PERSONAL DATA PROCESSING POLICY

1. General provisions

1.1. The Personal Data Processing Policy (hereinafter referred to as Policy) regulates the legal relationship on personal data processing between Equation Training institute LLC, license No. 1279472, legal address: 602, Rasis Business Center, Al Barsha 1, Dubai, United Arab Emirates (hereinafter referred to as the Company) and the User of the Site https://mathacademyequation.com (hereinafter referred to as the User).

2. Terminology

2.1. A "User" means a capable individual who has reached the age of majority and wants to purchase the Company's services, leave a comment, register on the Website, or perform other actions provided for by the functionality of the Company's Internet resource.

2.2. The "Website" or "the Company’s Internet resource" means a website https://www.mathacademyequation.com including all levels of domain names owned by the Company.

2.3. "Personal data" means any information related directly or indirectly to a specific or identifiable individual (citizen), recorded on electronic, paper and (or) other tangible media or directly defined in the legislation of the country where the Website is hosted.

2.4. "Processing of personal data" means any action (operation) or a set of actions (operations) with personal data performed using automation tools or without the use of such tools. Such actions (operations) include: collection, receipt, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.

2.5. The Policy may use the terms "We" in relation to the Company, and "You" in relation to the User, respectively.

2.6. All other terms and definitions used in the Policy are interpreted in accordance with the current legislation of the Company’s country.

3. Scope of application

3.1. The Policy defines the procedure for processing personal data of Users of the Site, the conditions and principles of personal data processing, user rights and obligations of the Company, information about the measures implemented to protect the processed personal data.

3.2. The Policy applies to all personal data that the Company receives from Users when the latter use the Website.

3.3. The Policy does not regulate or establish the rights and obligations of third parties anddoes not apply to any third-party applications and/or software that Users can integrate with the functional features of the Website.

3.4. The Policy applies only to the specified Company Website. The Company does not control and is not responsible for third-party websites to which the User can click on links available on the Company's Website.

The User understands that when clicking on some links posted on the Website, theymay be redirected to websites/applications of other companies on the Internet, where information about users is collected outside the direct control of the Company. In this case, the privacy policies of third-party websites and/or applications will regulate the processing of information received from Users by these third parties.

4. Acceptance of the Policy

4.1. The User agrees to the Policy by marking the consent in the dialog box of the Website "I consent to the processing of personal data" and/or simultaneously entering their first name (last name – at the request of the User), e-mail address (email) and mobile phone number when clicking the "Access", "Send", "I agree", "Sign up for the course", "Book a discount", "Get", "Get advice", "Get a discount" and other similar buttons and dialog boxes provided by the functionality of the Website.

4.2. In case of disagreement with the terms of the Policy, part of the special (individual) functionality of the Website may not be available to the User.

4.3. Do not use the Website if you do not agree with the terms and scope of the Policy.

5. Processing of personal data

5.1. The personal data of Users is processed by the Company.

5.2. When using the functionality of the Website, the User can provide to the Company the following categories of personal data: public, special, except for biometric and genetic, as well as other personal data not related to public and special personal data, which, consequently, the Company processes.

5.3. We process the necessary minimum of users’ personal data for the purposes stipulated by the Policy, including, but not limited to (depending on the functionality of the Site):

(a) account data: username and password (if created), user identification data (user ID);

(b) personal information: first name, last name, registration number;

(d) professional information: name of the employer company (place of work), position;

(e) payment information: information about access related transactions (payment status and payment amount);

(f) information in the feedback, complaint, and feedback forms: the content of the request (if it contains personal data);

(g) additional information (may in some cases be collected automatically depending on the functionality of the Website and the User's personal settings in the appropriate browser): IP address, cookies, geolocation, information about Website visits provided by statistical services (for example, such as Yandex Metrika and Google Analytics, or similar), information usage and settings information, device information, information from server event logs, and other system-level information.

5.4. When making an Online payment using the functionality of the Website, the Company may request an Individual Identification (Registration) Number of the User. At the same time, all payments are made and processed through Internet acquiring through a specialized payment system, the Company does not store the User's credit card data.

5.5. By submitting their personal data, the User agrees to their processing (up to the withdrawal of the User's consent to the processing of personal data), including collection, storage, depersonalization, transfer to third parties in accordance with the Policy and legislation of the country of the Company, in order to provide the User with advertising, reference information, services in accordance with the functionality of the Website and in other purposes stipulated by the Policy and legislation of the country of the Company.

5.6. When processing personal data, the Company is guided by the provisions of the General Data Protection Regulation of the European Union dated April 27, 2016 and other local regulatory legal acts of the country of the Company.

6. User Rights

6.1. The consent provided by the User to the processing of personal data is valid from the date of granting such consent until the goals of processing are achieved or the User withdraws consent, unless otherwise provided by the current legislation of the country of the Company.

6.2. In accordance with the legislation of the country of the Company, the User has the right to receive information regarding the processing of his personal data, change data, receive information about the provision of personal data to third parties, file a request to terminate the processing of personal data and (or) delete them, appeal against actions (inaction) and decisions of the Company related to processing of personal data, withdrawal of consent to the processing and transfer of personal data, except in the following cases, when personal data is processed on the basis of the law or other grounds other than consent.

6.3. The User can revoke the consent provided to the Company at any time in accordance with the procedure established by the Policy and legislation of the country of the Company.

6.4. If the User wishes to clarify personal data in the case when personal data is incomplete, inaccurate or irrelevant, or wishes to withdraw their consent to the processing of personal data, the User must send an official request to the Company with the subject "Clarify personal data" or "Stop processing personal data" to the e-mail address (e-mail) through the functionality of the Website or by a separate letter in which theymust specify their full name and email address/phone number and the corresponding requirement.

6.5. As soon as we receive a request to revoke consent to processing, we will no longer process personal data for the purposes to which the User initially agreed, unless we have other legal grounds for doing so. In the absence of the technical possibility of deleting users' personal data, we undertake to take measures to prevent further processing of personal data by blocking or depersonalizing them.

6.6. In case of detection of incompleteness, inaccuracy or irrelevance of information, the Company, based on the User's information, makes the necessary changes to the User's personal data within a period not exceeding 7 (seven) business days and notifies the User of the changes made.

6.7. If the User or their representative provides the Company with confirmation of the fact of illegal receipt or processing of their personal data, as well as the fact that actions with his personal data do not correspond to the purposes of processing, the Company, within a period not exceeding 7 (seven) business days, undertakes to destroy such personal data of the User and notify the User of the measures taken.

6.8. The Company reserves the right to verify the authenticity of your identity before exercising any rights upon your request. We will also explain the reasons to you in cases where we are unable to exercise any of your rights or provide you with any information.

7. Purposes of personal data processing

7.1. The Company processes the data provided by the User for the purposes (including, but not limited to, depending on the functionality and purposes of the User's use of the Website):

(a) registration of the User on the Website, identification of the User of the Websitewithin the framework of granting access, including access to the account/account on the partner websites – before deleting the account;

(b) communication at the request of the User, consulting on the provision of services by the Company, satisfaction of the User's request – within 3 years from the date of the last active action; offering the User services that could be useful and interesting based on the services previously purchased by the user, information, advertising, promotion of goods, works (services) based on the information received about the User's personal preferences and settings – until the withdrawal of consent, or within 3 years from the date of the last active action;

(c) evaluating and analyzing the operation of the Company's Website, improving the quality of services – until the withdrawal of consent, or within 3 years from the date of the last active action;

(d) analytics of the effectiveness of advertising, statistical research based on impersonal information provided by the User;

(e) distribution of marketing and informational materials, including information about promotions, discounts and special offers, including by e-mail, telephone communication – before withdrawal of consent or within 3 years from the date of the last active action;

(f) conducting an analysis of the audience, the preferences and interests thereof and other marketing research, including the involvement of third parties as a contractor (contractor, consultant) – before revoking consent or within 3 years from the date of the last active action;

(g) communicating with partner banks regarding the provision of loans to the User and/or agreeing on loan terms – before deleting the account or within 3 years;

(h) ensuring the implementation of Internet payments on the Website through Internet acquiring – before deleting the account or within 3 years;

(i) elimination of software errors, optimization of the Website operation – until the withdrawal of consent or within 3 years from the date of the last active action.

(j) providing other services and services available for use through the functionality of the Website.

(k) for other purposes provided for by the legislation of the country of the Company.

7.2. The basis for processing the above-mentioned personal data is your consent, which is obtained in electronic form, including by filling out special forms on the Website and/or reviewing/agreeing to a public service agreement or a user agreement, depending on the functionality and content of the Website.

7.3. The period of processing of personal data is determined by the Company and is limited to achieving the above goals but does not exceed 3 years.

8. Personal data protection

8.1. The Company does not verify the data provided or specified by the User. In this regard, the Company assumes that when submitting personal data, the User:

(a) is a legally capable person. In case of incapacity of the person using the Website, consent to the processing of personal data is provided by their legal representative;

(b) indicates reliable information about themselves (or about the incapacitated person represented by them);

(d) is aware that the information on the Website posted by the User may become available to other persons, may be copied or distributed by such users in cases provided for by the Policy.

8.2. The Company processes personal data based on the following principles:

(a) legality;

(b) restrictions on the processing of personal data to achieve specific predetermined legitimate goals;

(c) preventing the processing of personal data incompatible with the purposes of collecting and/or storing data received from the User;

(d) compliance of the content and volume of the processed personal data with the purposes of their processing;

(e) preventing the processing of redundant data in relation to the purposes of processing;

(f) ensuring the accuracy, sufficiency and relevance of personal data in relation to the purposes of their processing;

(g) destruction or depersonalization of personal data in order to prevent their disclosure when the purposes of data processing are achieved, the need for such processing is lost, or when the User receives a request for the destruction of personal data or receives an application for revocation of consent to the processing of personal data.

8.3. When processing personal data, the Company takes necessary and sufficient organizational and technical measures to protect personal data from unauthorized access to them, as well as from other illegal actions with respect to personal data, provided for by the legislation of the Company's country and its internal policies and procedures.

8.4. The processing of personal data of Users is carried out by the Company taking into account the following:

(a) The processing of personal data of Users is carried out using databases in the relevant territory.

(b) The processing of personal data is carried out both with the use of automated means and without their use.

(c) The Company undertakes not to transfer the information received from the User to third parties, except in cases specifically stipulated in the Policy or expressly provided for in the legislation of the Company's country. The transfer of personal data of Users to third parties – partners of the Company, if necessary, is carried out on the basis of the consent of Users in order to fulfil obligations to Users.

(d) The Company and, in case when transfer of Users' personal data to third parties– partners of the Company is necessary, the latter, too, undertake to keep confidential and not disclose or distribute personal data without the User's consent, unless otherwise provided by the current legislation of the Company's country and/or Policy.

(e) The storage of Users' personal data is carried out on electronic and, for the purposes of fulfilling obligations to Users, it can be carried out on tangible media after the extraction of personal data.

(f) The storage of personal data is carried out within the period objectively necessary for the fulfillment of obligations to Users, and is determined by the following events (depending on which event occurs earlier):

➢ until the User deletes personal data through the personal account;

➢ until the moment of destruction of personal data by the Company in connection with the receipt of a request from the User to destroy personal data or revoke consent to their processing;

➢ until the User's consent expires.

(g) The Company has the right to store the User's personal data, except in cases of receiving a request for data destruction or revocation of consent to data processing, in an impersonal form after fulfilling obligations to the User for the purposes specified in the Policy in accordance with the procedure and conditions determined by the legislation of the Company's country.

9. Transfer of personal data

9.1. Individual personal data, namely personal, contact, and payment information, may be transferred to legal entities or individual entrepreneurs who are engaged by the Company to fulfill obligations to Users, as well as for other purposes provided for by the Policy and/or legislation of the Company's country.

9.2. When making an online payment with a bank payment card, a bank (correspondent bank, recipient bank) or a specialized payment system (including VISA, MasterCard, etc.) always participates in the transaction. In order to make and process payments, the Company is obliged to provide information about the User to specified third parties, in particular, last name, first name and registration number. The Company does not store and, accordingly, does not transfer the User's credit card data.

At the same time, all data transmitted by the Company is transmitted exclusively in encrypted form. The security of the User's online payment processing is guaranteed by the payment system and the issuing bank of the payment card. All transactions with payment cards are performed in accordance with the requirements of payment systems.

9.3. The disclosure of personal data of Users may be mandatory for the Company in accordance with the law, the requirements of legal proceedings or at the request of government agencies, as well as if necessary for national security, law enforcement, protection of the rights and legitimate interests of third parties or for other socially important purposes.

9.4. If it is necessary to transfer Users' personal data to third parties – partners of the Company in cases expressly provided for by the Policy, such transfer is carried out in compliance with the following conditions:

(a) a third-party partner of the Company ensures the confidentiality of personal data during their processing and use and undertakes not to disclose the data to other persons, as well as not to distribute personal data of Users without their consent;

(b) a third-party partner of the Company guarantees compliance with the following measures to ensure the security of personal data during their processing: the use of information protection tools; detection and fixation of unauthorized access to personal data and taking measures to restore personal data; restriction of access to personal data; control and evaluation of the effectiveness of measures applied to ensure the security of personal data, other measures provided for by law;

9.5. The following is not considered as a violation of the obligations provided for by the Policy: the transfer of information in accordance with the reasonable and applicable requirements of the legislation of the Company's country, as well as the provision of information by the Company to partners acting on the basis of an agreement with the Company to fulfil obligations to the User; the transfer of User data by the Company to third parties in an impersonal form for the purpose of evaluating and analysing the operation of the Company's Website, providing personal recommendations, displaying advertisements based on personal preferences and User settings, as well as conducting marketing, analytical and/or statistical research.

10. Rules for the processing and use of "cookies"

10.1. The Company has the right to use the technology "cookies".

Cookies are data that can be automatically transmitted to the Company during the use of the Website using software installed on the User's device, including IP address, geographical location, information about the browser and the type of operating system of the User's device, technical characteristics of the equipment and software used by the User, date, and time of access to the Website.

Cookies do not contain confidential information. Cookies are used to remember User preferences and settings, as well as to collect analytical data about Website visits. Using the Website means that the User agrees to the use of all cookies and analytical data on Website visits, as well as their transfer to third parties.

You have the right to restrict or prohibit the use of cookies technology by applying the appropriate settings of your browser. Please note that disabling cookies may, in some cases, lead to limited functionality of the Website.

10.2. The Company receives information about the User's IP address and information about the link from which Internet website they came from. This information is not used to identify the Website visitor.

11. Final provisions

11.1. The Company undertakes to take all necessary organizational and technical measures to ensure the confidentiality, integrity, safety and accessibility of Users' personal data.

11.2. The Company undertakes to comply with the legal rights of Website Users in the field of personal data processing, as well as to comply with other requirements for the processing of personal data established by the legislation of the Company's country.

11.3. The Company independently determines the list of third–party Partners of the Company and brings it to the attention of Users by any available means, including by publishing on the Website.

11.4. The policy was last updated on Feb 22, 2024. The Company has the right to make changes and/or additions to the Policy at any time. The current text of the Policy is posted on the Website.

11.5. Continued use of the Website or its services after the publication of a new version of the Policy means acceptance of the Policy and its terms by the User. In case of disagreement with the terms of the Policy, including after its change, the User must immediately stop using the Website and its services.

11.6. All questions regarding the Policy and/or processing of personal data are sent to the Company's email address indicated on the Website.

EQUATION