but not limited to, providing certain content to the User; or

(5) saving the life or health of the User, when consent to the processing of his Personal Data cannot be obtained in advance.

In case of depersonalization of Personal Data, which does not allow to directly or indirectly identify the User, the subsequent use and disclosure of such data to third parties is allowed and the rules of this Policy are no longer applied to them.

The Rightholder takes all possible measures to protect the confidentiality of the received Personal Data, except when the User has made such data publicly available.

The processing of Personal Data is carried out using automation tools and without the use of such automation tools.

THIRD PARTY ACCESS TO PERSONAL DATA

Using analytics platforms The Copyright Holder uses the Yandex analytical platform to

(1) track the frequency of site visits by Users; and (2) tracking how the User uses the Site and/or its content; and (3) identifying the type and kind of content that is popular among Users; and (4) determining the location of the User. The User also gives his consent to the Copyright Holder to use the information received about the User from Yandex.

For these purposes, the Yandex analytical platform may collect data about the User’s IP address, geolocation, behavior, as well as their preferences and interests in relation to certain content.

The Yandex analytical platform gains access to Personal Data in order to provide the Copyright Holder with an understanding of how efficiently his Website works, what kind of content is popular, how effective it is to place this or that advertisement, as well as for the purposes of developing and/or improving an existing marketing strategy. Copyright holder.

From the moment of using the Site, the User agrees to Yandex’s Privacy Policy, as well as to the automatic installation of appropriate Cookies on the User’s device.

Disclosure of personal data to third parties The Copyright Holder has the right to disclose Personal Data

(1) to its affiliates, branches and representative offices opened both on the territory of the Russian Federation and on the territory of other states;

(2) to the successors of the Copyright Holder, which arose as a result of its liquidation, reorganization or bankruptcy, and who received exclusive rights to own the Site;

(3) to third parties solely for the purpose of providing the User with certain content or access to it;

(4) to third parties when the User has given consent to the disclosure, transfer or processing of their Personal Data, as well as in other cases expressly provided for by the Law or this Policy.

The Copyright Holder discloses Personal Data only if (1) is sure that third parties will comply with the terms of this Policy and take the same measures to protect the confidentiality of Personal Data that the Copyright Holder takes, and (2) consent to such disclosure has been previously expressed by the User and/or is permitted by law.

ADVERTISING

Advertising on the Site The Copyright Holder does not place advertisements on the Site.

Distribution of promotional materials The User agrees with the Rightholder’s right to send personalized advertising and marketing materials to the provided email address and/or mobile phone.

The User has the right to opt out of receiving such advertising and marketing materials at any time by performing the following actions:

[email protected] Please note that in case of refusal to receive advertising and marketing materials, the User may continue to receive any notifications from the Copyright Holder related to the use of the Site and / or its content.

SENDING COMPLAINTS AND REQUESTS TO THE RIGHT HOLDER

Request to stop processing personal data Each User has the right to express his objection to the Right Holder against the processing and / or storage of his Personal Data.

Such an objection can be expressed as follows:

[email protected]

Request for information about personal data

If the User has questions related to the procedure for applying or using this Policy, the procedure and / or method of processing Personal Data, the User can ask such a question as follows:

[email protected]

Changing (updating, supplementing, correcting) or deleting personal data

The User has the right to change or delete Personal Data at any time by sending a special request to the Copyright Holder at the following address: [email protected].

The Rightholder has the right to refuse to change or delete Personal Data if such actions will lead (1) to a violation of the rules of this Policy; or (2) to violate the Law; or (3) the nature of the Personal Data is evidence in any litigation that has arisen between the Copyright Holder and the User.

TERMS AND PROCEDURE FOR STORING PERSONAL DATA

Storage is carried out independently by the Copyright Holder. Storage is carried out within the following period: 3 from the moment of receipt of such information. After the expiration of the period of storage of Personal Data, such data is subject to their immediate destruction or depersonalization, unless otherwise prohibited by the Law or the provisions of this Policy.

ACCESS TO THE SITE FOR MINORS

The use of the Site is intended for persons over 18 years of age who access it only subject to the provision of prior consent to the processing of their Personal Data.

If the User is a minor, then he must immediately stop using the Site.

Protecting the confidentiality of Personal

Data is a paramount and important task for the Copyright Holder.The Rightholder adheres to all required international standards, rules and recommendations for the protection of Personal Data.

The Rightholder has implemented a number of technical and organizational methods aimed at protecting Personal Data from disclosure or unauthorized access by third parties. To ensure the safety and confidentiality of the received Personal Data, the Copyright Holder uses the following means of protection:

(1) SSL (Security Sockets Layer) protocol.

FINAL PROVISIONS

Policy Text Availability Users can read the terms of this Policy at the following link: keeyak.com/privacy-policy.

This version of the Policy is effective from February 18, 2023.

Changing and supplementing the policy This Policy may be changed from time to time.

The Copyright Holder does not bear any responsibility to the User for changing the terms of this Policy without the permission and / or consent of the User.

The user undertakes to regularly check the provisions of this Policy for possible changes or additions.

Disclosure Risk

Regardless of the measures taken by the Copyright Holder to protect the confidentiality of the received personal data, the User is hereby considered to be properly aware that any transfer of Personal data on the Internet cannot be guaranteed secure, and therefore the User carries out such transfer at his own risk.